Cement Kilns PDF

ACKNOWLEDGEMENTS
We are grateful for the assistancefrom representativesof industry and other agenciesin
developingthis manual. We especiallythank the following peoplefor their extra efforts and
their thoughtful comments:
DouglasShumway EnvironmentalManager,Mitsubishi CementCorporation

JohnBlytbe EnvironmentalManager,Southdown,Victorville CementPlant
StephenJenkins Mojave DesertAir Quality ManagementDistrict (MDAQMD)
Principal Author
Allan Roundy
Contributing ARB Staff

Gary Hunter
Cheryl Haden
TABLE OF CONTENTS
/’
i
100 INTRODUCTION ........................................................................................
100 . 1
101 What This Manual Is About ...................................................................................... 100 . 1
102 What Are Cement Kilns’ ............................................................................................ 100 . 1
103 California Air Resources Board ................................................................................ 100-2
104 Compliance Assistance Program ............................................................................... 100-3
104.1 Focus / Target Audience for this Manual ...................................................... 100-4
104.2 Manual Design ................................................................................................ 100 . 5
104.3 Manual Maintenance ...................................................................................... 100 . 6
105 California Clean Air Act ........................................................................................... 100 . 7
106 Air Pollution Health Concerns ................................................................................. 100 . 7
106.1 Volatile Organic Compound (VOC) and PM10 ........................................... 100 . 7
106.2 Standards for Ozone and Particulate Matter (PMlO) ................................. 100 . 8
200 CATEGORY DESCRIPTION .................................................................... 200- 1
201 Historical Highlights of Development ...................................................................... 200- 1
201.1 Clays ................................................................................................................. 200-2
201.2 Common Limes ................................................................................................ 200-2
201.3 Hydraulic Limes .............................................................................................. 200-3
201.4 Natural Cements .............................................................................................. 200-3
201.5 Pozzolana Cements .......................................................................................... 200-4
202 Later Events Leading to Portiand Cement .............................................................. 200-5
203 Basic Cement Plant Processes ................................................................................... 200-9
203.1 Selection of Raw Materials ............................................................................ 200-9
203.2 Layout and Workflow of a Cement Facility ................................................. 200- 10
204 Fueling the Fire .......................................................................................................... 200-15
204.1 Conventional Fuels .......................................................................................... 200-15
204.2 Supplemental Fuels ......................................................................................... 200 -16
205 Cement Kilns and Air Quality .................................................................................. 200-20
300 PROCESS AND CONTROL ...................................................................... 300- 1
301 Processes in Brief ....................................................................................................... 300- 1
302 Processes in Detail .................................................................................................. 300-5
302.1 Quarrying Operations ..................................................................................... 300-5
302.2 Preliminary Grinding and Mixing ................................................................. 300-5
302.3 Kilning / Clinkering ........................................................................................ 300-9
302.4 Finish / Fine Grinding ..................................................................................... 300- 11
302.5 Storing, Packaging, and Shipping .................................................................. 300-12
303 Possible Sources of Emissions ................................................................................... 300-12
304 Control of Air Pollution ............................................................................................ 300-13
304.1 Rules and Regulations For Control ............................................................... 300-13
304.2 -Methods of Control ......................................................................................... 300-14
400 INSPECTION ............................................................................................... 400- 1
401 Pre-inspection Procedures ........................................................................................ 400-2
402 Facility Inspection Procedures ................................................................................ 400-4
403 Post-inspection Procedures ...................................................................................... 400- 11
404 Inspector Safety ......................................................................................................... 400 -12
OCT 1996 i
500 LEGAL REQUIREMENTS ..................................................................................
500 - 1
501 District Requirements ............................................................................................... 500 - 1
501.1 Authority to Construct and Permit to Operate .......................................... 500-2
501.2 Visible Emissions (VE) ................................................................................... 500-3
501.3 Particulate Matter Emission Limits ............................................................. 500 - 4
501.4 Fugitive Dust Emissions ................................................................................. 500 - 4
501.5 Nuisance .......................................................................................................... 500 - 5
501.6 Equipment Breakdown Provisions ............................................................... 500 - 5
501.7 Variances ......................................................................................................... 500-7
502 California Health and Safety Code (HSC) Summary Listing ............................. 500 - 9
503 Introduction, Health and Safety Code .................................................................... 500 - 10
LIST OF FIGURES
Figure 200.1 An Early Cement Kiln Built By William Aspdin In 1848 ............................. 200-6
Figure 200.2 A Long Dry Cement Kiln Near Victorville ...................................................... 200-7
Figure 200.3 A Preheater / Precalciner Plant Near Victorville ............................................ 200 . 11
Figure 200.4 Workflow of Processes to Make Portland Cement .......................................... 200 . 12
Figure 200.5 A Long Dry Kiln ................................................................................................. 200 . 13
Figure 200.6 Packaged Portlaud Cement ...ttUI..Htt..)m-...--..~ ............................................ 200 . 14
Figure 200.7 A Pneumatically Loaded Cement Truck-Trailer ............................................ 200 . 14
Figure 200.8 Used Tires for Disposal as Supplemental Fuel ................................................ 200 . 17
Figure 200.9 Tires Are Conveyed into the Kiln at a Measured Rate .................................. 200 . 17
Figure 300.la Workflow and Process ..................................................................................... 300-2
Figure 300.lb Workflow and Process ..................................................................................... 300-3
Figure 300.2 A Preheater / Precalciner Cement Kiln Facility .............................................. 300-4
Figure 300.3 Quarrying and Crushing Cement Materials .................................................... 300-6
Figure 300.4 A Limestone Quarry With Heavy Equipment ................................................. 300-7
Figure 300.5 Kiln Operations, Finish Grinding, and Shipping ............................................ 300 . 10
Figure 300.6 A Finish Mill for Fine Grinding ........................................................................ 300 . 11
Figure 400.1 A Baghouse with Stacks and a CEM ................................................................ 400-9
Figure 400.2 Baghouse and Cleaning Methods ...................................................................... 400 . 10
LIST OF TABLES
Table 100.1 Ambient Air Quality Standards ......................................................................... 100-9

Table 200.1 Summary of Six Classes of Cement .................................................................... 200-4
Table 200.2 Some Notable Events In The Cement Industry ................................................. 200-S
Table 200.3 Burning Tires: A Test Demonstration .............................................................. 200 - 18
Table 300.1 Typical Emission Sources and Control Measures ............................................. 300 - 14
ii OCT 1996
100 INTRODUCTION
101 WHAT THIS MANUAL IS ABOUT

This technicalmanualaddresses
the control andreductionof the air pollution
which cementkilns cozddproduce. In these pages you can find:
W Descriptions of processesand equipment,
W Regulation requirementsfor air pollution control, What, Why,
How
W Checklists/inspectionaidsand supportingmaterialsto helpyou comply. to Comply
You can learn about:

+ The pollution problems posed by plant operations,
+ The air contaminants which could affect your health, What’s
+ The rewards of complying with regulations, in it
For You
+ The consequences of violations and how to avoid them. ?
Aggregates,AsphaltHot Mix Facilities, and ConcreteBatch Plants,although

related,arenot the main focusof this CementKilns manual;our compliance
assistanceprogram(CAR) hasseparatetechnicalmanualsdevotedto eachof
these. However, you may wish to consultthe complementingquartetof these
manuals,alongwith otherssuchasBaghousesandElectrostaticPrecipitators.
102 WHAT ARE CEMENT KILNS?

Basically,a cementkiln is the key pieceof equipment,ajkrnace, in an industrial
facility which turns a mixture of calcium carbonate/limestone
andshales,clays,
Cement
and iron oresinto a fine, powdery substancecalledcement. The cementcan
Furns Limestone
then be usedto bind togethersand,gravel,and other ingredientsto makethe
into
syntheticrock which we call concrete. The generalterm, “cementkiln” is often Synthetic Rock:
usedto mean“cementplant.” Furthermore,the main focus of this manualis on Concrete
the portland classof cement,madefrom limestone,silica,iron, and alumina.
A cementkiln facility quarrys,crushes,andgrindsthe raw materials,measures,

proportions,blends,andintroducesthem into the kiln, wherethey areheatedto a
temperatureof about2700degreesFahrenheit.The result is hard, cookedpieces
i of calciumsilicates,calledclinker, which arethen groundwith gypsuminto a
fine, powderedcementandshippedto markets. Detailed explanationsare
presentedin Chapters2 and 3.
Ott 1996 Page100-1
Cement Kilns 100 INTRODUCTION
How can cement kilns relate to air quality? In severalstagesof the processes,
opportunitiesmay occurfor pollutantsto escapeor to be propelledinto the air.
Theair quality may be at risk from the time when the sourceelementsare mined
Tom within the earth,crushed,conveyed,stored,mixed into concrete,anduntil
The Purpose thepatio surfaceis finished. Thesepollutantsare mainly particulates, or dust;
of he sourcesand controlsarediscussedin detail in this manual.
This Manual
ro help educate plant operatorsandinspectorsin propermethodsto contain,
capture,andcontrol errantparticulates,andthus to promote cleaner air, is the
Contain, mainpurposeof this manual. We alsohopeto help plant operatorsavoidviola-
Capture,
tions,fines, and costly shutdowns.
Control
First, let’s look at our California agencieswhich regulateair pollution:
103 CALIFORNIA AIR RESOURCES BOARD

Air pollution is a seriousproblem in California. We are pumpingtons of pollut-
ing materialinto Californiaair every day from the activitiesof 29 million resi-
dents,23 million cars,anda myriad of industrialsourceslargeand small. Un-
fortunately,the air pollution is not blown awayby fresh seabreezesfrom the
PacificOcean. To the contrary,this air pollution tendsto remain in place,dueto
thedominantatmospherichigh pressure,the atmospherictemperatureinver-
sions,the terrain barriersandbasins,andother factors.
On the other hand,Califomia leadsthe nationin programsto cleanup the air. In

1955,the Bureauof Air Sanitationbeganidentifying the air pollution levelsthat
couldendangerpublic health. Recognizingcarsandtrucks asa major causeof
smog,the Stateformed the Motor VehiclePollution Control Board (MVPCB) in
1960to regulatetailpipe emissions.California was the first stateto adopt
ARB vehicleemissionstandardsfor hydrocarbons(HC) and carbonmonoxide(CO).
Created
ln 1967the MVPCB andthe Bureauof Air Sanitationwere combinedto create
the Air Resources Board (ARB). With this merger,the authority to definethe
healththreat of air pollution andto regulateits causeswas united into a single
organization. Sincethenthe ARB, working with county andregionalair
pollution control districts, (APCDs) and air quality managementdistricts,
(AQMDs) hascreatedoneof the world’s most comprehensiveair quality
cleanupprograms.(For simplicity,the term, “air districts”maybe used.)
Next camethe California EPA. In July, 1991, the California Environmental

ProtectionAgencywas formed to bring together,under a singleaccountable
Page 100 - 2 Ott 1996
100 INTRODUCTION Cement Kilns
Cabinetlevel agency,theseentities: the Departmentof PesticideRegulation,the

Departmentof Toxic Substances Control, the Offke of EnvironmentalHealth
HazardAssessment,the IntegratedWasteManagementBoard,the StateWater
ResourcesControl Board,nine RegionalWater Quality Control Boards,andthe
Air ResourcesBoard. What doesthe Air ResourcesBoarddo?
What Does
As the primary statutoryauthority, the ARB establishesandenforcesstandards the ARB Do
to limit air pollutantemissionsfrom motor vehicles. The ARB doesmore: ?
1. Conductsinspections,in cooperationwith the air districts to ensure

compliancewith air pollution regulationsby applyingconsistent and
evenhanded enforcement.
2. Developssuggested rules andregulationsto assistlocal air districts in

their efforts to improvethe air quality.
3. Establishesair quality standardsto protectthe healthof the vulnerable

membersof our populationandto preventdamageto property andcrops.
4. Evaluatesthe effectivenessof pollutant control strategiesandprograms

for vehiclesandindustry.
5. Monitors air quality throughoutthe State.
6. Conductsextensiveresearchprograms.
The ARB’s pastefforts andthe cooperationof industryandthe public have

reducedthe pollution emittedfrom vehiclesandother largesources.Now and
for the future, the ARB aimsto continueto enforcepresentregulationsandto
further reducethe effectsof other, smallersourcesof pollution. Continuingto
cleanup our air requiresdifficult choices,carefulplanning,andthe supportof
all Californians.
104 COMPLIANCE ASSISTANCE PROGRAM

Within the ComplianceDivision, the California Air ResourcesBoardhasa CAP
ComplianceAssistanceProgram(CAP). The CAP producesinnovative publi- Promotes
cations to provideassistance
to industryandregulatorsfor comprehensive, Awareness
consistent,andaccuratecomplianceinspections.The goal of the CAP is to
reduceair pollution by promotinga greaterawarenessof air quality regulations
Ott 1996 Page 100 - 3
100 INTRODUCTION
andby encouragingcooperationbetweenregulatorsand industry. Toward this

goal,the CAP providesindustrywith information, checklists,andother self-
auditingtools to help them know how to stay in compliance.
Enforcementauditsof someindustrialsourceshave shownnoncompliancerates

up to 50 percent. Reducingtheseratescanbring rewardsto everyone.
If We Basedon the ideathat emissionsourceoperatorswill comply with air quality

Understand regulationsif they understandwhat is requiredof them, the CAP identifiesthe
We requirementsandpresentsthem in severalalternativeformats. TheseCAP
Will Comply publicationscan assistindustriesto monitor their operationsandto conducttheir
own daily inspections,thus increasingtheir complianceratesandreducingcostly
violations.
Throughthe developmentanddistribution of theserule-specificpublications,

CAP createsa flow of information in a variety of useful forms:
Handbooks. Easy-to-read,colorfully illustratedhandbooksare developedfor

the industriallabor force on the productionline. Most can be read in 10
minutes, andall containhelpful self-inspectionchecklists.
Pamphlets. Quick-referencepamphletscontaindetailedflow charts,checklists,

andmeaningfuldiagramsto assistplant supervisorsandtheir inspectors.
Technical Manuals. Detailedtechnicalinspectionmanualsaredeveloped

Who Will Use
mainly for industry’s environmentalmanagers,ARB inspectors,and local air
this
Manual district inspectors. Thesecontainrule information, processdescription,and
step-by-stepproceduresfor complianceinspections.
?
104.1 FOCUS / TARGET AUDIENCE FOR THIS MANUAL
The primary focus of the ComplianceAssistanceProgramis to improve the

knowledgeof inspectorsandindustrialoperatorsabout air emissions. In orderto
What, Why, reducenoncomplianceandexcessemissions,both the inspectorand the operator
How needto know what is regulated,why it is regulated,andhow complianceis
to Comply determined.
This technicalmanualis targetedfor corporateandindustrial managersandtheir

staffs, includingproductionenvironmentalmanagers,and for air pollution
control district inspectors.
Page 100 - 4 Ott 1996
100 INTRODUCTION Cement Kilns
104.2 MANUAL DESIGN
This cementkiln manualis designedto assistyou, the inspectorsin government

andin industry, in assuringthat cementplant operationsmeetthe requirements
of air pollution control regulations.
This manualcomplementsan existingtrio of CAP Manuals. Together,they can

form a quartet of referencemanualsfor your office or your inspectionkit:
A
CementKilns, ConcreteBatchPlants,AggregatesPlants,andAsphaltHot Mix
Quartet
Facilities. In a musicalanalogy,sincecement is the basiswhich holdsthe other
of
productstogether,it may be calledthe bassof the quartet,which holdschords
Manuals
together. ConcreteBatch,with so many versatileapplications,canbe the
melody, while Aggregatesand AsphaltPlantscanbe woven in asthe tenor and
baritone. Other CAP manualsandpamphlets,suchasBaghouses,andVisual
EmissionsEvaluations,canprovidethe percussionandrhythm.
This manualprovidesboth an overviewand detailedinformation, alongwith

referencesfor further details. It is divided into easy-to-use,numberedsections
andsubsectionsfor your convenience.
Section 100 providesoverviews of air pollution problemsin California,the

formation of the ARB andthe ComplianceAssistanceProgram,andthe design What is in
andpurposeof this manual. Each
Section
Section 200, Category Description, includesa brief overview of the historical ?
eventsin the developmentof cements,brief descriptionsof plant operationsand
equipment,anda summaryof known air pollutant emissionsfrom cementplants.
Section 300, Process and Control, describesin more detailthe various

processesusedin cementkilns andthe controlsusedto protect our air quality.
Section 400 describesInspection Procedures for assuringcompliance,includ-

ing checklists, other inspectionaids,andguidelines.
Section 500 presentsthe Legal Requirements of the laws andregulations

governingcementkilns.
The Glossary containsa collectionof terms usedin the manualandthe industry.

Q The Appendices containsupplementalinformation suchascopiesof pertinent
sectionsof regulations: Appendix A containsa fugitive dust samplecontrol
plan andlL4CM; B citesParticulateMatter (PMlO) emissionsdeterminations
Ott 1996 Page 100 - 5
(EPAMethod 5); C containsVisible EmissionsEvaluationprocedures;

D containsa pre-inspectionworksheet,a sampleinspectionchecklist,and
troubleshootingguidelinesfor baghouses;E containssimilar materialfor elec-
trostaticprecipitators;F containssamplePermitsto Operateandan Authority to
Construct;G lists referencesusedin producingthis manual;H is AP-42
emissionfactors, andAppendixI is providedasa placefor your district rules.
TheIndex at the endof the manualcanhelpyou to find topics.
104.3 MANUAL MAINTENANCE
Thismanualis a dynamic,living documentthat relies on your experienceand

A expertisefor its changesandimprovements.Pleasereadthe manualto familiar-
Dynamic, ize yourself with its contents,how it is organized,andhow to useit. As you do,
Living pleasejot down any questionsyou may have,andhighlight anythingthat is
Document unclearto you. The arnendmentprocessstartswith you; pleaseusethe proce-
dureincludedhereto shareyour observationsand suggestions.
As you identify issuesthat you think will benefit others,talk with your supervi-
sor and expressyour concerns.If you want further clarification of a point, call
the ARB, ComplianceDivision, ComplianceAssistanceSectionat (916) 324-
7659or leavea messageat l-800-952-5588. Whenyou believethat the manual
shouldbe arnended,write down your proposedamendmentand sendit to:
Air ResourcesBoard
ComplianceDivision, ComplianceAssistanceSection
P. 0. Box 2815
Sacramento,CA 95812
Whenwe receiveyour proposedamendment,we will review it, contactothersto

seehow widespreadthe issueis, andwe will respondbackto you. For those
proposedamendmentsthat needimmediateresponse,a workshopmay be sched-
uled or draft changeswill be providedfor comment. For thosechangesthat may
Manual be lesscritical, we will wait until we haveseveralbeforehaving a workshopor
Updates commentperiod andmaking the appropriatechanges.
Right now, when you first receive this manual, please be sure to fill in the
tracking card locatednearthe front page,andpromptly mail it to the ARB.
Thenwe canmail you anupdatefor your manualeachtime there is a change.
Page100-6 Ott 1996

100 INTRODUCTION
105 CALIFORNIA CLEAN AIR ACT

The California State Legislature, aware of California’s seriousair pollution
problems and the inability of many areasto meet the State and Federal
ambient air quality standards,passedthe California Clean Air Act of 1988
(CCAA). The CCAA requiresthe air pollution control districts to develop
control measuresto achievea five percent annualemissionreduction of
volatile organic compounds(VOCs) in those districts that are designated
non-attainment for the State’s air quality standardfor ozone.
106 AIR POLLUTION HEALTH CONCERNS

This section includes information about California’s air pollution health People Want
concernsin general, in order to show how emissionsfrom cement kilns may Healthful
relate to the larger air pollution problem. Air
Air pollution has causedconcernsas a seriousproblem for the health of the
29 million peopleof California. To protect human health, the ARB has set
standardsfor air quality. Thesestandardsare basedon researchindicating
the concentrationsat which pollutants can be harmful, andthey include a
margin of safety to protect people who are particularly sensitiveto air pollu-
tion, such asthe young, the elderly, and those with allergiesor asthma.
Volatile organic compoundsare precursorsto both ozone,a serious concern,

and particulate matter (organic particles with diameters of lessthti 10
microns, known as PMlO, which may be an even more seriousconcernthan
ozone). Cement kiln dust (CID) is mostly particulate matter. Over 90
percent of California’s population live in areasof non-attainment for the
State ozoneand PM10 standards. The following subsectionsdiscussand
illustrate VOCs, PMlO, ozone, and our ambient air quality standards.
106.1 VOLATILE ORGANIC COMPOUND (VOC) AND PM10
A volatile organiccompound(VOC) is a carbonsubstancewhich canbe a cause

of air pollution. VOCs containat leastone atomof carbon,excludingmethane,
carbondioxide, andcertainother organiccompoundsdeterminedby the
EnvironmentalProtectionAgency(EPA) andthe ARB to be non-photochemi- vocs:
tally reactive(primarily halogenatedhydrocarbons). Precursors of
Ozone
VOCs are known precursorsof ozoneandPMlO. That is, VOC emissionscause
the formation of ozoneand a smalleramountof PM10. Ozoneis formed in the
Ott 1996 Page100-7
lower atmosphereduring a seriesof chemicalreactionsbetweenvolatile organic

compounds(VOCs ) andnitrogenoxides(NOx) in the presenceof sunlight.
voc, PM10 levelsarethe result of both direct andindirect sources.Direct sources

Ozone, includefuel combustion,dust, and soil erosionby wind. Indirect sources
PM10 includethe chemicalreactionsof VOCs, nitrogenoxides,sulfur oxides,other
chemicalsin the air, andcondensations of emittedgasesin the air. From these
reactions,solid andliquid particlesform with diameterslessthan 10 microns.
For the year 1991, the ARB emissionsinventory showsthat cementkilns in

California emitted 1,216tons per day of particulatematter (PM) andparticulate
matter lessthan 10micronsin diameter(PM10).
106.2 STANDARDS FOR OZONE AND PARTICULATE MATTER (PMIO)
Ozoneis a strongrespiratoryirritant that canimpair the normalfunction of the

lungs,especiallyduringvigorousphysicalactivity. This healtheffect is
particularlyacutein children,the elderly, andpeoplewith respiratorydifficul-
ties. Ozonecanalsodamagesometypesof vegetation,reducingcrop yields.
Particulatematter with equivalentaerodynamicdiameterssmallerthan 10

microns(PM10) canadverselyaffect our breathing. Smallenoughto pass
throughour naturalfilters, PM10 invaderscanbe inhaleddeeplyinto the lungs,
causingirritation to the respiratorytract. Furthermore,asthey invadeour lungs,
theseparticlesmay bring alongtoxic substancesclinging to their surfaces.
PM10 can alsobe anaestheticnuisance:sinceit is just largeenoughto be seen,
it scatterslight andreducesour atmosphericvisibility.
Air Quality To protect California’spopulationfrom the harmful effects of ozoneandPMlO,

Standards federalandStateair quality standardshavebeenestablishedfor thesecontami-
Established nants,as shownin Table100.1. The Statehourly ozonestandardis 0.09 parts
per million (ppm) andthe federalhourly ozonestandardis 0.12 ppm. The State
PM10 standardfor a 24 hour period is 50 microgramsper cubic meter (pg/m3)
andthe federalstandardis 150pLg/m”,determinedover a 24-hour period.
Page 100 - 8 Ott 1996

100 INTRODUCTION
Table 100.1 Ambient Air Quality Standards
Ambient Air Quality Standards

For Ozone and PM10
Pollutant Averaging Time State Std. Federal Std.
Ozone 1 hour 0.09 ppm 0.12ppm

(180 cLg/m3) (235clg/m3
1
Standards
for
PM10 Annual Ozone
GeometricMean 30 pg/m3 --- and PM10
24 hours 50 j.&m3 150pg/m3
hual
Arithmetic Mean --- 50 j@rn3
Today, most of California’speoplelive in districts which haveattainedneither

of theseStatestandards,neitherozonenor PM 10.
Ott 1996 PagelOO-

200 CATEGORY DESCRIPTION
This chapterdescribesthe categoryof Portland cement,the fine powderusedto

makeconcrete,includingan overview of modemcementman~acturing meth-
ods and equipment.First, a look at someof the significanthistoricaleventsin
the developmentof cement’singredientsandmethodsof production.
201 HISTORICAL HIGHLIGHTS OF DEVELOPMENT

The cement/concreteindustry hasbecomean increasinglyimportantand grow-
ing sectorof commerceandemploymentin the United States. Modem cement Historical
technologyhasvisibly enhancedour quality of life in the forms of highways, Highlights
bridges,airports,skyscrapers,public housingcomplexes,bungalows,driveways,
patios, swimming pools,andneighborhoodbasketballcourts. Theportland
cementwe know, however,basedon lime, is the result of a long evolution
through trial, error, study, andexperimentation.
Early forms of cement/concretewere hardand durable,but they borelittle

resemblanceto the product of presenttechnology,with its sophisticated
ingredientsandinnovativemethodsof application. Although lime is a primary
ingredientin the manufactureof modemcements,severalbuildershaveused Lime is a
other substances to hold togetherfragmentsor solid masses,datingfrom the Primary
time of brick walls in ancientEgypt. Thesebricks were held togetherwith moist Ingredient
layersof clay from the Nile River. Theresultingwalls, solid massesof dry clay,
haveenduredin the dry environment,but they would not havedoneso well in a
rainy climate.
The AssyriansandBabyloniansusedbitumen to hold alabasterslabsandburnt

bricks together,andthe Egyptiansuseda materialobtainedby burninggypsum
to createwhat is now calledplasterof Paris. Thereasonfor usinggypsummay
havebeenthat it could be processedat a lower temperaturethan that neededfor
lime, and fuel was scarce. The Greeksusedslaked lime (calciumhydroxide)
mixed with sand,andthe Romansalsousedit to producea mortar which was
exceedinglyhard.
Examplesof the tenacity anddurability of slakedlime mortars still survivein Craftmanship:

ancientRomanbrickwork. Historiansandbuildershavemadein-depthstudies the
to determinehow the hardnessof this mortar was achieved. Of the various Essential
methodsandprocessesusedin producingmortar, includingthe additionof Factor
molasses,it hasbecomeapparentthat, ratherthan any secretingredientor
methodof processingthe lime, the essentialfactor which producedthe remark-
ablehardnesswas thoroughlymixing andrammingthe mortar: craftsmanship!
Ott 1996 Page 200 - 1
Cementitious Materials: Somematerialscantemporarily acquireplasticity.

During their stateof plasticity, they canbe pressed,cast,molded, andformed
into definite shapes,but then, the materialshardenor set,retainingtheir shape.
Here, the term “plastics”usuallymeansorganicplastics;thosewhich canhold
togetherfillers or aggregatesarecalledcementitiousmaterials.
Five cementitiousmaterialshavebeenusedto developcement: clays,common

limes, hydrauliclimes, naturalcements,andpozzolanacements. Thesemateri-
Five Classes als sharean important characteristic:they achieveplasticity when mixed with
of water. Whenthe water is removed,suchasby evaporation,sedimentation,or
Cements chemicalreaction,the plasticity disappears.
Classes of Cements: Althoughthis manualis mostly concernedwith today’s

portland cement,severalother classesof cementaredescribedherefirst, for
comparisonandcontrast:
+ Clays,
Commonlimes,
: Hydraulic limes,
+ Natural cements,and
+ Pozzolanacements.
201.1 CLAYS
Clays may beusedaloneor mixed with other substances.Clays areformed by

Clays the disintegrationof mineralscontainingaluminum,generallykaolin minerals:
kaolin&e,nacrite,and dickite. However, the compositionvarieswidely, with
different proportionsof silicon andaluminum,andothermetalsmay alsobe
present,suchas magnesium,sodium,andpotassium. As a result, different clays
havedifferent characteristics,suchasplasticity andfusing points.
Clay was easyto use,becauseit requiredno preliminaryprocessing. In fact,

ancientclaysnaturallyformed molds of plantsandanimals,providing fossils for
sciences.Sun-driedclaysare still usedfor adobebrick in dry climates;warm
temperaturesdry andhardenthe clay. However, clays do not harden in water.
201.2 COMMON LIMES
After clays, Zimeswere probably some of the earliest cementitiousmaterials,

but commonlimes do not set underwater, andthey do requireprocessing.Limes
must be heatedbeforewater is added. Limes areproducedfrom calcium
carbonate,CaCO3,commonlyknown as calcite. Somehigh-calciumlimestones
Page 200 - 2 Ott 1996
200 CATEGORY DESCRIPTION Cement Kilns
containmagnesium.Dolomite, CaMg(COs)2,containscalciumcarbonateand
magnesiumcarbonatein equalmolecularproportions.
201.3 HYDRAULIC LIMES
Hydraulicsis a scienceconcernedwith water. Unlike claysandcommonlimes,

a hydrauliclime canbe usedto form a hydrauliccementitiousmaterial. In other
words, the materialcan set andhardenunderwater andwithstandthe erosive
effects of water. It couldbe usedto constructa dam. TheAmerican Societyfor
TestingandMaterials(ASTM) C 141-61definesit:
“An hydraulic hydrated lime is the hydrated, dry cementitiousproduct

obtainedby calcining a limestone containing silica and aluminato a ATSM
temperatureshort of incipient fusion, so as to form sufficient free lime Definitions
(CaO) to permit hydration, and at the sametime leaving unhydrated
sufficient calcium silicates to give the dry powder, meeting the
4’ requirementshereinprescribed,its hydraulicproperties.” [Calcining
amountsto cooking the limestone to free the embeddedcarbon dioxide.]
201.4 NATURAL CEMENTS
Natural cementsare hydraulic cementitiousmaterials; they are similar to

hydraulic limes. Eachraw material containscompoundsof silicon, aluminum,
and calcium. The only preparationrequired for the raw materials before
calcinationis to crushandgrind them to a smallsize. While the main useof
hydraulic limesis for mortar, the main useof naturalcementsis for concrete.
ASTM C lo-54 definesmodernnaturalcement:

“The product obtainedby finely pulverizing calcinedargillaceouslimestone.
The temperature of calcinationis no higherthan is necessaryto drive off
carbonicacid gas.” [CO,]
In brief, this is one manufacturing process for natural cement:

The rock is blasteddown from the faceof the quarry,crushedinto a size
suitablefor the kiln, loadedinto dumptrucks, anddumpedinto a rotary
kiln with coal -- a layer of rock andthen a layer of coalin a continuous
operation. As the chargeworks its way throughthe kiln, it becomes
calcined,e.g., heatedto removeits carbondioxide(CO,). Whenit reaches
the endof the kiln, a conveyortakesit to the grinderto be groundinto a
fine powder, naturalcement.
Ott 1996 Page 200 - 3

Cement Kilns 200 CATEGORY DESCRIPTION
201.5 POZZOLANA CEMENTS
This class of cements was made by the Romans from hydrated lime and finely
ground volcanic materials containing aluminum, silicon, sodium, and potassium.
Named for a town in Italy, Pozzolana cements were among the very earliest
forms of hydraulic cements. Of the six classes addressedhere, it is the only one
Cement which required two raw material components, as shown in Table 200.1.
History
is Between those ancient cements and the modem product lies a fascinating drama
Intriguing of chemical and mechanical experimentation, abundantly described by a number
of authors, some of whom are cited in this manual’s references. Skipping on to
more recent events, we leave to the reader the pleasure of discovering more of
the charm and intrigue enfolded within cement’s ancienthistory.
Table 200.1 Summary of Six Classes of Cement
Number of Main Compounds

Steps Required
Class of Cement Materials Which Produce
to Produce it
Required Characteristics
Clays None
I Aluminum
Silicates
Common Limes
Hydraulic Limes
Natural Cements Calcinate and Grind Silicates

I
4
Calcinate Limestone,
Pozzolana Cements 2 Mix with Silicates Yes
Finely Ground Pozzolana
Grind, Blend with Raw
Silicates,
Portland Cements 1* Materials, Produce Clinker, Yes
Aluminates
Grind Clinker
* Generally,f our components are used to produce modem portland cement:

limestone, silica, iron, and alumina.
Page 200 - 4 Ott 1996

202 LATER EVENTS LEADING TO PORTLAND CEMENT

For the last hundredyears,the main type of cementusedin the United Stateshas
beenPortland cement. It is a hydrauliccement,meaningthat it withstandsthe
effects of water. Its namemay haveoriginatedfrom a commentmadeby an
eighteenthcentury engineer,JohnSmeaton.In rebuildinga lighthousewhich
had beenheavily damagedby the poundingsaltwaterwavesof the ocean,
Smeatonsaidhe developeda cementwhich “. . . would equalthe bestmerchant-
ablePortlandStonein solidity anddurability . . .” (Its color was similar to the
limestoneon the Isle of Portland.)
Events
Then, in 1824,after persistentefforts andexperimentalrefinementsof many in
other constructionpioneers,JosephAspdinfirst patenteda materialwhich he Developing
named“Portland Cement.” (As a rule, the nameis no longercapitalized.) Cement
Using Aspdin’sdesignfrom England,depictedin Figure200.1,David Saylor

built a kiln in this country. It wasa vertical, domedkiln for burningbricks
formed from powderedlimestoneandclay. He groundthe burnedbrick clinker
into a powder, portlandcement,which won an awardat the CentennialExposi-
tion in Philadelphiain 1876. By 1890therewere seventeencementplantsin the
United States,producingover 330,000barrelsper year. Onebarrelof cement
equaledfour 94-lb bags,or 376poundsnet; we now measureproductionin tons.
Equipment. During the nineteenthcentury,therewas little mechanizationof

cementplants. The old vertical kiln was fuel efficient, but it requireda lot of
manuallabor. In developinga continuousoperationrequiringlesslabor, engi-
neerstried both horizontalandverticalmodels.
Then, FrederickRansomedevelopeda successfulrotary modelabroad,andthe

Atlas CementCompanyusedit in Pennsylvaniain 1899. It was only 25 feet
long and 5 feet in diameter,andit rotatedon a horizontalaxis. ThomasEdison
later patentedonemeasuring150feet long and8 feet in diameter,andsubse- Thomas
quent kilns were evenlarger. Figure200.2showsa kiln nearVictorville, mea- Edison’s
suring 450 feet by 16 feet. Fueledby coal,oil, andnaturalgas,thesecontinuous Kiln
operation rdtary kilns revolutionizedcementproductionin the United States.
Equipmentfor crushingandgrindingthe kilned clinker into powdery cement

also evolved. For example,the Gatescrusherandthe Griffin mill were not only
efficient anddependable,but they alsomadea fine, uniform product.
Ott 1996 Page 200 - 5

Developments in the United States. After the inventionofportland cement,

many yearspassedbeforethe industrybecameimportant in the United States.
The first U. S. productionwas in 1875. From 1875through 1879,the total
productionwas only 82 thousandbarrels,but the annuaZ productionincreasedto
42 thousandbarrelsin 1880,176million in 1928,and 182million in 1942. In
modemmeasure,tons, 182million barrelsis approximately34 million tons.
As a summaryup to that point, Table200.2lists someof the important eventsin

developingthe cementindustry. Eachof thesehashad a significant impact on
plant design,manufacturingprocesses,development,or use of the product.
Figure 200.1 An Early Cement Kiln Built By William Aspdin In 1848
Page 200 - 6 Ott 1996

Figure 200.2 A Long Dry Cement Kiln Near Victorville
Table 200.2 Some Notable Events In The Cement Industry
Before history: The first use of clays.

Before history: The first useof commonlimes.
1756: Smeaton’sdevelopmentof hydrauliclime, and the Eddystonelighthouse.
1818: The first naturalcementmanufacturedin the United States.
1824: Aspdin’spatentfor Portland cement.
1868: The first reinforcedconcrete.
Notable 1873: Invention of the rotary kiln.
Events 1875: The first portlandcementmanufacturedin the United States.
1880: The first useof the barrel pulverizer,the prototype of the tube mill.
1886: The first rotary kiln madein America.
1887: The discoveryof tricalcium silicateby Le Chatelier.
1891: The first concretehighway,built in Bellafontaine,Ohio.
1898: The first wasteheatboiler.
1902: Organizationof the Associationof PortlandCementManufacturers.
1903: The constructionof an eighteenstory reinforcedconcretebuilding in
Cincinnati.
1905: Organizationof the National Associationof CementUsers,which later
becamethe AmericanConcreteInstitute.
1905: The first usein the industry of the Batesvalve bag andpackingmachine.
1911: Applicationof the Cottrell precipitatorto cementmanufacturing.
1920: Invention of the Fuller-Kinyonpump.
1935: The first soil-cementsecondaryroad.
Recognition and Development of Potential. Since 1942, the industry has
advancedmainly through the continueddevelopmentof techniquesandthe use
of computers. Furthermore,ascementwasmanufacturedwith greater
uniformity andreliably met standardizedspecifications,planners,architects,
contractors,andbuildersbeganto seeits enormouspotential. As a result, the
building industry was revolutionized. As of the year 1993,the latest complete
data available,California had 13 cementkiln facilities andproduced
approximately10 million tons of cement.
Page 200 - 8 Ott 1996

203 BASIC CEMENT PLANT PROCESSES

The portland cementmanufacturingprocessesandmethodsof controllingair
pollutantsarediscussedin detail in the next chapter,but here is an overview of
the basic processes.
203.1 SELECTION OF RAW MATERIALS
Portlandcementgenerallycontainsfour chemicalelements:calcium,silicon,
aluminum,andiron, usuallyin the form of oxides. The iron andaluminum are
only a small percentageof the total mix. In selectingthe raw materials,these
factors are considered: Choosing
Raw
l Composition l Quantity
Materials
l Uniformity l Location,topography
l Physicalcharacteristics l Transportation
l Overburden l unit cost
Composition: The requirementsfor raw materialsfor clinker are these:

+ The essentialelementsmust bepresent.
+ Proportioningthe materialswithin desiredlimits mustbe possible.
+ The amountof nonessentialelementspresentis not excessive.
Uniformity: If a raw materialis not fairly uniform, it may requireexcessive

extra analysesandmixing operations;perhapsa better sourcecouldbe located.
Physical Characteristics: Someimportantphysicalcharacteristicsof the raw

materialsare grindability, homogeneity,andthe uniformity of its hardness.
Specialconsiderationsmay alsoapply:
+ If its hardnessvaries,doesit tend to segregateafter it is ground?
+ If it is to be blastedin a quarryor mine, doesit shattereasily?
Overburden: The amountof overburden,or waste material, and its physical

characteristicsmay makethe useof a raw materialimpractical.
Quantity: The supplyof the primary raw materialsmust be adequatefor the

plannedannualproductionandthe numberof yearsof operation. Primary
materialsare thosewhich form over 85 percentof the clinker weight, mainly
limestoneand silica. Secondarymaterialsform lessthan 15percent.
Location, Topography, and Transportation Methods: Theseinterdependent

factors in determiningplant locationcan affect the unit cost of the product.
Ott 1996 Page 200 - 9
203.2 LAYOUT AND WORKFLOW OF A CEMENT FACILITY
Eachplant is unique, but two main types of dry processplants predominate:
n Preheater/ precalcinerkilns, as pictured in Figure 200.3 and

describedin Figure 200.4, and
Each n Long dry kilns, aspictured in Figure 200.5.

Plant
is Typically, but with differences at individual plants, the process goeslike
Unique this: The basic raw materials, limestone (CaCO,) and silica (SiO,), are
mined at an adjoining or nearby quarry, loadedonto huge, 85-ton dump
trucks (for example), and hauledto a primary crusher. After the material is
crushedto piecesof approximately 8 inchesin diameter, it is moved by
covered conveyor belts to secondaryand tertiary cone crushers, which
reduceit to about 2 inch and then half-inch marble sizedpieces.
Next, the marble sized raw materials go to the pre-blending pile. In the
facility shown in Figure 200.3, the pile is inside a huge pre-blending dome
at the right edgeof the picture. The dome protects the materials from wind
erosion. In a pre-blending station, the primary materials (limestone and
sometimesshales)are mixed and blended. The blendedmaterial is further
mixed with iron, clay, and/or bauxite, which are stored in silos, on its way to
a grinding mill, where it is convertedinto powder. In this particular facility,
the mill is a 5,400 horsepowerbaZZmill, using tumbling steel balls to reduce
the marblesto powder. Figure 200.3, a compositephoto, shows a typical
preheater/ precalcinerplant, and Figure 200.4 shows the basic process.
An essential key to the efficiency and success of preheater / precalciner

Pre-Heat plants is the pre-heat tower near the mouth of the kiln. In Figure 200.3,the
Tower tower is in the centerof the picture. The kiln is fired from the opposite end,
At and the combustionheat of 2,700degreesFahrenheittravelsthrough the kiln to
15OOOF the mouth, wherethe valuableheatenergyis capturedand usedto preheatthe
raw materialsto 1,500degrees.Thefeed is thus precalcined(the carbondioxide
is driven off) beforeit is introducedinto the kiln.
[The text continues, entrained in sequence with the figures.]
Page 200 - 10 Ott 1996

Figure ZOO.3 A Preheater / Precalciner Plant Near Victorville
r
PREHEATER
H
DUST
COLLECTOR
g-I
m
c)
5. Hot combustiongasesmove up the kiln againstthe flow 0
arefed in at the upperendof the slightly inclinedand of the tumbling raw materials, Exhaustfans draw the gases
rotating kiln. Tires andcertainwastesusedas into the pre-heater,where the heat is usedto raise the
z
supplementalfuels may be introducedhere. temperatureof the raw materialsto about 1,500degrees.
2. Fossil fuels, coal, oil, or natural gas, and solvent- 6. Powderedlimestone,a primary componentof the raw
type fuels, if used, are introducedinto the kiln here. feed mix, chemicallyscrubsthe hot gasesasthey pass
3. In the burningzone,the flame reaches3,500degrees throughthe pre-heater,helpingto neutralizethe acid gases.
Fahrenheit.The raw materialsaverage2,450degrees.
Here,tires undergoa chemicalreaction,oxidizingtheir 7. A dust collectionsystem,suchasa baghouse,traps kiln
organiccompounds.Inorganicsteelbeltsoxidizeand dust,which is then eitherfed backinto the kiln asa raw
material,recycledin otherprocesses,or disposedof.
bondwith raw materials,forming nodulesof “clinker.”
g 4. Marble-sizedclinker leavesthe kiln and entersa 8. Carbondioxide,nitrogen,andwater vapor comprisemost
2 coolingchamber. Ultimately, cooledclinker is mixed of a kiln’s emissions.Other emissionsaredetailedin this
3 with a bit of gypsumandgroundinto portlandcement. chapter.
Figure 200.4 Workflow of Processes to Make Portland Cement
In contrastto preheater/ precalcinerkilns, long dry kilns suchasthat in Figure

200.5do not usepreheaters.The five vertical tubescollectand cool the kiln dust
beforeit entersthe baghousein orderto preventburning out the bags.
Long Dry
In both typesof kiln processes,however,aschemicalreactionsoccur within the Kilns
kiln to produceclinker, chemistscontinuouslymonitor andanalyzethe accuracy
of the blend. Using X-ray fluorescenceand computerizedmechanizationsuch
as that showninsetin Figure200.5, they makeadjustmentsasnecessary.Then,
after a hot journey through the kiln, the clinker is cooled and conveyedto a
Figure 200.5 A Long Dry Kiln

(Controllers are Inset)
Ott 1996 Page 200 - 13
Next, gypsumis added,to make concreteworkable,i.e., when the cementis

mixed with sandandgravelto produceconcrete,the gypsumdelaysthe setting
time. Then,someof the cementmay be packaged,as shownin Figure 200.6,
andthe rest is storedin bulk to await shipping. For bulk shipping,the most
commonmethodsareby rail andin the pneumaticallyloadedandrecognizable
truck-trailerssuchasthat shownin Figure200.7.
Some is
Packaged;
Some is
Bulk
Figure 200.6 Packaged Portland Cement
Cement
Transport
Trucks
Figure 200.7 A Pneumatically Loaded Cement Truck-Trailer

Page 200 - Ott 1996
204 FUELING THE FIRE

Cementplantsuseconventionalsolids,liquids,andgasesfor fuel, usually coal,
oil, and naturalgas. A few plantsalsouseselectedwastematerialsto Fuels:
supplementtheir main fuel, wastessuchas scraprubbertires, wastesolvents, Solid, Liquid,
and sludgesremainingfrom recyclingsolvents. Gas, and
Waste
204.‘l CONVENTIONAL FUELS
The solid fuels usedin cementfacilities areusuallycoals,suchasthe low-sulfur

product minedat Sunnyside,Utah. Someplantshaveusedpetroleumcoke or
small amountsof anthraciteandcoke, groundup andmixed with bituminous
coal. The liquid fuels arepetroleumproducts,andthe gaseousfuels areusually
naturalgas.
At most plants,fuels cost morethan any other materials,andonly occasionally

doesa site havenearbycoal deposits. Consequently,most fuels areboughtfrom
availablemarket suppliesandshippedin, often by rail.
Fuel storage: Cementfacilities usuallykeepa reservestock of fuels in order to

maintainproductionin spiteof anytransportationdisruptions,but stockpiling
hassomedisadvantages.Thecoal stockpileshouldhavegooddrainage,andall
nearbyvegetationmust be removed. Coalsfrom two sourcesshouldnot be
mixed, becauseof their different characteristics.Whencoal is stored,it is
importantto considerthesefactors:
. The possibility of fires in stockpiles,
. The graduallossof heat contentby oxidation,and
. Contaminationof the coal duringhandling.
Reserveoil stocksmay alsopresentdisadvantages, suchasthe needto provide

large storagetanks, sincethe consumptionis high. Furthermore,thick oil may
needto be heatedduring cool weather.
Gaseousfuels, while not normally stockpiledin reserve,may still be diminished

or interruptedfrom time to time, so someplantsmay substitutecoal or oil during
emergencies.
Fuel choice: The selectionof fuel for a cementplant may dependon the types
of fuels availablein the vicinity, the plant equipment,andthe relative cost of
eachtype. Thereareadvantagesanddisadvantages peculiarto eachtype.
Ott 1996 Page 200 - 15
Coal is usedat many plants becauseit is available and broadly distributed

throughout geographicalareas. By net heat energy, coal may have somewhat
Coal higher thermal efficiency than gas. However, while oil and gasmay be
burned asthey are received, coal must be crushed,finely ground, and
sometimesdried. Coal is also subject to considerationsof uniformity and its
level of contents of heat energy, ash, and sulfur.
On a net heat energyper unit cost basis, someoperatorshave chosenoil.

Oil Kiln fuel control may be easierwith oil than with coal, and in caseswhen the
color of the cementmay be significant, oil may affect the color lessthan
doescoal.
Natural gasmay be a very desirablefuel for cementplants, dependingon its

quality, quantity, and price, becauseof its relative easeof handling and ease
Natural Gas
of controlling the rate of fueling the kiln. However, since the gas flame
burns faster and hotter than coal, for example,it may produce larger
quantities of fJOX (oxides of nitrogen).
204.2 SUPPLEMENTAL FUELS
A few cement plants supplementtheir main fuel with permitted, measured

amountsof selectedwaste materials such as usedrubber tires, waste
solvents, and the sludgesremaining from solvent recycling. Burning these
2,700 Degrees wasteshasraised questionsfrom people who are concernedabout the effects
Fahrenheit on the environment. However, sincekilns provide controlled burning at
temperaturesabove2,700 degreesFahrenheit, perhapsburning somewastes
in kilns can be a welcome solution to someof our difficult and expensive
disposalproblems.
Disposing of thesewastes has posedthe problems of storage,handling,

transportation, and sometimeslandfill considerations. Each year, for
example,California generatesan estimated2300,000 tires for disposal.
Unmanagedor illegally stockpiled, these scraptires can pose environmental
and health risks.
Page 200 - 16 Ott 1996

(”
Alternative “disposal”methodsfor rubbertires havecausedtheseproblems:
II Tires canbe a habitat for vermin andthey may containpuddlesof casual

water for mosquitosand otherpests
WhY
N Tires haveoften beenirresponsiblydumpedin rivers, streams,andother Burn
remoteproperty, for convenienceandto avoid a $2 disposalfee. Tires?
W Stacksof tires canposea serioustire hazard. Tires buriedin a central

California landfill recentlycaughtfire. The fire was difficult to quench,
and it producedthick, blacksmokefor about10days.
Furthermore,disposingof tires in landfills canbe an energywaste. According

to studiesby Southdown,Inc., “Theaveragepassengerradial tire containsover
50percentpure rubber polymer and syntheticfibers, which meanseachtire is More Energy
packed with energypotential -- about 15,000Btuper pound, comparedto about Than Coal
IO, 000Btu per pound of coal.” Other sourcesestimatethat the heatenergyof
coal is about 12,000Btu per pound,while tires canproduceabout 1.2times as
much, or 14,400Btu.
The Southdowncementplant, nearVictorville, was oneof the first plantsin

California to usetires asa fuel supplement.Their staff found a suitableratio of
tires to naturalfuel anddevelopedmethodsof handlingthe tires. In 1991, they
performeda test comparingkiln emissionswith andwithout tire burning. As
shownin Table200.3,the resultswere favorable. Plantemissions,for example,
containedlessnitrogenoxide (NOX) with tires as a fuel supplementthan
without. One witnesswho watcheda tire enterthe kiln exclaimed,“Within afew
feet of the entry, the tire was completelyvaporized!” The steel belts from
radial tires becomechemicallylockedinto the cement,to augmentthe
purchasediron, an essentialingredientof cement.
Southdownultimately determinedthat burningtires was not economically

feasiblefor their plant. Other plants,however,suchasthe Mitsubishi Cement
Company,continueto usetires to supplementlow-sulfur coal. They have
installedan automatedsystemfor loadingthe tires and conveyingthem into the
kiln at a measuredrate, as shownin Figures200.8and 200.9.
Ott 1996 Page 200 - 17

Table 200.3 Burning Tires: a Test Demonstration
Cement Kiln Emissions, Using Tires

for Supplemental Fuel
Victorville, CA, April ‘91
Compound Measured Coal Only Coal and Tires
Sulfur Dioxide, ppm 4 2
Oxides of Nitrogen, ppm 435 336
Carbon Monoxide, ppm 980 770
Total Hydrocarbons, ppm 12.5 8.6
What kinds of wastes may be suitable for burning as supplemental fuels?

There are two main stipulations:
+ The waste must contain a significant amount of potential energy to

Stipulations
augment the primary fuel.
for
Burning Waste
+ The waste must not contain RCRA (Resource Recovery and
Conservation Act) regulated substanceswhich could produce toxic
emissions, e.g., metals such as antimony, arsenic, barium, beryllium,
cadmium, or hexavalent chromium, etc., unlessthe kiln complies
with the detailed requirements imposed by the EPA Boilers and
Industrial Furnaces rule.
Page 200 - 18 Ott 1996

Figure 200.8 Used Tires for Disposal as Supplemental Fuel
Figure 200.9 Tires Are Conveyed into the Kiln at a Measured Rate.
Ott 1996 Page 200 - 19
205 CEMENT KILNS AND AIR QUALITY

How cancementkilns affect our air quality? In most stagesof the processes,
opportunitiescanoccur for pollutantsto escapeor to be propelledinto the air.
Pollutantsmay escapefrom the time the sourceelementsare minedfrom within
the earth,crushed,conveyed,mixed, fired in the kiln, groundinto powder,
stored,anduntil the final product is shipped.
The pollutantsfrom cementkiln facilities aremainly particulatesand productsof

combustion. Someof the particulatesemitted areof smallerdiameterthan 10
microns; theseare calledPMlO. Operatorsarevery awareof cementkiln dust,
(CKD) not only becauseit could pollute the air, but alsobecauseit isproduct.
In yearspast,CKD was often presentthroughoutmost plants,but with modern
equipmentandcontrols,now CKD occursmostly at the feed endof the kiln,
where nearlyall cementplantsin California captureandrecycleit. Details of
sources and controls are presented in Chapter 3.
The APB’s EmissionsInventory Branchlists the emissionsfor eachCalifornia

cementkiln facility. Thetotal emissionsby classificationsfor the year 1993,the
Emissions latestyear for which dataanalysisis completeandavailable,are listed below:
from
Cement Plants
+ Total organic gases (TOG) 450.5 tons/year
+ Total carbonmonoxide (COT) 4,759.2 tons/year
+ Oxides of nitrogen (NW 15,043.o tons/year
+ Oxides of sulfur @OX) 1,535.4 tons/year
+ Particulatematter PM) 6,810.6 tons/year
(This datais reviewedanddiscussedin more detail in Chapter3.)
Page 200 - 20 Ott 1996

300 PROCESS AND CONTROL Cement Kilns
This chapterdescribesthe processesusedin cementkiln operations,someof the

equipmentused,andthe control methodsusedto limit air pollutantemissions. What’s
Most of the emissionsoccurwherevermaterialsarehandledor transported. in
This Chapter
301 PROCESSES IN BRIEF
With referenceto a typical plant layout shown in Figures 300.la, 300.lb,

and 300.2 on the next three pages,this is briefly how portland cement is
made: Shale or clay and a calcareous material (a substancecontaining
calcium carbonateor lime) are quarried, crushed,carefully proportioned,
mixed, groundto a fine powder,andthen cookedat about2,700OF.
Process
For mixing and grinding, either a wet processor a dry processmay be used, Overview
but it is essentialthat the mixture be correctly proportioned, finely ground,
and thoroughly intermixed. California cement kilns have usedthe wet
processin the past, but most or all haveconverted to the dry process,
becauseevaporating extra moisture in the kiln requires more heat energy.
Next, iron and aluminum are added,and the mixture is fed into a slightly
inclined kiln which rotates about its nearly horizontal axis. As the mixture
makes its way slowly toward the low end of the kiln, it is heatedto the
sintering point -- a temperatureat which the massbecomesshapedandpartly
fused, but below the melting point. The water and carbon dioxide are re-
moved before the massbecomeshot enoughto form clinker. As the mass
becomeshotter, chemicalreactionstake place within the mixture, forming
new compounds. Someof these compoundsmelt to partially fuse the mass.
The resulting clinker is then droppedinto a cooler or conveyedto a clinker

pile to be cooled, sometimeswith a water spray. When cool, the clinker is Gypsum
mixed with a small amount of gypsum, and the mixture is ground to a very is Added
fine powder, portland cement, which is usedto make concrete. The gypsum to Provide
allows the concreteto remain workable for a longer time before it sets. Workability
The finely ground cement, which must conform to certain standardspecifica-

tions of composition, fineness,strength, and other physical properties, is
conveyed to silos, whereit is storeduntil it is shipped. It is usually shipped
in bulk by specialtrucks, or by rail, but may also be packagedin bags of 94
pounds net, 4 of which constitute a barn9 of 376 poundsnet. Barrels used
to be the common unit of measure,but now we use tons. Processes are
described in more detail after the layout figures on the next few pages.
Ott 1996 Page 300 - I
300 PROCESS AND CONTROL
This is a fairly typical preheater / precalciner plant,

except that most plants finish-grind their own clinker.
CRUSHED BLENDING IL RECLAMATION
COAL STORAGE
(Most plants grind their own clinker.)
CEMENT MILLING
Figure 300.la Workflow and Process
(Two adjoiningpages)
Page 300 - 2 Ott 1996

RAW MILLING
WltGALWNtil
PREHEATER BAG HOUSE
CEMt :NT STORAGE CEMENT SHIPPING -
Figure 300.1 b Workflow and Process
Ott 1996 Page 300 - 3

Figure 300.2 A Preheater / Precalciner Cement Kiln Facility
Page 300 - 4 Ott 1996

302 PROCESSES IN DETAIL

In this section we presentdetails of thesecement plant processes:
(PleaseseeFigures 300.3 and 300.4.)
. Cement Kiln
Quarrying Operations
. Preliminary Grinding and Mixing Processes
. Kilning / Clinker@, and
. Finish / Fine Grinding
. Storing, Packaging,and Shipping
302.1 QUARRYING OPERATIONS
While safety is an essentialconsiderationthroughout the cementplant, and

hard hats are always required outside of vehicles and offices, the quarry may
require even more vigilance. In this openpit mine, tons of material are harry Safety
drilled, blasted, scooped,loaded,and dumped. In blasting,
+ Peripheralpersonnelmust be aware and protected,
+ Radio transmissionsmust be restricted to prevent premature ignition,
+ The plume and its debris must be safely contained,and
+ The plume must remainwithin plant boundaries.(Checkthe wind first.) Blast Plume
Must
Heavy equipment abounds. Huge loaders,and dump trucks standing 18 feet Remain . . .
tall weighing 85 tons, carry their 85 tons of rock quickly along unpavedroads
to the preliminary crushermills. If the mined raw material is dry, then
personnelmust take precautionsto prevent dust from escapinginto the air.
The roads may needto be sprayedso that vehicleswill not raise dust into the
air. Often, covered conveyorsare used insteadof trucks to move the raw
materials to be processed. Covers may be required by the conditions of the
permitted equipment.
302.2 PRELIMINARY GRINDING AND MIXING
Preparing the Raw Mix: In preparingthe raw mix, the goalsare that:
n The raw materials are combinedin the desiredproportions,
n They are blendedas completely as practicable, and
n They are ground to an optimum size so that the ratio of surfaceareato
weight will allow the chemicalreactions in the kiln to reach equilibrium.
Main Raw
The two main raw materials,limestoneand shale,andusuallyiron andalumina, Materials:
are combinedalongthe way. They are carefully proportioned;it is crucialto Limestone, . . .
obtain the desiredratios. The raw mix may be so finely groundthat 85 per cent
of it will passthrough a 200-meshsieve,where eachopeningis about.003inch.
In the past,both wet and dry processeshavebeenusedto preparethe mix.
Ott 1996 Page 300 - 5
Drill Rig
Overburden Dumpedto Blastingis conductedwith greatcare. Most blastsproducemuch

smallerplumesof rock anddust.
1%&d Shaleor Clay
Figure 300.3 Quarrying and Crushing Cement Materials

(Blasting is Inset)
Figure 300.4 A Limestone Quarry With Heavy Equipment
Ott 1996 Page 300 - 7

The Wet Process is the older of the two methods. The amount of water
neededfor the wet processdependson the physical and chemicalproperties
of the raw materials. For example,the water for limestone-clay slurries may
be about 50 per cent, while limestone-shaleslurries may require less. In any
Wet Process
event, all of the water addedto preparethe kiln feed has to be removed
is Older
eventually, andthat can require expensivefuel consumption.
Similar types of mills and operationsare usedin both the dry and wet pro-
cesses. However, in the wet process,there may be more options to the
sequenceof operations,dependingupon the physical characteristicsof the
raw materials as they are received at the plant.
After crushing,the material is dumped into hugebins, from which the chem-
ist blendsthe correct proportions. The componentsof the feed are measured,
and small adjustmentsmay be madeto the amountsof shaleor limestone in
order to provide a constantand optimum mixture to be fed into the kiln. As
the feed approachesthe kiln, waste heat from the kiln entranceis usually
usedto pre-heat the feed to a temperatureof about 1500 degreesFahrenheit.
Dry Process In the dry process, raw materials may be dried before entering the
preliminary mills, but the heat generatedby the friction of preliminary
grinding may be sufficient, and waste heat from the kiln may also be used
for drying the material.
Preliminary blending of the raw materials may be accomplishedin the

quarry by a huge frontloader, as depicted in Figure 300.4. For example, one
scoopof stripping and two of rock may be loadedinto the 85-ton transport
trucks suchas the one also depictedin Figure 300.4. The proper proportions
may also be blendedlater, when the material is conveyedto the crushers,
where it is reducedto the size of marbles. For this dry process,the material
is ground and pulverized without adding water, and the finely crushedrock
may be dried before it is pulverized.
Wet or Dry Process ? Eachfacility does only one process,not both, and
Wet or Dry?
switching back and forth is not practical. For the dry process, most of the
water content of the mix must be removed early in the preparations. For the
wet process, the mix has a large percentageof water when it entersthe kiln.
However, it requires lessheat energy to remove the moisture at the
beginning of the dry method than to remove the water for the wet method
during the kilning process. Consequently,taking into account the following
considerations,most California kilns currently use the dry method.
Page 300 - 8 Ott 1996
Wet or Dry? Five Factors Which May Affect the Choice:
0 Water content of the raw materials Choosing

0 Water supply at the plant the
0 Cost of fuel Process
a Dust collection
0 Uniformity of the product
Water Content of the Raw Materials: If the primary materials are wet
when receivedat the plant, then the wet processmay be suggested.Wet
materials include marl, granulatedblast furnace slag, and some clays. If the
materials contain only surfacewater, then adding large quantities of water to
be removed later may not be fuel efficient.
Water Supply: Many plants are locatedin dry areasof the state.
Cost of Fuel: Relatively expensivefuel favors the dry process,becausedry

feed requires lessfuel to heat and maintain the kiln at 2,700 degrees
Fahrenheit. However, burning hazardouswastesto augmentthe usual fuels,
coal or gas, may lower the cost of fuel, making the wet processmore viable.
Dust Collection: Less dust may be expectedfrom the wet processthan from
the dry process,requiring less dust control equipment.
Uniformity: A total weight of about 600 poundsof dry raw materials is

required to produce a 376-poundbarrel of clinker. It may seemthat the
slurry for wet-processcement would be more uniform than the dry-process
materials. However, dry mix can be weighed after preliminary grinding,
allowing accuracyof mix ratios in order to producedry processcement
which is uniform enough for any commercial use.
302.3 KILNING / CLINKERING
The kiln, such as that shown in Figure 300.5, may havemore functions than
any other piece of equipment in a cementplant. The kiln servesas:
+ A chamberfor the combustionof fuel,
+ A flue for gasesand vapors,
A conveyor for solids,
ii A heat exchangerand dryer,
A calciner (It drives off calcium carbonate),
: A mixer for the raw feed, and
+ A host for chemically transforming the feed into clinker.
Ott 1996 Page 300 - 9
--Jo Kiln Clinker
Clinker + gypsumconveyed
to grindingmill
Clinker Separator Dust

Collector f F-\~\T\/ PneumaticDucts
Bulk Trucks andBoxcars
Figure 300.5 Long Dry Kiln Operations

Sinceit hassomany functions,the kiln may not produceoptimum resultsfor

any one function, so compromisesor additionsmay be madein favor of one or
more of the others. For example,the first two do not requirerotation, andasa
conveyor,the kiln neednot be so elaborate.The last function, of course,is the
essentialandnearlyfinal goal in producingPortlandcement.
302.4 FINISH / FINE GRlNDtNG
By the processalready shown in Figure 300.5, the finish or fine grinding of

marble-sizedclinker is accomplishedby a heavy duty device such as shown
in Figure 300.6, a 4,500 horsepowersteel ball mill. In this rotating, drum-
like device with inwardly protruding feet, the clinker is lifted and dropped Steel Bat Is
by the feet, while steel balls pummel and mash it into a fine powder. The Pummel and
fine grinding is not always completedat the kiln site. At least one plant Mash
sendsthe clinker marblesto a plant which specializesin finish or fine
grinding, packaging,and shipping.
Figure 300.6 A Finish Mitt for Fine Grinding
Ott 1996 Page 300 - 11

Cement Kilns 300 PROCESS AND CONTROL
302.5 STORING, PACKAGING, AND SHIPPING
The fine, powderedcementmust be kept captive;it is the valuableendproduct

of a long and exactingprocess,but it is alsoa potentialair pollutant. It is usu-
ally pneumaticallypumpedthroughvalves,ducts,and tubesfrom onehost to
another,i.e., from mill to silo to bulk truck to concretebatch plant storageto
concretemix, etc. It is essentialto assurethat the connectionsdo not leak.
303 POSSIBLE SOURCES OF EMISSIONS

The ARB’s emissionsinventory separatelylists emissionsfor each Califor-
nia cementplant. As introduced in the previous chapter, the total emissions
by classification for the year 1993,the latest year for which data analysisis
complete and available, are listed below:
+ Total organic gases (TOG) 450.5 tons/year

Emissions + Total carbon monoxide (COT) 4,759.2 tons/year
+ Oxides of nitrogen (NW 15,043.o tons/year
+ Oxides of sulfur (SW 1,535.4 tons/year
+ Particulatematter PM) 6,810.6 tons/year
(This datawas mentionedbriefly in Chapter2.)
Where do these emissionscome from? The types of pollutants emitted from

eachpZantdependon its peripheral operationsand components, assorted
machinery, internal combustionengines,and motor vehicles. Basically,
Where do most opportunities for pollutants to escapeinto the air occur at the mouth of
Emissions the kiln, at points where materials are handledor transferred from one place
Come From or carrier to another, and where control equipmentis not operating properly.
?
Fugitive dust can come from quarrying, crushing, and grinding operations.
Oxides of nitrogen can come from combustion sources,the amount depend-
ing on the type of fuel, the burning temperature,and other variables. The
Emission Factors are included in Appendix G, AP-42, but they are
approximations,and specific casesmay vary.
From a constructive point of view, the many possible sourcesof pollution at

cementfacilities couldbe called,“Opportunities to Prevent Air Pollution.”
Page 300 - 12 Ott 1996

Through conscientioususe of proceduresand controls, pollution may be

preventedat eachof theseopportunities:
n The mouth of the kiln,
n Elevators, and conveyor belts,
n Filters / dust collectors throughout the plant,
n Roadways in plants and entries to public roads, and
n Loading / transportation points.
304 CONTROL OF AIR POLLUTION

The cement industy has already attained significant reductions in their air
emissionsthroughout the years, as new technologybecameavailable. We Industry
can continue to control air pollutants from cementfacilities throughout Has Reduced
California by complying with the rules and regulations,by using control Their
devicesas appropriate,and by implementing frequent, effective maintenance Emissions
and housekeepingpractices.
304.1 RULES AND REGULATIONS FOR CONTROL
Rules, regulations, and the permitting processare designedto control

emissionsfrom plants by setting limits and requiring specific operating
conditions. Theseregulationsare stringent, and they vary from one district
to another,but they generally include:
+ Visible emissions- not greater than 20% opacity or higher than a
Ringelmann 1; State law doespermit no greaterthan 40% / Ringelmarm 2.
+ Fugitive dust - dust usually cannot crossproperty line.
+ Breakdown - must report breakdownswithin one hour.
+ Nuisance - must not emit pollutants which causeinjury, detriment,
nuisance,or annoyanceto any considerablenumber of personsor to the
public, or which endangerthe comfort, repose,health, or safety of any such
personsor the public, or which cause,or have a natural tendencyto cause,
injury or damageto businessor property.
+ Permit to Construct - to construct or modify, must havethis permit.
Regular
+ Permit to Operate- must operateunder the conditions listed on the permit. Maintenance
+ Regular maintenance- can help assure compliance with air pollution Pays
regulations, avoid breakdowns, and maintain production efficiency.
Ott 1996 Page 300 - 13
04.2 METHODS OF CONTROL
be of the primary elements of maintenance is thorough cleaning. Most

ontrol devicesused at cement plants collect and / or suppressdust which is
redominantly particulate matter.
Cjementkiln dust, known asCKD, hasbeena problemthroughoutthe plant in

CKD: Y’earspast,particularlywherevermaterialswere handledor transported. Today,
Cement Kiln dlustcollectorsare usedin most areas,with devicesbasedon inertia, filtration,
Dust SC:dimentation,or electricalprecipitation. The dustis usuallyeither a raw
rc:sourceor a valuableproduct, portlandcement,so it canbe addedto oneof the
ri LWmaterialsor to the raw mix, or perhapsit canbe fed directly into the kiln.
Clollection devicesinclude electrostaticprecipitators and baghouses. CAP

h,astechnical manualsfor both, checklists and operatingtips from which are
PIrovided in the Appendix of this manual. Various designsof these devices
Ci an attain collection efficiencies as high as 99%. The many variableswhich
dleterminetheir efficiencies include design,bag material, particle size, flow
rilte, etc. Table 300.1 shows typical emissionsourcesand control measures.
Table 300.1
Typical Emission Sources and Control Measures
Source Control Options

How
to Blasting Water / chemical suppressants
Control CKD Crushing Water sprays
Overburden Water sprays
Fuel deliveries Coveredcoal cars or train enclosure
Coal storageand handling Covered storage
Preheater Baghouses
Kiln Baghouses
Cement transfer / shipping Pneumaticducts with sealedvalves
Cement screws Sealsand socks
Conveyors Cover, vent, capture, suppress,spray
Yard and road dust Wash, sweep,pave, spray, landscape
Public roads (trackout) Cleantruck tires and rails at departure
Stockpiles(ground) Water sprays,windbreaks, covers,
structured storage,trapdoor access
Page 300 - 14 Ott 1996
400 INSPECTIONS Cement Kilns
How to do an Inspection. This chapter,written primarily for the regulatory

inspector, can be an excellent sourceof information about conducting facil-
ity self-inspections. It can guide you through a complete complianceinspec-
tion of a cement facility. It discussesproceduresfor pre-inspection,post-
inspection, sampling, and inspector safety. Guidelinesand checklist materi-
als are provided here. When you use your checklists, you may find
rewards: Your inspectionswill be more effective, andyou will save time as
you are more aware of theseaspectsof your inspection:
n What to look for,

n What questionsto ask,
n How to locate unpermitted cementequipment, and
n How to conduct, complete,and documentyour inspection.
The standardsand policies you needto determinecompliancewith each

i requirement will dependon your specific district rule and implementation
strategy. You may place a copy of your district rule and your inspection aids
in the appendixprovided for it.
First, follow the pre-inspectionprocedures. Review the sourcefiles and

applicablerules, learn what equipmentyou may need,what information to
exchangewith the facility manager,and what to check for on the Permit to
Operate.
Then, proceedwith a complete complianceinspection, including cement

plant equipment, operations,and administrative requirements.
the post-inspectionproceduresprovide guidanceon how to deter-

Finally,
mine compliancerates, calculateexcessemissions,and assurefollow-up.
Your objectivesasyou inspecta cementkiln areto assurecompliancewith:
+ Stateandfederalregulations,
+ District regulations,
+ Authority to Construct/ modify and
+ Permitsto Operate.
District regulationswhich are generallyassociatedwith concretebatchplants

includethoseconcerningfugitive dust, visible emissions,particulatematter,
Ott 1996 Page 400 - 1

Cement Kilns 400 INSPECTIONS
breakdowns, nuisance, and Permits to Operate, specifying conditions under

which the equipment and facility must operate (such as hours of operation,
production rate, etc.). An extensive baghouse inspection checklist and associ-
ated information are included in Appendix D.
401 PRE-INSPECTION PROCEDURES

Before you visit the site, your preparations are essential. Some of the general
guidelines and steps to follow are discussed here:
File Review. In the District source file, check all the information available
about the plant, including:
1. Equipment lists
2. Permit applications
3. Permits approved
4. Conditions for each permitted unit
5. Previous inspection reports
6. Reports of Violation (note rule sections and equipment)
7. Enforcement action taken
8. Complaints
9. Variance history
10. Abatement orders
11. Source test date
12. Breakdown report
13. Authority to Construct
You may enhance the tenor of the pre-inspection meeting by completing some
portions of the inspection documentation before arriving at the facility. If your
district has specific checklists or forms, use them.
Regulation Review. Review any references to specific rules which may be

noted in the source files, assuring that you are familiar with each standard and
exemption for each applicable rule. Discuss the legal requirements with experi-
enced personnel and review any policies your district may have. Assure that
you receive consistent interpretations on how to apply requirements of the rules.
Page 400 - 2 Ott 1996

Equipment Check. Assembleall appropriateequipmentfor the inspection,

suchas:
1. Vision andhearingprotection
2. Safetyshoes,hard hat, andgloves
3. Identification cardsand businesscards
4. Samplingsupplies,if samplesmay be required: cans,labels,pens,seals,
wipes, and containerto carry cans
5. Forms for inspectionandchainof custody
6. Specializedequipmentsuchasa visible emissionsevaluationkit,
includingprovisionsfor determiningtemperature,dewpoint,andwind
7. Cameraand film
Pre-entry and Entry.
1. Look at the plant from the outside. Do you smell any odorsor seeany
emissions?Note the sizeandlayout of the facility. Identify andprioritize
potentialproblem areasto inspectfirst if your time is runningshort.
2. Enter the facility throughthe normalpublic access.
3. Presentyour businesscredentials.
4. Requestto seethe contactpersonmentionedin the files, suchasthe plant

manageror a supervisorof environment,production,or maintenance.
Be preparedto cite andprovide copiesof thesesectionsof the CaliforniaHealth

& Safety Code(HSC) in casethe sourcerepresentativemay not be familiar with
your district’s authority:
- 41510:Right of Entry
- 42303:Information Required
Know your district’s policy for refused entry.
Ott 1996 Page 400 - 3

Pre-inspection Meeting. Before you begin your inspection, meet with the
source representative to obtain operating information. State the purpose of your
inspection and identify the equipment which you will inspect.
During this meeting, obtain information including:
1. Name, complete address, and ownership of the plant

2. Contact name, title, and phone number
3. Operating season, schedule, and production rate
4. All fuels used and sulfur contents (for permitted tanks)
5. Date of last breakdown
6. A copy of the annual inventory reports as required by the district permit
7. Any unfinished district business such as variances, Authority to Construct,
and breakdown correction reports.
Discuss sample collection and any required safety procedures, and request
copies you need, such as production records and material safety data sheets
(MSDS).
Check Permits. Request to see a copy of each permit for the facility - permits
should be posted - and check that they are current and valid. Check existing
permit conditions and ask if any changes to the operation have been made which
are not reflected in the permits.
402 FACILITY INSPECTION PROCEDURES

Begin the inspection of the facility, keeping in mind throughout, these
six points of inspection:
n Capture / Point of Contaminant Generation
w Transport
n Air Mover
n Instrumentation
w Subsystem
w Control Device
In order to assure that you do not overlook any equipment or operations,

you may wish to conduct your inspection in the same order as the production
process, from quarrying to shipping. As you proceed, ask yourself questions
about each phase and aspect of the facility to help you determine compliance
with your district’s regulations and permit conditions.
Page 400 - 4 Ott 1996
Most districts have developedan inspection form tailored for their own
regulations and permit conditions. Write the answerson the inspectionform.
If your district does not have a tailored inspection form, the questionsin
the following sectionsmay help you to developa sourcespecific inspection
form pertinent to the regulationsand permit conditions for facilities in your
district. Sampleinspection guidesare included in Appendix D.
Compliance with Regulations. Check compliancewith the regulations

commonly associatedwith concretebatch plants, including the requirements
related to visible emissions, fugitive dust, and particulate matter.
(Compliance Assistance technical manuals are also available for Aggre-
gates, Hot Mix Asphalt Facilities, and Baghouses.)
1. Visible Emissions (VE) Checklist (A CAP VE handbookis available.)

a. VE from the facility - Do you seeany which violate opacityor
i\
Ringelmannlimits for your district?
b. Emissionpoints - Checkall possiblepoints.
In order to perform a visible emissionsevaluation, you must be certified.
For information on becoming certified, contact the ARB at 800-952-5588. If
you do evaluateVE, be sure to follow the prescribedprocedures. Use a stop
watch or one with a secondhand, and rememberto determinethe relative
humidity. An evaluation form, along with techniquesfor making and re-
cording smoke evaluationsfrom stationary sourcesis includedwith EPA
Method 9, located in Appendix C. Further details about VE observationsare
provided in the APB’s VE certification courseand in the CAP handbook.
2. Fugitive Dust Checklist (A CAP handbook is also available.)
a. Dust, outside - Do you seeany comingfrom the plant?
b. Propertyline - Whereis it? Doesany dust travel pastthe line?

c. Dust, inside - Precautionsadequateto minimize dust?
Do trucks track cementonto road / yard area?
Pavedroads or wet roads
Speedlimits for vehicles
Wind breaks: screens,walls, bushes/trees
Stockpilescovered or watered
Conveyors coveredor watered
Program of control or watering
Ott 1996 Page 400 - 5
d. Cement - Are filters / collectorsfor silos/ bins usedeffectively?

e. Public roads - Precautionsto preventdepositingproduct?
(Trackout) Is dustremovedfrom trucks beforethey enter
public roads?If tracks occur,promptly removed?
f. Wind - Write down the presentspeedanddirection:
Takethreewind readingsat 15-minuteintervalswith Dwyer gauge,or get wind
datafrom nearestair monitoring stationor a wind instrumentlocatedat the site.
3. Particulate Matter Checklist
4 Visible emissions - Violation of limits?
4 Control equipment - ConditionOK andoperatingproperly?
4 Productionrate - Changedsincelast inspection?

By how much?
Permit to Operate - Compliance. The permit issuedby your district will list
the conditionswhich must be met in orderto comply with your district’s air
pollution requirements.Determinewhetherthe plant complieswith its permit.
If the plant doesnot havea permit, or if the permit is not current andposted
properly,or if the conditionsare not met, issuea Notice of Violation or take
other actionconsistentwith your district’s policies.
Permit Checklist
a. Permit - Current andproperlypostedfor equipmentsuch

assilos, bin vent filters, mixers, and scales?
(Somedistrictsissuepermits for combinationsof
equipment;othersissueindividual permits.)
b. Equipment - Accuratelylisted? Substituted,added,or modzjZed

without Permitto Operate/ Authority to Construct?
c. Equipment - In goodworking condition?
d. Operatingconditions - As specifiedby the permit ?
Page 400 - 6 Ott 1996

Be sure to check all conveyors and transfer points, including valves and
ducts. For Maintenanceand Self-inspection,managersmay regularlyaddress
the items listed below to help maintainequipmentin good working condition.
As you checkeachpieceof equipment,use a checklist.
1. Raw Materials Conveyors Checklist
a. Raw material - Any emissionsfrom it?
b. Conveyorcovers - Are they usedto control dust?
c. Dischargechutes - Any emissionscoming from product?
d. Collector dischargevalves - Working properly?
e. Lubejoints and gearboxes - Date last lubricated? How often?
2. Loading Stations
a. Pneumaticvalves - Freeof leaks?
b. Filters / collectors - Operatingproperly?
3. Ductwork
a. Material buildup - How often is ductwork inspected?
b. Deterioration - Any dents,rust, holes,or cracks?
c. Fugitive leaks - Inspectcloselyaroundbends,elbows

andtransitionpieces. Look andListen.
d. Dustpiles - Checknearbyandunderneathducts.
Ott 1996 Page 400 - 7

4. Bayhouse Figure400.1is a photo of a baghousewith a continuous

emissionsmonitor, (CEM.)andFigure400.2is a diagramshowingbag cleaning
methods. Here is a shortbaghouseinspectionchecklist. A more extensive
exampleis in AppendixD, anda CAP baghouse technicalmanualis alsoavailable.
a. Pressuresystem: positive,or negative?
b. Write down the pressuredrop acrossthe baghouse.
c. Write down the inlet andoutlet temperatures.
d. Any fugitive leaksfrom housing?
e. What type of cleaningsystemis used?
f. How often arethe bagscleaned?
g. Are therevisible emissionsduring cleaning?
h. Is compressedair pressurefor cleaningadequate?
i. How arebagschecked?How often are they checked/changed?
5. Plant Towers
a. Are therefugitive leaksfrom the housing?
b. Any holes,cracks,or signsof corrosion?
c. Overflow chutes: Any dischargeonto the ground?
6. Fan
a. Location:
b. Type of fan:
c. Motor horsepower:
d. Pressuredrop acrossthe fan:
e. Excessivevibration or noise?
f. Visible emissionsfrom the fan?
7. Storape Bins
a. Are thereemissionsfrom the storagebins?
b. How many bins arethere? Of what capacity?
8. Recvclinp Svstem
a. What materialsarerecycled?
b. What percentof the mix is from recycledmaterials?
c. Is wastematerialcontained,or trackedaway or carriedto waterways?
After collectingall of the information that you needto determinecompliance

with regulationsandpermit conditions,you are readyto begin the post-
inspectionphaseof the inspection.
Page 400 - 8 Ott 1996

400 INSPECTIONS
Ott 1996 Page 400 - 9

Sonic Vi brati ion verii cal
Figure 400.2 Baghouse and Cleaning Methods
Page 400 - IO Ott 1996

r;
403 POST-INSPECTION PROCEDURES

Beforeleavingthe facility,
1. Determinewhetherthe plant is in compliance.
2. Inform the plant representativeof the inspectionresults: If appropriate,

issuea Notice of Violation (NW), adviseof additional concerns,and
indicate whether more information or investigation is needed.
3. Document samplecollections, any unresolvedconcerns,and requests

for additional information.
Follow up on all violations, consistentwith your district’s policy, to ensure

that the facility is brought into compliance. Using your district’s format,
preparea report for your district’s files. The report may include or refer to
i:-
the following items, some of which may alreadybe in your district’s file for
that facility. They may needto be updated,however.
- A written descriptionof the facility andprocesses.
- A plan diagramshowingthe locationof equipmentandemissionpoints.
- A processdiagram: materials,flow rates,temperatures,pressures,etc.
- A statementindicatingcomplianceor violation for eachemissionpoint.
- Recommendations,if any, suchasa sourcetest or an engineering

evaluationfor emissionsregulatedby rulesother than the opacityrule.
- Assessmentof fugitive emissionsandotherpotentialimpacts.
If you take any samples,then follow your district’s chain of custody policy.
Ott 1996 f‘age 400 - 11

400 INSPECTIONS
404 INSPECTOR SAFETY

YOUR YOUR safety in the industrial environment is important to everyone! Please
Safety
is refer to the ARB safety manual and observe the safety policies and proce-
Important dures of your district and of the facility that you inspect. Ask the plant
representative about any particular precautions for his or her plant.
Review
Your usual safety equipment includes: hard hat, safety glasses, ear plugs,
AR6 Safety
Manual safety shoes, and gloves. Take these with you on all inspections.
Here are some specific hazards and cautions which you may want to
consider: (Many of these have been learned from experience.)
1. Dust can be particularly hazardous. Besides being a threat to lungs and

eyes, dust can cause poor visibility, leading to accidents around trucks,
front-end loaders, and other moving equipment near stockpiles or bins.
2. Noise is not only harmful to hearing, but it can also distract you from
avoiding moving equipment or other dangers. Some noises may have
special significance: backup horns and blast warning whistles.
Safety Tips 3. Conveyor belts transporting aggregates demand your constant

and awareness. Pulleys, belts, and sprocket-and-chain drive mechanisms
Reminders can quickly capture your loose clothing.
4. Good housekeeping (neatness) is helpful to minimize these hazards:
- Protruding pipes, hoses or other obstacles

- Wet surfaces
- High voltage lines and loose wires or lines
- Field connections
- Frayed insulation
- Improperly grounded electrical equipment
- Dust on ground / floor which may cause slipping
5. Stockpiles. Standing on the stockpiles or on the bunkers over feeder

gate openings can be dangerous. People have been pulled down into the
material and buried alive so quickly that they could not escape.
Page 400 - 12 Ott 1996

400 INSPECTIONS
6. Goggles and faceshield are safeguardsfor prevention, to be donnedin

advance, whenever appropriate. Shirt collars and cuffs can be closed,
and your boot tops can be coveredby your pantlegs.
7. Climbing on or in any part of the facility requires extreme caution.

Ladders, stairways, and handrailsneedto be secure. Before going near
an enclosureor heavy machinery,you may want to assurethat the power
to operateit is locked off so that no one else can inadvertently turn it on.
8. Entering an enclosuremay be neither appropriatenor allowed. Check

with your district. If you enter an enclosure, you wiZZwant to
assure that: Guidelines
for
0 The power which operates the equipment is locked off, inspectors
l You have a confined spaceentry permit if required, and that
0 You meet requirementsof CAL-OSHA and GeneralIndustry Safety
Orders.
9. Truck traffic. As you enter and leavethe plant, you may seetraffic
signs and directions; thesesigns are postedto enhanceyour safety.
You may be a visitor in a foreign land, but you know that vehicles will
be working around loading zones. You may find it helpful to establish
eye contact with the driver before crossinghis or her path.
10. Loaders move fast. They scurry about and scoot everywhere, along
pathways which are not well defined. They can appearunexpectedly,
often backing up unpredictably. Their drivers have blind spots, and
you may not hear a backup alarm.
Ott 1996 Page 400 - 13

i
500 LEGAL REQUIREMENTS Cement Kilns
In this chapter we addressair quality legal requirementsfor cementkilns,

beginning with district requirements and ending with pertinent verba-
tim sections of the California Health and Safety Code (HSC). Other What’s in
environmental regulations also apply to noise, water, and hazardous This
materials, but they are not the main focus of this manual. Chapter
?
INTRODUCTION
The California Legislaturepasseslaws, called statutes,that authorize Execu-

tive Branch agenciessuchas the Air ResourcesBoard (ARB) to implement
these statutesby adopting and enforcing regulations. The ARB directly
regulates air pollutant emissionsfrom motor vehicles and someother
sources. However, most industrial emission sourcesare regulated
principally by the local Air Pollution Control Districts and Air Quality
Management Districts. Cementkilns are also regulatedby other agencies,
f’
including the Department of Toxic SubstancesControl (DTSC) and the
Office of Environmental Health Hazard Assessment(OEHHA).
501 DISTRICT REQUIREMENTS
Each local air district within the statehasits own legal requirementsbasedon
its own specialneeds. Theserequirementsvary from one district to another
due to the nature of the particular air quality problemsand the sourcetypes
within the districts.
To assurecompliance,the inspector is to collect and apply the rules for his

or her local district. Appendix I is provided as a collection place for you to
put the rules for your district. All districts haverequirementsin the follow-
ing areas,eachof which is discussedhere, somein detail: All Districts
Regulate . . .
n Authority to Construct (includingmodifications)
n Permitto Operate
n Visible Emissions
n ParticulateMatter Emissions
n Fugitive Dust Emissions
n Nuisances
n BreakdownandVariances
Ott 1996 Page 500 - 1

Cement Kilns 500 LEGAL REQUIREMENTS
501 .I AUTHORITY TO CONSTRUCT AND PERMIT TO OPERATE
The districts usethesetwo documentsto permit the constructionandoperation

of facilities and equipmentwhich could causeair pollutant emissions.These
documentsalso specifyconditionsfor the constructionandoperation.
Specified Conditions for Permits to Operate. Under the authority of the

CaliforniaHealth and SafetyCode(HSC), andin orderto comply with the
California StateImplementationPlanwhereapplicable,the districts may issue
conditions,other thanthe applicablegeneralemissionslimitations, for the
operationof equipmentandcomponentsof facilities. Theseconditionsare
statedin the Permit to Operate(PO), andoften includesuchitems asthese:
operatinghours,throughput,materialstype and quantity, andemissionslimits.
Maintenance Program. The Permitto Operatestipulatesthat the equipment

must be properly maintainedandkept in goodoperatingcondition. The facility
managermay alsobe directedto developa maintenanceprogram for the equip-
Maintenance
ment listed in the Permit in order to precludea violation of the California Health
Program andSafetyCodeandapplicabledistrict rulesandregulations.
Monitoring and Recordkeeping. Documentationof key operatingparam-

etersmay be requiredin somePermitsto Operate. The recordsmay take the
form of handwrittenlogbooks,completedpreprintedforms, strip or circular
recordingchartsfrom continuousrecordingreadouts,or a computerizeddata-
base. Computerrecordsmay do more than merely archivemonitoredoperating
parameters;they may alsohelp to analyzeproblems.
Rule Violations. In the eventthat any equipmentviolatesdistrict rules and

regulations,many districtsrequirethe facility managerto stop operatingthe
pertinentequipmentand proceedasnecessaryto endthe violation. The facility
managermust notify the district of any upsetconditions,breakdownor sched-
uled maintenancewhich causesemissionsin excessof limits establishedby the
district. A varianceallowing a facility to temporarilypollute while it works
towardscompliancemay be allowedby the local air district hearingboardif
legalrequirementsaremet.
Facility Inspection. The facility owner may be requiredto submit a periodic

inspectionreport. The report may includethe amountof emissionsproduced,
operatingconditions,calibrationof monitoringinstruments,andwhether or not
the operatingconditionscompliedwith the Permit to Operateor were within the
manufacturer’sspecifications.Data from the report canbe usedfor the emis-
sionsinventory andto validatethe accuracyof monitoring records.
Page 500 - 2 Ott 1996
Maintenance Logs. Permitconditionsmay requirerecordsof maintenance

performed,includingthe time, date,typesof problemsandtheir resolutions,and
the namesof personsdoingthe work. Theserecordsmust be retainedfor speci-
fied periodsof time, typically threeyears,andthey must be madeavailableto
Logs
the air pollution control district uponrequest.
Manuals for Operation and Maintenance. SomePermitsrequireopera-

tors to obtain andbe familiar with an OperationsandMaintenanceManual
(O&M) preparedspecificallyfor their facility. The manufacturermay have
preparedmost of this information. Thesemanualstypically include:
Manuals
1. Generalinformation aboutthe facility designandequipment.
2. Plansdescribingproceduresandoperatingparameters.
3. Plansdescribingpreventivemaintenanceschedules,inspectionandrepair
programs,andthe recommendedsparepartsinventory.
4. Emergencyproceduresfor fires, gasleaks,power losses,wastespills, etc.
5. MSDS information.
Many permits requirethat the equipmentbe operatedin accordancewith

manufacturer’sinstructions,unlessthe instructionsconflict with district rulesor
permit conditions. The manufacturerinstructionsandprocedures,alongwith the
OperatingPermit, typically must be postedon the control panelor other equip-
ment, and must be readilyvisible or availableto the operator.
501.2 VISIBLE EMISSIONS (VE)
Eachof the air pollution control districts in California hasa visible emissions
limitation rule. Although the texts of theserulesvary, they providethat:
“... no personshall dischargeinto the atmospherefrom any sourcewhatsoever
any contaminant,otherthan uncombinedwater vapor, for a period or periods
aggregatingmore than threeminutesin any onehour which is:
(a) As dark or darkerin shadeasthat designatedasNo. 1 (or 20% opacity) on
the RingelmannChart, aspublishedby the United StatesBureauof Mines,
[Somedistricts useRingelmannNo. 2 or 40% opacity.]
(b) Or of suchopacity asto obscurean observer’sview to a degreeequalto or
greaterthan doessmokedescribedin subdivision(a).”
Ott 1996 Page 500 - 3

500 LEGAL REQUIREMENTS
The State standard for visible emissions (Section 41701, California Health
and Safety Code) is No. 2 on the Ringelmann Chart, or 40% opacity.
Appendix C contains detailed descriptions for evaluating visible emissions

and how to become certified to do so. The Ringelmann system is used to
determine whether emissions of smoke are within the limits or standards
which are set by statutes and ordinances and defined by the Ringelmamr
Ringelmann
Chart. In this system, smoke density in a plume is compared with a series of
System
graduated shades of gray, as judged by the inspector. EPA Reference
Method 9 is also provided in Appendix C.
The Compliance Division of the ARB conducts a “Fundamentals of

Enforcement” class four times a year to train and certify government and
industry personnel to perform these evaluations. The certification is valid
for a period of six months, after which recertification is available.
Calculating the results of visible emissions evaluations: For HSC appli-

cations, the inspector counts all of the 15-second readings for which the
VE opacity was observed to exceed the Ringelmann limit. A total of more than
Calculations 12 readings, over three minutes in a one hour period constitutes a violation.
By contrast, for federal applications of EPA Reference Method 9 (ASPS
applications), opacity exceedance is determined by averaging any 24
consecutive readings taken by the inspector at 15-second intervals (six
minutes). If the average exceeds the standard, the facility is in violation.
501.3 PARTICULATE MATTER EMISSION LIMITS
Air pollution control districts have general rules which apply to any source
operation which emits or may emit dust, fumes, or suspended particulate matter.
Some rules specify limits by concentration, in grains per cubic foot, for
example; other rules specify weight of emissions per unit of production. Most
districts have both limits. To determine the concentrations of particulate
emissions at facilities would require source testing, using EPA Method 5, which
is contained in Appendix B.
Dust 501.4 FUGITIVE DUST EMISSIONS
Fugitive dust regulations prevent or limit the amount of dust which could escape
into the ambient air. In most cement kilns, dust is not ordinarily a problem, but
Page 500 - 4 Ott 1996
without adequatecontrolsit could emanatefrom somelocations,e. g., at the

points of movement,supplyor storage.
501.5 NUISANCE
District rules basedon Section41700,HSC, protect the public’shealthand Odors

welfare from the dischargeof air contaminantswhich constitutea public nui-
sance. This conceptincludesprotectionfrom injury, detriment,andannoyances
suchas odorsfrom emissions.
501.6 EQUIPMENT BREAKDOWN PROVISIONS
Each district hasan equipmentbreakdownrule for reasonablemalfunctions. For

statedconditions,the rule givessomeprotectionfrom enforcementactionswhen
certainequipmentfails andpreventscompliancewith air pollution regulations.
Industrial managersmay want to keepa copy of the breakdownrule at the work
site and assurethat personnelknow their responsibilitiesin the eventof an
equipmentmalfunction.
In order to qualify for district breakdownprovisions,a malfunctionmust meet

the conditionsspecifiedby the district. Theseconditionsaretypical:
+ The breakdownis a result of a failure that was unforeseeable,
+ The breakdownis not the resultof neglector disregardof any air

pollution control law, rule, or regulation,
+ It is not intentionalor the result of negligence,
+ It is not the result of impropermaintenance,
+ It doesnot constitutea nuisance,and
+ It is not an abnormallychronicbreakdownof the sameequipment.
District rules alsolist a numberof procedureswhich must be followed in report-

ing the breakdownin a timely mannerto the district. If the breakdownis not
reportedto the district within the allowedtime period,as statedin the rule, a
separateviolation occurs,for which enforcementaction is appropriate.
Ott 1996 Page 500 - 5

When a breakdown is reported to the district it is recorded in the district’s

breakdown log. Sources must provide the district with this information:
1. The source’s name and location and the source contact’s name and
telephone number,
2. The specific equipment affected by the breakdown,
3. The specific equipment that failed,
Breakdown 4. The date and time that the breakdown occurred,

Log
5. The date and time that the breakdown is being reported to the district, and
6. The remedy proposed by the source.
Upon receipt of a breakdown report, the district performs an on-site investi-

gation of the malfunctioning equipment to determine whether it meets the
prescribed breakdown conditions. If the inspector determines that a valid
breakdown condition does not exist, he or she may initiate enforcement
action. This could lead to fines, abatement orders, and injunctions against
further operations.
Filing a breakdown report which is false, or claiming that a malfunction is a

breakdown, may constitute a violation. The burden of proof is on the source
to provide sufficient information to show that a breakdown did occur. Oth-
erwise, the source is subject to appropriate enforcement action.
A source with a breakdown must take immediate steps to correct the mal-
function as quickly as possible. If a source finds that repairs cannot be
completed within the district’s allowable duration for a breakdown, the
source may file for an emergency variance in order to avoid enforcement
action. The allowable duration is usually 24 hours for continuous processes
which cannot be shut down immediately, but all other equipment may be
operated only to the end of the cycle.
Page 500 - 6 Ott 1996

After a breakdown has been repaired, andwithin a specifiedtime limit,

district rules require sources to submit written details to the air pollution
control officer:
. Proof of the source’sreturn to compliance,includingthe dateand
time that the breakdownwas corrected,
. The durationof excessiveemissions, Report
. An estimateof the quantity of excessemissions, Breakdown
Repair
. A statementof the causeof the occurrence,and
. The correctivemeasuresto be takento preventrecurrences.
The district log will alsoincludethe following information, someof which may
be enteredasthe caseprogresses:
1. A confirmationthat the breakdownis allowableunderdistrict rules,
2. The nameof the district investigator,
3. The initial inspectionfile number,
4. The complianceconfirmationinspectionfile number,
5. The datethat the breakdowncorrectionreport was filed by the source,and
6. An indication of whetheror not a variancewasrequested.
501.7 VARIANCES
A facility operatormay petition for a variancein eitherof thesesituations:
1. Pollution control equipmenthasbrokendown andmeetsthe criteria for

breakdownconditionunderdistrict rules,but the operatorfinds that it will take
longer to repair the breakdownthanprovidedfor underthe district breakdown Situations
rule. In sucha case,the operatormay wish to apply for an emergency vari- for
ance. If good causeis shown,applicationsfor emergencyvariancesmay be Variance
approvedquickly: the chairmanof a district hearingboardor any designated
membermay issuean emergencyvariancewithout a notice andhearing.
2. A sourceis out of compliance,eitherby its own determinationor by that of

other inspectors,or expects to soonbe out of compliancewith someair pollution
control district rule or regulation,or with Section41701 of the HSC.
Ott 1996 Page 500 - 7
Cement Kilns 500 LEGAL REQUlREiVlENTS
In either of these two situations the operator may want to apply for a variance in
an attempt to obtain a shield from enforcement action during the temporary
period of noncompliance. The decision and the impetus to file for a variance
belongs to the source operator.
An application for either a short variance (90 days maximum) or a regular

variance (1 year maximum, unless a schedule for progress is included) also asks
for an interim variance (up to 90 days or until the next Hearing Board meeting,
whichever comes first). It is the source’s responsibility to estimate the length of
variance needed and to apply for the appropriate one.
The approval authority for variances is the district Hearing Board rather than
the air pollution control officer or his or her staff. A favorable decision is
usually more likely if the source provides ample information in the application.
Although each district has its own rules for variances, the district rules are based
on the HSC. Some of the pertinent sections are included at the end of this
chapter. It would be helpful for district inspectors as well as source operators to
be familiar with the local district variance requirements.
The law (HSC) says that:
1. Sources are not allowed to operate in violation of ARB or district require-

ments without a variance, even if the source is working towards a solution to the
problem. Under HSC Section 42400.2, if a source continues to operate in
Each Day violation of district rules, it may be subject to a fine of $25,000 per day, or up to
of Violation one year in the county jail, or both. Under HSC Section 42400.3, for wiZZ$dand
is a intentionalviolations, the penalty can be $50,000 per day, or up to one year in
Separate the county jail, or both.
Offense
In general, penalties specified for criminal offensesmay include jail time, and
penalties for civil offenses do not. Also, fines can be imposed as separate
offenses for each day of violation. Please consult the Health and Safety Code.
2. A variance will not be granted unless the Hearing Board makes all of the
findings listed in HSC, Section 42352.
Verbatim sections of the Health and Safety Code begin on the next page.
Page 500 - 8 Ott 1996

502 CALIFORNIA HEALTH AND SAFETY CODE (HSC)

Summary Listing
The following sectionsof the CaliforniaHealthAnd SafetyCodehavebeen

selectedfor verbatim presentationhere,after this list. These HSC sections are
the basis for air pollution control laws, including the authority of districts to
adoptand enforceregulations,to perform inspections,andto issuepermits with
conditions. For specificsituations,you maywish to consultthe completeHSC.
39000 LegislativeFindings- Environment
39001 LegislativeFindings- AgencyCoordination
39002 Local and StateAgencyResponsibilities HSC
39003 ARB Responsibilities Sections
40000 Local / StateResponsibilities Summary
40001 Adoption andEnforcementof RulesandRegulations Listing
40702 Adoption of RulesandRegulations
41509 No Limitation on Powerto AbateNuisance
41510 Right of Entry With InspectionWarrant
41700 No PersonShallDischargePollutants
41701 Opacity Standards- No EmissionsShallExceedRingelmann2 . . .
42300 District Permit System
42301 Permit Issuance- Requirements
42301.6 Permit Approval: PowersandDutiesof Air PollutionControlOfficer
42301.7 Air Contaminants,ThreatenedRelease
42303 Information Disclosure- Air ContaminantDischarge
42303.5 FalseStatementsin PermitApplications
42304 Permit Suspension(Failureto SupplyInformation)
42352 Variance- FindingsRequiredfor Issuance
42400 Penalties,Criminal - Misdemeanor, $1,OOO/Day
and/orSixMonthsJail
42400.1 Penalties,Crirninal - Negligence,$l$OOO/Dayand/orNine MonthsJail
42400.2 Penalties,Criminal - Knowingly, $25,OOO/Day and/orOneYearJail
42400.3 Penalties,Criminal - Willfully . . . $5O,OOO/Day
and/orOneYearJail
42401 Penalties,Civil - Violating Order of Abatement $25,OOO/Day
42402 Penalties,Civil - Violations. . . $1,OOO/Day
42402.1 Penalties,Civil - Negligence, $15,OOO/Day
42402.2 Penalties,Civil - Knowingly, $25,OOO/Day
42402.3 Penalties,Civil - Willfully . . . $5O,OOO/Day
42402.5 Penalties,Civil - Administrative, $SOO/Each Violation
42403 Penalties,Civil - RelevantCircumstances
42404.5 Statuteof Limitations for Civil Actions
42450 Ordersof Abatement,District Board: Authority, Notice, Hearing
Ott 1996 Page 500 - 9
503 INTRODUCTION, CA HEALTH AND SAFETY CODE
The California Legislaturepasseslaws, calledstatutes,that authorizeExecutive

branchagencies(suchasthe Air ResourcesBoard)to implementlaws, through
regulations,pursuantto the directivesof the statutes.
The following relevantCaliforniaHSC referencesareincludedverbatimto

provideyou with the basisfor CaliforniaAir PollutionControl Laws. The
HSC paragraph numbers are the HSC Section numbers in numerical order:
Sections
in 39000 LEGISLATIVE FINDINGS - ENVIRONMENT
Numerical
Order TheLegislaturefinds anddeclaresthat the peopleof the Stateof California have
a primary interestin the quality of the physicalenvironmentin which they live,
andthat this physicalenvironmentis beingdegradedby the waste andrefuseof
civilization polluting the atmosphere,therebycreatinga situationwhich is
detrimentalto the health,safety,welfare, andsenseof well-being of the people
of California.
39001 LEGISLATIVE FINDINGS - AGENCY COORDINATION
The Legislature,therefore,declaresthat this public interestshallbe safeguarded

by an intensive,coordinatedstate,regional,andlocal effort to protect and
enhancethe ambientair quality of the state. Sinceair pollution knows no politi-
cal boundaries,the Legislaturedeclaresthat a regionalapproachto the problem
shouldbe encouragedwheneverpossibleand,to this end,the stateis divided
into air basins. The stateshouldprovideincentivesfor suchregionalstrategies,
respecting,when necessary,existingpolitical boundaries.
39002 LOCAL AND STATE AGENCY RESPONSIBILITIES
Local andregionalauthoritieshavethe primary responsibilityfor control of air

pollution from all sourcesother than vehicularsources.The control of vehicular
sources,exceptasotherwiseprovidedin this division, shallbe the responsibility
of the StateAir ResourcesBoard. Exceptas otherwiseprovided in this division,
including,but not limited to, Sections41809,41810,and 4 1904,local and
regionalauthoritiesmay establishstricter standardsthanthose set by law or by
the stateboard for nonvehicularsources.However, the stateboard shall, after
holding public hearingsasrequiredin this division, undertakecontrol activities
Page 500 - IO Ott 1996

in any area wherein it determines that the local or regional authority has
failed to meet the responsibilities given to it by this division or by any other
provision of law.
39003 ARB RESPONSIBILITIES
The State Air Resources Board is the state agency charged with coordinating
effbrts to attain and maintain ambient air quality standards, to conduct research
into the causes of and solution to air pollution, and to systematically attack the
serious problem caused by motor vehicles, which is the major source of air
pollution in many areas of the state.
40000 LOCAL / STATE RESPONSIBILITIES
The Legislature finds and declares that local and regional authorities have the
primary responsibility for control of air pollution from all sources, other than
emissions from motor vehicles. The control of emissions from motor vehicles,
except as otherwise provided in this division, shall be the responsibility of the
state board.
40001 ADOPTION & ENFORCEMENT OF RULES I REGULATIONS
(a) Subject to the powers and duties of the state board, the districts shall adopt
and enforce rules and regulations to achieve and maintain the state and federal
ambient air quality standardsin all areasaffected by emission sourcesunder their
jurisdiction, and shall enforce all applicable provisions of state and federal law.
(b) The rules and regulations may, and at the request of the state board shall, Prevent
provide for the prevention and abatement of air pollution episodes which, at and
intervals, cause discomfort or health risks to, or damage to property of, a Abate
significant number of persons or class of persons. Episodes
(c) Prior to adopting any rule or regulation to reduce criteria pollutants, a

district shall determine that there is a problem that the proposed rule or regula-
tion will alleviate and that the rule or regulation will promote the attainment or
maintenance of state or federal ambient air quality standards.
40702 ADOPTION OF RULES AND REGULATIONS
A district shall adopt rules and regulations and do such acts as may be necessary
or proper to execute the powers and duties granted to, and imposed upon, the
Ott 1996 Page 500 - 1 I
district by this divisionand other statutoryprovisions. No order, rule, or regula-

tion of any district shall,however,specifythe designof equipment,type of
construction,or particularmethodto be usedin reducingthe releaseof air
contaminantsfrom railroadlocomotives.
41509 NO LIMITATION ON POWER TO ABATE NUISANCE
No provisionof this division, or of any order,rule, or regulationof the state

boardor of any district, is a limitation on:
(a) Thepower of any local or regionalauthority to declare,prohibit, or abate

nuisances.
(b) Thepower of the Attorney General,at the requestof a local or regional

authority, the stateboard,or upon his own motion, to bring an action in the
nameof the peopleof the Stateof California to enjoinany pollution or nuisance.
(c) Thepower of a stateagencyin the enforcementor administrationof any

provision of law which it is specificallypermittedor requiredto enforceor
administer.
(d) Theright of any personto maintainat any time any appropriateaction for
relief againstany privatenuisance.
41510 RIGHT OF ENTRY WITH INSPECTION WARRANT

Right
of For the purposeof enforcingor administeringany stateor local law, order,
Entry regulation,or rule relatingto air pollution, the executiveofficer of the state
boardor any air pollution control officer havingjurisdiction, or an authorized
representativeof suchoffker, upon presentationof his credentialsor, if neces-
saryunderthe circumstances,after obtainingan inspectionwarrant pursuantto
Title 13 (commencingwith Section1822.50),Part 3 of the Code of Civil Proce-
dure, shallhavethe right of entry to any premiseson which an air pollution
emissionsourceis locatedfor the purposeof inspectingsuchsource,including
securingsamplesof emissionstherefrom, or any recordsrequiredto be main-
tainedin connectiontherewith by the stateboardor any district.
Page 500 - 12 Ott 1996

41700 NO PERSON SHALL DISCHARGE POLLUTANTS
Exceptasotherwiseprovidedin Section41705,no personshalldischargefrom

any sourcewhatsoeversuchquantitiesof air contaminantsor othermaterial
which causeinjury, detriment,nuisance,or annoyanceto any considerable
numberof personsor to the public, or which endangerthe comfort, repose,
health,or safetyof any suchpersonsor the public, or which cause,or havea
naturaltendencyto cause,injury or damageto businessor property.
41701 OPACITY STANDARDS - NO EMISSIONS SHALL EXCEED

RINGELMANN 2
Opacity
Except asotherwiseprovidedin Section4 1704,or Article 2 (commencingwith
Section41800) of this chapterother than Section41812, or Article 2 (commenc-
ing with Section42350)of Chapter4, no personshalldischargeinto the atmo-
spherefrom any sourcewhatsoeverany air contaminant,other thanuncombined
water vapor, for a period or periodsaggregatingmore than threeminutesin any
onehour which is:
(a) As dark or darkerin shadeasthat designatedasNo. 2 on the Ringelmann
Chart, aspublishedby the United StatesBureauof Mines, or
(b) Of suchopacity asto obscurean observer’sview to a degreeequalto or

greaterthan doessmokedescribedin subdivision(a).
42300 DISTRICT PERMIT SYSTEM
(a) Every district boardmay establish,by regulation,a permit systemthat

requires,exceptas otherwiseprovidedin Section42310, that beforeany person
builds, erects,alters,replaces,operates,or usesany article, machine,equipment,
or other contrivancewhich may causethe issuanceof air contaminants,the
personobtaina permitto do socorn the air pollutioncontrolofficer of the district.
(b) Theregulationsmay providethat a permit shallbe valid only for a speci-

fied period. However, the expirationdateof any permit shallbe extendedupon
completionof the annualreview requiredpursuantto subdivision(e) of Section
42301 andpaymentof the feesrequiredpursuantto Section42311, unlessthe air
pollution control offrcer or the hearingboardhasinitiated actionto suspendor
revoke the permit pursuantto Section42304,42307,or 42390,that actionhas
resultedin a final determinationby the officer or the boardto suspendor revoke
the permit, andall appealshavebeenexhaustedor the time for appealsfrom that
final determinationhasbeenexhausted.
Ott 1996 Page 500 - 13
(c) The annualextensionof a permit’s expirationdatepursuantto subdivision

(b) doesnot constitutepermit issuance,renewal,reopening,amendment,or any
other action subjectto the requirementsspecifiedin Title V.
42301 PERMIT ISSUANCE - REQUIREMENTS
Permit A permit systemestablishedpursuantto Section42300shalldo all of the

System following:
Shall Do.. .
(a) Ensurethat the article, machine,equipment,or contrivancefor which the
permit was issueddoesnot preventor interferewith the attainmentor mainte-
nanceof any applicableair quality standard.
(b) Prohibit the issuanceof a permit unlessthe air pollution control officer is
satisfied,on the basisof criteria adoptedby the district board,that the article,
machine,equipment,or contrivancewill complywith all of the following:
(1) All applicableorders,rules, andregulationsof the district and of the

stateboard.
(2) All applicableprovisionsof this division.
(c) Prohibit the issuanceof a permit to a Title V sourceif the Administrator of

the EnvironmentalProtectionAgency objectsto its issuancein a timely manner
asprovidedin Title V. This subdivisionis not intendedto provide any authority
to the EnvironmentalProtectionAgencyto objectto the issuanceof a permit
other than that authority expresslygrantedby Title V.
(d) Providethat the air pollution control officer may issueto a Title V sourcea
permit to operateor useif the owner or operatorof the Title V sourcepresentsa
varianceexemptingthe owneror operatorfrom Section41701,any rule or
regulationof the district, or any permit conditionimposedpursuantto this
section,or presentsan abatementorderthat hasthe effect of a varianceandthat
meetsall of the requirementsof this part pertainingto variances,andthe
requirementsfor the issuanceof permits to operateare otherwisesatisfied.
The terms and conditionsof any varianceor abatementorder may be incorpo-
rated into the permit asa complianceschedule,to the extent requiredby Title V.
(e) Require,upon annualrenewal,that eachpermit be reviewedto determine

that the permit conditionsare adequateto ensurecompliancewith, andthe
enforceabilityof, district rules andregulationsapplicableto the article, machine,
Page 500 - 14 Ott 1996
equipment,or contrivancefor which the permit was issuedwhich were in effect

at the time the permit was issuedor modified, or which havesubsequentlybeen
adoptedandmaderetroactivelyapplicableto an existingarticle, machine,
equipment,or contrivance,by the district boardand,if the permit conditionsare
not consistent,requirethat the permit be revisedto specifythe permit conditions
in accordancewith all applicablerules andregulations.
(f) Providefor the reissuanceor transfer of a permit to a new owneror opera-

tor of an article, machine,equipment,or contrivance.An applicationfor transfer
of ownershiponly, or changein operatoronly, of anyarticle, machine,equip-
ment, or contrivancewhich had a valid permit to operatewithin the two-year
period immediatelyprecedingthe applicationis a temporarypermit to operate.
Issuanceof the final permit to operateshallbe conditionalupona determination
by the district that the criteria specifiedin subdivisions(b) and(e) are met, if the
permit was not surrenderedasa conditionto receivingemissionreduction
credits pursuantto bankingor permitting rules of the district. However, under
no circumstancesshallthe criteria specifythat a changeof ownershipor operator
aloneis a basisfor requiringmore stringentemissioncontrolsor operating
conditionsthan would otherwiseapply to the article, machine,equipment,or
contrivance.
42301.6 PERMIT APPROVAL: POWERS AND DUTIES OF

AIR POLLUTION CONTROL OFFICER
(a) Prior to approvingan applicationfor a permit to constructor modify a

sourcewhich emits hazardousair emissions,which sourceis locatedwithin
1,000feet from the outerboundaryof a schoolsite,the air pollution control Near
officer shallpreparea public notice in which the proposedproject or modifica- a
tion for which the applicationfor a permit is madeis fully described.Thenotice Schoolsite
may be preparedwhetheror not the materialis or would be subjectto subdivi-
sion (a) of Section25536,if the air pollution control officer determinesandthe
administeringagencyconcursthat hazardousair emissionsof the materialmay
result from an air release,asdefinedby Section44303. Thenoticemay becom-
binedwith any other noticeon the projector permit which is required by law.
(b) The air pollution control officer shall, at the permit applicant’sexpense,
distribute or mail the public noticeto the parentsor guardiansof childrenen-
rolled in any schoolthat is locatedwithin one-quartermile of the sourceandto
eachaddresswithin a radiusof 1,000feet of the proposednew or modified
sourceat least30 daysprior to the datefinal actionon the applicationis to be
Ott 1996 Page 500 - 15
taken by the officer. The officer shall review and consider all comments
Public received during the 30 days after the notice is distributed, and shall include
Comments written responsesto the comments in the permit application file prior to taking
Considered fmal action on the application.
(1) Notwithstanding Section 49073 of the Education Code, or any other

provision of law, the information necessary to mail notices required by this
section shall be made available by the school district to the air pollution control
officer.
(2) Nothing in this subdivision precludes, at the discretion of the air pollu-
tion control officer and with permission of the school, the distribution of the
notices to the children to be given to their parents or guardians.
(c) Notwithstanding subdivision (b), an air pollution control officer may

require the applicant to distribute the notice if the district had such a rule in
effect prior to January 1, 1989.
(d) The requirements for public notice pursuant to subdivision (b) or a district
rule in effect prior to January 1, 1989, are fulfilled if the air pollution control
offker or applicant responsible for giving the notice makes a good faith effort to
follow the procedures prescribed by law for giving the notice, and, in these
circumstances, failure of any person to receive the notice shall not affect the
validity of any permit subsequently issued by the officer.
(e) Nothing in this section shall be deemed to limit any existing authority of
any district.
(f) An applicant for a permit shah certify whether the proposed source or
modification is located within 1,000 feet of a schoolsite. Misrepresentation of
this fact may result in the denial of a permit.
(g) The notice requirements of this section shall not apply if the air pollution
control officer determines that the application to construct or modify a source
will result in a reduction or equivalent amount of air contaminants, as defined in
Section 39013, or which are hazardous air emissions.
(h) As used in this section:
Page 500 - 16 Ott 1996

.
(1) “Hazardous air emissions” means emissions into the ambient air of air
contaminants which have been identified as a toxic air contaminant by the state
board or by the air pollution control officer for the jurisdiction in which the Toxic
project is located. As determined by the air pollution control offrcer, hazardous Air
air emissions also means emissions into the ambient air from any substances Contaminant
identified in subdivisions (a) to (f), inclusive, of Section 44321 of the Health and
Safety Code.
(2) “Acutely hazardous material” means any material defined pursuant to

subdivision (a) of Section 25532.
42301.7 AIR CONTAMINANTS - THREATENED RELEASE
(a) If the air pollution control officer determines there is a reasonably foresee-
able threat of a release of an air contaminant from a source within 1,000 feet of
the boundary of a school that would result in a violation of Section 41700 and
impact persons at the school, the officer shall, within 24 hours, notify the admin-
istering agency and the fire department having jurisdiction over the school.
(b) The administering agency may, in responding to a reasonably foreseeable

threat of a release, do any of the following:
(1) Review the facility’s risk management and prevention plan prepared
pursuant to Section 25534 to determine whether the program should be modi-
fied, and, if so, require submission of appropriate modifications. Notwithstand-
ing any other provision of law, the administering agency may order modification
and implementation of a revised risk management and prevention plan at the
earliest feasible date.
(2) If the facility has not filed a risk management and prevention plan with
the administering agency, require the preparation and submission of a plan to the
administering agency pursuant to Section 25534. Notwithstanding any other
provision of law, the administering agency may require the filing of a risk man-
agement and prevention plan and its implementation at the earliest feasible date.
(c) The air pollution control officer may, in responding to a reasonably fore-
seeable threat of a release, do any of the following:
(1) If necessary, issue an immediate order to prevent the release or mitigate

the reasonably foreseeable threat of a release in violation of Section 41700
pending a hearing pursuant to Section 42450 when there is a substantial prob-
ability of an injury to persons at a school resulting from a release that makes it
Ott 1996 Page 500 - 17
reasonablynecessaryto take immediateactionto prevent,reduce,or mitigate

Prevent, that injury. The officer may not issuesuchan orderunlessthereis written
Reduce, concurrenceto issuethe orderby a representativeof the administeringagency.
Mitigate (2) Apply to the district boardfor issuanceof an order for abatement
Injury pursuantto Section42450.
(d) Nothing in this sectionlimits any existingauthority of any district.
42303 INFORMATION DISCLOSURE - AIR CONTAMINANT

DISCHARGE
An air pollution control officer, at any time, may requirefrom an applicantfor,

or the holder of, any permit providedfor by the regulationsof the district board,
suchinformation, analyses,plans,or specificationswhich will disclosethe
nature,extent, quantity,or degreeof air contaminantswhich are,or may be,
dischargedby the sourcefor which the permit was issuedor applied.
42303.5 FALSE STATEMENTS IN PERMIT APPLICATIONS
No personshall knowingly makeany false statementin any applicationfor a

permit, or in any information, analyses,plans,or specificationssubmittedin
conjunctionwith theapplicationor at the requestof the air pollutioncontrolofficer.
42304 PERMIT SUSPENSION (FAILURE TO SUPPLY INFORMATION)
If, within a reasonabletime, the holderof any permit issuedby a district board
willfully fails andrefusesto furnishthe information, analyses,plans,or specifi-
cationsrequestedby the district air pollution control offker, suchofficer may
suspendthe permit. Suchofficer shallservenoticein writing of suchsuspension
andthe reasonstherefor on the permittee.
42352 VARIANCE - FINDINGS REQUIRED FOR ISSUANCE
(a) No varianceshallbe grantedunlessthe hearingboard makesall of the

following findings:
Variance
Conditions (1) That the petitionerfor a varianceis, or will be, in violation of Section
41701 or of any rule, regulation,or order of the district.
(2) That, dueto conditionsbeyondthe reasonablecontrol of the petitioner,
requiring compliancewould resultin either (A) an arbitrary or unreasonable
Page 500 - 18 Ott 1996
taking of property, or (B) the practicalclosingandeliminationof a lawful

business.In making thosefindings wherethe petitioneris a public agency,the
hearingboardshall considerwhetheror not requiringimmediatecompliance
would imposean unreasonable burdenuponan essentialpublic service. For
purposesof this paragraph,“essentialpublic service”meansa prison,detention
Essential
facility, police or firefighting facility, school,healthcarefacility, landfill gas
Public
control or processingfacility, sewagetreatmentworks, or water delivery opera-
Service
tion, if ownedand operatedby a public agency.
(3) That the closingor taking would be without a correspondingbenefit in
reducingair contaminants.
(4) That the applicantfor the variancehasgiven considerationto
curtailing operationsof the sourcein lieu of obtaininga variance.
(5) During the periodthe varianceis in effect, that the applicantwill
reduceexcessemissionsto the maximum extentfeasible.
(6) During the periodthe varianceis in effect, that the applicantwill
monitor or otherwisequantify emissionlevelsfrom the source,if requestedto do
so by the district, andreport theseemissionlevelsto the district pursuantto a
scheduleestablishedby the district.
(b) As usedin this section,“public agency”meansany stateagency,board,or

commission,any county, city andcounty, city, regionalagency,public district,
or other political subdivision. [Further stipulationsof Subsection42352.5are
not includedin this technicalmanual.]
42400 PENALTIES, CRIMINAL - MISDEMEANOR
(a) Exceptas otherwiseprovidedin Section42400.1,42400.2,or 42400.3,any

Criminal
personwho violatesthis part, or any rule, regulation,permit, or orderof the state
Misdemeanor
boardor of a district, includinga district hearingboard,adoptedpursuantto Part
1 (commencingwith Section39000)to Part 4 (commencingwith Section
4 1SOO),inclusive,is guilty of a misdemeanorandis subjectto a fine of not more
than one thousanddollars($1,000)or imprisonmentin the countyjail for not
more than six months,or both.
(b) If a violation under subdivision(a) with regardto the failure to operatea

vapor recovery systemon a gasolinecargotank is directly causedby the actions
of an employeeunderthe supervisionof, or of any independentcontractor
working for, any personsubjectto this part, the employeeor independentcon-
tractor, asthe casemay be, causingthe violation is guilty of a misdemeanorand
is punishableas providedin subdivision(a). That liability shallnot extendto
Ott 1996 Page 500 - 49
the person employing the employee or retaining the independent contractor,

unless that person is separately guilty of an action that violates this part.
(c) The recovery of civil penalties pursuant to Section 42402,42402.1,

42402.2, or 42402.3 precludes prosecution pursuant to this section for the same
offense. When a district refers a violation to a prosecuting agency, the filing of
a criminal complaint is grounds requiring the dismissal of any civil action
brought pursuant to this article for the same offense.
Each Day
a (d) Each day during any portion of which a violation of subdivision (a) occurs
Separate is a separate offense.
Offense
42400.1 PENALTIES, CRIMINAL - NEGLIGENCE
(a) Any person who negligently emits an air contaminant in violation of any
provision of this part or any rule, regulation, permit, or order of the state board or
Criminal of a district pertaining to emission regulations or limitations is guilty of a misde-
Misdemeanor meanor and is subject to a fine of not more than fifteen thousand dollars ($15,000)
or imprisonment in the county jail for not more than nine months, or both.
(b) Any person who owns or operates any source of air contaminants in viola-
tion of Section 41700 which causes actual injury, as defined in paragraph (2) of
subdivision (d) of Section 42400.2, to the health or safety of a considerable
number of persons or the public is guilty of a misdemeanor and is punishable as
provided in subdivision (a).
(c) Each day during any portion of which a violation occurs is a separateoffense.
(d) The recovery of civil penalties pursuant to Section 42402,42402.1,

Page 500 - 20 Ott 1996

42400.2 PENALTIES, CRIMINAL - KNOWINGLY, DOCUMENT

FALSIFICATION / FAILURE TO TAKE CORRECTIVE ACTION
(a) Any personwho emits an air contaminantin violation of any provision of

this part, or any order,rule, regulation,or permit of the stateboardor of a Criminal
district pertainingto emissionregulationsor limitations, andwho knew of the Knowingly
emissionandfailed to take correctiveactionwithin a reasonableperiodof time
underthe circumstances,is guilty of a misdemeanorandis subjectto a fine of
not more than twenty-five thousanddollars($25,000)or imprisonmentin the
countyjail for not more than oneyear, or both.
(b) For purposesof this section,“corrective action” meansthe terminationof

the emissionviolation or the grant of a variancefrom the applicableorder, rule,
regulation,or permit pursuantto Article 2 (commencingwith Section42350). If Corrective
a district regulationregardingprocessupsetsor equipmentbreakdownswould Action
allow continuedoperationof equipmentwhich is emitting air contaminantsin
excessof allowablelimits, compliancewith that regulationis deemedto be
corrective action.
(c) Any personwho, knowingly andwith intent to deceive,falsifies any

documentrequiredto bekept pursuantto anyprovision of this part, or any rule,
regulation,permit, or order of the stateboardor of a district, is guilty of a
misdemeanorandis punishableasprovidedin subdivision(a).
(d) (1) Any personwho owns or operatesany sourceof air contaminantsin

violation of Section41700which causesactualinjury to the healthor safetyof a
considerablenumberof personsor the public, andwho knew of the emission
and failed to take correctiveactionwithin a reasonableperiodof time underthe
circumstances,is guilty of a misdemeanorand is punishableasprovidedin
subdivision(a).
(2) As usedin this subdivision,“actual injury” meansanyphysicalinjury
which, in the opinionof a licensedphysicianandsurgeon,requiresmedical
treatmentinvolving more than a physicalexamination.
(e) Eachday during any portion of which a violation occursconstitutesa

separateoffense.
(f) The recoveryof civil penaltiespursuantto Section42402,42402.1,

42402.2,or 42402.3precludesprosecutionpursuantto this sectionfor the same
offense. When a district refers a violation to a prosecutingagency,the filing of
Ott 1996 Page 500 - 21

42400.3 PENALTIES, CRIMINAL - WILLFULLY, INTENTIONALLY
(a) Any person who willfully and intentionally emits an air contaminant in
violation of any provision of this part or any rule, regulation, permit, or order of
the state board or of a district, pertaining to emission regulations or limitations is
Criminal guilty of a misdemeanor and is subject to a fine of not more than fifty thousand
Willfully dollars ($50,000) or irnprisonment in the county jail for not more than one year,
or both.
(b) The recovery of civil penalties pursuant to Section 42402,42402.1,

(c) Each day during any portion of which a violation occurs constitutes a
separate offense.
42401 PENALTIES, CIVIL - VIOLATING ORDER OF ABATEMENT

Civil
Abatement Any person who intentionally or negligently violates any order of abatement
Violation issued by a district pursuant to Section 42450, by a hearing board pursuant to
Section 4245 1, or by the state board pursuant to Section 41505 is liable for a
civil penalty of not more than twenty-five thousand dollars ($25,000) for each
day in which the violation occurs.
Civil 42402 PENALTIES, CIVIL - GENERAL VIOLATIONS
(a) Except as otherwise provided in subdivision (b) or in Section 42402.1,

42402.2, or 42402.3, any person who violates this part, any order issued pursu-
Strict ant to Section 423 16, or any rule, regulation, permit, or order of a district,
Liability including a district hearing board, or of the state board issued pursuant to Part 1
(commencing with Section 39000) to Part 4 (commencing with Section 41500),
inclusive, is strictly liable for a civil penalty of not more than one thousand
dollars ($1,000).
Page 500 - 22 Ott 1996

(b) (1) Any personwho violatesany provision of this part, any orderissued
pursuantto Section42316, or any rule, regulation,permit, or order of a district,
including a district hearingboard,or of the stateboardissuedpursuantto Part 1
(commencingwith Section39000)to Part 4 (commencingwith Section4 1SOO),
inclusive,is strictly liable for a civil penaltyof not morethanten thousand
dollars($10,000).
(2) Where a civil penaltyin excessof onethousanddollars($1,000)for
eachday in which the violation occursis sought,thereis no liability under*tis
subdivisionif the personaccusedof the violation allegesby affirmative defense
and establishesthat the violation was causedby an act which was not the result
of intentionalor negligentconduct. In a district in which a Title V permit
programhasbeenfully approved,this paragraphshallnot applyto a violation of
federally enforceablerequirementsthat occursat a Title V source.
(c) Eachday during any portion of which a violation occursis a separate

offense.
42402.1 PENALTIES, CIVIL - NEGLIGENCE OR ACTUAL INJURY
(a) Any personwho negligentlyemits an air contaminantin violation of this Civil

part or any rule, regulation,permit, or order of the stateboardor of a district Negligence
pertainingto emissionregulationsor limitations is liablefor a civil penaltyof
not more than fifteen thousanddollars($15,000).
(b) Any personwho owns or operatesany sourceof air contaminantsin viola- Owner
tion of Section41700which causesactualinjury, as definedin paragraph(2) of or
subdivision(d) of Section42400.2,to the healthor safetyof a considerable Operator
numberof personsor the public is liable for a civil penaltyasprovidedin subdi- is
vision (a). Liable
(c) Eachdayduringanyportionof which a violationoccursis a separateoffense.
42402.2 PENALTIES, CIVIL - KNOWINGLY, DOCUMENT

FALSIFICATION, FAILURE TO TAKE CORRECTIVE ACTION
Civil
(a) Any personwho emits an air contaminantin violation of anyprovisionof Knowingly
this part, or any order, rule, regulation,or permit of the stateboardor of a
district pertainingto emissionregulationsor limitations, andwho knew of the
emissionandfailed to take correctiveaction, asdefinedin subdivision(b) of
Section42400.2,within a reasonableperiodof time underthe circumstances,is
liablefor a civil penalty,of not morethantwenty-fivethousanddollars($25,000).
Ott 1996 Page 500 - 23
(b) Any personwho, knowingly andwith intent to deceive,falsifies any

documentrequiredto be kept pursuantto any provision of this part, or anyrule,
regulation,permit, or orderof the stateboardor of a district, is subjectto the
samecivil penalty asprovidedin subdivision(a).
(c) Any personwho ownsor operatesany sourceof air contaminantsin viola-

tion of Section41700which causesactualinjury, as definedin paragraph(2) of
subdivision(d) of Section42400.2,to the healthor safety of a considerable
numberof personsor the public, andwho knew of the emissionandfailed to
take correctiveaction,asdefinedin subdivision(b) of Section42400.2,within a
reasonableperiod of time underthe circumstances,is subjectto a civil penaltyas
providedin subdivision(a).
(d) Eachday duringanyportionof which a violation occursis a separateoffense.
42402.3 PENALTIES, CIVIL -WILLFULLY AND INTENTIONALLY
(a) Any personwho willfully and intentionallyemits an air contaminantin

violation of this part or anyrule, regulation,permit, or order of the stateboard,
or of a district, pertainingto emissionregulationsor limitations, is liable for a
civil penaltyof not morethan fifty thousanddollars($50,000).
(b) Eachday duringanyportionof whicha violationoccursis a separateoffense.
42402.5 PENALTIES, CIVIL - ADMINISTRATIVE

Civil
Administratiw In additionto any civil andcriminal penaltiesprescribedunderthis article, a
district may imposeadministrativecivil penaltiesfor a violation of this part, or
any order,permit, rule, or regulationof the stateboardor of a district, including
a district hearingboard,adoptedpursuantto Part 1 (commencingwith Section
39000)to Part 4 (commencingwith Section41500),inclusive,if the district
boardhasadoptedrules andregulationsspecifyingproceduresfor the imposition
andamountsof thesepenalties.No administrativecivil penalty leviedpursuant
to this sectionmay exceedfive hundreddollars($500) for eachviolation. How-
ever,nothing in this sectionis intendedto restrict the authority of a district to
negotiatemutual settlementsunder any otherpenaltyprovisionsof law which
exceedsfive hundreddollars($500).
Page 500 - 24 Ott 1996

42403 PENALTIES, CIVIL - RELEVANT CIRCUMSTANCES
(a) The civil penaltiesprescribedin Sections 39674,42401,42402,42402.1,

42402.2,and42402.3shallbe assessed andrecoveredin a civil actionbrought in
the nameof the peopleof the Stateof California by the Attorney General,by any
district attorney,or by the attorneyfor any district in which the violation occurs
in any court of competentjurisdiction.
(b) In determiningthe amountassessed, the court, or in reachingany settle-

ment, the district, shalltake into considerationall relevantcircumstances,
including,but not limited to, the following:
Civil
(1) The extent of harm causedby the violation. Penalties
(2) The natureandpersistenceof the violation. May Depend
(3) The length of time overwhich the violation occurs. On . . .
(4) The frequencyof pastviolations.
(5) The recordof maintenance.
(6) The unprovenor innovativenatureof the control equipment.
(7) Any action takenby the defendant,includingthe nature,extent,andtime
of responseof the cleanupandconstructionundertaken,to mitigate the
violation.
(8) The financialburdento the defendant.
42404.5 STATUTE OF LIMITATIONS FOR CIVIL ACTIONS
Any limitation of time applicableto actionsbroughtpursuantto Section42403

shallnot commenceto run until the offensehasbeendiscovered,or could
reasonablyhavebeendiscovered.
42450 ORDERS OF ABATEMENT, DISTRICT BOARD: AUTHORITY,

NOTICE AND HEARING
The district boardmay, after notice anda hearing,issuean orderfor abatement

wheneverit finds that any personis constructingor operatingany article, ma-
chine, equipment,or other contrivancewithout a permit requiredby this part, or
is in violation of Section41700or 41701 or of any order,rule, or regulation
prohibiting or limiting the dischargeof air contaminantsinto the air.
In holding sucha hearing,the district board shallbe vestedwith all the powers
and dutiesof the hearingboard. Notice shall be given, andthe hearingshallbe
held, pursuantto Chapter8 (commencingwith Section40800)of Part 3.
Ott 1996 Page 500 - 25
GLOSSARY
ACFM - Actual cubic feet per minute.
Anemometer - An instrumentfor measuringthe velocity of air or gas.
Atmospheric Pressure - The pressureof the atmosphereasmeasuredby means

of the barometerat a locationspecified.
APCD - An acronymfor Air PollutionControl &t-r&, but usedcoincidentally

in other contexts,includingthe cementkiln vocabulary,to meanAir Pollution
Control Device - suchasa baghouseusedto capturecementparticulates.
ASTM - AmericanSocietyfor Testingand Materials.
Backwash - A methodof cleaningbaghousefabric in which directionof air

flow is reversed,accompaniedby flexing of the fabric andbreakingof the dust
cake. Also known as backpressure, repressure,collapse-clean,etc.
Baghouse - A devicecontaininga fabric filter mediumin the shapeof a bag,

sleeve,envelope,cartridgeor pocket,for the purposeof removingparticulate
entrainedin a gasstream.
Barrel - Formerly, a customarymeasurementof a quantityof cement. One

barrel was equalto 376 poundsnet weight, or 4 bagsof 94 poundseach.
BIF - Boilers andIndustrial FurnacesRule.
Bleed - Particlesof dust or fumesthat leakthroughthe bag.
Bridge - Material blockageacrossan openingsuchasa hopperoutlet.
Burnability - An index or factor which indicatesthe easeof burninga given

clinker. Higher numbersindicateharderto burn.
Cake - The dust layer developedon the surfaceof the baghousefilter medium
during the filtration process.
Calcine, Calcination - A processusedin producingcement;to changeto calx

or powder by heatingto a high temperature,but below the meltingpoint; to burn
to ashesor powder; or to oxidize at high temperature.In the kiln, at about2200
Ott 1996 Gloss - 1

GLOSSARY
degreesF andrising, the processin which carbondioxideis liberatedfrom the

carbonatesof the raw materials.
Cement - A substancewhich canbind togetherother dissimilarmaterials.

Portland cementis the productkilned from the raw materialslimestoneand
shaleor clay which containsalumina,iron oxide, andtracesof other substances.
Gypsumand other materialsmay alsobe addednearthe end of the process.
Cementitious Material - A substanceof moldableplasticity that may be used

to bind togetheroneor more other materials,known asfillers or aggregates.
Cement Kiln Dust (CKD) - Dust, fine particulatesincludingPMlO, formed in

kilning processes.
CFR - Codeof FederalRegulations.
CKD - CementKiln Dust.
Clinker - The incombustibleresidue,fusedinto an irregular lump, that remains

after the combustionof fuel andcement’sraw materials. The clinker is then
finely groundinto powdery cement.
Coefficient of Haze - A measureof light transmittedthrough a filter soiledwith

ambientair. Coefficient of hazeunits arein terms of 100times the optical
densityasdeterminedby transmittance.
Collection Efficiency - Percentageof emissionscollectedby a control device.
Combustion - A chemicalchange,esp.oxidation,accompaniedby the

production of heatandlight.
1 Comminuted - Reducedin size.
Compound - A pure,homogeneoussubstanceconsistingof atoms or ions of

two or more different elementsin definite proportions.
Concentration - Amount of dust in a volume of gas. Usually expressedin

terms of grain&u I?, lb/1000lb. of gas,ppm, mg/cu m. or lb/million Btu.
Condensation - The processof changinga vapor into liquid, usually by cooling.
Gloss - 2 Ott 1996

GLOSSARY Cement Kilns
Contaminate - To make impure or corrupt by contactor mixture.
Corrosion - Deteriorationor physicaldegradationdueto chemicalaction.
Decomposition - Breakingdown into components.
Density - Theratio of the massof a substanceto the volume. Themassof a unit

volume of a substance.
Diameter, Aerodynamic - The diameterof a sphereof unit densityhavingthe

sameterminal settlingvelocity asa particle in question,regardlessof its geomet-
ric size,shape,andtrue density.
Dust - Solid particleslessthan 100micronscreatedfrom largerparticles.

Particlesthus formed are not usuallycalleddust unlessthey arelargerthan about
1 micron in diameter.
Electrostatic Filter - Filter using electrostaticchargeeffectsto enhancethe

captureof particles.
Disintegration - Theprocessof separatinginto components.
Electrostatic Precipitator - An air pollution control devicewhich usesan

electricchargeto collect particulates.
Emissions - Particulatesandchemicalsleavinga processwhich enterthe

ambientair.
Evaporation - The changeof statefrom a liquid to a vapor.
Filter cake - The accumulationof dust on a baghousebag. It often assistsin the

filtration process. Also, seeCake.
Fossil Fuels - Fuelssuchas oil and coal,formed from ancientplantsand ani-

mals underheat andpressure.
Fines - Particulatematter lessthan 1 micron in diameter.
Fluxing - Removingoxidesor preventingtheir formation.
Ott 1996 Gloss - 3

GLOSSARY
Fugitive Emissions - Nonstack emissions which may be caused by leaks, faulty

operations, or poor housekeeping.
Fume - Fine particles dispersed in air or gases, formed by condensation, subli-

mation or chemical reaction. Particles are usually less than one micron in size.
Fusing - The liquid or melted state induced by heat.
Gas - A formless state of matter like air, which completely occupies a contained
space.
Gypsum - Calcium sulfate dihydrate, an ingredient of cement which controls the

rate of setting.
Grain - A unit of weight equivalent to l/7000 of a pound, or 65 milligrams.
Hazardous Wastes - Left-over materials which are no longer commercially

usable and which are either listed as hazardous by the U. S. EPA, or which meet
any of the four characteristics used by the EPA to define hazardous wastes:
Toxicity, Reactivity, Ignitabilty, and Corrosivity. Disposal of these materials
can pose a problem, but their use as a supplemental fuel for kilns can be a
productive solution.
Haze - A state of atmospheric obscuration due to the presence of fine, solid and/
or liquid particles in stable suspension.
Hopper - A temporary storage enclosure, such as at the top of a recycler or at

the bottom of a baghouse to catch dust.
Humidity, Absolute - The weight of water vapor carried by a unit weight of dry
air or gas. Pounds or grains of water vapor per pound of dry air.
Humidity, Relative - The ratio of the water vapor in a gas to the amount of
water vapor that the gas is capable of carrying at the same temperature.
Hydraulic - Ability to set and harden under water, i.e. Portland Cement.
Inch of Water - A unit of pressure equal to the pressure exerted by a column of

liquid water one inch high at a standard temperature. The standard temperature
is normally taken as 70°F. One inch of water at 70 OF= 5.196 lb per sq. ft.
Gloss - 4 Ott 1996
GLOSSARY Cement Kilns
Inclination - A slant. Kilns areinclinedabout4 degreesfrom the horizontal.
Lime - Calcium oxide, CaO, alsocalledburnt lime, calx,quicklime,or caustic

lime. It is formedin the calciningzoneof a kiln.
Limestone - Calcium carbonate,CaCO,.
Maximum Exposed Individual (MEI) - A hypothicalperson-Nhoreceivesth.e

most exposurepossibleto a hazardoussubstance,includingall possiblesources
andpathways,24 hours everyday.
NESHAPs - National EmissionStandardsfor HazardousAir Pollutants
Net Gas-to-Cloth Ratio - The total baghouseinlet gasvolumedividedby the

areaof on-streamfilter media. Whenonecell is off streamfor cleaning,its area
is deductedfrom the total availablecloth areain calculatingthe net ratio. Net
gas-to-cloth ratio = Total Inlet GasVolumetric Flow/On StreamCloth Area.
Opacity - The light attenuationof a stackplume. A perfectly clearplume

(100% light transmission)haszero opacity. A plumethat transmitsno light at
all has 100%opacity.
Particle - A small discretemassof solid or liquid matter suchasdust, fume,

mist, smoke,andfog.
Particulate Matter - Any dispersedmatter, solid or liquid, in which the indi-

vidual particlesor agglomeratesmay rangefrom 0.002micron up to 500 mi-
crons. Particlelifetimes in the suspendedstaterangefrom a few secondsto
severalmonths. Additional termsusedto describeparticulatematter may
includedust, fly ash,smoke,soot, droplets,mist, fog, andfumes.
Plasticity - Ability to be shaped,as in modelingclay.
PM,, - Particulatematter lessthan 10 micronsin diameter.
Potash - Any of severalcompoundscontainingpotassium.
PPM - Partsper million.
Ott 1996 Gloss - 5

Cement Kilns GLOSSARY
Pressure Drop - Resistanceto gasflow, suchaspressuredifferentialacrossone

bag,acrossa baghouse,
or acrossanentiresystem.Units areusuallyinchesof water.
Pressure, Gauge - Pressuremeasuredfrom atmosphericpressureas a base.

Gaugepressuremay be indicatedby a manometerwhich hasone leg connected
to the pressuresourceandthe other exposedto atmosphericpressure.
Pressure Loss - Pressurerequiredto overcomethe resistanceto gasflow in a

systemthat includesthe resistanceof straightruns of pipe, entrancesto headers,
bends,elbows,orifice losses,andpressuredrop through gascleaningdevices.
Pressure, Static - The pressureexertedin all directionsby a fluid at rest. For a

fluid in motion, it is measuredin a directionnormalto the direction of flow.
Pulse Cycle - The interval of time betweenonecleaningcycle pulsingof a row

of bagsandthe next pulsingof the samerow.
Pulse Jet - Genericnamegivento all pulsingbaghousecollectors. Gasflow is

f?omthe outsideof the bagsto the insideof the bags.
RCRA - ResourceRecoveryand ConservationAct -- Restrictionson burning

certainsubstanceswhich could producetoxic emissions.
Retrofit - The additionof a baghousesystemto an existingprocess.
SCFM - Specificcubic feet per minute.
Screen #s - A #4 has4 openingsper squareinch of approximately1/4-&h each.
Screw - mechanicaldevicefor moving material,may havereplaceableshoesto

take the brunt of abrasivewear.
Shale - A fossilrockcomposedof laminated,claylike,fine-grainedsediments
Slaked Lime - Calciumhydroxide,Ca(OH),.
Slaking - Exothermicreactionof water with lime to makeslakedlime, Ca(OH),.
Smoke - Smallgas-borneparticlesusuallyresultingfrom incompletecombus-

tion. Suchparticlesconsistpredominantlyof carbonandother combustible
material andarepresentin sufficient quantityto be observableindependentlyof
other solids.
Gloss - 6 Ott 1996
GLOSSARY
Sonic Cleaning - Sonicenergyfrom air-poweredhornsproducesshockwaves

which enhancedust removalfrom fabrics in baghouses.
Stilling Chamber - Headboxbefore conveyortunnel,to allow dustto settle.
Volatile - Able to evaporatereadily at normaltemperaturesandpressures.
Temperature, Dewpoint - Thetemperatureat which the condensationof water

vapor begins,at a givenhumidity andpressure,asthe temperatureis reduced.
The temperaturecorrespondingto saturation(100 % relativehumidity).
Temperature, Dry-Bulb - The temperatureof a gasor mixture of gases

indicatedby an accuratethermometerafter correctionfor radiation.
Temperature Scales - The sizesof the degreeson Centigrade(Celsius)and

Fahrenheitscaleswere determinedby choosing100incrementsbetween the
freezing point and melting point of water for Centigrade,and 180increments
for Fahrenheit.A Fahrenheitdegreeis thereforethe smaller: 100/l 80, or 5/9 of
a Centigradedegree. The Fahrenheitscaleis usuallyusedfor ambientair. The
Rankinescale,alsocalledFahrenheitabsolute,labelsthe lowestattainable
temperatureaszero, exactly 459.67degreesbelow Fahrenheit’szero. To con-
vert Fahrenheitto Rankine(R), add 459.67(or 460) degrees.
Temperature, Wet-Bulb - A measureof the amountof water vaporin the air,

indicatedby a wet bulb psychrometer.
Transmissometer - An instrumentfor measuringthe visibility. A light of

known intensity is beamedthrough a portion of the atmosphereto a receiver
which measureshow much of the original light penetratesany obstructionsto
visibility. Also calledtelephotometer,transmittancemeter, hazemeter,or smoke
densityindicator.
TSCA - Toxic Substances

Control Act.
U. S. EPA - United StatesEnvironmentalProtectionAgency.
Ott 1996 Gloss - 7

APPENDIX A Cement Kilns
--SAMPLE --
FUGITIVE DUST CONTROL PLAN

AND
RACM
July 1996 Page A - 1

SAMPLE
Fugitive Dust Emissions
ControI Plan
In onia fir Dim-h stM to wnkh an app+ion for approvalof a fugilive dust
emissionwntndphq the adivj, muszdemibe tdtingficgitie dim somzesbasedon
lht? c7imia presousry prmm.td TheaaMynuutaLsodesaibethe’Zeasonab~
awi?able&sl wnuolm-” appliedto eachof the iakntiifiedfug&e dust soumx
PART L -GENERAL INF0RMATr0N
Name of Owner: E. 2. Nodust Pacific A!zrePate Comuanv)
Name of Operator. R. U. Shoor
Phone numbec j7141555-1212 AuxiEary phone numberz_(213~555-1212

.-
Complete add-s of site or assessor parcel number if no address is available
1.23West Street
Riverside, California 92501

Conehalf mile north of the intersecrion of South and North Streets]
Q-p of Activity: Sand and Gravel (Aggregate) Production

(wmmuion prvja aggrqze processingczem%lmmuj2ftming etc)
Scale of opxafion:j 40 ) acres/C 15.000 j cubic yards makmum

througllput
(Note- Only opwmions with a d.imrM noface am in w of 100 acresor with a
nrcocimumthro@pLLt in excessof 10,000cubic yards are .&jeU to the paGicuhe
mQ.tm ?Tl.onirocngr-efpke?n~ of Rule 403)
10-2
PART 2 SOURCES OF FUGITIVE DCST
In the space provided below, please &a mzd de&be all sourcc~ of figirive aim ar
yourfadity bared on the sounz akuib& on pages listed in the Reason&& Available
Conmd Meanves section of this doa.mem You may wish to provide mapping if you
beiieve it necissa~~ to uruksand ttre duwderidic of the site
If!& JIleSet)tion of !sonrce

1 Unpaved roads - Site has 2 miles of unpaved roads which are usegobgz
trucks, heavy and light duty tnr& and assenger cars.
roximately 20 feet wide. Average daily n-a& c levels range from 50 to 100
Tl
ve ‘de trips per day.
2 stage* paa - Bulk material is brought to the site and stored prior to
proqssmg. Once the material has been processed, it is again stored prior to
commeraal sale. In toa approximately 800 tons of material can be stored
at any one time. The storage piles are conical and have an average height of
15 feet
3 Paved road track out - Haul vehicles which exit the site have the potential to
track material out on to West Street On average 300 vehicles exit the site
per work day.
. ‘.
4 Earth moving - ?he bulk material stored on site is moved around the site for
processing and sale. This invok.s use of front end loaders and other heavy
machinery.
5 Disturbed surface areas - The entire site has been disturbed from its natural
condition in one way or another due to changing business practices.
PART 3 DUST CONTROL ACYIONS
Reasonabiv Available Control Measures
In the space prcnided pietue describe all dust control measures which me b&g used at
your site Piease wnrsPond the wnLro1 meunue desaiptionx wifh tfre 7rwnbtig
previouslypn@ai IfyoubeIievetha~anywr~~~lmeawgs mnotfdkorifthey
wdd wr$ia with other n@ationr please describe t?z iusrificmion in the space
P-
Description oi .Tustifimtion
The area between the wheel washer and the site
entty/exit has been paved with axxrete. Th% area
doesn’t need street sweeping due to its shon length (100
feet). and becausevehicleswhich travel on irs surface
have been essentially cleaned from the wheel washer
- system. It is periodically .hoseddown if mater@ gets
.. tracked onto it
1 Chem Stab. &paved roads are treated at the first of the month with
a solution of 5 parts water to 1 pan magnesium
chloride.
1 watering In @e spring and summer months the unpavedroads
are treated with watering trucks at a frequency of 4
times per work day. In the fall and winter months the
unpaved roqds are treated with wasering tmcks at. a
hquency of 2 times per work day. W~,have two
watering trucks on site at all times for this purpose.
1 Reduce speeds AlI unpaved roadways on tie site have a maximum
speed limit of 15 miles per hour.
2. Wet suppression The plant hasboth “wet sand”and “dry sand” operations.
Thedxysandproazssingareahasaspraybarsystem
comprised of 10 spray bars, one aver each dry sand
storage pile in excess of ten feet talk These spray bar
systems are turned on for one half hour, once in the
morning and once in the afternoon and as needed
during windy conditions- The wet sand portion of the
plant is not neared with spray bars or other watering
methods because the material has a high moisnue
content as a result of the treaunent process.
2 Loadinfloadout All loadin/loadout procedures are oriented towards the
downwind portion of the storage piles.
3 Wheel waxhers A wheel washer system is located 100 feet from the
enq/exit to the site off of West Street The system
cleans wheels and provides moisture to the to-p of haul
vehicles thereby increasing the stab&q of the bulk
lo-4
material being hauled. At the end of the work day an
inspection of West Street is made to determine if
material has been tracked our f?om haul vehicles. If
material has been tracked out it is removed and
returned to the site.
4 Watering Water is applied to the bulk material prior to
movement as needed based on visible emissions.
4. Wind fencing Urban development borders the eastern portion of the
site. We have installed wind fencing in conjuntion with
our existing security fencing in order to reduce wind
speeds at the site and to prevent wind blown mater&l
from leaving the site.
Revegetion/Watexing We have seeded disuubed Surface areas which

are no longer used with native, drought tolerant grasses.
- - This seeding was followed by watering which aided in
_. the growth of the ground cover as weil as providing a
.. thin crust over the surface. Results have been favorable
with approximately 75 percent of the abandoned
disturbed surface area covered with vegetation.
5 Wind fencing See No. 4 Above.
10-5
I certifjl that the information anrained in this fugitive dust emission conrrol plan &
true and correct and that all conuol measures are being implemented at the site in
the manner ser forth herein
I have read the amditions of this fugitive dust emission control plan and the owner
has ti+horized tie iqAemen.tation of aI3of its prtions.
1i-L6
R U LE 403/403.-r
IMPLEMENTATION HANDBOOK
REASONABLY AVAILABLE CONTROL MEASURES
As s-pecif?ed by subparagraph (e)(3) of .Rule 403, any person seeking

approval of a fugitive dust emissions control plan must demonstrate to the
satisfaction of the District that the given ac5viry is employing all reasonably
available fugitive dust control measures. The District has prepared the
attached guidelines for demonstrating implementation of all reasonably
available fugitive dust control measures. These guidelines were developed
.-based on the U. S. Environmental Protection Agency’s reference document
entitled, “Control of Open Fugitive Dust Sources,” Midwest Research
Institute, September 1988.
9-1
REASONABLY AVAILABLE CONTROL MEASURES
77ze k$ column contains dust which are .tiended for em&ion control
the SOLUM of fugitive
wzder Diszkt Rule 403. The two right columns contain an inventory and description of
reason&y ava.ihble figitive dust control meaxua for each of the’ sources. Please use this
information (zli a guide when preparing a fugitive dust emission control plan
Reasouably Available
Sonra ContmI Mcasurts Comments
UlIpaved Paving (I) Best choice

Roads (2) Requires street nvecping/cl&ng if subject to material
auzumukion
chemical stabiljration (1) Second best choice

(2) Vendors can suppiy information as to application methods and
conantratious
(3) Not rc.commeadcd for high volume, heavy trafiic use
- -
Watering (1) In sufkienr quantities to keep sarfaa moist
c (2) Required application frequency wiIl F according to soil type,
wcalhcr conditions, and ~chiadar use
Reduce spad limits (1) 15 mile per hour maximum
Reduce v&i& n;ps (1) Aacss rhction or rcdircaing tra.ffic to paved roads in order to
rcdua vehicle trips by a minimum of 60 percent
Storage Wid sheltering (1) Best choice, cndoscd silos

Piles (2) Alternate choiaz, three sided barriers equal to height pf
material with no more than 50 percent poro$
Wet suppression (1) Application methods include: spray bars, hoses and trucks
(2) Frequency of application will vary on site spedfic ~~nditi~n~
-.
ChCmicdl suppression (1) Best for use on storage piles subject KO infrequent d&.ubantcs
Aking loadinfioadout (I) Confine loadin/loadour proadurcs to leeward (downwind) side

procedures of the material
(2) Most cffcaivc when used in conjunaion with wind sheltering
Covctigs (1) Tarps. plasric, or orh:r material can bc used as temporary

coverings
(2) When used, rhcsc should bc anchored to prcvcnr wind from
removing coverings
Paved Wheel washers (1) Should be placed where vehicles exit unpaved arcas onto paved
Road areas
Trick-out (2) System can be adjusted IO spray cnrirc vchiclc, including stored
bulk material in haul vchiclcs
Swccp/dcau roadways (1) Either sweeping or water flushing may be used
Cover haul vchidcs (1) Entire surface arca should be covered once vehicle & full
9-2
Reasonably &aiiabk
Soom ~ootrol MC&U- Comments
EiVCd BCdlkfSillhZiUl (1) When feasible, use in bottom dumping haul vchidcs
Road vchidcs
Trick-out
Land Watering (I) Application of water by means of truck hoscz and/

Qcaring/ or sprinklers prior COany land dcaring or car&
Earth- movement will ircrcasc the moisture content thereby
moyipg inucasing sitaMity of material
(2) Once the idid land &zing/earth movcmcnt a&vi&s arc
compkc, a second round of watering can gcncratc a thin
a-w which stabii the disxurbcd surkz areas providd
that ix is not disturbed
(3) Secmixy fen&g cil~l be used to pnvcnt unwanted kure
disnuhancc~ of sites where a surfaa aust has been created
ChqmicalnabiIbation (1) Only cffcaivc in arcas which arc not subject to daily distnrbanccs
.
(2) Vendors can supply information on pro&a application and
rtquired mrccnvations
Wmd fencing (I) Three to f3-e foot barriers adjacent to roadways or urban areas
can be c&ctivc in reducing the amount of wind blown
makrial lea* a site
(2) Should be used in conjunction with other mcasnrcs ’
cm-u haulvchides (1) Ekrc surfacc arca should bc covered once: vchidc is fuII
(1) When feasible, use in bottom dumping haul chicks
(1) Should be placed where vchiclu exit unpaved arcas on to pavcd
(2) Systaz bc adjusted to spray cntirc vchidc, induding stored

bulk marcrial in haul v&ides
Dktnrkd Chemical stabllirarion (1) BCSIchoice for arca~ where active operations have ceased
sudaa (2) Vendors can supply information on muhods for application and
rcquircd concentrations
Watering (1) Would rcquirc frequent applications unicss a crust

can be dcvclopcd over the sire
Wmd fencing (1) Three IO five foor bank-s adjaanr to roadways or urban arcas
can bc cffcaivc in reducing the amount of wind blow-n
material having a sire
(2) Should be used in conjunction with orhcr mcasurcs
(1) Establish a~ q&Hy a~ possible when auivc operations have

cwd
(2) Use of drought tolcran~ native vcgctarion is encouraged
9-3
Maricopa County 2406 S. 24th Street, Suite E-214
Environmental Services Department Phoenix, Arizona 85034
Field ServicesDivision - Air Pollution Control (602) 5064700 l FAX] (602) 5066862
c
Application for Earth Moving Permit, Demolition & Dust Control Plan
Applicant: 0 0 wrier/Operator/Leasee [7 General/PrimeContractor 0 Developer FOR OFFICE USE ONLY

Diet. #
Legal BusinessName:
NOV #
Address: Permit #
Date Issued
City/State/Zip: Fee Paid
Phone: Fax: Approved by

PU Mail-
Primary ContactPerson:
Pager/Mobile @site Gffsite
Title Phone Phone YhOne
PropertyOwner/Genera.lContractor ,.;:.::::;:::“::~::::: -
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Legal Description(from Phoen&Meuopoli~~~:.~~~~~~~~

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size of Project in Acres (incl~~~~g *d..~
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Brief descriptiopoiQh&project:
Type of Project (mark all applicable codes):
q Residential (RD) q CommerciaHndustrial (CD) aRoad Work (RC) q TemporaryStorageNard (TS)
[ZlTrenching (TR) aSite Preparation/Laud Dev (SP) OWeed Control (WC) aDemolition (TIE)
For renovation or demolition activities the following information is required:

Is asbestospresent? AHERA Determinationmadeby Date
Has 10 Day NESHAP If Yes, Copy of 10 Day
Notification beensubmitted? date: Notification attached?q Yes lJNo StartDate:
In accordance with Rule 310, Section 401.2, a plot plan is required. Provide a plot plan sketch on 8 l/2 in. by
11 in. paper which includes the total area to be disturbed. Indicate sources of fugitive dust emissions on the plot
plan, including delivery, transport, and storage areas. Be sureto includelinear dimensionsin feet on plot plan.
Pursuantto Rule 310, Section303, a dust control plan is requiredwith any earthmovingapplication.
Additional measures and comments may be attached to this form. Pursuant to Rule 310, Section 503, records
of actual implementation or application of these measuresmust be maintained daily and kept on site and made
available upon request by the Control Officer or designee. The records must be retained for at least 3 years
by the permittee.
l/26/96
DUSTCONTROLPLAN
Choose at least one measure as a primary RACM (Reasonably Available Control Measure) per category.
Unless designated, any other control measurein the category will be considered a contingency or back-up
control measure. You may prepare your own plan to submit by following the guidelines in Rule 310, Section
401.
Earthmoving / Demolition (ie.,trenching,roughgrading,final grading, landscaping,material handling)

Conductwatering as necessaryto preventvisible emissions
Prewetsite
Ceaseoperations (contingencyonly, cannotbe usedas a primary RACM)
Disturbed surface areas
On the last day of active operationsandwhen activeoperationswill not occur for not more than fifteen days;
Apply chemical stabilizers.Reapplyasnecessaryto maintainstabilization.
Apply water to all unstablizeddisturbedareas3 times per day
Install wind fences/screens
Constructberms
Within 8 monthsof the last day of active operations:
Pavethe affectedarea
Physicalstabilizationwith gravel/recycledasphalt
Physicalstabilizationwith vegetation
Unpaved roads ; : :..
Stabilizewith gravel/recycledasphalt .I.,:...:
: .’
Apply chemicalstabilizers to all unpavedroadsurfacesin sufflcie++ntity andfrFpt?qito,
maintain a stabilizedsurface .-.. . .. ..:
Water all roadsusedfor any vehicular.~~~~~as$&&d to &&t&l e&&ions -:;Y$~::;:,~..
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;.i~~‘~i:i-I;:-:“::~~:~‘~~~~ly
wat~~~ithe surface ~~~~f ~l~:;open ~~~~~~e;;~i;~S-on a daily basis;when there is evidence of
..::‘i~-iii::~~~i:~~~~~d
drive~@$ive .du& $I$:.-/‘;.. .y .I..’
.‘::;‘;ii.~;~~~~~~~ll
te~~~~jcove*ings/e~~l~sures
Access mJ!@& ,:,;...I .1’.;:I,;;:“-:: ..
‘:-i:;.-e~~:i’~~~~~~ll
a stibi’iized constructionentrance/gravelpad (Requiredfor all accesspoints on sitesof 5 acres
:..:~:::,:::,;~~~~~~t
more)
Install a wheel washer
Limit, restrict, reroutemotor vehicleaccess
Vacuum/ Wet broom daily
Hauling
X Haul trucks carrying bulk materialsmust be tarped
Describe available water supply, distance from worksite, method of application, & water storage:
I certify that I am familiar with the operationspresentedin this application and agree to conduct all operations
related to the worksite in compliance with the above dust control plan, Rule 310, any permit conditions and all
applicable environmen& regulations.
Signature of Responsible Official
Print Name & Title

(i%e responSble oficial is an oficer or designated signer from the company named as applicant. If a designated signer is
used, a written designation signed by an oficer shall be on fire with this office.)
APPENDIX B Cement Kilns
Particulate Matter (PM 10)

Emissions Determinations
(EPA Method 5)
Ott 1996 Page B - I

METHOD 5
DETERMINATION OF PARTICULATE EMISSIONS
i FROM STATIONARY SOURCES
1. PrincipleandApplicability
1.1 Principle. Particulatematter is withdrawn isokineticallyfrom the sourceandcollectedon a

glassfiber filter maintainedat a temperaturein the rangeof 12&14” C (248&25’ F) or such
othertemperatureasspecifiedby an applicablesubpartof the standardsor approvedby
Administrator,U.S. EnvironmentalProtectionAgency, for a particularapplication.The particulate
mass,which includesany materialthat condensesat or abovethe filtration temperature,is
determinedgravimetricallyafter removalof uncombinedwater.
1.2 Applicability. This methodis applicablefor the determinationof particulateemissionsfrom
stationarysources.
2. Apparatus
2.1 SamplingTrain. A schematicof the samplingtrain usedin this methodis shownin Figure 5-l.
Completeconstructiondetailsaregiven in APTD-0581 (Citation 2 in Bibliography);commercial
modelsof this train are alsoavailable.For changesfrom APTD-0581 andfor allowablemodifications
of the train shownin Figure 5-1, seethe following subsections.Theoperatingandmaintenance
proceduresfor the samplingtrain aredescribedin APTD-0576(Citation 3 in Bibliography). Since
correctusageis important in obtainingvalid results,all usersshouldreadAPTD-0576and adoptthe
operatingandmaintenanceproceduresoutlinedin it, unlessotherwisespecifiedherein.The sampling
train consistsof the following components:
2.1.1 ProbeNozzle. Stainlesssteel(3 16) or glasswith sharp,taperedleadingedge.The angleof

taper shallbe ~30” andthe taper shallbe on the outsideto preservea constantinternaldiameter.
Theprobenozzleshallbe of the button-hookor elbow design,unlessotherwisespecifiedby the
Administrator. If madeof stainlesssteel,the nozzleshall beconstructedfrom seamlesstubing; other
materialsof constructionmay be used,subjectto the approvalof the Administrator. A rangeof
nozzlesizessuitablefor isokineticsamplingshouldbe available,e.g., 0.32 to 1.27cm ( l/8 to l/2
in-)-or larger if highervolume samplingtrains are used-insidediameter(ID) nozzlesin increments
of 0.16 cm ( l/16 in.). Eachnozzleshallbe calibratedaccordingto the proceduresoutlined in
Section5.
2.1.2 ProbeLiner. Borosilicateor quartzglasstubing with a heatingsystemcapableof
maintaininga gastemperatureat the exit endduring samplingof 12W14” C (248k25o F), or such
other temperatureas specifiedby an applicablesubpartof the standardsor approvedby the
Administrator for a particularapplication,(Thetestermay opt to operatethe equipmentat a
temperaturelower than that specified.)Sincethe actualtemperatureat the outlet of the probe is not
usuallymonitoredduring sampling,probesconstructedaccordingto APTD-0581 andutilizing the
calibrationcurvesof APTD-0576(or calibratedaccordingto the procedureoutlinedin APTD-0576)
will be consideredacceptable.Either borosilicateor quartzglassprobelinersmay be usedfor stack
temperaturesup to about480” C (900” F); quartzliners shallbe usedfor temperaturesbetween480
and 900” C (900 and 1,650” F). Both typesof liners may be usedat highertemperaturesthan
specifiedfor short periodsof time, subjectto the approvalof the Administrator.The softening
1
temperaturefor borosilicateis 820°C (1508”F), and for quartzit is 1500°C (2,732”F).
Wheneverpractical,every effort shouldbe madeto useborosilicateor quartz glassprobeliners.

Alternatively,metal liners(e.g., 3 16stainlesssteel,Incoloy 825,2or other corrosionresistant
metals)madeof seamlesstubing may be used,subjectto the approvalof the Administrator.
2.1.3 Pitot Tube.Type S, asdescribedin Section2.1 of Method 2, or other deviceapprovedby
the Administrator.Thepitot tube shallbe attachedto the probe(as shownin Figure 5-l) to allow
constantmonitoringof the stackgasvelocity. The impact (high pressure)openingplaneof the pitot
tube shallbe evenwith or abovethe nozzleentry plane(seeMethod 2, Figure2-6b) during
sampling.The Type S pitot tube assemblyshallhavea known coefficient, determinedas outlinedin
Section4 of Method 2.
2.1.4 Differential PressureGauge.Inclinedmanometeror equivalentdevice(two), asdescribed
in Section2.2 of Method 2. One manometershallbe usedor velocity head(ARHO) readings,
andthe other, for orifice differential pressurereadings.
2.1.5 Filter Holder. Borosilicateglass,with a glassfiit filter supportanda siliconerubber
gasket.Other materials of construction(e.g., stainlesssteel,Teflon, Viton) may be used,subjectto
approvalof the Administrator. Theholder designshallprovidea positive sealagainstleakagefrom
the outsideor aroundthe filter. The holder shallbe attachedimmediatelyat the outlet of the probe
(or cyclone,it used).
2.1.6 Filter Heating System.Any heatingsystemcapableof maintaininga temperaturearound
the filter holderduring samplingof 120~~14”C (248*25OF), or suchothertemperatureas specified
by an applicablesubpartof the standardsor approvedby the Administrator for a particular
application.Alternatively,the tester may opt to operatethe equipmentat a temperaturelower
than that specified.A temperaturegaugecapableof measuringtemperatureto within 3 OC (5.4” F)
shallbe installedsothat the temperaturearoundthe filter holdercanbe regulatedand monitored
during sampling.Heatingsystemsother thanthe one shownin APTD-0581 may be used.
2.1.7 Condenser.The following systemshallbe usedto determinethe stackgasmoisture
content:Four impingersconnectedin serieswith leak-freegroundglassfittings or any similar leak-
free non-contaminatingfittings. The first, third, andfourth impingersshallbe of the Greenburg-
Smith design,modified by replacingthe tip with 1.3 cm ( l/2 in.) ID glasstube extendingto about
1.3 cm ( l/2 in.) from the bottom of the flask. The secondimpingershallbe of the Greenburg-Smith
designwith the standardtip. Modifications (e.g., usingflexible connectionsbetweenthe impingers,
usingmaterialsother than glass,or usingflexible vacuumlinesto connectthe filter holder to the
condenser)may be used,subjectto the approvalof the Administrator.
The first andsecondimpingersshall containknown quantitiesof water (Section4.1.3), the third

shallbe empty, andthe fourth shall containa known weight of silica gel, or equivalentdesiccant.
A thermometer,capableof measuringtemperatureto within 1OC (2” F) shallbe placedat the outlet
of the fourth impingerfor monitoring purposes.Alternatively, any systemthat coolsthe samplegas
streamand allowsmeasurementof the water condensedandmoistureleavingthe condenser,eachto
within 1 ml or 1 g may be used,subjectto the approvalof the Administrator. Acceptablemeansare
to measurethe condensedwater either gravimetricallyor volumetricallyandto measurethe
moistureleavingthe condenserby: (1) monitoring the temperatureandpressureat the exit of the
condenserandusingDalton’slaw of partial pressures;or (2) passingthe samplehas streamthrough
a tared silica gel (or equivalentdesiccant)trap with exit gaseskept below 20OC (68 o F) and
determiningthe weight gain. If meansother than silica gel areusedto determinethe amountof
2
moistureleavingthe condenser,it is recommendedthat silica gel (or equivalent)still be used
,, betweenthe condensersystemandpump to preventmoisturecondensationin the pump and
i meteringdevicesandto avoid the needto make correctionsfor moisturein the meteredvolume.
Note: If a determinationof the particulatematter collectedin the impingersis desiredin addition

to moisturecontent,the impinger systemdescribedaboveshall be used,without modification.
Individual Statesor control agenciesrequiringthis information shall be contactedasto the sample
recoveryandanalysisof the impingercontents.
2.1.8 Metering System.Vacuumgauge,leak-freepump, thermometerscapableof measuring
temperatureto within 3 OC (5.4OF), dry gasmeter capableof measuringvolumeto within 2
percent,andrelatedequipment,as shownin Figure 5-l. Other meteringsystemscapableof
maintainingsamplingrateswithin 10percentof isokineticand of determiningsamplevolumesto
within 2 percentmay be used,subjectto the approvalof the Administrator. Whenthe metering
systemis usedin conjunctionwith a pitot tube, the systemshallenablechecksof isokineticrates.
Samplingtrains utilizing meteringsystemsdesignedfor higherflow ratesthan that decribedin
APTD-0581 or APDT-0576may be usedprovidedthat the specificationsof this methodare met.
2.1.9 Barometer.Mercury aneroid,or other barometercapableof measuringatmospheric
pressureto within 2.5 mm Hg (0.1 in. Hg). In many casesthe barometricreadingmay be obtained
from a nearbyNational WeatherServicestation,in which casethe stationvalue(which is the
absolutebarometricpressure)shallbe requestedandan adjustmentfor elevationdifferences
betweenthe weatherstationand samplingpoint shallbe appliedat a rate of minus 2.5 mm Hg (0.1
in. Hg) per 30 m (100 ft) elevationincreaseor vice versafor elevationdecrease.
2.1.10 GasDensity DeterminationEquipment.Temperaturesensorandpressuregauge,as
describedin Sections2.3 and 2.4 of Method2, and gasanalyzer,if necessary,asdescribedin
Method 3. Thetemperaturesensorshall,preferably,be permanentlyattachedto the pitot tube or
samplingprobein a fixed configuration,suchthat the tip of the sensorextendsbeyondthe leading
edgeof the probesheathanddoesnot touch any metal. Alternatively, the sensormay be attached
just prior to usein the field. Note, however,that if the temperaturesensoris attachedin the field,
the sensormust be placedin an interference-freearrangementwith respectto the Type S pitot tube
openings(seeMethod 2, Figure 2-7). As a secondalternative,if a differenceof not morethan 1
percentin the averagevelocity measurementis to be introduced,the temperaturegaugeneednot be
attachedto the probeor pitot tube. (This alternativeis subjectto the approvalof the Administrator.)
2.2 SampleRecovery.The following items are needed.
2.2.1 Probe-LinerandProbe-NozzleBrushes.Nylon bristle brusheswith stainlesssteelwire
handles.Theprobebrushshall haveextensions(at leastaslong asthe probe)of stainlesssteel,
Nylon, Teflon, or similarly inert material.The brushesshallbe properly sizedand shapedto brush
out the probeliner andnozzle.
2.2.2 WashBottles-Two. Glasswashbottles arerecommended;polyethylenewashbottles may
be usedat the option of the tester.It is recommendedthat acetonenot be storedin polyethylene
bottles for longerthan a month.
2.2.3 GlassSampleStorageContainers.Chemicallyresistant,borosilicateglassbottles, for
acetonewashes,500ml or 1000ml. Screwcap liners shalleitherbe rubber-backedTeflon or shall
be constructed‘soasto be leak-freeandresistantto chemicalattackby acetone.(Narrow mouth
glassbottleshavebeenfound to be lessproneto leakage.)Alternatively, polyethylenebottlesmay
be used.
2.2.4 Petri Dishes.For filter samples,glassor polyethylene,unlessotherwisespecifiedby the
3
Administrator.
2.2.5 GraduatedCylinder and/orBalance.To measurecondensed water to within 1 ml or 1 g.
Graduatedcylindersshallhavesubdivisionsno greaterthan 2 ml. Most laboratorybalances
arecapableof weighingto the nearest0.5 g or less.Any of thesebalancesis suitableor usehereand
in Section2.3.4.
2.2.6 PlasticStorageContainers.Air-tight containersto storesilicagel.
2.2.7 FunnelandRubberPoliceman.To aid in transferof silicagel to container;not necessaryif
silica gel is weighedin the field.
2.2.8 Funnel.Glassor polyethylene,to aid in samplerecovery.
2.3 Analysis.For analysis,the following equipmentis needed.
2.3.1 GlassWeighingDishes.
2.3.2 Desiccator.
2.3.3 Analytical Balance.To measureto within 0.1 mg.
2.3.4 Balance.To measureto within 0.5 g.
2.3.5 Beakers.250 ml.
2.3.6 Hygrometer.To measurethe relative humidity of the laboratoryenvironment.
2.3.7 TemperatureGauge.To measurethe temperatureof the laboratoryenvironment.
3. Reagents
3.1 Sampling.The reagentsusedin samplingareas follows:
3.1.1 Filters. Glassfiber filters, without organicbinder, exhibitingat least99.95 percent
efficiency (x0.05 percentpenetration)on 0.3~microndioctyl phthalatesmokeparticles.Thefilter
efficiency test shallbe conductedin accordancewith ASTM StandardMethod D2986-71
(Reapproved1978)(incorporatedby reference-see$60.17). Test datafrom the supplier’squality
control program aresufficient for this purpose.In sourcescontainingSO2or S03, the filter material
must be of a type that is unreactiveto SO2 or S03. Citation 10in Bibliography,may be usedto
selectthe appropriatefilter.
3.1.2 Silica Gel. Indicatingtype, 6 to 16mesh.If previouslyused,dry at 175o C (350” F) for 2
hours.New silica gel may be usedas received.Alternatively, othertypesof desiccants(equivalent
or better) may be used,subjectto the approvalof the Administrator.
3.1.3 Water. When analysisof the materialcaughtin the impingersis required,deionized
distilledwater shallbe used.Run blanksprior to field useto eliminatea high blank on test samples.
3.1.4 CrushedIce.
3.1.5 StopcockGrease.Acetone-insoluble,heat-stablesiliconegrease.This is not necessaryif
screw-onconnectorswith Teflon sleeves,or similar, areused.Alternatively, other types of
stopcockgreasemay be used,subjectto the approvalof the Administrator.
3.2 SampleRecovery.Acetone-reagentgrade,<O.OOlpercentresidue,in glassbottles-is
required.Acetonefrom metal containersgenerallyhasa high residueblank and shouldnot be used.
Sometimes,supplierstransferacetoneto glassbottlesfrom metal containers;thus, acetoneblanks
shallbe run prior to field useandonly acetonewith low blank values(r;O.OOlpercent)shallbe used.
In no caseshall a blankvalueof greaterthan 0.001percentof the weight of acetoneusedbe
subtractedfrom the sampleweight.
3.3 Analysis.Two reagentsarerequiredfor the analysis:
3.3.1 Acetone.Sameas3.2.
3.3.2 Desiccant.Anhydrouscalciumsulfate,indicatingtype. Alternatively, other typesof
desiccantsmay be used,subjectto the approvalof the Administrator.
4
4. Procedure
4.1 Sampling.The complexity of this methodis suchthat, in orderto obtainreliableresults,
testersshouldbe trained andexperiencedwith the test procedures.
4.1.1 PretestPreparation.It is suggestedthat samplingequipmentbemaintainedaccordingto the
proceduredescribedin APTD-0576. Weigh several200 to 300 g portionsof silica gel in air-tight
containersto the nearest0.5 g. Recordthe total weight of the silicagel plus container,on each
container.As an alternative,the silica gel neednot be preweighed,but may be weigheddirectly in
the impingeror samplingholderjust prior to train assembly. Checkfilters visually againstlight for
irregularitiesandflaws or pinholeleaks.Label filters of the properdiameteron the back sidenear
the edgeusingnumberingmachineink. As an alternative,labelthe shippingcontainers(glassor
plasticpetri dishes)andkeepthe filters in thesecontainersat all times exceptduring samplingand
weighing. Desiccatethe filters at 2ti5.6 OC (6U 10OF) andambientpressurefor at least24 hours
andweigh at intervalsof at least6 hoursto a constantweight, i.e., 0.5 mg changefrom previous
weighing; recordresultsto the nearest0.1 mg.
During eachweighing the filter must not be exposedto the laboratoryatmospherefor a period
greaterthan 2 minutesanda relativehumidity above50 percent.Alternatively (unlessotherwise
specifiedby the Administrator), the filters may beoven dried at 105OC (220OF) for 2 to 3 hours,
desiccatedfor 2 hours, andweighed.Proceduresotherthan thosedescribed,which accountfor
relativehumidity effects,may be used,subjectto the approvalof the Administrator.
4.1.2 PreliminaryDeterminations.Selectthe samplingsite andthe minimum numberof
samplingpoints accordingto Method 1 or asspecifiedby the Administrator. Determinethe stack
pressure,temperature,andthe rangeof velocity headsusingMethod 2; it is recommendedthat a
leak-checkof the pitot lines (seeMethod 2, Section3.1) be performed.
Determinethe moisturecontentusingApproximationMethod 4 or its alternativesfor the purposeof
making isokineticsamplingrate settings.Determinethe stackgasdry molecularweight, as
describedin Method 2, Section3.6; if integratedMethod 3 samplingis usedfor molecularweight
determination,the integratedbag sampleshallbe taken simultaneouslywith, andfor the sametotal
length of time as,the particulatesamplerun. Selecta nozzlesizebasedon the rangeof velocity
heads,suchthat it is not necessaryto changethe nozzlesizein orderto maintain isokineticsampling
rates.During the run, do not changethe nozzlesize.
Ensurethat the proper differential pressuregaugeis chosenfor the rangeof velocity heads
encountered(seeSection2.2 of Method 2). Selecta suitableprobeliner andprobelength suchthat
all traversepoints canbe sampled.For largestacks,considersamplingfrom oppositesidesof the
stackto reducethe length of probes. Selecta total samplingtime greaterthan or equalto the
minimum total samplingtime specifiedin the test proceduresfor the specificindustry suchthat (1)
the samplingtime per point is not lessthan 2 min (or somegreatertime interval as specifiedby the
Administrator), and(2) the samplevolumetaken (correctedto standardconditions)will exceedthe
requiredminimum total gassamplevolume.
The latter is basedon an approximateaveragesamplingrate. It is recommendedthat the numberof
minutessampledat eachpoint be an integeror anintegerplus one-halfminute, in orderto avoid
timekeepingerrors. The samplingtime at eachpoint shallbe the same. In somecircumstances,
e.g., batchcycles,it may be necessaryto samplefor shortertimes at the traversepoints andto obtain
smallergassamplevolumes.In thesecases,the Administrator’sapprovalmust first be obtained.
5
4.1.3 Preparationof CollectionTrain. During preparationandassemblyof the samplingtrain, keepall
openingswherecontaminationcanoccur covereduntil just prior to assemblyor until samplingis aboutto
begin. Place100ml of water in eachof the first two impingers,leavethe third impinger empty, and
transfer approximately200 to 300 g of preweighedsilica gel from its containerto the fourth impinger.
More silica gel may be used,but careshouldbe takento ensurethat it is not entrainedand carriedout
from the impingerduring sampling.Placethe containerin a cleanplacefor later usein the sample
recovery.Alternatively, the weight of the silica gel plus impingermay be determinedto the nearest0.5 g
andrecorded. Using a tweezeror cleandisposablesurgicalgloves,placea labeled(identified) and
weighedfilter in the filter holder.Be surethat the filter is properlycenteredandthe gasketproperly placed
so asto preventthe samplegasstreamfrom circumventingthe filter. Checkthe filter for tearsafter
assemblyis completed. When glassliners areused,install the selectednozzleusing a Viton A O-ring
when stacktemperaturesarelessthan 260°C (500” F) and an asbestosstring gasketwhen temperatures
arehigher. SeeAPTD-0576for details.Other connectingsystemsusing either 316 stainlesssteelor
Teflon ferrulesmay be used. Whenmetal liners are used,installthe nozzleasaboveor by a leak-free
direct mechanicalconnection.
Mark the probewith heatresistanttape or by someother methodto denotethe proper distanceinto the
stackor duct for eachsamplingpoint.
Setup the train asin Figure5-1, using (if necessary)a very light coat of siliconegreaseon all ground
glassjoints, greasingonly the outerportion (seeAPTD-0576) to avoidpossibility of contaminationby the
siliconegrease.Subjectto the approvalof the Administrator, a glasscyclonemay be usedbetweenthe
probeandfilter holderwhen the total particulatecatchis expectedto exceed100mg or when water
dropletsarepresentin the stackgas. Placecrushedice aroundthe impingers.
4.1.4 Leak-CheckProcedures.
4.1.4.1 PretestLeak-Check.A pretestleak-checkis recommended,but not required.If the testeroptsto
conductthe pretestleak-check,the following procedureshallbe used. After the samplingtrain hasbeen
assembled,turn on andset the filter andprobeheatingsystemsat the desiredoperatingtemperatures.
Allow time for the temperaturesto stabilize.If a Viton A O-ring or other leak-freeconnectionis usedin
assemblingthe probenozzleto the probe liner, leak-checkthe
train at the samplingsite by pluggingthe nozzleandpulling a 380 mm Hg (15 in. Hg) vacuum.
Note: A lower vacuummay be used,providedthat it is not exceededduring the test. If an asbestos

string is used,do not connectthe probeto the train during the leak-check.Instead,leak-checkthe train by
first pluggingthe inlet to the filter holder (cyclone,if applicable)andpulling a 380 mm Hg (15 in. Hg)
vacuum(seeNote immediatelyabove).Thenconnectthe probeto the train andleak-checkat about25
mm Hg (1 in. Hg) vacuum;alternatively,the probemay be leak-checkedwith the rest of the sampling
train, in one step,at 380mm Hg (15 in. Hg) vacuum.Leakageratesin excessof 4 percentof the average
samplingrate or 0.00057m3lmin (0.02 cf?n),whicheveris less,are unacceptable.
The following leak-checkinstructionsfor the samplingtrain describedin APTD-0576 and APTD-0581

may be helpful. Start the pump with bypassvalve fully openandcoarseadjustvalve, completelyclosed.
Partially openthecoarseadjustvalve andslowly closethe bypassvalve until the desiredvacuumis
reached.Do not reversedirectionof bypassvalve; this will causewater to back up into the filter holder.If
the desiredvacuumis exceeded,either leak-checkat this highervacuumor endthe leak-checkas shown
below andstart over. Whenthe leak-checkis completed,first slowly removethe plug from the inlet to
the probe,filter holder,or cyclone(if applicable)and immediatelyturn off the vacuum pump. This
6
preventsthe water in the impingersfrom beingforcedbackwardinto the filter holder andsilica gel from
beingentrainedbackwardinto the third impinger.
4.1.4.2 Leak-ChecksDuring SampleRun. If, duringthe samplingrun, a component(e.g., filter assembly

or impinger)changebecomesnecessary,a leak-checkshallbe conductedimmediately
beforethe changeis made.The leak-checkshallbe doneaccordingto the procedureoutlinedin Section
4.1.4.1above,exceptthat it shall be doneat a vacuumequalto or greaterthan the maximum
valuerecordedup to that point in the test. If the leakagerate is found to be no greaterthan 0.00057
m3/min (0.02 cfin) or 4 percentof the averagesamplingrate (whicheveris less),the resultsare
acceptable,andno correctionwill needto be appliedto the total volume of dry gasmetered;if, however,a
higherleakagerate is obtained,the testershalleitherrecordthe leakagerate andplan to correctthe sample
volume asshownin Section6.3 of this method,or shallvoid the samplingrun. Immediatelyafter
componentchanges,leak-checksareoptional;if suchleak-checksare done,the procedureoutlined in
Section4.1.4.1aboveshallbe used.
4.1.4.3 Post-testLeak-Check.A leak-checkis mandatoryat the conclusionof eachsamplingrun. The
leak-checkshallbe donein accordancewith the proceduresoutlinedin Section4.1.4.1,
exceptthat it shallbe conductedat a vacuumequalto or greaterthanthe maximumvaluereachedduring
the samplingrun. If the leakagerateis found to be no greaterthan 0.00057m3/min (0.02
cfin) or 4 percentof the averagesamplingrate (whicheveris less),the resultsareacceptable,andno
correctionneedbe appliedto the total volumeof dry gasmetered.If, however,a higherleakagerate is
obtained,the testershalleitherrecord the leakagerate andcorrectthe samplevolume asshownin Section
6.3 of this method,or shallvoid the samplingrun.
4.1.5 ParticulateTrain Operation.During the samplingrun, maintainan isokineticsamplingrate
c‘. (within 10percentof true isokineticunlessotherwisespecifiedby the Administrator) anda temperature
aroundthe filter of 12W14o C (248*25 ’ F), or suchother temperatureas specifiedby an applicable
subpartof the standardsor approvedby the Administrator. For eachrun, recordthe datarequiredon a
data sheetsuchasthe oneshownin Figure5-2. Be sureto recordthe initial
dry gasmeter reading.Recordthe dry gasmeterreadingsat the beginningandend of eachsamplingtime
increment,when changesin flow ratesaremade,beforeandafter eachleak-check,andwhen samplingis
halted.Takeother readingsrequiredby Figure 5-2 at leastonceat eachsamplepoint during eachtime
incrementandadditionalreadingswhen significantchanges(20 percentvariation in velocity head
readings)necessitateadditionaladjustmentsin flow rate.
Level andzerothe manometer.Becausethe manometerlevel andzero may drift dueto vibrationsand

temperaturechanges,makeperiodicchecksduringthe traverse. Cleanthe portholesprior to the test run
to minimizethe chanceof samplingdepositedmaterial.To beginsampling,removethe nozzlecap,verify
that the filter andprobeheatingsystemsareup to temperature,andthat the pitot tube andprobeare
properly positioned.Positionthe nozzleat the first traversepoint with the tip pointingdirectly into the gas
stream.Immediatelystart the pump and adjustthe flow to isokineticconditions.Nomographsare
available,which aid in the rapid adjustmentof the isokineticsamplingrate without excessive
computations.
Thesenomographsare designedfor usewhenthe Type S pitot tube coefficient is 0.85~tO.02,

andthe stack
gasequivalentdensity(dry molecularweight) is equalto 29k4. APTD-0576detailsthe procedurefor
“, usingthe nomographs.If Cp andMd are outsidethe abovestatedrangesdo not usethe nomographs
unlessappropriatesteps(seeCitation 7 in Bibliography)aretakento compensatefor the deviations.
7
Project No. '-
Location Pitot Tuba Facto+ _ Plant Name
Oate Probe Tip Dia. in. Ambient Tenlp l F,
Operator Probe Length Heter Tenlp l F
Hater Box No. Sample Train Bar. .Press, *Hg
local The,' Leak Test . Stack Press, "II20
Start/Stop Before After Assumed Moisture, X
Pltot lube hater Box Settlng, .F I
Leak Test Probe Heater Setting, 'F
Before After
\
Flltar
PItot " Orifice AH Iatpinger Box Stack
Clock Dry Gas In. 40 In 1120 T~IIJ~. Temp. Purt\p Vat: uutii
Point Time Meter, CF b P DeJlred Actual t- 'TP* OF in. II9
Stlrrt
. ---i
I
Whenthe stackis undersignificantnegativepressure(height of impingerstem), take careto close
the coarseadjustvalve before insertingthe probeinto the stackto preventwater from backinginto
the filter holder.If necessary,the pump may beturned on with the coarseadjustvalve closed.
Whenthe probeis in position, block off the openingsaroundthe probeandportholeto prevent
unrepresentativedilution of the gasstream. Traversethe stackcross-section,asrequiredby
Method 1 or as specifiedby the Administrator,beingcareful not to bump the probenozzleinto the
stackwalls when samplingnearthe walls or when removingor insertingthe probethrough the
portholes;this minimizesthe chanceof extractingdepositedmaterial.
During the test run, makeperiodic adjustmentsto keepthe temperaturearoundthe filter holder at
the properlevel; addmore ice and, if necessary,salt to maintaina temperatureof lessthan 20” C
(68’ F) at the condenser/silicagel outlet. Also, periodicallycheckthe level andzero of the
manometer. If the pressuredrop acrossthe filter becomestoo high, making isokineticsampling
difficult to maintain,the filter may be replacedin the midst of a samplerun. It is recommendedthat
anothercompletefilter assemblybe usedratherthanattemptingto changethe filter itself. Before a
new filter assemblyis installed,conducta leak-check(seeSection4.1.4.2). The total particulate
weight shallinclude+hesummationof all filter assemblycatches.
A singletrain shallbe usedfor the entire samplerun, exceptin caseswheresimultaneoussampling

is requiredin two or more separateductsor at two or more different locationswithin the sameduct,
or, in caseswhereequipmentfailure necessitates a changeof trains.In all other situations,the useof
two or more trains will be subjectto the approvalof the Administrator. Note that when two or
more trains areused,separateanalysesof the front-half and(if applicable)impingercatchesfrom
eachtrain shallbe performed,unlessidenticalnozzlesizeswere usedon all trains, in which case,
the front-half catchesfrom the individualtrains may be combined(asmay the impingercatches)and
one analysisof front-half catchand oneanalysisof impinger catchmay be performed.Consultwith
the Administrator for detailsconcerningthe calculationof resultswhen two or more trains areused.
At the endof the samplerun, turn off the coarseadjustvalve, removethe probeandnozzlefrom the
stack,turn off the pump, recordthe final dry gasmeterreading,andconducta post-test
leak-check,asoutlinedin Section4.1.4.3. Also, leak-checkthe pitot linesasdescribedin Method 2,
Section3.1; the linesmust passthis leak-check,in orderto validatethe velocity headdata.
4.1.6 Calculationof PercentIsokinetic. Calculatepercentisokinetic(seeCalculations,Section6)
to determinewhetherthe run was valid or anothertest run shouldbe made.If therewas difficulty in
maintainingisokineticratesdueto sourceconditions,consultwith the Administrator for possible
varianceon the isokineticrates.
4.2 SampleRecovery.Propercleanupprocedurebeginsas soonasthe probeis removedfrom the

stack at the endof the samplingperiod. Allow the probeto cool. Whenthe probe canbe safely
handled,wipe off all externalparticulatematter nearthe tip of the probenozzleandplace
a cap over it to preventlosing or gainingparticulatematter. Do not cap off the probetip tightly
while the samplingtrain is cooling down asthis would createa vacuumin the filter holder,thus
drawing water from the impingersinto the filter holder.
Before moving the sampletrain to the cleanupsite, removethe probefrom the sampletrain, wipe
off the siliconegrease,and capthe openoutlet of the probe.Be carefulnot to loseany condensate
that might be present.Wipe off the siliconegreasefrom the filter inlet where the probewas fastened
8
andcapit. Removethe umbilical cord from the last impinger andcapthe impinger.If a flexible line
is usedbetweenthe first impingeror condenserand the filter holder,disconnectthe line at the filter
holderandlet any condensed water or liquid drain into the impingersor condenser.After wiping off
the siliconegrease,cap off the filter holderoutlet and impingerinlet. Either ground-glassstoppers,
plasticcaps,or serumcapsmay be usedto closetheseopenings. Transferthe probeand filter-
impingerassemblyto the cleanuparea.This areashouldbe cleanandprotectedfrom the wind
so that the chancesof contaminatingor losingthe samplewill be minimized. Savea portion of the
acetoneusedfor cleanupasa blank. Take200 ml of this acetonedirectly from the wash bottle being
usedandplaceit in a glasssamplecontainerlabeled“acetone blank.” Inspectthe train prior to and
during disassemblyandnoteany abnormalconditions.
Treatthe samplesas follows: ContainerNo. 1. Carefully removethe filter from the filter holder
andplaceit in its identifiedpetri dish container. Use a pair of tweezersand/orcleandisposable
surgicalglovesto handlethe filter. If it is necessaryto fold the filter, do so suchthat the particulate
cakeis insidethe fold. Carefullytransfer to the petri dish any particulatematter and/or filter fibers
which adhereto the filter holdergasket,by usinga dry Nylon bristle brushand/or a sharp-edged
blade.Sealthe container. ContainerNo. 2. Taking careto seethat dust on the outsideof the probe
or other exterior surfacesdoesnot get into the sample,quantitativelyrecoverparticulatematter or
any condensatefrom the probenozzle,probefitting, probe liner, andfront half of the filter holderby
washingthesecomponentswith acetoneandplacingthe washin a glasscontainer.
Distilled water may be usedinsteadof acetonewhen approvedby the Administrator and shallbe
usedwhen specifiedby the Administrator; in thesecases,savea water blank andfollow the
Administrator’sdirectionson analysis.Performthe acetonerinsesasfollows: Carefully removethe
probenozzleandcleanthe insidesurfaceby rinsing with acetonefrom a washbottle andbrushing
with a Nylon bristle brush. Brushuntil the acetonerinse showsno visible particles,after which
makea final rinse of the insidesurfacewith acetone. Brush andrinsethe insideparts of the
Swagelokfitting with acetonein a similar way until no visible particlesremain. Rinse the probe
liner with acetoneby tilting androtating the probewhile squirtingacetoneinto its upper endso that
all insidesurfaceswill be wettedwith acetone.
Let the acetonedrain from the lower endinto the samplecontainer.A funnel (glassor polyethylene)
may be usedto aid on transferringliquid washesto the container.Follow the acetonerinsewith a
probebrush.Hold the probein an inclinedposition, squirt acetoneinto the upper end asthe probe
brushis beingpushedwith a twisting actionthrough the probe;hold a samplecontainerunderneath
the lower endof the probe,andcatchany acetoneandparticulatematter which is brushedfrom the
probe.Run the brushthroughthe probethreetimes or more until no visible particulatematter is
carriedout with the acetoneor until noneremainsin the probeliner on visual inspection.With
stainlesssteelor other metalprobes,run the brushthrough in the aboveprescribedmannerat least
six times sincemetal probeshavesmall crevicesin which particulatematter canbe entrapped.Rinse
the brushwith acetone,andquantitativelycollectthesewashingsin the samplecontainer.After the
brushing,makea final acetonerinse of the probe as describedabove.
It is recommendedthat two peoplecleanthe probeto minimize samplelosses.Betweensampling
runs,keepbrushescleanandprotectedfrom contaminations.After ensuringthat all joints have
beenwiped cleanof siliconegrease,cleanthe insideof the front half of the filter holder by rubbing
the surfaceswith a Nylon bristle brushandrinsing with acetone.Rinseeachsurfacethreetimes or
more if neededto removevisible particulate.Make a fmal rinseof the brushand filter holder.
9
Carefully rinse out the glasscyclone,also(if applicable).After all acetonewashingsandparticulate
matter havebeencollectedin the samplecontainer,tighten the lid on the samplecontainerso that
acetonewill not leak out when it is shippedto the laboratory.Mark the height of the fluid level to
determinewhether or not leakageoccuredduring transport.Labelthe containerto clearly identify its
contents.
ContainerNo. 3. Note the color of the indicating silicagel to determineif it hasbeencompletely

spentandmake a notationof its condition.Transferthe silica gel from the fourth impingerto its
original containerandseal.A funnel may makeit easierto pour the silica gel without spilling. A
rubberpolicemanmay be usedasan aid in removingthe silicagel from the impinger. It is not
necessaryto removethe small amountof dust particlesthat may adhereto the impingerwall andare
difficult to remove.Sincethe gainin weight is to be usedfor moisturecalculations,do not use any
water or other liquids to transferthe silica gel. If a balanceis availablein the field, follow the
procedurefor containerNo. 3 in Section4.3. Impinger Water. Treatthe impingersasfollows; Make
a notationof any color or film in the liquid catch.Measurethe liquid which is in the first three
impingersto within hl ml by usinga graduatedcylinder or by weighingit to within ho.5 g by using
a balance(if oneis available).Recordthe volume or weight of liquid present.This information is
requiredto calculatethe moisturecontentof the effluent gas.
Discard the liquid after measuringandrecordingthe volume or weight, unlessanalysisof the
impinger catchis required(seeNote, Section2.1.7). If a different type of condenseris used,
measurethe amountof moisturecondensedeither volumetricallyor gravimetrically. Whenever
possible,containersshouldbe shippedin sucha way that they remainupright at all times.
4.3 Analysis.Recordthe datarequiredon a sheetsuchasthe oneshownin Figure 5-3. Handle

eachsamplecontaineras follows:
ContainerNo. 1. Leavethe contentsin the shippingcontaineror transferthe filter and anyloose
particulatefrom the samplecontainerto a tared glassweighingdish.Desiccatefor 24 hours
in a desiccatorcontaininganhydrouscalcium sulfate.Weighto a constantweight and report the
resultsto the nearest0.1 mg. For purposesof this Section,4.3, the term “constant weight”
meansa differenceof no more than 0.5 mg or 1 percentof total weight lesstare weight, whichever
is greater,betweentwo consecutiveweighings,with no lessthan 6 hoursof desiccationtime
betweenweighings. Alternatively,the samplemay be oven driedat 105o C (220” F) for 2 to 3
hours, cooledin the desiccator,andweighedto a constantweight, unlessotherwisespecifiedby the
Administrator. The testermay alsoopt to oven dry the sampleat 105o C (220o F) for 2 to 3 hours,
weigh the sample,andusethis weight asa final weight.
ContainerNo. 2. Note the level of liquid in the containerandconfirm on the analysissheet

whether or not leakageoccurredduring transport.If a noticeableamountof leakagehas occurred,
either void the sampleor usemethods,subjectto the approvalof the Administrator, to correctthe
final results.Measurethe liquid in this containereither volumetricallyto *l ml or gravimetricallyto
*O-5 g. Transferthe contentsto a tared250-ml beakerand evaporateto drynessat ambient
temperatureandpressure.Desiccatefor 24 hoursandweigh to a constantweight. Report the results
to the nearestO:l mg. ContainerNo. 3. Weighthe spentsilica gel (or silica gel plus impinger) to the
nearest0.5 g usinga balance.This stepmay be conductedin the field. “Acetone Blank” Container.
Measureacetonein this containereithervolumetrically or gravimetrically.Transferthe acetoneto a
tared 250-ml beakerand evaporateto drynessat ambienttemperatureandpressure.Desiccatefor 24
hours andweigh to a constantweight. Report the resultsto the nearest0.1 mg.
10
Note: At the option of the tester,the contentsof ContainerNo. 2 aswell asthe acetoneblank
containermay be evaporatedat temperatureshigherthan ambient.If evaporationis doneat an
elevatedtemperature,the temperaturemust bebelow the boiling point of the solvent;also,to
prevent“bumping,” the evaporationprocessmust be closelysupervised,and the contentsof the
beakermust be swirled occasionallyto maintainan eventemperature.Use extremecare,asacetone
is highly flammableandhasa low flash point.
4.4 Quality Control Procedures.Thefollowing quality control proceduresare suggestedto check

the volumemeteringsystemcalibrationvaluesat the field test site prior to samplecollection.
Theseproceduresare optionalfor the tester.
4.4.1 Meter Orifice Check.Using the calibrationdataobtainedduringthe calibrationprocedure
describedin Section5.3, determinethe AH@for the meteringsystemorifice. The AH@is the orifice
pressuredifferential in units of in. I-I20 that correlatesto 0.75 c&n of air at 528”R and 29.92in. Hg.
The AH@is calculatedas follows:
Tm 02
~H@=0.0319 AH Eq. 5-9
Pbar Y2 V2m
Where:
rH=Averagepressuredifferential acrossthe orifice meter, in. H20.
Tm=Absoluteaveragedry gasmetertemperature,“R.
Pba.r=Barometric
pressure,in. Hg.
O=Total samplingtime, min.
Y=Dry gasmetercalibrationfactor, dimensionless.
Vm=Volume of gassampleasmeasuredby dry gasmeter, dcf.
0.0319=(0.0567in. Hg/“R) x (0.75 cfin)2.
Before beginningthe field test (a setof threeruns usuallyconstitutesa field test), operatethe
meteringsystem(i.e., pump, volume meter, andorifice) at the AH@pressuredifferential
for 10minutes.Recordthe volume collected,the dry gasmetertemperature,andthe barometric
pressure.Calculatea dry gasmeter calibrationcheckvalue,Yc, asfollows:
10 [ 0.0319Tm] l/2
Yc= - Eq. 5-10
Vm [ Pba 1
Where:
Yc=Dry gasmeter calibrationcheckvalue, dimensionless.
lO=lO minutesof run time.
Comparethe Yc valuewith the dry gasmeter calibrationfactor Y to determinethat:
0.97Y < Yc < 1.03Y
If the Yc valueis not within this range,the volumemeteringsystemshouldbe investigatedbefore

beginningthe test.
11
4.4.2 CalibratedCritical Orifice. A calibratedcritical orifice, calibratedagainsta wet test meter or
spirometeranddesignedto be insertedat the inlet of the samplingmeterbox may be usedas a
ir quality control checkby following the procedureof Section7.2.
5. Calibration Maintain a laboratorylog of all calibrations.

5.1 ProbeNozzle. Probenozzlesshallbe calibratedbeforetheir initial usein the field. Using a
micrometer,measurethe insidediameterof the nozzleto the nearest0.025mm (0.001in.).
Make three separatemeasurements using different diameterseachtime, andobtainthe averageof
the measurements. The differencebetweenthe high andlow numbersshallnot exceed0.1 mm
(0.004in.). When nozzlesbecomenicked,dented,or corroded,they shahbe reshaped,sharpened,
andrecalibratedbefore use.Eachnozzleshallbe permanentlyanduniquelyidentified.
5.2 Pitot Tube.The Type S pitot tube assemblyshallbe calibratedaccordingto the procedure
outlinedin Section4 of Method 2.
5.3 Metering System.
5.3.1 CalibrationPrior to Use. Beforeits initial usein the field, the meteringsystemshallbe
calibratedasfollows: Connectthe meteringsysteminlet to the outlet of a wet test meterthat is
accurateto within I percent.Refer to Figure 5.5. Thewet test meter shouldhavea capacityof 38
liters/rev (1 fit 3 /rev). A spirometerof 400 liters (14 fit 3 ) or more capacity,or equivalent,may be
usedfor this calibration,althougha wet test meter is usuallymore practical.The wet test meter
shouldbe periodicallycalibratedwith a spirometeror a liquid displacementmeterto ensurethe
accuracyof the wet test meter.
Spirometersor wet test metersof other sizesmay be used,providedthat the specifiedaccuraciesof

the procedurearemaintained.Run the meteringsystempump for about 15minuteswith the orifice
i
manometerindicatinga medianreadingasexpectedin field useto allow the pump to warm up and
to permit the interior surfaceof the wet test meterto be thoroughlywetted. Then,at eachof a
minimum of three orifice manometersettings,passan exactquantity of gasthroughthe wet test
meter andnote the gasvolume indicatedby the dry gasmeter. Also note the barometricpressure,
andthe temperaturesof the wet test meter,the inlet of the dry gasmeter, andthe outlet of the dry
gasmeter. Selectthe highestand lowestorifice settingsto bracketthe expectedfield operatingrange
of the orifice. Use a minimum volumeof 0.15 m3 (5 cf) at all orifice settings.Recordall the data
on a form similar to Figure5.6, andcalculateY, the dry gasmeter calibrationfactor, and AH@,the
orifice calibrationfactor, at eachorifice settingas shownon Figure5.6. Allowabletolerancesfor
individual Y and AH@,valuesare givenin Figure 5.6. Use the averageof the Y valuesin the
calculationsin Section6.
[ Part 60, page747.Figure 5-5. ]
[ Part 60, page748.Figure 5-6.1
Before calibratingthe meteringsystem,it is suggestedthat a leak-checkbe conducted.For

metering systemshavingdiaphragmpumps,the normal leak-checkprocedurewill not detect
leakageswithin the pump. For thesecasesthe following leak-checkprocedureis suggested:makea
lo-minute calibrationrun at 0.00057mt 3 /min (0.02 cfm); at the end of the run, take the difference
of the measuredwet test meter and dry gasmeter volumes;divide the differenceby 10,to get the
leak rate. The leak rate shouldnot exceed0.00057m t 3 /min (0.02 cfin).
12
5.3.2 CalibrationAfter Use. After eachfield use,the calibrationof the meteringsystemshallbe
checkedby performing three calibrationruns at a single,intermediateorifice setting(based
on the previousfield test), with the vacuumset at the maximum valuereachedduringthe test series.
To adjustthe vacuum,insert a valve betweenthe wet test meter andthe inlet of the meteringsystem.
Calculatethe averagevalueof the dry gasmeter calibrationfactor. If the valuehaschangedby more
than 5 percent,recalibratethe meter over the full rangeof orifice settings,aspreviouslydetailed.
Alternativeprocedures,e.g., recheckingthe orifice meter coefficientmay be used,subjectto the

approvalof the Administrator.
5.3.3 AcceptableVariation in Calibration.If the dry gasmetercoefficient valuesobtainedbefore
andafter a test seriesdiffer by more than 5 percent,the test seriesshalleitherbe voided, or
calculationsfor the test seriesshallbe performedusingwhichevermeter coefficient value(i.e.,
beforeor after) givesthe lower value of total samplevolume.
5.4 ProbeHeaterCalibration.The probeheatingsystemshallbe calibratedbeforeits initial use
in the field. Use a heatsourceto generateair heatedto selectedtemperaturesthat approximatethose
expectedto occurin the sourcesto be sampled.Passthis air throughthe probeat a typical simple
flow ratewhile measuringthe probeinlet andoutlet temperaturesat variousprobeheatersettings.
For eachair temperaturegenerated,constructa graphof probeheatingsystemsettingversusprobe
outlet temperature.The procedureoutlinedin APTD-0576canalsobe used.Probesconstructed
accordingto APTD-0581neednot be calibratedif the calibrationcurvesin APTD-0576 are
used.Also, probeswith outlet temperaturemonitoringcapabilitiesdo not requirecalibration.
5.5 TemperatureGauges.Use the procedurein Section4.3 of Method 2 to calibratein-stack
temperaturegauges.Dial thermometers,suchasare usedfor the dry gasmeter and condenseroutlet,
shallbe calibratedagainstmercury-in-glassthermometers.
5.6 Leak Checkof Metering SystemShownin Figure 5-l. That portion of the samplingtrain
from the pump to the orifice meter shouldbe leakcheckedprior to initial useand after each
shipment. Leakageafter the pump will result in lessvolumebeingrecordedthan is actually
sampled.The following procedureis suggested(seeFigure 5-4): Closethe main valve on the meter
box. Insert a one-holerubber stopperwith rubbertubing atachedinto the orifice exhaustpipe.
Disconnectandvent the low sideof the orifice manometer.Closeoff the low sideorifice tap.
Pressurizethe systemto 13to 18 cm (5 to 7 in.) water columnby blowing into the rubbertubing.
Pinchoff the tubing andobservethe manometerfor oneminute. A lossof pressureon the
manometerindicatesa leak in the meterbox; leaks,if present,must be corrected.
5.7 Barometer.Calibrateagainsta mercury barometer.
6. Calculations
Carry out calculations,retainingat leastone extradecimalfigure beyondthat of the acquireddata.
Roundoff figures after the final calculation.Other forms of the equationsmay be used
aslong asthey give equivalentresults.
[ Part 60, page750. Figure5-4.1
6.1 Nomenclature.
An=Cross-sectionalareaof nozzle,m2 (ft.2).
Bws=Watervapor in the gasstream,proportionby volume.
Ca=Acetoneblank residueconcentration,mg/mg.
cs=Concentrationof particulatematter in stackgas,dry basis, correctedto standardconditions,
g/dscm(g/dscf).
13
I=Percentof isokineticsampling.
La=Maximum acceptableleakagerate for either a pretestleak checkor for a leak checkfollowing
* a componentchange; equalto 0.00057m3/min (0.02 cfin) or 4 percentof the average
I samplingrate, whicheveris less.
Li=Individual leakagerate observedduringthe leakcheckconducted prior to the “ith”
componentchange(i=l, 2,3....n), m3/min (cfm).
Lp=Leakagerate observedduringthe post-testleak check,m3/min (cfm).
ma=Massof residueof acetoneafter evaporation,mg.
mn=Total amountof particulatematter collected,mg.
Mw=Molecular weight of water, 18.0 g/g-mole(18.0lb/lb-mole).
Pbar=Barometricpressureat the samplingsite, mm Hg (in. Hg).
Ps=Absolutestackgaspressure,mm Hg (in. Hg).
Pstd=Standardabsolutepressure,760 mm Hg (29.92 in. Hg).
R=Ideal gasconstant,0.06236mm Hg-m3/“K-g-mole (21.85 in. Hg-ft3/“R-lb-mole).
Tm=Absoluteaveragedry gasmetertemperature(seeFigure 5- 2), “K (OR).
Ts=Absoluteaveragestack gastemperature(seeFigure 5-2), “K (OR).
Tstd=Standardabsolutetemperature,293OM (528OR).
Va=Volume of acetoneblank, ml.
Vaw=Volume of acetoneusedin wash,ml.
Vlc=Total volume of liquid collectedin impingersand silica gel (seeFigure 5-3), ml.
Vm=Volume of gassampleasmeasuredby dry gasmeter, dcm (dscf).
Vm(std)=Volumeof gassamplemeasuredby the dry gasmeter, correctedto standardconditions,
dscm (dscf).
Vw(std)=Volume of water vaporin the gassample,correctedto standardconditions,scm (scf).
vs=Stackgasvelocity, calculatedby Method 2, Equation2-9, usingdataobtainedfrom Method 5,
mkec (ftlsec).
Wa=Weight of residuein acetonewash,mg.
Y=Dry gasmeter calibrationfactor.
AH=Averagepressuredifferential acrossthe orifice meter (see Figure 5-2), mm H20 (in. H20).
RHOa=Density of acetone,mg/ml (seelabel on bottle).
RHOw=Density of water, 0.9982g/ml (0.002201lb/ml).
O=Total samplingtime, min.
Ol=Sampling time interval, from the beginningof a run until the first componentchange,min.
@i=Samplingtime interval, betweentwo successivecomponentchanges,beginningwith the
interval betweenthe first and secondchanges,min.
Op=Samplingtime interval,from the final (nth) componentchangeuntiltheendof the samplingn,m,min.
13.6=Specificgravity of mercury.
60=Sec/min.
1OO=Conversion to percent.
6.2 AverageDry GasMeter TemperatureandAverageOrifice PressureDrop. Seedata sheet
(Figure 5-2).
14
6.3 Dry GasVolume. Correct the samplevolumemeasuredby the dry gasmeter to standard
conditions(20” C, 760 mm Hg or 68’ F, 29.92in. Hg) by usingEquation5-1.
Tstd ( Pbar+AH / 13.6)

Vm(std) = VmY (-)
Tm Pstd
Pbar+ (AH / 13.6)

=KlVmY
Tm
Equation5-1
Where;
K1=0.3858“K/mm Hg for metric units
=17.64 “R/in. Hg for Englishunits
Note: Equation5-l canbe usedaswritten unlessthe leakagerate observedduring any of the

mandatoryleakchecks(i.e., the post-testleakcheckor leak checksconductedprior to component
changes)exceedsLa. If Lp or i exceedsLa, Equation5-l must be modified asfollows:
(a) CaseI. No componentchangesmadeduring samplingrun.
In this case,replaceVm in Equation5-l with the expression:
wm-(LP-La)@1
(b) CaseII. Oneor more componentchangesmadeduringthe samplingrun. In this case,replace
Vm in Equation5-l by the expression:
n
Vm - (Ll-La)01 - C @J-La)01- (Lp La)Qp 1
I=2
and substituteonly for thoseleakagerates(Li or Lp) which exceedLa.
6.4 Volumeof WaterVapor.
Vlc RHOw R Tstd

Vw(std) = =K2Vlc
Mw Pstd
Eq. 5-2
Where:
K2=0.001333m3/ml for metric units=0.04707ft3/rnl for Englishunits.
15
6.5 Moisture Content.
VW (std)
Bws = Eq. 5-3
Vm (std)+Vw(std)
Note: In saturatedor water droplet-ladengasstreams,two calculationsof the moisture contentof

the stackgasshallbe made,onefrom the impinger analysis(Equation5-3), anda secondfrom the
assumptionof saturatedconditions.The lower of the two valuesof Bws shallbe consideredcorrect.
The procedurefor determiningthe moisturecontentbasedupon assumptionof saturatedconditions
is given in the Note of Section1.2 of Method 4. For the purposesof this method,the averagestack
gastemperaturefrom Figure5-2 may be usedto make this determination,providedthat the accuracy
of the in-stacktemperaturesensoris f lo C (2 OF).
6.6 AcetoneBlank Concentration.
ma
Ca =
Va RHOa Eq. 5-4
6.7 AcetoneWashBlank.
Wa = Ca Vaw RHOa Eq. 5-5
6.8 Total ParticulateWeight. Determinethe total particulatecatchfrom the sum of the weights
obtainedfrom Containers1 and2 lessthe acetoneblank (seeFigure 5-3).
Note: Refer to Section4.1.5 to assistin calculationof resultsinvolving two or more filter

assembliesor two or more samplingtrains.
6.9 ParticulateConcentration.
cs=(O.OOlg/mg) (mn/Vm (std))

Eq. 5-6
16
6.10 ConversionFactors:
From To Multiply by
scf....................... m3.................. 0.02832.

mg.. ...................... 0.001
$33
.............................................. grm.. .................. 15.43.
gKt3 ..................... lb/ft3.. .................. 2.205X101-3.
g/j?3..................... g/m3...................... 35.31.
6.11 IsokineticVariation.
6.11.1CalculationFrom Raw Data.
100Ts[K3Vlc+(Vm Y/Tm)(Pbar+GI/13.6)]
I= Eq. 5-7
600~s PsAn
Where:
K3=0.003454mm Hg-m3/ml- “K for metric units. =0.002669-m Hg-ft3/mI-“R for Englishunits.
6.11.2 CalculationFrom IntermediateValues.
100Ts Vm(std) Pstd

I=
60 Tstd Vs 0 An Ps (1-Bws)
K4 Ts Vm(std)
=
PsVs An 0 (1-Bws)
Eq. 5-8
where:
K4=4.320for metric units=O.O9450
for Englishunits.
6.12 AcceptableResults.If 90 percent2 I .S110percent,the resultsare acceptable.If the

particulaterest& arelow in comparisonto the standard,andI is over 110percentor lessthan 90
percent,the Administratormay acceptthe results.Citation 4 in the bibliographysectioncanbe used
to makeacceptabilityjudgments.If I is judgedto be unacceptable,reject the particulate
resultsandrepeatthe test.
17
6.13 StackGasVelocity andVolumetric Flow Rate. Calculatethe averagestackgasvelocity and
volumetric flow rate, if needed,usingdataobtainedin this methodandthe equationsin Sections5.2
and 5.3 of Method 2.
7. AlternativeProcedures
7.1 Dry GasMeter asa CalibrationStandard.A dry gasmeter may be usedasa calibration
standardfor volume measurements in placeof the wet test meter specifiedin Section5.3, provided
that it is calibratedinitially andrecalibratedperiodicallyasfollows:
7.1.1 StandardDry GasMeter Calibration.
7.1.1.1 The dry gasmeter to be calibratedandusedas a secondaryreferencemeter shouldbe of
high quality andhavean appropriatelysizedcapacity,e.g., 3 liters/rev(0.1 fi t 3 /rev). A spirometer
(400 liters or more capacity),or equivalent,may be usedfor this calibration,althougha wet test
meter is usuallymore practical.Thewet test meter shouldhavea capacityof 30 liters/rev (lft t3
/rev) andcapableof measuringvolumeto within &l .Opercent;wet test metersshouldbe checked
againsta spirometeror a liquid displacementmeterto ensurethe accuracyof the wet test meter.
Spirometersor wet test metersof other sizesmay be used,providedthat the specifiedaccuraciesof
the procedurearemaintained.
7.1.1.2 Setup the componentsasshownin Figure 5.7. A spirometer,or equivalent,may be used
in placeof the wet test meter in the system.Run the pump for at least5 minutesat a flow rateof
about 10 liter&in (0.35 cfin) to conditionthe interior surfaceof the wet test meter.The pressure
drop indicatedby the manometerat the inlet sideof the dry gasmeter shouldbe minimized [no
greaterthan 100mm H20 (4 in. H20) at a flow rate of 30 liter&in (1 cfin)]. This canbe
accomplishedby usinglargediametertubing connectionsand straightpipe fittings.
[ Part 60, page753. Figure5-71
7.1.1.3 Collect the dataasshownin the exampledatasheet(seeFigure5-S).Make triplicate

runs at eachof the flow ratesandat no lessthan five different flow rates.The rangeof flow rates
shouldbe between10 and34 literslmin (0.35 and 1.2 cfm) or overthe expectedoperatingrange.
[ Part 60, page754. Figure 5-8.1
7.1.1.4 Calculateflow rate, Q, for eachrun usingthe wet test meter gasvolume, VW, andthe IUI
time, 0. Calculatethe dry gasmetercoefficient, Yds, for eachrun. Thesecalculationsare as
follows:
Pbar VW
Q=Kl
tw+tstd 0
VW (tds+tstd) Pbar
Yds =
Vds (tw+tstd) (Pbar+ -1

13.6
Where:
Kl=O.3858for internationalsystemof units (SI); 17.64for Englishunits.
Vw==Wettest meter volume, liters (fi3).
18
Vds=Dry gasmeter volume,liters (ft3).
tds=Averagedry gasmetertemperature,“C (OF).
tstd=273OC for SI units; 460o F for Englishunits.
tw=Averagewet test metertemperature,“C (OF).
Pbar=Barometricpressure,mm Hg (in. Hg).
~p=Dry gasmeter inlet d‘ff
i erentialpressure,mm I-I20 (in. H20).
Q=Run time, min.
7.1.1.5 Comparethe threeYds valuesat eachof the flow ratesanddeterminethe maximum and
minimum values.The differencebetweenthe maximumandminimum valuesat eachflow rate
shouldbe no greaterthan 0.030.Extra setsof triplicate runs may be madein orderto completethis
requirement.In addition,the meter coefficientsshouldbe between0.95 and 1.05.If these
specificationscannotbe met in three setsof successivetriplicate runs,the meter is not suitableasa
calibrationstandardand shouldnot be usedassuch.If thesespecificationsare met, averagethe three
Yds valuesat eachflow rate resultingin five averagemeter coefficients,Yds.
7.1.1.6 Preparea curveof meter coefficient, Yds, versusflow rate, Q, for the dry gasmeter. This
curve shallbeusedas a referencewhenthe meter is usedto calibrateother dry gasmetersandto
determinewhetherrecalibrationis required.
7.1.2 StandardDry GasMeter Recalibration.
7.1.2.1 Recalibratethe standarddry gasmeter againsta wet test meter or spirometerannuallyor
after every 200hoursof operation,whichevercomesfirst. This requirementis valid providedthe
standarddry gasmeter is kept in a laboratoryand,if transported,caredfor asany other laboratory
instrument.Abuseto the standardmetermay causea changein the calibrationand will requiremore
frequentrecalibrations.
7.1.2.2 As an alternativeto full recalibration,a two-point calibrationcheckmay be made.Follow
the sameprocedureand equipmentarrangementasfor a full recalibration,but run the meter at only
two flow rates [suggestedratesare 14 and28 liters/mm (0.5 and 1.Ocfm)]. Calculatethe meter
coefficientsfor thesetwo points, andcomparethe valueswith the meter calibrationcurve. If the two
coefficientsarewithin *1.5 percentof the calibrationcurvevaluesat the sameflow rates,the
meterneednot be recalibrateduntil the next datefor a recalibrationcheck.
7.2 Critical Orifices As CalibrationStandards.Critical orifices may be usedas calibration

standardsin placeof the wet test meter specifiedin Section5.3, providedthat they are selected,
calibrated,andusedasfollows:
7.2.1 Sectionof Critical Orifices.
7.2-l. 1 The procedurethat follows describesthe useof hypodermicneedlesor stainlesssteel
needletubingswhich havebeenfound suitablefor useascritical orifices. Other materialsand
critical orifice designsmay be usedprovidedthe orifices act astrue critical orifices; i.e., a critical
vacuumcanbe obtained,asdescribedin Section7.2.2.2.3.Selectfive critical orifices that are
appropriatelysizedto coverthe rangeof flow ratesbetween10 and34 liters/min or the expected
operatingrange.Two of the critical orifices shouldbracketthe expectedoperatingrange.
A minimum of three critical orifices will be neededto calibratea Method 5 dry gas meter @GM);
the othertwo critical orificescan serveassparesandprovidebetter selectionfor bracketing
the rangeof operatingflow rates.The needlesizesandtubing lengthsshownbelow give the
following approximateflow rates:
19
I Flow rate Flow rate
Gauge/cm (liters/mm) Gauge/cm (liters/ min)
1217.6 32.56 1412.5 19.54

12/10.2 30.02 14/5.1 17.27
1312.5 25.77 14/7.6 16.14
13/5.1 23.50 15/3.2 14.16
13/7.6 22.37 15M.6 11.61
13i10.2 20.67 15/10.2 10.48
7.2.1.2 Theseneedlescanbe adaptedto a Method 5 type samplingtrain asfollows: Insert a

serumbottle stopper,13- by 20-mm sleevetype, into a l/2-inch Swagelokquick connect.Insert
the needleinto the stopperasshownin Figure5-9.
[ Part 60, page756.Figure 5-9. ]

7.2.2 Critical Orifice Calibration.Theproceduredescribedin this sectionusesthe Method 5
meter box configurationwith a DGM asdescribedin Section2.1.8 to calibratethe critical orifices.
Other schemesmay be used,subjectto the approvalof the Administrator.
7.2.2.1 Calibrationof Meter Box. The critical orifices must be calibratedin the same
configurationasthey will be used;i.e., there shouldbe no connectionsto the inlet of the orifice.
7.2.2.1.1 Before calibratingthe meterbox, leak checkthe systemas follows: Fully openthe
coarseadjustvalve, andcompletelyclosethe by-passvalve. Plugthe inlet. Thentrun on the pump,
anddeterminewhetherthere is any leakage.The leakagerate shallbe zero; i.e., no detectable
movementof the DGM dial shallbe seenfor 1 minute.
7.2.2.1.2 Checkalsofor leakagesin that portion of the samplingtrain betweenthe pump andthe
orifice meter. SeeSection5.6 for the procedure;make any corrections,if necessary.If leakageis
detected,checkfor crackedgaskets,loosefittings, worn O-rings, etc., andmakethe necessary
repairs.
7.2.2.1.3 After determiningthat the meterbox is leakless,calibratethe meter box accordingto the
proceduregiven in Section5.3. Make surethat the wet test metermeetsthe requirementsstatedin
Section7.1.1.1. Checkthe water level in the wet test meter. Recordthe DGM calibrationfactor, Y.
7.2.2.2 Calibrationof Critical Orifices. Setup the apparatusas shownin Figure 5-10.
[ Part 60, page757.Figure 5-10.1
7.2.2.2.1 Allow a warm-up time of 15minutes.This stepis importantto equilibratethe

temperatureconditionsthroughthe DGM.
7.2.2.2.2 Leak checkthe systemasin Section7.2.2.1.1.The leakagerate shallbe zero.
7.2.2.2.3 Before calibratingthe critical orifice, determineits suitability andthe appropriate
operatingvacuumasfollows: Turn on the pump, fully openthe coarseadjustvalve, andadjust
the by-passvalve to give a vacuumreadingcorrespondingto abouthalf of atmosphericpressure.
Observethe meter box orifice manometerreading,H. Slowly increasethe vacuumreadinguntil
a stablereadingis obtainedon the meterbox orifice manometer.Recordthe critical vacuumfor
eachorifice. Orifices that do not reacha critical value shallnot be used.
20
7.2.2.2.4 Obtainthe barometricpressureusinga barometerasdescribedin Section2.1.9. Record
the barometricpressure,Pbar,in mm Hg (in. Hg).
7.2.2.2.5 Conductduplicateruns at a vacuumof 25 to 50 mm Hg (1 to 2 in. Hg) abovethe
critical vacuum.The runs shallbe at least 5 minuteseach.The DGM volume readingsshallbe in
incrementsof 0.00283m3 (0.1 ft3) or in incrementsof completerevolutionsof the DGM. As a
guideline,the times shouldnot differ by more than 3.0 seconds(this includesallowancefor
changesin the DGM temperatures)to achievef 0.5 percentin K’. Recordthe information listed in
Figure5-l 1.
7.2.2.2.6 CalculateK’ usingEquation5-9.
KlVmY (Pbar+AW13.6)\/ Tamb

K’ = Eq. 5-9
PbarTmO
Where:
(m3)(“K)I l/2 i (ft3)(“R)t l/2

K = Critical orifice coefficient,
(mm- Hg) (min) IL(in. W (min>
Tamb=Absoluteambienttemperature,“K (OR).
Averagethe K’ values.The individualK’ valuesshouldnot differ by more than *to.5 percentfrom
the average.
7.2.3 Using the Critical Orifices as CalibrationStandards.
7.2.3.1 Recordthe barometricpressure.
21
Date Train ID DGM cal. factor Critical orifice ID -
Dry gasmeter
‘I Run number
I 1
I
2
Final reading....................... m3 (ft3). .....................

Initial reading..................... m3 (ft3). ........................
Difference,Vm ...................... m3 (ft3). .......................
Inlet/Outlet temperatures:
Initial ............................ “C (OF)................. I ... .... .. . I
Final.............................. “C (OF)................. I ......... I
Avg. Temperature,tm ............... “C (OF)...................... ..........
Time, 0 ............................. minlsec.............. .I ........ I
min.......................... . . . . . ..*.1
Orifice man. rdg., AH .............. mm (in.) H20 ..................

Bar. pressure,Pbar................. mm (in.) Hg.. .................... . . . . . ...*.
Ambient temperature,tamb........... “C (OF).............................. . . .. .. .. . . .. .
Pumpvacuum......................... mm (in.) Hg.. ................... . . . . . . . . . . . .
K factor........................... . . . . . . . . . .. . . .. . . . . . . . . . . . ..‘..............
Average...........................
Figure 5-11.Data sheetfor determiningK’ factor.
7.2.3.2 Calibratethe meteringsystemaccordingto the procedureoutlined

in Sections7.2.2.2.1to 7.2.2.2.5.Recordthe information listed in Figure5.12.
7.2.3.3 Calculatethe standardvolumesof air passedthroughthe DGM andthe critical orifices,
and calculatethe DGM calibrationfactor, Y, usingthe equationsbelow:
Pbar+(N13.6)
Vm(std) = Kl Vm Eq. 5-10
Tm
Pbar@
Vcr(std)=K’ Eq. 5-l 1
d Tamb
Vcr(std)
Y= Eq. 5-12
Vm(std)
where:
Vcr(std)=Volumeof gassamplepassedthroughthe critical orifice, correctedto standardconditions,
i dsm3 (dscf).
K1=0.3858 “K/mm Hg for metric units =17.64 “R/in. Hg for Englishunits.
22
7.2.3.4 Averagethe DGM calibrationvaluesfor eachof the flow rates.The calibrationfactor, Y,
at eachof the flow ratesshouldnot differ by morethan rt2 percentfrom the average.
7.2.3.5 To determinethe needfor recalibratingthe critical orifices, comparethe DGM Y factors
obtainedfrom two adjacentorifices eachtime a DGM is calibrated;for example,when checking
13/2.5,useorifices 12/10.2and 13E.l. If any critical orifice yields a DGM Y factor differing by
more than 2 percentfrom the others,recalibratethe critical orifice accordingto Section7.2.2.2.
Date Train ID Critical orifice ID Critical orifice K’ factor
Dry gasmeter
‘I \ Runnumber
I
I I II 1
Final reading............................ m3 (IU)..... ...... .........

Initial reading.......................... m3 (ft3)..... ...... .........
Difference, Vm.. ......................... m3 (ft3)..... ...... .........
Inlet/outlet temperatures:
Initial ................................. “C (OF)...... I I
Final................................... “C (OF)...... I I I
Avg. Temperature,tm.. .................. “C (OF)...... ...... .........
Time, 8 .................................. minlsec...... I I
min..... .. .. . ...... I.........
Orifice man. rdg., AH ................... mm (in.) H20. ...... .........
Bar. pressure,Pbar...................... mm (in.) Hg.. ...... I’.........
Ambient temperature,tamb................ “C (OF)...... ...... .........
Pumpvacuum.............................. mm (in.) Hg.. ...... .....f...
Vm(std).................................. m3 (ft3)..... ...... .........
Vcr(std)................................. m3 (ft3)..... ...... .........
I ........
DGM cal. factor, Y.. ..................... ...... .. .. ... ...... .
Figure 5-12. Data sheetfor determiningDGM Y factor.
23
FIGURE 5-3-ANALYTICAL DATA
Plant ___-_-------------------------------------------------------------
Run No .----------------------------------------------------------------
Filter No .-------------------------------------------------------------
Amout liquid lost d&g &mspofi __________ - _________________________
Acetone bl& vo1un-q r& ________________________________________-------
Acetone wash volume, ml------- ______________
--__- ______________________
Acetone blank concentration, mg/mg (Equation 5-4)----------------------
Acetone wash bl&, mg (Equation 5-5)------------------- _______________
Weight of particulate collected, mg
Total.. ... ................. .. ........................
Less acetone blank ... .... ......_......-............. I
Weight of particulate matter .............~..........
Volume of liquid water collected
Impinger volume, ml Silica gel weight, g
Final ........................
Initial.. ....................
Liquid collected.. .......
Total volume collecte g* ml
*Convert weight of water to volume by dividing total weight increase by

density of water (1 g/ml).
Increase, g
= Volume water, ml
(1 g/ml)
24
8. Bibliography
1. Addendumto Specificationsfor Incinerator Testingat FederalFacilities.PHS,NCAPC. Dec. 6,

1967.
2. Martin, RobertM. ConstructionDetails of Isokinetic Source-Sampling Equipment.
EnvironmentalProtectionAgency.ResearchTrianglePark,NC. APTD-0581. April 1971.
3. Rom, JeromeJ. Maintenance,Calibration,and Operationof Isokinetic SourceSampling
Equipment.EnvironmentalProtectionAgency. ResearchTrianglePark,NC. APTD-0576.March,
1972.
4. Smith, W. S., R. T. Shigehara,andW. F. Todd. A Method of Interpreting StackSamplingData.
PaperPresentedat the 63d AnnualMeeting of the Air Pollution Control Association,St. Louis, MO,
June14-19,1970.
5. Smith, W. S., et al. StackGasSamplingImproved and SimplifiedWith New Equipment.APCA
PaperNo. 67-l 19. 1967.
6. Specificationsfor IncineratorTestingat FederalFacilities.PHS,NCAPC. 1967.
7. Shigehara,R. T. Adjustmentsin the EPA Nomographfor Different Pitot Tube Coefficientsand
Dry MolecularWeights.StackSamplingNews 2:4-l 1, October, 1974.
8. Vollaro, R. F. A Surveyof CommerciallyAvailableInstrumentationFor the Measurementof
Low-RangeGasVelocities.U.S. EnvironmentalProtectionAgency,EmissionMeasurement
Branch.ResearchTrianglePark,NC. November, 1976(unpublishedpaper).
9. AnnualBook of ASTM Standards.Part 26. GaseousFuels;Coal and Coke; Atmospheric
Analysis.AmericanSocietyfor TestingandMaterials.Philadelphia,PA. 1974.pp. 617-622.
10. Felix, L. G., G. I. Clinard, G. E. Lacey, and J. D. McCain. Inertial CascadeImpactor Substrate
Media for Flue GasSampling.U.S. EnvironmentalProtectionAgency.ResearchTrianglePark,
NC 27711,PublicationNo. EPA-600/7-77-060.June1977.83p.
11. Westlin, P. R. andR. T. Shigehara.Procedurefor CalibratingandUsing Dry GasVolume
Metersas CalibrationStandards.SourceEvaluationSocietyNewsletter. 3( 1):17-30.February1978.
12.Lodge,J.P.,Jr., J.B. Pate,B.E. Ammons, andG.A. Swanson.TheUse of HypodermicNeedles
as Critical Orifices in Air Sampling.J. Air Pollution Control Association.16:197-200.1966.
25
APPENDIX C Cement Kilns
Visual Emissions Evaluations

Including
Ringelmann Procedures
and
Method 9
Ott 1996 Page C - 1

GELMANN CHART AND EOUIVALENT OPACITY
Division 26, Part 4, Chapter 3, Article 1, Section41701 of the Health and Safety code
of the State of California states:
“.-no person shall discharge into the atmosphere from any source whatsoever any air
contaminant, 0the.rthan uncombined water vapor, for a period or periods aggregating more
than three minutes in any one hour which is:
(a) As dark or darker in shade as that designatedas No. 2 on the Ringehnann

Chart, as published by the United StatesBureau of Mines, or
(b) Of such opacity asto obscurean observer%view to a degreeequalto or greater

than does smoke described in subdivision (a).
.
Ruwelmann Chae
The RingehnaxmChart was one of the first tools used to measure emissions to the
atmosphere(seeattachment). It was developedby Maxim&r Ringelmann in the late 1800’s
( and has been used by almost every industrial nation ever since. The Ringelmann Chart is
-
thoroughly covered in the Bureau of Mines Information Circular No. IC8333 (May 1967).
The Ringelmann Smoke Chart, giving shadesof gray by which the density of columns
of smoke rising from stacks may be compared, was developed by Professor Maximilian
Ringehnann of Paris. Ringlemann, born in 1861, was professor of agricultural engineering
at I’Institute Agronomique and Director de1la Stationd’Essaisde Machines in Paris in 1888,
and held those positions for many years thereafter.
The chart apparently was introduced into the United States by William Kent in an
article published in Engineering News November 11, 1897, with a comment that he had
learned of it in a private communication from a Bryan Donkin of London. It was said to
have come into somewhat extensiveuse in Europe by that time. In 1899, Rent proposedthat
it be acceptedas the standardmeasureof smoke density in the standard code for power plant
testing that was being formulated by the American Society of Mechanical Engineers.
The Ringelmann Chart was used by the engineersor the Technologic Branch of the
U.S. Geological Survey (which later formed the nucleus of the present Bureau of Mines) in
their studies of smokeless combustion beginning at St. Louis in 1904. By 1910 the
Ringelmann Chart had beenrecognized officially in the smoke ordinance for Boston passed
‘..-- _ by the MassachusettsLegislature.
The chart is now used as a device for determining whether emissions of smoke are
within establishedlimits or standardsof permissibility (statutes and ordinances) expressed
with reference to the chart. It is widely used by law-enforcement or compliance officers in
jurisdictions that have adopted standardsbasedupon the chart.
;DescriDtion and Method of PreDarinp the Chart
The Ringelmann system is a schemewhereby graduated shadesof gray, varying by

five equal steps between white and black, may be accurately reproduced by means of
rectangular grid of black lines of definite width and spacing on a white background.
Professor Ringelmann establishedthe following rule for reproducing the chart:
Card0 - All white.

Card1 - Black lines 1 mm thick, 10 mm apart, leaving white spaces 9 mm
square.
Card2 - Lines 2.3 mm thick, spaces7.7 mm square.
Card5 - All black.
The chart, as distributed by the Bureau of Mines, provides the shadesof Cards 1,2,
3, and 4 on a single sheet,which are know as Ringelmann No. 1,2,3, and 4, respectively.
Additional copies of the chart may be obtained free by applying to the Publications
Distribution Branch, Bureau of Mines, 4800 Forbes Avenue, Pittsburgh, Pennsylvania,
15213.
Use of Chart
Many municipal, State, and federal regulations prescribe smoke density limits based
on the Ringelmann Smoke Chart, aspublishedby the Bureau of Mines. Although the chart
was not originally designedfor regulatory purposes, it is presently used for this purpose in
many jurisdictions where the results obtained are acceptedas legal evidence.
While the chart still serves a useful purpose, it should be remembered that the data
obtainedby its use is empirical in nature and has definite limitations. The apparent darkness
or opacity of a stack plume dependsupon the concentration of the particulate matter in the
effluent, the size of the particulate, the depth of the smoke column being viewed, natural
lighting conditions (such as the direction of the sun relative to the observer), and the color
of the particles. Since unburned carbon is a principal coloring material in a smoke column
from a furnace using coal or oil, the relative shadeis a fimction of the combustion efficiency.
i”
i While the Ringelmann Smoke Chart has many limitations, it gives good practical
results in the hands of well-trained operators. However, it is questionable whether results
should be expressedin fractional units becauseof variations in physical conditions and in the
judgement of the observers.
To use, the chart is supported at eye level in line with the stack, at such a distance
from the observerthat the lines on the chart merge into shadesof gray. The observer glances
fkom the smoke to the chart and notes the number of the chart most nearly corresponding
with the shade of the smoke. The observer then records this number with the time of
observation. A clear stack is recorded as No. 0, and 100 percent black smoke as No. 5.
Eauivalent ODacitv
Becausethe Ringelmann Chart is only useful in evaluatingblack or gray emissions,

a principle of equivalent opacity was developedlater which makes possible the application
of the Ringelmann principle to other colors of smoke.
One of the first appearancesof this conceptwas in the air pollution control ordinances
of the County of Los Angeles in 1945. In 1947 the Health and Safety Code of the State of
California was amended to provide for the establishment of country-wide air pollution
control districts. As already statedone section of this act limits visible emissions for a given
period of time, not only to Ringehnann No. 2 shadeof gray but also any visible emission of
such opacity asto obscurean observersview to a degreeequalto or greater than Ringelmann
No. 2 Opacity simply means the degree to which transmitted light is obscured. Thus it is
mandatory for any air pollution control district in California formed under this law to use the
equivalent opacity concept.
Below is the relationship between Ringelmann number and opacity.
ECingelmannNumber Opacity Percent I
60
3
Advantages
Some of the advantages of the use of visible emission control regulations by air
pollution control districts are:
1. The validity of using the Ringelmann Chart and equivalent opacity concepthas
beenestablishedin the field of air pollution control legislation and the courts.
2. Observers can be trained in a relatively short time (24 to 32 hours) and it is not
necessarythat they have an extensive technical background.
3. No expensive equipment is required.
4. One person can make many observationsper day.
5. Violators can be cited without resorting to expensive time consuming source

testing.
6. Questionable emissions cm be located and the actual emissions then

determined by source tests.
7. It is usually not possibleto quan@ the reduction in total air pollution by the
control of visible emissions. However, it is reasonableto assumethat there
will be a reduction in the discharge of dusts, gases, and mists to the
atmosphere.
8. Control can be achieved for those operations not readily suitable to regular
source testing methods. Examples are teepeeburners for lumber mill waste,
dust and other leakagefrom processequipment,visible automobile and aircraft
exhaust,and bulk loading or unloadingof dusty materials such as grains, ores,
coal, etc.
4
AIDS FOR VISIBLE EMISSION EVALUATION
A number of smoke reading aids have been developed to assist in evaluating the
density of visible emissions. These aids include smoke charts, tinted glass or film
comparators, telephotometers, transmissometers, photography and laser techniques.
Smoke Char@
The various smoke chartsthat havebeendevelopedwork in the Ringelmann principle,

comparing shadesof gray printed on paper, with the source emissions. They are simply
smaller, hand held Ringelmann charts, and can be used to evaluate shadesof gray or black
only.
ComDarat0x-q
The comparatorsthat havebeendevelopedinclude the smokescope,smoke tintometer

and umbrascope. The umbrascope and tintometer use tinted glass for comparison. The
smokescopeusesa Clm’disc mounted in a device resembling a set of binoculars. The smoke
is viewed through an eyepieceof the smokescopeand matched to the smoke density shown
in the other eyepiece. This device is said to minimize the problems with variations in
ambient lighting and those resulting when the observermust refocus his eyes from the chart
to the source. One disadvantage of this device is that the film discs represent only
Ringelmann number 2 and number 3.
A film strip comprised of films of densities 20,40,60, and 80 percent transmission,

has been developedby the Public Health Service and is identified as a smoke inspection
guide. The inspector views the source emission through the film strip and matches it as
closely aspossible with one of the densities on the guide.
White smoke comparators might be developed consisting of small cells containing

liquid suspensionsof fine opaqueparticles of different concentrations and sizes.
A telephotometer is used to measure the intensity of light from a source.

Telephotometers can be used to evaluate the transmittance of plume, even when light
( scattering from other sources is present.
L, 2
5
One type of telephotometer can be usedto measurethe transmittance of a plune by
measuring the luminance (candles/squaremeter) difference between a pair of contrasting
targets through the plume (BY-B’Z) and clear of the plume (B 1-BZ). The transmittance is
calculated from the relationship:
T=B’l-B’2
Bl-B2
A secondtype of telephotometer requires only two measurementsto obtain the plume

transmittance. The instrument is calibrated by measuring the background luminance clear
of the plume. The 1uminance of the same background through the plume is then measured.
The transmittance of the plume is displayed in the telephotometer. This type of
telephotometer must be frequently recalibrated to correct for changes in the background
luminance.
A hand held device similar to a telephotometer has been developed for determining
plume transmittance by viewing a light sourcethrough the plume. The light source must be
several orders of magnitude brighter than the surroundings. During the day, the sun is
normally used; at night a bright artificial light source is used. Plume transmittance is
indicated from the luminance difference of the light source viewed through the plume and
viewed clear of the plume.
There are someproblems in using this device. The device will not work if the day is
even slightly overcast. In test comparison with an in-stack transmissometer, the opacities
measuredby this device did not correlatewell with thosemeasuredwith the transmissometer.
Photomanhv
Photography can be used to evaluateplume transmittanceby placing filters alongside

of the camera film plane so that a ciaibration scale is superimposedon the negative. The
camera is oriented to position the filters in the negative. The camera is oriented to position
the filters in the brightest part of the scenewhen taking the photograph. A calibration curve
is obtained from the filter image on the photograph negative. The negative density of the
filter image is plotted againstthe known filter density (seefigure 1). Then by measuring the
densities, on the negative, of contrasting targets through and clear the curve. A densitometer
was used to measurenegative densities. The transmittance of the plume is then determined
by the same relationship used for the telephotometer.
6
Laser Techniaueq
From Appendix A of 40 CFR Part 60, Alternate Method 1 to Reference Method 9 of

Federal Register:
“Lidar, an acronym for Light Detection and Ranging, was first applied to
meteorological monitoring in 1963. Since that time lidar has been developed as a
measurementtechnique for plume opacity, and today is approved as an alternate to
ReferenceMethod 9 which employs visible emission observers.
Lidar contains its own unique light source (a laser transmitter which enables
a short pulse of light) which enables it to measurethe opacity of stationary source
emissions during both day-and nighttime ambient lighting conditions. The optical
receiver within the lidar collects the laser light backscatters (reflected) from the
atmosphericaerosolsbefore and beyond the visible plume as well as those from the
aerosols @articulates) within the plume. The receiver’s detector converts the
backscatteroptical signal into an electronic signal. Plume opacity is calculated from
the backscatter signal data obtained Tom just before and beyond the plume.”
Backscatteris defined as the scattering of laser light in a direction opposite to that of

the incident laser beam due to reflection from particulate along the beams atmospheric path
which may include a smoke plume.
CaDabiIitieq
The Iidar unit includes an automatic horizontal stepping function, enabling it to make
a horizontal scan across the emission points of known sources of pollution. Scansof this
type have revealed additional source of visible emissionsat night.
The lidar is additionally capablethrough vertical scanning,of drawing cross sectional

views of particular plumes. Severalyears ago, Stanford ResearchInstitute conducted a study
at the Ranch0 SecoNuclear Generating Station in which the lidar drew cross sections of a
plume created by a large smoke generator. The experiment attempted to show where
radioactive materials would touch ground in the event of an accidental release at the plant.
When directed skyward, the lidar can also measurethe height of the inversion layer.
With the truck in motion, the unit can be fried by an odometertriggered mechanism and the
Iidar can map plume dispersion and inversion layer heights.
7
Advantapes of Lidar
1. Versatility of function
2. Precision of opacity readings
3. Useful for calibrating in-stack transmissometers
4. Need not comply with all visible opacity reading constraints applicable to subjective
evaluation as enumerated by the Enviromnental Protection Agency Method 9.
5. Readings can be made at night.
6. Mobile
7. Readings can be made from many kilometers away.
pisadvantapes of the Lidar
1. The plume must be at a range of at least 50 metersor three consecutivepick intervals

(whichever is greater) from the lidar’stransmitter/receiverconvergencedistancealong
the line of sight. Pick interval is defined as the time or range intervals in the lidar
backscatter signal whose minimum averageamplitude is usedto calculate opacity.
2. Requires clear air behind the plume.
3. Potential eye damage ifbeam is viewed directly even from a considerable distance.
4. Unable to quantitatively distinguish between water droplets and particulate matter.
5. Cost estimates in excessof $100,000.
6. Cost estimates for maintenance/operationare yet undermined.
Transmissometers
Many permanently installed, m-stack devices are commercially available to

continuously monitor and record emission transmittance. Some are designed to set off an
alarm to warn operatingpersonnelwhen transmittancereachesa presetlevel. Others indicate
the transmittance on a meter or record it on strip paper.
Most of these devices use either a light sourcephotocell combination to measure the
transmission of light through the plume or remove a sample of plume and measure the
transmissionthrough this sample. One problem with the light source-photocell system is that
both the light source and photocell deteriorate and require frequent recalibration. Ifthe light
transmissions of a sample is measured, it is frequently difficult, especially under varying
conditions, to obtain a representative sample.
The bolometer is another device availablethat usesthe same general principal as the
light source-photocell. This device measuresthe resistancechangeacross a filament which
is proportional to the light that is transmitted through the emission.
According to the manufacturer the main advantageof the bolometer over the light
8
source-photocellsystem is that the bolometer components do not age as rapidly. The device
thus does not require as frequent recalibration.
Other systems are now available that include automatic recalibration features and
sophisticated optical system for more accurate results.
Starlbht Scone
One tool which the Air Resources Board staff has been using recently for opacity
observation during hours of darknessis the “Starlight Scope”.
This instrument was developed for military purposes and is now available
commercially. Starlight Scopes are available for loan for law enforcement purposes.
Districts wishing to borrow a Starlight Scopemay contact the Compliance Division of the
Air Resources Board. This Division will coordinate the arrangements for the loan. Air
pollution control personnel wishing to use the Starlight Scope for visible emissions
evaluations must, of course, become certified in its use.
The Starlight Scopecombinesthe capability of a telescopeto magnify an image with

the electronic capability to amplify available light. Becauseof its weight, and to minim&
vibration, the effects of which are magnified, it is recommended that the scope be mounted
on a tripod. adaptors are available which enablesa videotape camera to be attached to the
scope for a historical record of visible emissions.
Although the scopeincorporatesan automatic shutter closing mechanism designedto

protect the viewer from eye damage,caution should still be exercised. The amplification of
ambient or artificial light of even moderate brightness may be harmful to the eye of the
observer.
a:
9
CONSTRUCTION AND OPERATION
m
SMOKE GENERATOR
In order to train personnel to read smoke, it is necessaryto have a unit which will
produce both black and white smoke and an instrument to measurethe transmission of light
through this smoke (see attached Figures). For this purpose the smoke generator was
developed. The smoke generatorthat the Air ResourcesBoard is currently using is mounted
on a trailer for portability. This unit includes the following systems:
SMOKE SYm
White smoke is createdby vaporizing fuel oil in the exhaustpipe of a small gasoline
engine. Smoke density is varied by adjusting the feed rate of the fiel oil. This system is
capable of producing equivalent opacities ranging Corn zero to one hundred percent.
Transmbometer
I u1
ii=
Exhaust Stack
Manifold
pump
l
I I 3
Fuel Oil
Storage
White Smoke Generating Equipment

BLACK SMOKE SYSTEM
i
Black smoke is createdby burning toluene in an insulated,twelve cubic foot stainless

steel combustion chamber. Incomplete combustion is accomplished by not introducing
sufficient excessair. Density of the smoke is varied by adjusting the toluene flow rate. A
secondary chamber is provided for further gas cooling. An induced-draft fan provides
adequateplume exit velocity. This system is capableof producing black smoke ranging fi-om
zero to Ringelmann number five rating.
Transmissometer I
I
d
Stack
‘nducT.i~Drm
_I
c. Ii
(
\
1
Toluene Storage
Black Smoke Generating Equipment

TRANSMISSOMETER SYSTEM
The transmissometer consists of mainly a light source and photocell combination.

The light source is aimed at the receiving photocell and through the smoke plume being
produced. The percent opacity is indicated by both an opacity meter and display on a strip
chart recorder which has been calibrated for values of zero to Ringehnann number five and
equivalent opacity. The light to photocell path is approximately four feet in length, but only
one foot (diameter of the smoke stack) is exposedto the smoke. The remaining three feet are
continually flushed with ambient air to prevent smoke build-up. The apparatusis calibrated
using neutral density filters.
smoke stops
lght Sour d
F
FtXi
. Transmissometer
12
READING AND RECORDING TECHNIOUES
Visible Emission Evaluation Training Form
A sample“Visible Emission Evaluation Training Form” is included. A similar form

will be usedto make 50 successivereadings of smoke from the smoke generator. Half of the
readingswill be on black or gray smoke. The other half will be on white smoke. Black or
gray smoke is to be recorded in FGngehnannnumbers to the nearestone-quarter unit. White
smoke is to be recorded in percent opacity to the nearest five percent.
The training form is filled out similar to the attached sample, with appropriate
information included at the top. After each 25 readings have been made, the observer’s
readings are compared with readings fi-om the transmissometer. To qualify as a visible
emission evaluator,two conditions must be met. First, no single reading may deviate by an
amount greater than 3/4 Ringelmann number of 15 percent opacity. Second, the average
deviation must not exceed7.5 percent for each set of 25 readings. Qualification is based on
50 consecutivereadings: half of which are black or gray, and half of which are white.
When theserequirements have been met the following entries should be made:
i”
!.
1. Sign the form
2. Wiid and sky conditions
3. Box-in statistical conditions
#teadinp Techniaues
1. Black smokeis read in densitiesand recorded in the appropriateRingehnann numbers

and fractions (one-quarter increments).
2 Other colored emissionare read in opacitiesand recorded in percentages(five percent

increments).
3 Opacities are related to corresponding densities on the Ringelmann Chart in the

following manner.
4. The observershould be positioned at a distance sufficient to provide a clear view of

the emissions,generally at least three stack heightsbut not more than one quarter mile
distance.
5. The light source(sun) should be oriented within a 140 degreesector to the observer’s
(\, back during dayhght hours.
13
6. The light source may be behind the plume during hours of darkness (transmitted
light).
7. Readingsshould be made approximately at right angles to wind direction.
8. Observations should be made at the point of greatest opacity in that portion of the
plume where condensedwater vapor is not present
Recordiw TechniaueS (field observations)
1. All appropriate information should be recorded in the appropriate space on the

reporting form (see attached Visible Emissions-Field Evaluation Form).
2. Observations times may be noted in terms of minutes and quarter minutes.
3. Record all emission during observation, showing reading and duration in consecutive
order.
4. Total only that time exceeding the Ringelmann number or opacity specified in the
standard.
5. Color of visible emissions should be recorded as seenand as it changes.
6. A Notice of Violation should not be issued unlessthe duration of smoke exceeding

the standardwas substantially greater than the duration specified in the standard. For
example, if the duration in the standard is three minutes a violation should not be
issued. A violation should only be issued if four or more minutes of violation has
beenreported.
7. Any hour means any consecutive 60 minute period.
8. Photographsshould be taken before or after but not during observation.
9. The same general rules apply to reading emissionsfrom moving sources.
Readiw Techniaues SDecificallv AmIicable to Abrasive Blasting
On September 22, 1974, air pollution standardsspecifically applicable to abrasive

blasting operations went into effect throughout California The standards specify that
applicablevisible emissionregulations for abrasiveblasting must be evaluated in accordance
14
with the following evaluation techniques:
09 Emission shall be read in opacities and recorded in percentages.

@> The light source should be at the rear of observer during daylight hours.
w The light source should be behind the emission during hours of darkness.
(d) Observerposition should be approximately right anglesto wind direction, and
at a distanceno lessthan twice the height of the source but not more than one-
quarter of a mile from the base of the source.
(e> Emissions from unconfined blasting shall be read at the densestpoint of the
emission after a major portion of the spent abrasive has fallen out, at a point
25 feet from the source; provided, however, the emission may be read from a
greaterdistanceif the observerreasonablydeterminesthat the greater distance
will not significantly affect the reading.
(0 Where the presence of uncombined water is the only reason for a failure to
meet the limitations of the visible emissions standard that standard shall not
apply. The burden of proof which establishesthat the standard should not
apply shall be upon the person seeking to some within its provision.
(g) Emissions from unconfined blasting employing multiple nozzles shall be

judged as single sourceunlessit can be demonstratedby the owner or operator
that each nozzle evaluated separately, meets the emission and performance
standardsprovided for in this subchapter.
00 Emissionsfrom confined blasting shall be read at the densestpoint after the air
contaminant leaves the enclosure.
Ringelmann’s Scale for Grading the Density of Smoke
-.
Ringelmann 2. Equivalent to 40% black

Ringelmann 1. Equivalent to 20% black
Ringelmann 3. Equivalent to 60% black T---- _ 1 Ringelmann 4. Equivalent to 80% black

example
16
State of California
Air Resources Board
Visible Emission Evaluation
17
SIBLE EMISSION EVALUATION TRAINING FORM
The sample of the “Visible Emission Evahtation Training Form” is included on the
next page. A similar form will be usedfor making 50 successivereadings of smoke from the
smoke generator. Half of the readingswill be on black or gray smoke. The other half will
be on white smoke. Black or gray smoke is to be recorded in Ringelmann numbers to the
nearestone-quarter unit. White smoke is to be recorded in percent opacity to the nearestfive
percent.
USE OF THE TRAINING FORM
Then use of a Visible Emission Evaluation (‘WE) Training Form for VEE
certification and recertification is to make certain that smoke readers certified by the
California Air Resources Board (CARB) conform to the United States Environmental
Agency’s Method 9 Guidelines ahd the CARB rules. To use this form, make certain that all
lines are completed When taking opacity certification readings, circle the number that you
determine the opacity to be, always making sure that you are on the correct line. If you
would like to changeyour reading, draw a horizontal line across the circle, and then draw a
i circle around your new reading.
When correcting the certification sheet,as the correct opacity reading is announced,
draw a diagonal line through the true reading. From the true reading, count the number of
readings up to and including your circled reading, and write that number on the right hand
side of the sheet. Remember that a number four is equivalent to twenty percent opacity,
which is out if the certification limit
If eachnumber on the right hand side of the sheetis three or less, add all twenty five
readings and write your total in the “Total” block If any number is four or more, or if the
total is thirty-eight or more, discardyour sheetand start your readings on a new sheet. If the
total is thirty-seven or less,multiply the total by decimal point two. This will give you your
correct percentageof error. Then continuethe aboveprocedure for twenty-five consecutive
readings. To certify as a smoke reader, both your black and white percentages of error are
at or below seven point four percent, complete your form and turn it in to your instructor.
18
-z
-v
-PL
STATE OF CALIFORNIA - AIR RESOURCES BOARD

.CO*,“*WCL. VISIBLEEMISSION EVALUATION TRAINING FORM
NAME: DATE /- 5 7.5
l? f;lAr( -yp
AFFIUATION: 43LkaL/Lrn &&pL&i _
BUSINESS ADDRESS: c5?2d%&dd
CI-IY: /h-&%d-y~&&T,TE: Gt..e zip CODE:~56,~~TELEpHONE: ( 9&) ~3~ 3 -/‘%8
DISTANCE & DIRECTION TO STACK SKY CONDITIONS f&y--

WIND SPEED MPH
SIGNATURE WITH SUNGLASSES NO YES 0
o-s
1 hereby ackn&edge that the readings below are my -.
17 I 0 I 5 10 15
18 1 0 1 5 10 15 20 t 25 1 30
‘1 5 20 .I 251<
1. USE PEN ONLY (BLACK INK PREFERED)
2. CIRCLE ONE AXSUER PER LIKE TO INDICATE THE OPACITY OR

RINGELWANN NUMBER THAT YOU HAYE CHDSEB.
3. IF THERE IS AN ERROR OR .YOU HEED ,TD CHAN6E YDUR ANSWER. DRAW A

HORIZONTAL LINE (-) OYER THE URONF; AXKER AHD CIRCLE THE
CORRECT OWE.
.
I.@!65 60 66 70175180 85 90 9511W
4. CALCULATE YOUR DEYIATIDH FOR EACH SET OF 26 READINGS (WHITE OR

BLACK SMOKE).
\
-
LEGEND: 0 - READER’S CIRCLED AKSUER

/ - CDRRECT AXSWER AS, AHNOUNCED BY 6EWERATDR OPESlATOR .
K TOTAL = x -2 - = I TOTAl = x .2 m ==
7. TOTAL f OF DEYIATIDHS FOR THE SET OF 25 READIH6S (XHITE OR BLACK)

=* TOTAL AYC. DEYIATION FOR THE SET OF 25 READIN6S (WHITE OR BLACK)
6. TOTAL AYERA6E DEYIATION CANNOT EXCEED 7.5 FOR A SET OF 25

READIN6S (WHITE OR 3LAtx SMOKE)
6. TOTAL DEYIATION CANNOT EXCEED 37 FOR A SET OF 25 READIN6S

(UHITE OR BIACK SUOKE)
7. NO SIN6LE READING IS ALLOWED A DEYIATION OF 201 OR MORE
8. DO NOT STARE AT THE PLUME
19
-w
?IL. STATE OF CALIFORNIA - AIR RESOURCES BOARD
c .CO*rLl*WCLoVISIBLE EMISSION EVALUATION TRAINING FORM
NAME: DATE:
BUSlNESS ADDRESS:
CITY: STATE: ZIP CODE: TELEPHONE: ( 1
DISTANCE & DIRECTION TO STACK SKY CONDITIONS I

6
WIND SPEED MPH
SIGNATURE WITH SUNGLASSES NO 0 YES a
I hereby acimowledge that the readings below are my own.
RUN NO. TIME
70 175 1 80 85 90 95 11
;t 251'.30 .35 40 45 1501 55 .60
RUN NO. TIME

2 7%
' 2~i 2%
2’hl 3%
I=# lOI’/
‘A H 36 111’hil’A 1 ‘.h 2 2% I 2x141 2% 3’A 3% 13% I 4 4’rG 4n 4% I 5 I 9
1 I 1x/.1 1% 1% 2 2% I 2%) 2% 3 3% 3% I 3% I 4 4% 4'h 4% I 5 I 18
hi
:~ 20 101 ‘A % ?A 1 ) 1 ‘A l’/, 1 ‘A 4% / 5 1 20
“21*;[“0 .I .‘h..*“- H ?4 1 11% 1% 1% 2 2% I2’/2 2% 3 3% 3’h 33k( .4 4% .-4lh,-..431;(.5:.1.‘21. .
.‘:.‘22;:1:{ :(,;I ;*&.-:;-:..y2’ ‘A ,l ) I’,& l’h l’h 2 2% 1 2'h 2% 3 3'A 3?4 3161 4 4% 4’h:+.‘. 4% ‘1 5;(1-22
-::23F...‘/‘0 1 “‘A ?.::‘1,$ ‘A 1 \ 1x1 l’fj 1% 2 2% (2% 2% 3 3% 3% 3x1 4 4% 4% :-r.4ic [ 5 :‘I “23
g;:. 24.;;‘1 -0 1 % I ‘h % 1 (I%( l'h 1% 2 2% [2KI 2% 3 3% 3'/?j 3% 1 4 4% &h.,.&‘(:fj.;1~24
. -25” 1 0 1 % y1 ‘A 1 ) 1x1 11% 1% 2 2X I 2x1 2% 3 3% 3% 13’kl
, , 4 4% 4% -4%. 1 5 j:‘:25
1‘-3 NPY -.?-,I :a,f’:-= -n-t, I

- -- ., ?= ’ TOTAL I
April 1983 1 Section 3.12.0
United States Environmentbl Monitoring Systems

Environmental Protection Laboratory
Agency Research Triangle Park NC 27711
Research and Deveiooment EPA-600/4-77-027b Feb. 1984
&EPA Section 3.12

Method g-visible
Determination of the
Opacity of Emissions from
Stationary .S.ources
Outline
Number
Section Documentation of Pages
Summary 3.12.0 2
Method Highlights 3.12.0 2
Method Description
1. Certification and Training of
Observers 3.12.1 5
2. Procurement of Apparatus and
Supplies 3.12.2
3. Preobservation Operations 3.12.3 :
4. On-Site Field Observations 3.12.4 18
5. Postobservation Operations 3.12.5 2
6. Calculations 3.12.6 7
7. Auditing Procedures 3.12.7 2
8. Refecence.Method. . 3.12.8 5
9. References and Bibliography 3.12-s 1
10. Data Forms 3.12.10 9
Summary
Many stationary sources discharge The appearance of a plume as
plume-shaped visible emissions into viewed by an observer depends upon
the atmosphere. Method 9 (EPA a number of variables, some of which
Reference Method) is used to may be controllable and some of
determine the opacity of this plume by which may not be controllable in the
qualified observers. The method field. Variables which can be
includes procedures for the training controlled to an extent to which they
and certification of observers and no longer exert a significant influence
procedures to be used by these upon plume appearance include:
observers in the field to determine angle of the observer with respect to
plume opacity. This section of the the plume; angle of the observer with
Quality Assurance (DA) Handbook respect to the sun; point of
primarily concerns procedures used by observation of attached and detached
the observers. Only Section 3.12~1 steam plumes and angle of the
reviews the training and certification observer with respect to a plume
procedures, which are described in emitted from a rectangular stack with
Reference 1 a large length to width ratio. The
section 3.12.0 2 April 1983
method includes specific criteria The positive observational error section is to provide a brief summary
applicable to these variables. associated with an average of twenty- of the certification and training
Other variables which may not be five readings is therefore established. procedures described in Reference 1.
controllable in the field are The accuracy of the method must be It includes a definition and a brief
luminescence and color contrast taken into account when determining history of opacity, and it discusses
between the plume and the possible violations of applicable observer training procedures and
background against which the plume opacity standards. certification and recertification of
is viewed. These variables exert an A/ore: Proper application of Method observers.
influence upon the appearance of a 9 by control agency personnel in 2. Procurement of Apparatus and
plume as viewed by an observer, and determining the compliance status of Supplies Section 3.12.2 presents
can affect the ability of the observer sources subject to opacity standards specifications criteria and design
to accurately assign opacity values to often involves a number of features to aid the procurement of
the observed plume. Research studies administrative and technical useful equipment that would provide
of plume opacity have demonstrated procedural steps not specifically good quality visible emissions data.
that a plume is most visible and addressed in the Federal Register The following are some recommended
presents the greatest apparent opacity method. Experience has shown these equipment items not specifically
when viewed against a contrasting steps are necessary to lay a proper required by Method 9: watch.
background. It follows from this, and foundation for any subsequent compass, range finder, Abney level or
is confirmed by field trials, that the enforcement action. To clearly clinometer, sling psychrometer,
opacity of a plume, viewed under delineate items that are EPA. _ binoculars, camera, safety equipment,
conditions where a contrasting procedural policy and requirements of clipboard, and accessories. Table 2.1
background is present can be the Method 9 from additional quality summarizes the quality assurance
assigned with the greatest degree of assurance procedures. a wording aspects of equipment procurement.
accuracy. However, the potential for a scheme was developed. All of
positive error is also the greatest Sections 3.12.1, 3.12.2. 3.12.3, 3. Preobservation Operations
3.7 2.6, and 3.12.7 are suggested Section 3.12.3 summarizes the
when a plume is viewed under such
quality assurance procedures except preobservation activities: gathering
contrasting conditions. Under
where noted as EPA policy or Federal facility information, providing prior
conditions presenting a less
Register citings. Section 3.12.4 notes notification, establishing protocol, and
contrasting background, the apparent
opacity of a plume is less and EPA requirements with directive performing equipment checks. Table
approaches zero as the color and statements using words such as shall, 3.1 summarizes these procedures.
luminescence contrast decrease should, and must. QA procedures are 4. On-Site Field Observations
toward zero. As a result, significant noted either with suggestive Section 3.12.4 contains detailed
negative bias and negative errors can statements using words such as procedures for determining the visible
be made when a plume is viewed recommended, suggested. and emissions WE). This section not only
under less contrasting conditions. A beneficial or by stating that the entire includes the recommended
negative bias decreases rather than subsection is recommended The use procedures for performing the
increases the possibility that a plant of these QA procedures should perimeter survey, plant entry, and VE
operator will be cited for a violation of provide a more consistent program, determination; it also contains a
opacity standards due to observer improved observer effectiveness and subsection on special observation
error. efficiency, and improved data problems. This subsection explains
documentation. how to take VE readings under less
Method 9 is applicable for the
determination of the opacity of Method Highiights than ideal conditions (e.g.. when the
emissions from stationary sources observer position .is restricted). The
Section 3.12 primarily describes. main feature of this section is the
pursuant to 60.1 l(b). Studies have Method 9 procedures for the
been undertaken to determine the presentation of detailed instructions
determination of plume opacity.
magnitude of positive errors that on how to complete the recommended
Section 3.12.1 briefly reviews the
qualified observers can make while VE data form, and examples of
quality assurance procedures to be
reading plumes under contrasting completed forms.
used in the observer training and
conditions and using the procedures certification procedures described in 5. Postobservation Operations.
specified in Method 9. The results of detail in Reference 1. The remaining Section 3112.5 presents a brief
these studies, which involve a total of sections describe the field procedures. discussion concerning the data
769 sets of 25 readings each, are as Section 3.12.10 provides blank data reporting procedures, data summary,
follows: forms recommended for use by the data validation, and equipment check.
observer and other personnel. as Section 3.12.6 contains a discussion
1. In the case of black plumes, 100 required. Partially completed forms, of the calculations required for
percent of the sets were read are inciuded in Sections 3.t 2.1 completing the data forms and
with positive error of less than through 3.12.7 of the Method reports. It also includes procedures for
7.5 percent opacity; 99 percent Description. Each form in Section calculating the path .length through
were read with a positive error of 3.12.10 has a subtitle (e.g., Method 9, the plume and for predicting steam
fess than 5 percent .opacity. Figure 2.1) to allow easy reference to plume formation by use of a
2. In thecase of white plumes, 99 the corresponding completed form. psychrometric chart and pertinent
Percent of the sets were read The following paragraphs present a measurements.
with a positive error (higher brief discussion of the contents of this
values) of less than 7.5 percent section of the CIA Handbook. 6. Audiring Procedures Section
opacity; 95 percent were read 3.12.7 recommends performance and
with a positive error of less than 1. Certification and Training of system audits for use with field VE
5 percent opacity. Observers The priman/ purpose of this determinations. The IWO performance
audits are an audit by senior

observer/supervisor and a data
calculation audit. A system audit is
suggested, along with a Method 9
checklist, as shown in Figure 7.1.
Table 7.1 summarizes the quality
assurance activities for audits.
7. References and Bibliography
Sections 3.12.8 and 3.12.9 contain
the Method 9 and suggested
references and bibliography.
8. Data Forms Section 3.12.10
provides blank data forms which can
be taken from the QA Handbook for
field use or serve as the basis of a
revised form to be used by the
Agency. Partially completed forms are
included in the corresponding section
of the CIA Handbook.
April 1983 Section 3.12.1
Certification and Training of Observers

The purpose of this section is to literal definition of plume opacity is integral part of the certification
summarize the content of the CA the degree to which the transmission program. A spring/fall schedule is
manual for VE training programs.’ of light is reduced or the degree to preferable because of weather
Since the observer must be properly which visibility of a background as considerations. Certifying previous
certified or a qualified VE reader in viewed through the diameter of a graduates while the smoke school is
order to have his/her opacity reading plume is reduced. in terms of physical in session is more efficient and less
accepted, it is important that he/she optics, opacity is dependent upon costly than scheduling a separate
fully understand this phase of his/her transmittance (i/l,,) through the session.
training. plume, where lo is the incident light 7.2.2 Classroom Training - The
flux and I is the light flux leaving the training is accomplished most
1 .l Definition and Brief plume along the same light path. effectively by holding an intensive 1-
History of Opacity Percent opacity is defined as follows: or 2-day classroom lecture/discussion
The VE evaluation system evolved Percent opacity = (1 -i/W x 1DO. session. Although this training is not
from the concept developed by Many factors influence plume. . . required, it is highly recommended for
Maximillian Ringelmann in the late opacity readings: particle density. the following reasons:
1800’s, in which a chart with particle refractive index. particle size 1. increases the VE observer’s
calibrated black grids on a white distribution, particle color. plume knowledge and confidence for the
background was used to measure background, path iength, distance and day-to-day field practice and
bleak smoke emissions from coal-fired relative elevation to stack exit, sun application.
boilers. The Ringeimann Chart was angle, and iighting conditions. Particle 2. Reduces training time required
adopted by the U.S. Bureau of Mines size is particularly significant; to achieve certification.
in the early 1900’s and was usad panicles decrease light transmission 3. Trains the smoke reader in the
extensively in efforts to assass and by both scattering and direct proper recording and
control emissions. In the early 1950’s. absorption. Thus, particles with presentation of data that will
the Ringelmann concept was diameters approximately equal to the withstand the rigors of litigation
expanded to other colors of smoke by wavetength of visible light (0.4 to 0.7
I. the introduction of the concept of pm) have the greatest scattering effect
and strengthens
compliance
an agency’s
and enforcement
c.- “equivalent
discontinued
opacity.”
The Federal government has
the use of Ringelmann
and cause the highest opacity.
1.2 Training of Observer

program.
4. Provides a forum for the periodic
exchange of technical ideas and
numbers in EPA Method 9 procedures Field inspectors and observers are information.
for New Source Performance required to maintain their opacity Some states require classroom
Standards (NSPS). Current procedures evaluation skills by periodically training for initial certificatiog only. It
are based solely on opacity. Although participating in a rigorous VE is recommended, however, that
some State regulations Still specify certification program. Accordingly, observers attend the classroom
the use of the Ringelmann Chart to EPA’s Stationary Source Compiiance training at 3-year intervals to review
evaluate black and gray plumes, the Division (SSCD) and Environmental proper field observation.techniques
general trend is toward reading all MonitoringSystemsLaboretory and method changes and to
emissions in percent opacity. (EMSL) have provided the CA training participate in the exchange of ideas
In practice. the evaluation of opacity document’ to individuals who conduct and new information.
by the human eye is a complex VE training and certification programs.
phenomenon and is not completely This section summarizes the training 7.2.3 Lecture Material - Example
understood. However, it is well program. lecture material for a thorough
documented that visible emissions training program is presented in
can be assessed accurately and with 1.2.1 Frequency of Training Sessions Section 3.1 and Appendix A of
good reproducibility by properly - Certification schools should be Reference 1. A typical six-lecture
trained/certified observers. scheduled at least twice per year classroom training program consists
The relationships between light since Method 9 requires a semiannual of the following:
transmittance. piume opacity, recertification. It is highly Lecture 1 --Background, principles.
Ringlemann number. and optical recommended that training be an and theory of opacity.
density are presented in Table 1.1. A Lecture 2-Sources of VE’s,
presented by someone
Table 1.7. Comparison of Light. Extinction Terms thoroughly familiar with
source conditions.
Light Optical density Plume Ringeimann
related particle
transmission. % units opacity, 70 number characteristics, and
0 N/A’ 100 5 opacity reading
20 0.70 80 4 procedures and
40 0.40 60 3 problems.
3: 60 0.22 40 2 Lecture 3-Proper procedures for
-, 80 0.10 20 7 conducting field
100 0.00 0 0 observations under a
‘N/A = not applicable. variety of conditions.
Section 3.12.1 2 April 1983
Lecture 4-Influence and impact of the double-wall combustion chamber. recommended that attendees be
meteorology on plume The toluene flowrate is also controlled advised to stay away from the
behavior. by valves and flowmeters. generator during training and test
Lecture 5-Legal aspects of VE and runs. It is also recommended that gas
7 -2.5 Equipment Calibration
opacity measurements. and fuel fines be correctly checked for
Procedures - Detailed calibration
Lecture 6-Actual leaks prior to each use of the
procedures are included in a QA generator to prevent fire and explosive
observation/testing
procedures manual for VE training
procedures. hazards to the operator and nearby
programs.’ The generator transmisso-
attendees.
7.2.4 Training Equipment - An meters must be calibrated every six Occasional breakdowns or
integral part of the training program is months or after each repair. The malfunctions of the generator usually
the design and operation of the smoke National Bureau of Standards (NBS) occur at the most inopportune times.
generator and its associated traceable standards (optical fitters) for The problem must be diagnosed and
transmissometer, as specified in linearity response are available from repairs made expeditiously to provide
Method 9 (reproduced in Section Quality Assurance Division, the proper training and maintain the
3.12.13). Such a program is essential Environmental Monitoring Systems interest of the course attendees.
because proper observer certification Laboratory, U.S. EPA, Research Some common malfunctions are listed
cannot take place without the proper Triangle Park. North Carolina 27711. in Section 4 of the CIA training
equipment. Section 4 of Reference 1 It is strongly recommended that the manual.’
presents performance specifications calibration be performed &fore and
and operating procedures for smoke after each certification course to 1.3’ Ctirtifikation of Observer
generators which, if followed under a ascertain whether any significant drift This section summarizes the
good QA program, will ensure or deviation has occurred during the certification part of the training
nationwide uniformity and consistency training period, The ‘*zero and span” program. The first part of the
with Method 9 criteria. check must be repeated before and certification program is to acclimate
The design and operation of the after each test run. If the drift exceeds the smoke readers. The following
smoke generator has evolved 1 percent opacity after a typical 30- procedure is recommended. Both
significantly since the mid-l 960’s. min test run, the instrument must be black and white plumes are produced
The basic components of the smoke corrected to 0 and 100 percent of at certain levels. and during this
generator now include: scale before resuming the testing. production, the opacity values are
1. Black and white smoke All of the smoke generator announced. After some standards
generating units, performance verification procedures exposure, four plumes are presented
2. Fan and stack, (e.g., repair and maintenance work. to the trainee for evaluation. The
3. Transmissometer system, and spectral response checks, calibration correct values of the four plumes are
4. Control panel and strip chart check, and response time checks) announced to provide the trainee with
recorder. should be documented in writing and immediate feedback. The majority of
Table 1.2 lists the design and dated; a bound logbook is highly the trainees should be ready to take
performance specifications for the recommended. These records become the test after a few sets. Cenification
smoke generator. it must generate part of the permanent files on the VE runs are made in blocks of 50
smoke with an opacity range of 0 to training program. readings (25 black smoke and 25
100 percent and be sufficiently white smoke). The trainees who
accurate to allow the operator to 7.2.6 Setup. Operating. and successfully meet the criteria receive
control and stabilize the opacity of the Shutdown Procedures - Detailed a letter of certification and a copy of
smoke. It is recommended that the procedures and a parts fist are given their qualification form. The school
generator also achieve and hold in Section 4.4 of Reference 7_ - retains the original of the qualification
opacities in 5 percent increments at form for a minimum of three years, to
7 -2.7 Storage and Maintenance of be available for any legal proceedings
+2 percent for a minimum of 5 s.
the Smoke Generator - Proper that might occur. According to Method
White smoke is produced by
storage and maintenance procedures
dispensing, at regulated rates. No. 2 9. certification is valid for a period of
are essential for smoke generators to only six months. Neither certification
fuel oil into the propane-heated
increase their useful operating life
vaporization chamber. The opacity or recertification procedures require
and to provide reliability.
varies in proportion to the volume of the observer to attend the lecture
fuel oil vaporized and is regulated by 7 -2.8 Common Problems. Hazards. program; however. it is recommended
adjusting the flow of fuel oil. and Corrective Actions - The that the observer attend the series
Black smoke is produced by the generator has hot surfaces that can during initial certification and
incomplete combustion of toluene in cause serious burns. It is thereafter every three years. It is also
recommended that all persons unable
Table 7 -2. Smoke Generator Design and Performance Specifications to pass after 10 qualification runs, be
provided additional training before
Parameter Performance allowing qualification runs to be
Light source Incandescent lamp operatedat &5% of made.
nominal rated voltage Test forms vary greatly because of
Photocell spectral response Photopic (daylight spectral response the specific needs and experiences of
of the human eye) each agency. Figure 1.1 illustrates
Angie of view 75O maximum total angle one suggested form. The form should
Angie of projection 7F maximum total angle be printed on two-copy paper. the
Calibration error 23% opacity. maximum origmal for the official file and the
Zero and span drift i I% opacity. 30 mm carbon copy for the trarnee to grade
Response time 5 s. maximum after each certiflcatlon run. The test
Affiliation fiAl& OFJC/p4L6//A _ _ Name 7brl BE __ _ Run Number i-8

Course iocarron fi=HHOVD --_ Sunglasses r/a -
Date 4 -I&* 82 Sky w Wj”d 3-5MpH
Distance and directlon to stack 150 f7: NIW
Reading
number Error
1 0 5 10 15 20 m 30 35 40 45 50 55 60 65 70 75 80 85 90 95 ? 00
2 0 5 10 15 20 25 @ 35 40 45 &5 55 60 65 70 75 80 85 90 95 100
3 0 5 10 15 20 25 30 35 40 45 55 60 65 70 75 80 85 90 95 100
4 0 5 10 15 @J 25 b 0 35 40 45 50 55 60 65 70 75 80 85 90 95 100
5 0 5 10 ?5 20 25 0 35 40 45 50 55 60 65 70 75 80 85 90 95 100
6 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100
7 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 85 100
8 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100
9 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100
10 0 5 10 75 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100
11 0 5 10 15 20 25 30 35 ,40 45 50’ 55 ‘60 65 70 75 80 85 90 95 100

12 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100
13 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100
14 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100
15 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100
16 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100
17 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100
18 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100
19 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100
20 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100
21 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100
22 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100
23 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100
I
24 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100
25 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100
Deviation
Reading
number Error
0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 -
2 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 -
3 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 -
0 5 10 ?5 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 -
: 0 5 10 15 20 25 30 35 40 45 50 55 ‘60 65 70’ 75 80 85 90 95 100 -
6 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 -
7 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 -
8 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 7W -
9 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 700 v
10 .O 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 7
11 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 -
12 0 5 10 75 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 -
13 0 5 10 ?5 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 -
74 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 -
15 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 -
?6 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 -
17 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 F
18 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 700 -
19 0 5 10 ?5 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 -
20 0 5 10 75 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 -
27 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 -
22 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 -
23 Q 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 -
24 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 -
25 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 -
Deviation
Figure 1.1. Sample certrhcatron test form

form must be filled in completely. 2. The difference of the average

Certification requires that both of the value between observers should
followinq criteria be satisfied: not exceed 10 percent.
1. NoTeading may be in error by
more than 15 percent opacity. 1.6 Smoke School
2. The average [absolute) error Certification Quality
must not exceed 7.5 percent for Assurance Program
either set of 25 white or 25 black It is recommended that any
smoke readings. The certification government agency planning to
runs may be repeated as often as develop a smoke. school certification
necessary. However, it is recom- program obtain a copy of the
mended that all persons who “Recommended Quality Assurance
have not passed after ten certi- Techniques and Procedures for Visible
fication runs be given addi- Emission Training Programs.“’ Table
tional training prior to conducting 1.3 contains an activity matrix for
additional certification runs. certification and training of observers.
The detailed testing and grading
procedures required to ensure a valid
test are outlined in Section 5 of the . ,. .._ .-,. _--
QA training manual.1 The Agency
should maintain a bound logbook.
arranged by training session, for at
least three years, as evidence that the
observer has been certified as a
qualified VE evaluator by a recognized
smoke training and certification group.
Each trainee who successfully meets
the Method 9 criteria receives a letter
of certification and a copy of his/her
qualification form. This iener includes
the date of expiration.
1.4 Recertification
Method 9 requires an individual to
be recertified every six months.
1.5 in-the-field Training

After the observer’s initial
certification, it is recommended that a
senior observer accompany the new
observer on a field observation trip
and that both individuals
simultaneously record (using the
same time piece) their opacity
readings as a QA check (see Section
3.12.7). A comparison of these
readings will indicate any problems
the new observer might have in
conducting observations under field
conditions. A significant discrepancy
between the readings of the two
observers, in individual or average
values. indicates the need for further
in-field training and continuance of
the-senior observer (not necessarily
the same one) QA check. After
satisfactory checks have been made
on two consecutive field. observations.
the new observer can confidently
conduct inspections without a senior
observer. The suggested standard for
a satisfactory check for 6-min
(minimum) of consecutive readings is:
1. No difference in individual
readings should exceed 20
percent.
Sectidn 3.12.1 5 April 1983
Table 7.3. Acrivity Matrix for Certification a+ Training of Observers

Frequency and Action if
Acceptance method of requirements
Activity limits measurement are not met
Classroom Classroom train- initially and Review training
training of ing per Ref. 1 every 3 years procedures per
observer (suggested) Ref. 1
Smoke generator Should be able Before each Adjust and make
to generate certification test repeat check of
smoke with an run: use method operation
opacity range of in Ref 1
0 to 100%; hold
opacities f209
for at ieast 5 s
Setup. operating, Adherence to Each test run Review pro-
and shutdown procedures in cedures
procedures Ref. I
Storage and As above As above . .. Asabeve- .
maintenance
Transmissometer
Design and perfor- Specifications in Upon receipt. Adjust and
mance spec#ications Table 1.2 repair. and at repeat specifica-
6-mo intervals tion check until
use method in specifications
RefI 1 are met
Calibration 33% opacity Every 6 mo or Adjust and
maximum after repair, recalibrate until
before and after acceptance
each cenifica- limits are met
tion course is
recommended:
use method in
Ref. 1
Zero and span Opacity drift As above Instruments
<I% afier a must be car--
typical 30-min rected to 0 and
test run 1 GUI% before
testing is
resumed
Certification of No reading must Take smoke Retake test until
observer be in error by reading test until- successfulrom- .
more than 15% a successful test pletion
and average has been com-
absolute error pleted
must not exceed
7.5% for either
white or black
smoke readings
Recertification As above Every 6 mo take As above
a smokereading
test until a
successful test
has been
completed
In-the-field training No reading in Checks are made Continue com-
error by more on the first two parisons until
than 20% differ- field observa- acceptance
ence and tions subse- limits are met
average absolute quent to the during two field
error should initial certifica- observations
not exceed tion; comparison
1 U% difference is made between
during the field new certified
observation observer and an
experienced
2.0 Procurement of Apparatus and Supplies

Method 9 does not specifically Table 2.1 at the end of this section magnetic with resolution better than
require any equipment or supplies. contains a summary of the quality 10“. II is suggested that the compass
Therefore, this entire section includes assurance activities for procurement be jewel-mounted and liquid-filled to
quality assurance procedures that are and acceptance of apparatus and dampen the needle swing; map
recommended to assist the observer supplies. reading compasses are excellent for
in documenting data. Nevertheless. 2.1 Stopwatch this purpose.
this section provides specifications A watch is used to time the 15 2.3 Range Finder
criteria or design features, as second intervals between opacity
applicable, to aid in the selection of A range finder is used to measure
readings. The watch should provide a
equipment that may be useful in the observer’s distance from the
continuous display of time to the
collecting VE data. Procedures and emission point and should be capable
nearest second.
limits for acceptance checks are also of determining distances to loo0
provided. During the procurement of 2.2 Compass meters with an accuracy of f10
equipment and supplies, it is A compass is useful for determining percent. The accuracy of the range
suggested that a procurement log the direction-of-the.emissiorrpoint finder should be checked upon receipt
(Figure 2.1) be used to record the from the spot where the VE observer and periodically thereafter with
descriptive title of the equipment. the stands and for determining the wind targets at known distances of
identification number (if applicable). direction at the source. For accurate approximately 500 meters and 1000
and results of any acceptance checks. readings, the compass should be meters.
Purchase Dare r
Item description Quantitv
order
number Vendor
-
Ordered
5182
Received Disposition Comments
2 u
Figure 2.1. Example of a procurement fog.

Section 3.122 2 April 1983
2.4 ‘-Abney Level or and the observer should always be 2.9 Safety Equipment
Ciineometer sure to purchase enough fresh color The following safety equipment.
An Abney level is a device for negative film (ASA 100 which should be approved by the
determining the vertical viewing angle. recommended) for his/her purposes. Occupational Safety and Health
For visible emission observation Association (OSHA). is recommended
purposes, it should measure within 5 2.8 Clipboard and for the VE observer:
degrees. The accuracy should be Accessories 0 Hard hat in high-visibility yellow
tested by placing the level flat on a For documenting the visible or orange
table that has been previously leveled emission observation, the observer 0 Safety glasses, goggles. or eye
with a referring level and checking it should have a 10 in. x 12 in. masonite shields
at a 45“ angle by placing it on a 45O or metal clipboard. several black baii- 0 Ear protectors
inclined plane constructed with the point pens (medium point), a large 0 Safety shoes (steel-toed for
plane as the hypotenuse of a right rubber band, and a sufficient number general industrial use).
triangle with equal base and height. of visible emission observation forms. Specially insulated safety shoes are
necessary in certain areas, such as
2.5 Siing Psychrometer the top of coke ovens.
The sling psychrometer is used in
cases where it is suspected that the
atmospheric conditions will promote
the formation of a steam plume (see
Subsection 6.3). The psychrometer
should consist of two thermometers,
accurate to 1/2Y. mounted on a
sturdy assembly whereby the
thermometers may be swung rapidly Table 2. I. Activity Matrix for Procurement of Recommended Equipment and
in the air. One thermometer should be Supplies
fitted with a wettable cotton wick tube Frequency and Action if
on the bulb. Thermometer accuracy method of requirements
should be checked by placing the Eouipment Acceptance limrts measurement are not met
bulbs in a fresh ice water bath at W’C. Watch Continuous Check upon Return to
display receipt supplier
2.6 Binoculars
Compass Magnetic with Check upon Return to
It is recommended that the observer
7 00 resolution receipt supplier
obtain binoculars preferably with a
magnification of at least 8 x 50 or- 10 Range finder Accuracy of Check upon Adjust or
x 50. The binoculars should have I1 0% over dis- receipt and return to
color-corrected coated lenses and a tances to loo0 m quarterly with supplier
rectilinear field of view. Color targets at known
correction can be checked by viewing distances of
a black and white pattern such as a about 5OOm and
Ringeimann card at a distance greater 7000 m
than 50 ft; no color rings or bands Abney level Accurate within Check at O” and Same as above
shouid be evident, only black and f5O 45O
whne. The rectilinear field of view can Sling psychrometer Each thermom.- Check thermom- Repair or return
be tested by viewing a brick wall at a eter accurate eter accuracy to supplier
distance greater than 50 ft. There to 1/2OC (IOF) with ice water
should be no distortion of the brick bath at O°C
pattern as the field of view is Binoculars Magnification of Check upon Return to
changed. The binoculars are helpful 8xSOor 10x50, receipt by view- supp fier
for identifying stacks. searching the color-corrected ing selected
area for emissions and aid in coated lenses objects
characterizing behavior and and a rectilinear
composition of plume. field of view
2.7 Camera and Accessories Camera 35-mm camera Check quality of Return to
with through- photos on supplier for
A camera is often used in VE
observations to document the the-lens light receipt andafter repair
metering processing film
emissrons before and after the actual
opacity determination. A 35-mm Clipboard/ 10 in. by 72 in. Check supplies Replenish
camera &th through-the-lens light accessories/forms clipboard: black periodically supplies
meterlng is recommended for this ball-point pens:
purpose. Useful accessories include a VE observation
“macro” lens or a 250-mm to 350- forms
mm telephoto lens. and a 6-diopter Safety equtpment Hardhat- yellow Check supply of Marntarn equip-
closeup lens (for photographing or orange. safety safer y equipment availability
logbook and evidence of particulate glasses and ment periodi-
deposition). A photo logbook is shoes. ear cally
necessarv . for .- orooer documentation. protectors
3.0 Preobservation Operations

The following procedures are not photographs. if available. A requires on-site observations during
required by Method 9 but are facility map is very helpful conditions of typical or normal
recommended in order to provide during inspection and should be maximum operations. if the facility is
more consistent data collection and a required item for every notified of the time of this evaluation,
better data documentation and Agency source file. The map some operating conditions may be
verification of representative plume makes it easier for the observer altered. if this situation appears likely,
viewing conditions. Not ail procedures to identify point sources and it is EPA’s policy not to give prior
are needed for every observation. activities. and it may be used to notification. EPA is obligated to notify
Before making on-site VE mark any emission points that State/local agencies of inspections
determinations, the observer should have been added or modified. and generally prefers to invite the
gather the necessary facility data. 12. if an operating permit exists. applicable agency to participate. The
provide prior notifications when obtain a copy because it may observer should notify the affected
applicable, establish an observation contain the VE limits for each facility and control agencies as soon
protocol, .and check for availability of point source and any special as practical following any official
supplies and properly maintained operating requirements. opatity readings.
equipment. Table 3.1 at the end of 13. Determine the status of the
this section summarizes the quality source with respect to any 3.3 Establish Observation
assurance activities for preobsewation variance or exemption from the Protocol
operations. Agency’s rules and regulations. Based on information collected
Observation may not berequired if under Section 3.1 and any prior
3.1 Gather Facility the source has a variance or is experience with the source, an
information exempt from the regulations. observation protocol should be
The observer should be thoroughly 14. Review plant terminology. established. First, the observer
familiar with the source facility, 15. Use references such as facility should determine whether one. two,
operation, emissions, and applicable maps and previous inspection or more observers will be required.
regulations. In preparation for the on- reports to determine if the For example, two observers may be
site visit, the observer should review viewing position is restricted required to simultaneously make the
the Agency’s information (in the official because of buildings or natural VE determination and gather other
source file) on the source in question. barriers. If the viewing position on-site data (e.g., take photographs,
The observer should: requires obsewations to be draw a new modified facility map if
1. Determine the pertinent people taken at a particular time of day one is not available from the plant or
to be contacted. (morning or evening) because gather other needed plant information).
2. Become familiar with the of sun angle, consider this in cenain situations where the VE
processes and operations at the when planning the inspection. observations must be correlated to
facility and identify those 16. Determine the possibility of process operation, the second person
facilities to be observed. water vapor in the plume will closely monitor the process
3. Review the permit conditions, condensing (see Section activity and record the exact time of
requirements, and recent 3.12.6). This determination may the operating modes of interest. Only
applications. prevent a wasted trip to the ‘. one observer will make the VE
4. Determine applicable emission facility on days when a determination unless an observer
regulations. persistent water droplet plume audit is being conducted. in this,case,
5. identify ail operating air is anticipated because of the designated observer is the one
pollution control equipment, adverse ambient conditions. being audited.
emission points, and types and Note: If the observer is not familiar The applicability of Method 9 (and
quantities of emissions. with the type of facility or operation, hence the method of observation)
6. Review history of previous he/she should consult available should be determined. if Method 9 is
inspections, source test results, reference material and inspection not applicable. see Section 3.12.4.
and complaints. manuals on the source category. Special Problems.
7. Check the file to become A written checklist regarding an
familiar with (or revrew) plant 3.2 Prior Notification expected walk-through of the plant
layout and possible observation The-usual procedure is to make the including questions to ask plant
sites. VE determination without prior officials may be helpful.
8. Determine normal productton notification unless the plant must be
and operation rates. entered first to obtain a good view of 3.4 Perform Equipment
9. identify unique problems and the emission point of interest. Checks for On-Site Use
conditions that may be However. this procedure is not always Be sure that the necessary
encountered (e.g., steam possible. especially in remote equipment and supplies are available
plume). iocatrons, when operations are for making the VE determination and
10. Discuss with attorney if case intermittent, or when specific documenting the results. Ail
development is expected. personnel must be present or equipment should be visually checked
‘\, contacted. Determming VE for
11 Obtain a copy of the facility for damage and satisfactory operatron
map with labeled emission compliance wrth State Implementation before each VE determination field
pomts, profile drawmgs. and Plan (SIP) or NSPS opacrty regulations trap.
Table 3.1. Activity Matrix for Preobservation Operations

Acceptance method of requirements
Gather facility Obtain neces- Check for com- Obtain missing
information sary facility data. pleteness of data data before on-
Subset 3.1 site visit. if
possible
Make prior Make VE deter- Check the pro- Make required
notification mination with- tocol for notifi- notifications
out prior notification before
cation except as each on-stie visit
stated in Subset and revise the
3.2.. EPA should protocolas
notify State/ necessary
local agencies
. and invite
participation
.
Establish protocol Prepare obser- Check before a. C?mpiete-or- . -’ - .-
vation protocol, on-site visit prepare protocol
Subset 3.3 as required
Perform equipment Ail equipment/ Same as above Replace or
check supplies avail- adjust
able and in sat- equipment
isfactory work-
4.0 On-Site Field 0 bservations
This section describes field 1. Other stacks and emission points granted by the owner or company
observation procedures. including whose visible emissions might official. Figure 4.1 lists the pertrnent
perimeter survey, plant entry, VE interfere with opacity readings. section of the Clean Air Act on facility
determination, and special observation 2. Fugitive emissions that result entry as well as information on
problems. The fatter subsection from product or waste storage confidentiality of process information.
supplements the subsection on VE piles and material handling and It is recommended that the inspector
determination by providing some may interfere with observations. have a copy of this information
information on how to take VE 3. Fugitive emissions that result available in case questions are raised
readings when unfavorable field from unpaved road travel and by source representatives.
conditions prevent the use of the may interfere with observations. 4.2.7 Entry Point - It is
procedure described in Subsection 4.3 4. Water vapor emissions from recommended that the plant premises
(e.g., when the emissions are sludge qr co.oling ponds.. be entered through the main gate or
intermittent or the observer position is 5. Open burning. through the entrance designated by
restricted). The QA activities are 6. Any unusual activities on or the company officials in response to
summarized in Table 4.2 at the end of around plant premises that could prior notification. The observer’s
this section. result in nonrepresentative arrival will usually occur during
emissions or interfere with normal working hours unless
4.1 Perimeter Survey opacity readings. conditions contributing to excess
Before and after the VE If deemed useful by the observer, opacity levels are noted at certain
determination, it is strongly photographs may be taken to times other than normal working
recommended that the observer make document extenuating conditions (see hours. If only a guard is present at the
a perimeter survey of the area discussion of confidentiality and the entrance, it is desirable for the
surrounding (1) the point of use of cameras in Subsection 4.2.7). observer to present the appropriate
observation and (2) the emission point credentials and to suggest that the
on which the determination is being 4.2 Plant Entry guard’s supervisor be contacted for
made. Such a survey also may be The following discussion presents the name of a responsible company
e\. made during the VE determination, if the recommended plant entry official. The observer would then ask
warranted. procedures. The VE readings . to speak with this official, who may be
A perimeter survey can be useful themselves should not be affected by the owner, operator, or agent in
in determining the presence of other a change in these procedures. charge (including the environmental
factors that could affect the opacity However. the usefulness of the engineer).
readings. For example, the readings in showing a possible
representativeness of the VE readings violation of the applicable standards 4.2.2 Credentials - After
for a given emission point could be may be compromised by not following courteously introducing
.questioned unless data is available to agency procedures for entering plants. himself/herself to the company
show that the observer excluded Depending on the location of emission officral. the observer should briefly
emissions related to material points at the plant and the availability describe the purpose of the visit and
stockpiling. open burning, and of observation points in the area present the appropriate credentials
ambient condensed water vapor in surrounding a facility, the VE observer confirming that he/she is a lawful
adjoining areas of the plant. It is vital may not have to gain entry to the representative of the agency. Such
that the observer be as aware as plant premises prior to making VE credentials will naturally differ
much as possible of extenuating observations. It may be preferable to depending upon the agency
conditions. The perimeter survey is gain access after taking readings to represented, but it is recommended
made to document these conditions. check on plant process control that they include at least the
Common sense should be used in equipment operating conditions or to observer’s photograph, signature,
determining the need and extent of complete a perimeter survey. Figure physical description (age, height,
the survey; in some cases (e.g.. a 4.1 is an example entry checklist that weight, color of hair and eyes). and
single 350-foot stack) a perimeter can be used to assist the observer in the authority for plant entry. Agencies
survey is not vital. organizing the information that could issue credentials in several forms.
Perimeter surveys can be made be used at the time of plant entry. including letters, badges. ID cards. or
from either outside or inside the plant folding wallets.
To maintain a good working
property, or both. This decision would relationship with plant officials and. 4.2.3 Purpose of Visit - When ftrst
depend on whether the VE most importantly, to comply with the meeting with a company official, the
observations are made from inside or Clean Air Act and avoid any legal observer needs to be prepared to state
outside of the plant, whether the conflict with trespass !aws or the succinctly the purpose of the visit.
observer actually gains entry to the company’s right to privacy and due including the reason for the VE
plant premises, and whether the plant process of law under the U.S. determlnatlon. Space is provided In
cT is sufficiently visible from outside the Constitution. the observer must follow the recommended form (Figure 4.1) to
t’ premises to make a reasonable certain procedures in gaining entry to spec!fy the exact purpose of the visrt.
survey. It is suggested that during the the plant’s private premises. In most and !ne observer can refer to this
survey the observer should note such cases, consent to enter (or the wher. talking with the company
factors as: absence of express denial to enter) IS official
Source name and address Observer JULW A. -5rllni

DRI - iihRD PORTLAND CEWJT
Agency u. s. ERA
2 HILES E. oF Rt. 1. ON
UtELmJ z
STITE RD. 18% Date of VE observation
PrWiOuS company contact (if applicable) qEo/rqE c. MMS
Title OWNER
Emission points at which VE observations to be conducted

Of GR7fVD% 3-05-097-02 03 CoAt-(ya5D KlLN 3-05-037-05
0.2 mYas */ A4 *z 3-&5-007~oz
Authority for entry {see reverse side)
Plant safety requirements

@ Hardhat Cl Coveralls
B Safety glasses g Dust mask suggested
Bl Side shields (on glasses) 0 Respirator&)
q Goggles Specify
0 Hearing protection ,z,Qw$u&I&N Fs mj
Specify Pm , 0 Other
@ Safety shoes (steel- toe@ Specify
0 lnsuiated shoes
0 Gloves
C6mPany official contacted (on this visit) 3TmPz.y 0. G<.bq .- -.

Title
Figure 4.1. Visible emission observer’s plant entry checklist.

Authority for Plant Entry: Clean Air Act. Section 7 14

(aJ(2J the Administrator or his authorized representative upon presentation of his credentials -
(A/ shall have a right of entry to, upon or through any premises of such person or in which any records required to be
maintained under paragraph (7/ of this section are located. and
(BJ may at reasonable times have access to, and copy of any records. inspect any monitoring equipment or methods
required under paragraph (11. and sample any emissions which such person is required to sample under
paragraph (Il.
(bJ (I J Each State may develop and submit to the Administrator a procedure for carrying out this section in such State. If the,
Administrator finds the State procedure is adequate. he may delegate to such State any authority he has to carry out this
section.
(2) Nothing in this subsection shall prohibit the Administrator from carrying out this section in a State.
(cl Any records. reports or information obtained under subsection (a)shaflbe available to the public except that upon a showing
satisfactory to the Administrator by any person that records, reports. or information. or particular part thereof (other than
emission data) to which the Administrator has access under this section if made public would divulge methods or processes
entitled to protection as trade secrets of such person. the Administrator shall consider such record. report. or information or
particular porjion thereof confi&ntrk# in accordance with.the purposesof .Section .7905 of Title 18 of the United States
concerned with carrying out this Act or when relevant in any proceeding under this Act. *’
Confidential Information: Clean Air Act, Section I 74 (see above) 4 f Federal Register 36902, September 1. 7976
If you believe that any of the information required to be submitted pursuant to this request is entitled to be treated as
confidential, you may assert a claim of business confidentiality, covering all or any part of the information. by placing on (or
attaching tol the information a cover sheat. stamped or typed legend or other suitable notice, employing language such es
“trade secret, . ‘*proprietary.
l *’ or ‘*cornpan y confidential. ** Allegedly confidential portions of otherwise nonconfidential
ihformation should be clearly identified. If you desire confidentiel treatment only until the occurrence of a certain event; the
notice should so state. Information so covered by a claim will be disclosed by EPA only to the extent. and through the procedures.
set forth at 40 CFR, Part 2. Subpart 8 {41 Fadaral Register 36902, September 1. 1976.)
If no confidentiality claim accompanies this information when it is receivedby EPA. it may be made available to the public by
EPA without further notice to you.
Figure 4.1. Reverse side of form. (Continued)
The principal purpose for an the company from tort liability. is to insure that the denial
observer’s visit to a plant will probably Signing this type of release form may has not been based on some sort
fall into one of three categories: (1) a waive the rights of the observer and of misunderstanding. Discussion
VE determination is being made his/her employer compensation in might lead to resolution of the
pursuant to a neutral administrative event of personal injury or damages; problem and the observer may be
scheme* to verify compliance with an the precise effect of signing an given consent to enter the
applicable SIP or NSPS, (2) a VE advance release of liability for . premises. If resolution is beyond
determination is being made because negligence depends upon the laws of his/her authority, the observer
some evidence of an opacity violation the state in which it is signed. If the should withdraw from the
already exists, or (3) an unscheduled plant official denies entry for refusal premises and contact his/her
VE determination has just been made to sign a .release form, the observer supervisor to decide on a
from an area off the plant property. should proceed as described in the subsequent course of action.
The statement of purpose should state section on entry refusal. Note the facility name and exact
clearly what has prompted the visit. address, the name and title of
At this time, the observer also 4.2.5 Section 7 14 - Section 114 of the plant officials approached.
should provide the company official the Clean Air Act addresses both the the authority of the person
with a copy of the opacity readings authority for plant entry and the issuing the denial. the dare and
and ask that person to sign an protection of trade secrets and time of denial, the reason for
acknowledgment of receipt of any VE confidential information. For the denial, the appearance of the
readings made previous to entry. In observer’s reference, the applicable facility, and any reasonable
lieu of the above, the agency should paragraphs are included on the suspicions as to why entry was
provide a copy within a reasonable reverse side of the entry checklist in refused.
time. Figure 4.1. The observer should be very
careful to avoid any situations
4.2.4 Visitor’s Agreements. Release 4.2.6 Entry Refusal - In the event that might be construed as
of Liability (Waivers) - The observer that an observer is refused entry by a threatening or inflammatory.
should not sign a visitor’s agreement, plant official or that consent is Under no circumstances should
release of liability (waiver), hold- withdrawn before the agreed-upon the potential penalties of entry
\( harmless agreement. or any other
\_ activities have been completed, the denial be cited.
- agreement that purports to release following procedural steps should be
followed: All evidence obtained prior to the
‘Any routme of selectmg sttes for observarmo 1. Tactful/y discuss the reason(s) for wnhdrawal of consent is considered
that 8s not dmctecl toward any company denial with the slant official; thus admtssible in court
When denied access only to certain before it will be treated as confidential declare its intentions regarding the
parts of the plant, the observer should pending legal determination. The plant information and the Agency has ruled
make note of the area(s) and the official should inform the observer of that the information is not legally
official’s reason for denial. After any sensitive areas of the facility or confidential.
completing normal activities to the processes where proprietary or trade
4.2.8 Determination of Safety
extent possible and leaving the secret information is indicated.
Requirements The violation of a
-
facility, the observer should contact Photographs are often used to
safety rule does not invalidate VE
his/her supervisor for further document visible emissions
readings; however, the observer
instructions. observations (see Subsection 4.3.4). should always anticipate safety
Before taking photographs from inside
4.2.7 Confidentiality of Data - In requirements by arriving at the plant
the plant premises, the observer must
conducting the VE investigation, the with a hardhat, steei-toed safety
have the consent of the plant official.
observer may occasionally obtain shoes, safety glasses with side
Most of an observer’s photographs
proprietary or confidential business shields, and ear protectors. Safety
will be of emission points only;
data. it is essential that this equipment also should include any
presumably. these should not include
information be handled properly. other equipment that is specified in
confidential areas of the plant. If any
The subject of confidential business the agency files and noted on the
opposition is encountered regarding
information known as “a trade secret” the use of a camera on the plant entry checklist form.
is addressed in Section 114 of the premises, the observer should-explain-’ Some companies require unusual
Clean Air Act (see Subsection 4.25) that the plant official should request -safety equipment, such as specific
and in the Code of Federal ’ confidential treatment of any
Regulations (40 CFR 2; 41 Federal respirators for a particular kind of
photographs taken. The observer
Register 36902, September 1. 1976. toxic gas. In many cases, these
must properly document each
as amended). The Code of Federal companies will provide the observer
photograph and handle those for
Regulations (40 CFR 2, Subpart 5, with the necessary equipment. In any
which confidential treatment has been
2.203) embodies a notice to be event. the observer must be aware of
requested in the same manner as
included in EPA information requests. and adhere to all safety requirements
other confidential data. Photographic
This notice is paraphrased on the before entering the plant. Information
documentation of VE observations on plant alarms and availability of first
reverse side of the entry checklist from an area of pubiic access outside aid and medical help may be needed.
(Figure 4.1) for the observer’s and of the plant premises does not require
plant official’s reference. The Code of approval from a plant official. provided
Federal Regulations (40 CFR 2, the documentation is accomplished
Subpart B, 2.211) also includes the without the use of highly 4.2.9 Observer Behavior -
penaliies for wrongful disclosure of sophisticated equipment or Observers must perform their duties
confidential information by Federal techniques. For example, use of a in a professional, businesslike. and
employees, in addition to the penalties high-power telephoto lens (over 100 responsible manner. They should
set forth in the United States Code, mm on a 35 mm camera) that yields always consider the public reiations
Title 18, Section 1905. Employees of extensive details (e.g., construction liaison part of their role by seeking to
other agencies should check with layout) might be construed as develop or improve a good working
agency attorneys to determine their surreptitiously taking confidential relationship with plant officials
exact personal liability. business information. Thus, a good through use of diplomacy, tact, and if
From the observer’s standpoint, rule of thumb is to be sure that any
confidential information may be necessary, gentle persuasion in all
pictures taken show only the details. deaiings with plant personnel. .
defined as information received under that could be seen with the naked eye
a request of confidentiality which may from an area accessible to the public.
concern or relate to trade secrets. A Specifically. observers
should be
trade secret is interpreted as an When preparing to leave the plant, objective and in conducting
impartial
unpatented secret, commercially the observer should allow the plant observations and interviews with
valuabie plan, appliance, formula, or official to examine the data collected plant officials. All information
process used in production. This and make claims of confidentiality. All acquired during a plant visit is
information can be in written form, in potentially confidential information intended for official use only and
photographs, or in the observer’s should be so marked, and while on should never be used for private gain.
memory. Emissions data are not the road, the observer should keep it Observers must be careful never to
considered confidential information. in a locked briefcase or file container. speak of any person, agency, or
Also the Agency reserves the right to It should be noted that emission data facility in any manner that could be
determine if information submitted to are not considered confidential. consrrued as derogatory. Lastly,
it under an official request should be When the observer returns to the observers should use discretion when
treated as confidential. agency office, the potentially asked to give a professional opinion
A good rule of thumb for the confidential information should be on specific products or projects and
observer to follow is to collect only placed in a secure, lockable file should never make judgments or draw
that process and operat‘ional cabinet designated especially for that conclusions concerning a company’s
information and to take only those purpose. The observer’s agency compliance with applicable
photographs that are pertinent to the should have an established secure regulations. Upon giving the data to
purpose of the plant visit. The plant filing system and procedures for the plant the observer can tell the
official should be advised that he safeguarding confidential documents. source these are the data that were
must request confidential treatment of In all cases, the observer should make obtained and no judgment as to
specific information provided (see no disclosure of potentially compliance can be made until all the
paragraph on claims of confidentiality confidential information until a data and the regulations are closely
on reverse side of entry checklist) company has had full opportunity to revlewed.
April 1983 . 5 Section 3.12.4
4.3 Visible Emission continental United States. The that were worn for certification
‘4’. If sunglasses were not worn
Determination preferred reading distance is
F between 3 stack heights and l/4 during certification, the observer
This subsection describes the
mile from the base of the stack. should remove them and allow
preferred approach to VE
determination. Because practical time for the eyes to adjust to the
considerations do not always permit 6. The reading location should be daylight before making VE
safe for the observer. determinations. It is
the observer to follow this procedure,
recommended that the observer
however, special observation Ooacity Observations
Droblems are discussed in Subsection ’ 1. Opacity observations not wear photo compensating
must be
is. made at the point of greatest
sunglasses.
8. The best viewing spot IS usually
4.3.1 Opacity Readings - The opacity in that portion of the within one stack diameter above
observer must be certified in plume where condensed water the stack exit, where the plume
accordance with Section 3.12.1, vapor is not present. is densest and the plume width
Subsection 1.3, and should use the 2. The observer must not look is approximately equal to the
following procedure for visually continuously at the plume (this stack’s diameter.
determining the opacity of emissions. causes eye fatigue), but should
Observer Position observe the plume momentarily 4.3.2 field Data: The “Visible
1. The observer must stand at a at 15-s intervals. .A-1 5-s beeper Emission Observation Form” - The
distance that provides a clear is recommended to aid in 1977 revision of EPA Method 9
view of the emissions with the performing the VE readings. specifies the recording.of certain
sun oriented in the 14D” sector 3. When steam plumes are information in the field documentatron
to his/her back. If the observer attached, i.e.. when condensed of a visible emission observation. The
faces the emission/viewing point water vapor is present within the required information includes the
and places the point of a pencil plume as it emerges from the name of the plant, the emission
on the sun location line such emission outlet, the opacity must location, the type of facility, the
that the shadow crosses the be evaluated beyond the point in observer’s name and affiliation, the
observers position, the sun the plume at which condensed date, the time. the estimated distance
location (pencil) must be within water vapor is no longer visible. to the emission location. the
the 14D” sector of the line. The observer must record the approximate wind direction, the
During overcast weather approximate distance from the estimated windspeed, a description of
conditions. the position of the emission outlet to the point in the sky conditions (presence and color
sun is less important. the plume at which the of clouds). and the plume background.
observations are made. Experience gained from past
Consistent with number 1 above, 4. When steam plumes are
when possible, the observer enforcement litigation involving
detached, i.e., when water vapor opacity readings as primary evidence
should, make observations from in the plume condenses and of emission standards violations has
a position in which the line of
becomes visible at a distinct demonstrated a need for additional
vision is approximately distance from the emission documentation when making visual
perpendicular to the plume outlet, the opacity of emissions determinations of plume opacity. The
direction; when observing
should be evaluated near the Visible Emission Observation Form
opacity of emissions from
outlet, prior to the condensation presented in Figure 4.2 is
rectangular outlets (e.g., roof
of water vapor and the formation recommended. This form was
monitors, open baghouses, and of the steam plume; unless the developed after reviewing the opacity
noncircular stacks), the opacity is higher after forms used in EPA Regional Offices
observer’s position should be dissipation. and State and local air quality control
approximately perpendicular to
5 Readings must be made to the agencies. The form includes not only
the longer axis of the outlet.
nearest 5 percent opacity. A the data required by Method 9. but
3 When multiple stacks are minimum of 24 observations also the information necessary for
involved, the observer’s line of must be recorded. It is advisable maximum legal acceptability. Valid
sight should not include more to read the plume for a data can be collected on any form;
than one plume at a time. and in reasonable period in excess of however, the recommended form may
any case. during observations. the time stipulated in the enhance observer efficiency and data
the observer’s line of sight regulations (i.e., at least 10 documentation. A detailed descrrption
should be perpendicular to the readings more than the minimum of the use of the recommended form
longer axis of a set of multiple required). is given in the following paragraphs.
stacks (e.g.. stub stacks on 6 A clearly visible background of
baghouses). . contrasting color is best for The Visible Emission Observation
4 The observer must stand at a greatest reading accuracy. Form can be functionally divided mfo
distance that provides total However, the probability of 11 major sections, as shown tn Frgure
perspective and a good view. positive error (higher values) is 4.3. Each section documents one or
5. In order to Comolv with the sun greater under these conditions. two aspects of the opacity
angle requirements (see item 1) Generally, the apparent plume determination. The form endeavors to
it is recommended that the opacity dimintshes and tends to cover all the required and
observer should try to avotd the assume a negative bras as the recommended areas of documentatQn
i.
i -’
noon hours (11:DO a.m. to 1:DO background becomes less In a rypical opacity observatron. A
p.m.) in the summertrme (when contrasting. “comments.’ section is included for
the sun is almost overhead). This 7 It IS recommended the observer notation of any relevant mformation
is more critical in the southern wear the same corrective lenses that IS not llsted on the form
VISIBLE EMISSION OBSERVA TON FORM

7
SOURCE NAME OBSERVATION DATE START TIME STOP TIME
ADMl&lL po\J= ?ufl 15 3u~Ymr f530 /34z
ADDRESS
f/r b=fw RoAo 0 75 30 45
’ 30 35 55 55 3f
2 55 50 qo 30 32
SOURCE ID NUMBER 3 35 35 35 35 33
1
NEDS -- 457z/
.
I
4 -30
I- 35
v- 35
” 35 34
PROCESS CQ&JfPMENI I OPERATNG MODE I = I -A I,, I -
OIL FJED BQfLCC &4sEL&w i/ Jv JJ -30 30 35 1
CONTROL EQUIPMENT OPERATING MODE 6 35 35 35 35 36

ELsclmmc ~izuP(7nToe , mvcflq
DESCRfEE EMISSzNflPOANJ, did.
7 30 30 35 35 37
START =‘== 38
DESCRIBE BACKGROUND
START SKv’ STOP W/aeoKEnt wDs
19 49
BACKGROUND COLOR SKY CONDITIONS
START && STOP?%& START m STOP ‘z$ 20 II 50 I
I I I I- I I I
WIND SPEED WIND DIRECTION 21 I I I I I 51 I I I I 1

START /%=/! STOP wnm START sti STOP /
AM%lENT TEMP. WET BULB TEMP. RH.percent
22 1 1 1 1 t 52 1 1 1 1 1
START e-f STOP / se &S% 23” ... 53
24 54
Source Layout Sketch Draw North Arrow 251 I I I 1551 I I’I I
-7 4/
X mission Point
26
27
91
L
I I I 1581
56
57
i
1 t 1 1
3 I 60
I
Observers Position ERAGE OPACITY FOR NUMBER OF READINGS ABOVE
HIGHEST PERIOD 40% % WERE //
RANGE OF OPACITY READINGS , rhd
Sun Location Line MINIMUM 36 70 MAXIMUM bvya
OBSERVER-S NAME (PRINT)
ul5. PWFO-
COMMENTS OESER VERIS SIGNA TURE DA TE
L/s -6 O/L u E./P/lW I5 lJay /fScC
I
ORGANIZATION
5?i?fE N/i muaw/ cm4-e~~ Df=D
OBSERVATIONS CERTIFIED BY DA TE
EBWSrErclulcAL A5=. I /swyf?S
TITLE u DATE VERIFIED BY DA TE
. SHfJT&m%Ee 7-/5-t% RiDA /5 Ai% mz
Figure 4.2. Visible emission observarlon form.
VlSltTLE EMISSION OBSERVATION FORM
This form is designed to be used in conjunction with EPA Method 9. --Visual Determination of the Opacity of Emissions from Stationary
Sources, *- Any deviations. unusual conditions. circumstances. difficulties. etc.. nor dealz with elsewhere on zhe form should be fully noted
in the section provided for comments. Following are brief descriptions of the type of information thaz needs to be enzered on the form: for a
more detailed discussion of each pari of the form. refer to the “Userf Guide to the Visible Emission Observation Form. -*
*Source Name - full company name. parent company or division ‘Sky Conditions - indicate cloud cover by percentage or by
information. if necessary. description (clear. scattered. broken, overcast. andcolor of clouds).
‘Address - street (not mailing) address or physical location lWindspeed - use Beaufon wind scale or hand-heldanomometer:
of facility where VE observation is being made. be accurate to ti mph.
Phone - self-explanatory. l Wind Direction - direction wind is from; use compass; be

accurate to eight points.
Source ID Number - number from NEDS. CDS. agency fife. etc. ‘Ambient Temperature - in OF or OC.
‘Process Equipment. Operating Mode - brief description of process **Wet St& Temperature - zhe wet bulb temperature from the
equipment (include ID no.) and opetating rate- % capacity utilization. sling psychrometer.
and/or mode (e.g.. charging, tappingj. -
*Control Equipmant, Operating Mode - speczfy control device type(s) “Relative Humidity - use sling psychrometer: use local U.S.
and % utilization. control efficiency. Weather Bureau on& if nearby.
‘Des&be Emission Point-stack or emission point location. geometry. ‘Source Layout Sketch - include wind direction. associated
diameter, color: for identification purposes. stacks. roads. and other landmarks to fully idenzify location of
emission point and observer position.
*Height Above Ground Level - stack or emission point height from Draw No-h Arrow - poinz line of sight in direction of emission
files or engineering drawings. point. place compass beside circfe. and draw in arrow parallel
to compass needle.
‘Height Relative to Observer - indicate vertical position of observation Sun Location Line - point line of sight in direction of emission
point relative to stack top. point. place pen upright on sun location line, and mark location
of sun when pen’s shadow crosses the observers position.
*Distance From Observer - distance to stack f 16%; to determine. use “Comments - factual implications. deviations. altercations.
rangefinder or map. end/or problems not addressed elsewhere.
*Direction From Observer - direction to stack,- use compass or map; Aoknowledgment - signature. title. and date of company official
be accurate to eight points of compass. acknowledging receipt of a copy of VE observation form.
‘Describe Emissions - include plume behavior and other physical ‘Observation Date - date observations conducted.
characteristics (e.g.. looping. lacy. condenstng. fumigating. secondary
particle formation, distance plume visible. etc).
*Emission Color - gray. brown. whzte. red. black- etc. ‘Start Time. Stop Time - beginning and end times of observation
period (e.g.. 1635 or 435 p.m.].
Plume Type: ‘Data Set - percent opacity to nearest 5Ok enter from left to right
Continuous - opacity cycle >6 minutes starting in left column.
Fugitive - no specificelly designed outlet
Intermittent - opacity cycle <6 minutes
l * Water Droplets Present - determine by observation or use wet sling ‘Average Opacity for Highest Period - average of highest 24
psychrometer; water droplez plumes are very white, opaque. and consecuzive opacity readings.
billowy in appearance. and usually dissipate rapidly.
**Jf Water Droplet Plume: Number of Readings Above (Frequency Count) - counz of total
Attached - forms prior to exiting stack number of readings above a designated opacity.
Detached - forms after exiting stack
“Point in the Plume at Which Opacity was Determined - describe ‘Range of Opacity Readings:
physic81 location in plume where readings were mdde (e.g.. 4 in. above Minimum - lowest readrng
stack exit or 10 it after dissipation of water plume]. Maximum - highesz reading
“Describe Background - object plume is read-against. include ‘Observer-s Name - prinz in full.
atmospheric conditions (e.g.. hazy).
‘Background Color - blue. white. new leaf green. ezc. Observer’s Signature, Date - sign and date after performing final
cakulations.
‘Organization - observer’s employer.
‘Certifier. Date - name of “smoke school”cerzifyingobserverand

*hQuNed by Reference Method 9: other nems daze of most recent cenifrcazion.
suggested
‘“Requ:red by Melhod 9 only when panicular Verifier. Date - signature of person responsible for verifying
factor could affect the readtng observer’s calculatrons and daze of verification.
Figure 4.2. Reverse side of form. (Conzinuedl

VISIBLE EMISSION OBSERVA TION FORM
SOURCE NAME OBSERVA TION DA TE START TIME STOP TIME
START STOP \vS

DISTANCE FROM OBSERVE-
START
EMISSION COLOR
fTlVE 0 INTERMITTENT 0 l4
WATER DROPLET PLUME: 15
NO0 YES0 A TTACHEO 0 DETACHED 0
START STOP
DESCRIBE BACKGROUND 18 48
START STOP
BACKGROUND COLOR 19 49
START STOP 20 . 50
WIN0 SPEEO \ +‘.“O DIRECTION 21 51
1 I I I I 1 1 I
22 t 52 1 I I
X Emrssron Point
0
-------m----r
Sun Locarron Line MAXIMUM
COMMENTS OBSERVER’S SIGNATURE DA TE
I HAVE RECEIVED A COPY E OPACITY OBSERVATIONS

ORGANIZA
CERTIFIED
T/ON
BY
(K) OA TE
SIGNA TURE
TITLE DA TE VERIFIEO BY - OA TE
Figure 4.3. Funcrlonal sections of ws~bie emlss:on observatron form

Each major section of the form is Process Equipment (Required) - Enter characteristics of the point of release
discussed in the following text. A a description of the process of emissions from the source. The
short explanation of each section’s equipment that emits the plume or descripnon must be specific enough
purpose, a background explanation of emissions to be read. The description so that the emisston outlet can be
each data element, a description of should be brief but should include as distrngutshed from all others at the
the type of information being sought. much information as possible, as source. In subsequent enforcement
and in some cases, appropriate indicated in the following examples: proceedmgs, the observer must be
entries are included. These Coal-Fired Boiler certain of the origin of the emisstons
discussions are keyed to Figure 4.3 by #2 Oil-Fired Boiler that were being read.
corresponding capital letters, and it is Wood Waste Conical Incinerator Typical descriptions of the emission
clearly indicated whether information is Paint Spray Booth outlet include the color, geometry of
required or recommended. Primary Crusher the stack or other outlet, and the
Fiberglass Curing Oven location in relation to other
A. SOURCE IDENTIFKA TION. Provides Reverberatory Smelting Furnace recognizable facility landmarks. Any
information that uniquely identiiies Basic Oxygen Furnace special identification codes the agency
the source and permits the observer Operating Mode (Recommended) - or source uses to identify a particular
to locate or make contact with the stack or outlet should be noted along
Depending on the type of process
source.
equipment. this information may vary with the source code used by the
Source name from a quantification of the current observer. The source of this
operating rate m a description of the information should be recorded (e.g..
portion of a batch-type process for plant layout map or engineering
1
Address which the emission opacity is being
read. For example, entries could
drawing).
Height Above Ground 1 eve/ (Required)
include “90 percent capacity” for a - Indicate the height of the stack or
boiler or ‘85 percent production ,rate” other emission outlet from its
for the shakeout area of a grey iron foundation base. This information is
foundry. For a steel making furnace, usually available from agency files,
entries would include the exact part of engmeering drawings, or computer
the process for which readings are printouts (such as NEDS printouts),
being made, such as “charging’. or The information also may be obtained
“tapping.” In some cases, the by using a combination of a
observer may have to obtain this rangefinder and an Abney level or
Source Name (Required) - include the information from a plant official.
source’s complete name. If necessary clineometer. The height may also be
for complete identification of the Control Equipment (Required) - Specify esttmated.
facility, the parent company name, the type@) of control equipment being Height Relative zo Observer (Requited)
division. or subsidiary name should be used in the system after the process - lndrcate an estimate of the height of
included. equipment in question (e.g., “hot-side the stack outlet (or of any other type
Address (Required) - indicate the electrostatic precipitator”). of emission outlet) above the position
street address of the source (not the Operating Mode (Recommended) - of the observer. This measurement
mailing address or the home office Indicate the degree to which the indtcates the observer’s position in
address) so that the exact physical control equipment is being utilized at relation to the stack base (i.e., higher
location of the source is known. If the time of the opacity observations or lower than the base) and may later
necessary, the mailing address or (e.g.. 76% capacity. full capacity, shut be used in slant angle calculations
home office address may be listed down, off line) and the operating (see Section 3.12.6 and Subsection
elsewhere. mode (e.g., automatic). The observer 4.4.6) if such calculations become
City, State. Zip. Phone will probably have to obtain this necessary.
(Recommended) - Self-explanatory. information from a plant official Distance From Observer (Required) -
Source ID Number (Recommended) - Record the distance from the point of
C. EMISSION POINT IOENTIFICA TlON
This space is provided for the use of observatron to the emission outlet.
Contains information uniquely
agency personnel and should be used Th1.s measurement may be made by
identifying the emission point and
to enter the number the agency uses its spatial relarronshrp wrth the usrng a rangefinder. If necessary, a
to identify that particular source, such observers poshion. map also may be used to estimate the
as the State file number, Compliance distance.
Data System number, or National ~-- It IS important that this
Emission Data System number. Describe emission point measurement be reasonably accurafe
Starr stop
if the observer is close to the stack
B. PROCESS AN0 CONTROL DEVICE (withzn 3 stack heights) because it is
TYPE. Includes a several word
Herght above Hetghr relatrve coupled with the outlet height relative
descriptor of the process and control
ground level to observer to the observer to determineThe slant
device. indication of current process
angie at which the observations were
operating capacity or mode. and
operational status of control Start stop Start stop maae (see Figure 4.4). A precise
eouioment. Oisrance from Olrecrlon from determlnatcon of the slant angle may
observer observer beccme important in calculating any
111
Process equipment Operating mode
pos~:~ve bias Inherent In the OPaCitY
Jrarr stop SWI slop reac’ngs.
Du=- --‘/on1 From Observer (Requtred) -
Describe Er+ssion Point (Required) . Sper iv the dIrectcon of the emission
Include the identifyrng physical POI-: irom the observer to the closest
of the eight points of the compass behavior. The behavior can be used to Plumes containing condensed water
(e.g., S, SE, NW. NE) or 4!7. Use of a determine the atmospheric stability on vapor (or “steam plumes”) are usually
compass to make this determination the day of the opacity observations. very white, billowy, and wispy at the
in the following manner is suggested: Emission Color (Required) - Note the point of dissipation, where the opacity
hold the compass while facing the color of the emissions. The plume decreases rapidly from a high value
emission point; rotate the compass color can sometimes be useful in (usually 100%) to 0 percent if there is
until the North compass point lies determining the composition of the no residual opacity plume contributed
directly beneath the needle (which emissions and will also serve to by contaminate in the effluent.
will be pointing towards magnetic document the total contrast between To document the presence or
North); then the point of the compass the plume and its background as seen absence of condensed water vapor in
closest to the emission outlet will by the opacrty observer during the the plume, the observer must address
indicate the direction (Figure 4.5). A observation period. two points. First, is sufficient moisture
map (plant layout) also may be used to Plume Type (Recommended) - Check present (condensed or uncondensed)
make this determination. “continuous” if the duration of the in the plume initially? Second, if
Describe Emissions (Required) - emissions being observed is greater enough moisture is present, are the
Include both the physical than 6 minutes. Check “intermittent” in-stack and ambient conditions such
characteristics of the emissions not if the opacity cycle is less than 6 that it will condense either before
recorded elsewhere on the form and minutes. Check ‘fugitive” if the exiting the stack or after exiting (when
the behavior of the resultant plume. emissions have no specifically it meets with the ambient air)? The
The description of the physical designated outlet. - first question can be answered by
characteristics might include terms Water Droplets Present (May be examining the process type and/or
such as lacy, fluffy, and detached required) - Check “yes” or “no” as the treatment of the effluent gas after
nonwater vapor condensibles. appropriate. In some cases, the the process. Some common sources
The terminology illustrated in Figure presence of condensed water vapor in of moisture in the plume are:
/
4.6 can be used to describe plume the plume can be easily observed. Water produced by combustion
-./w--I
of fuels,
0’
\ 1/ Water from dryers,
-0 ‘T
L’ - Observer Path Length
Water introduced by wet
L - Actual Path Length
scrubbers,
I.’ Water introduced for gas cooling
0’/L
Ill
Height prior to an electrostatic
,
/
/
Relative
Observer
to
4-t precipitator.
device, and
or other control
Observer ,/ ’ Slant
/
,
/
/ ’ Stack
0 Stack Water used to control the
temperature of chemical
~7 450 Angle
reactions.
---- If water is present in the plume,
+-- data from a sling psychrometer, which
Distance from observer
measures relative humidity. in
combination with the moisture
Figure 4.4. Slant angle relationships.
content and temperature of the
effluent gas can be used to predict
whether the formation of a steam
plume is a possibility (see Section
3.12.6).
If Water Droplet Plume: (May be
Stack
Observer required) - Check “attached” if
-------------------
n
t ----- ---------- condensation of the moisture
contained in the plume occurs within
the stack and the steam plume is
visible at the stack exit. Check
“detached” if condensation occurs
Compass
some distance downwind from the
stack exit and the steam plume and
Figure 4.5. Direction from observer is NE.
the stack appear to be unconnected.
Point in the Piume at Which Opacity
was Determined (May be required) -
Describe as succinctly as possible the
D. EMfSSIONS DESCRIPTION. Includes physical location in the plume where
information that definitely
the observations were made. This
establishes what was observed
while making the vrsible emrsslons description is especially important in
rr lE:EE
/
determinatron the case where condensed water
vapor and/or secondary plume is
present. For example, were the
readings made prior to formation Of
Point in the plume at which opacity was the steam plume? If the readings were
made subsequent to dissipation (e.g..
in the case of an attached steam
i;-
c Coning
Figure 4.6. Plume behavior descriptors.
plume). then specify how far

downwind of the dissipation point and
how far downwind of the stack exit
the reading was made. This
information can be used to estimate
Area of Steam
the amount of dilution that occurred
prior to the point of opacity readings. I Condensation
Descriptions such as 4 feet above

outlet and 80 feet downstream from
outlet, 10 feet after steam dissipation
are appropriate.
figure 4.7 shows some examples of
the correct location for making opacity
readings in various steam plume and
/ secondary plume situations.
Q*. Describe Background
Describe the background
(Required) -
that the
plume is obscuring and against which
the opacity is being read. While
describing the background, note any
imperfections or conditions, such as Area of Steam
texture, that might affect the, ease of 1 Condensation
making readings. Examples of
background descriptions are roof of Detached steam plume. In Read Here -.\rf.;;;::-.::.:
*..*.-*‘..:**.:
.::..-.
::. *-
roof monitor, stand of pine trees, edge
of jagged stony hillside, clear blue sky,
rare cases. it may be
necessary to make readings
(preferred)
\
stack scaffolding,
obscured by haze.
Background
and building
Color (Required) -
at the point of steam
sipation
more opaque
if the plume is
dis-
a2 that point.
t Or-Here
Point of Steam
Dissipation
Accurately note the background color

(e.g., new leaf green, conifer green,
brick red, sky blue, and gray stone).
E. OBSERVATION CONDITIONS.
Covers the background and ambient Area of Steam
weather conditions that occur during Secondary Plume Formation
Condensation
the observation period and could I
affect observed opacity.
Plume from a sulfuric acid
Describe background plant with detached steam
I plume. Plume is clear at
Start stop stack exit. Secondary acid
Background color Sky conditions mist is formed in area of
Start Star, Start Stoo steam condenserion.
Windspeed Wind direction
Start Stop 1 Start stop
Ambient temp.1 Wer bulb1 Relative humidity
Start Stop temp.
I Figure 4.7. Location for reading opacity under various conditions.
Sky Conditions (Required) - Indicate the wind direction at the observation F. OBSERVER POSITION AND SOURCE
the percent cloud cover of the sky. point may be different from that at the LA YOUT. Clearly identifies the
This information can be indicated by emission point; the wind direction at observeri position in relation to the
emission point. plant landmarks.
using straight percentages (e.g., 10% the emission point is the one of
topographic features. sun position.
overcast, 100% overcast) or by interest. and wind direction.
description. as shown below. Ambient Temperature (Required) - The
outdoor temperature at the plant site Draw North Arrow
Term
Clear
Amount of cloud
<lO%
cover is measured by a thermometer
degrees Fahrenheit or centigrade)
(in I 0
Scattered loo/o to 50% obtained from a local weather bureau
X Emission Point
Broken 50% to 90% or estimated. Be certain to note which
I
Overcast temperature scale is used. This is
done in conjunction with the wet
Windspeed (Required) - Give the bulb temperature and is only needed
windspeed accurately to f5 miles per when there are indications of a
hour. The windspeed can be condensing water droplet plume.
determined using a hand-held Wet Bulb Temperature (May be
anemometer (if available), or it can be required) - Record the wet bulb
estimated by using the Beaufort Scale temperature from the sling
of Windspeed Equivalents in Table psychrometer. .Thii-is to be-done’only Source’Layoiri Sketch (Required) -
4.1. when there are indications of a This sketch should include as many
Wind Direction (Required) - Indicate condensing water droplet plume. landmarks as possible. At the very
the direction from which the wind is Relative Humidity (May be required) - least, the sketch should locate the
blowing. The direction should be Enter the relative humidity measured relative position of the observed outlet
estimated to eight points of the by using a sling psychrometer in in such a way that it will not be
compass by observing which way the conjunction with a psychrometric confused with others at a later date,
plume is blowing. If this type of chart. This information can be used to and clearly locate the position of the
estimation is not possible, the determine if water vapor in the plume observer while making the VE
direction may be determined by will condense to form a steam plume readings. The exact landmarks will
observing a blowing flag or by noting (see Section 3.12.6). If a sling depend on the specific source, but
the direction a few blades of grass or psychrometer is not available, data they might include:
handfull of dust are blown when from a nearby U.S. Weather Bureau l Other stacks
tossed into the air. Keep in mind that can be substituted 0 Hills
0 Roads
Table 4.7 _ The Beaufort Scale of Windspeed Equivalents 0 Fences
0 Buildings
Limits of velocity 0 Stockpiles
General 33 ft (70 m) above 0 Rail heads
description Specifications level around, mph 0 Tree lines
Calm Smoke rises verticaliy Under 1 0 Background for readings
Direction of wind shown by smoke To assist in subsequent analysis of .
drift but not by wind vanes 1 to3 the reading conditions, sketch in the
Light Wind felt on face: leaves rustle; plume (indicate the direction of wind
ordinary vane moved by wind 4 to 7 travel). -The wind directi-on also must
be indicated in the previous section.
Gentle Leaves and small twigs in constant
motion; wind extends light flag 8to 12 Draw North Arrow (Recommended) -
Moderate Raises dust and loose paper; small To determine the direction of north,
branches are moved 13 to 78 point the line of sight in the source
Fresh layout sketch in the direction of the
Small trees in leaf begin to sway;
crested wavelets form -on inland actual emission point. place the
compass next to the circle and draw
waters 19 to 24
an arrow in. the circle parallel to the
Large branches in motion; whislling compass needle. A map (plant layout)
heard in telegraph wires: umbrelias may also be used to determine
used with difficulty 25 to 31 direction north.
Strong Whole trees in motion; inconven- Sun’s Location (Recommended) - It is
ience felt in walking against the important to verify this parameter
wind 32 to 38 before making any opacity readings.
Twigs broken off trees; progress The sun’s location should be within
generally impeded 39 to 46 the 140° sector indicated in the layout
Gale Slight structural damage occurs sketch: this confirms that the sun is
(chimney pots and slate removed) 47 to 54 within the 1 40° sector to the
Trees uprooted; considerable observer’s back.
To draw the sun’s location, point the
structural damage occurs 55 to 63
line of sight in the source layout
Whole gale Rarely experienced accompanied sketch in the direction of the actual
by widespread damage 64 to 75 emission point, place a pen upright
Hurricane Above 75 along the .‘sun location line” until the
shadow of the pen falls across the Signature (Recommended) - This

observer’s position. Then draw the space is provided for the signature of
sun at the point where the pen a plant official who acknowledges that
touches the “sun location line.” he/she has received a copy of the
observer’s opacity readings. His/her
G. COMMENTS. includes all
implications. deviations.
signature does not in any way
disagreement with plant personnel indicate that he/she or the company
and/or problems of a factual nature concurs with those readings.
that have bearing on the opacity Title (Recommended) - Include the
observations and that cannot be or Average Opacity for the Highest
acknowledging official’s company title. Period (Required) - Enter the average
have not been addressed elsewhere
Dare (Recommended) - The company of the sum of the highest 24
on the form.
official should enter the date of consecutive readings (6-minute set).
acknowledgment. In other words. identify the 24
1
Comments
i. DATA SE?.
observation
Opacity
period.
readings
organized
for
by
the consecutive readings that would sum
to the greatest value and then divide
minute and second. This section this value by 24 to get the average
also includes the actual date and opacity for that set of readings. Note:
start and stop times for the The average should not include a time
Comments (May be required) - Note ob?ervation period. lapse for which a valid reading could
all implications, deviations, have been taken but was not (see
disagreements with plant personnel, Section 3.12.6).
or problems of a factual nature that Number of Readings Above . ..% Were
cannot be or have not been addressed . . . (Recommended) - Indicate an
elsewhere on the form. Examples of optional frequency count of the
points to be included in this section opacity readings above a particular
are: value. The value is chosen according
0 Changes in ambient conditions to the opacity standard for the
from the time of the start of emission point and is generally the
readings. actual value of the standard.
l Changes in plume color, Method 9 does not specify the use
behavior, or other characteristics. Observation Date (Required) - Enter of frequency counting to reduce data.
l Changes in observer position and the date on which the opacity but many States use it to determine
reasons for the change; a new observations were made. compliance with their time exemption
t’ form should also be initiated in Start Time. Stop Time (Required) - opacity standards. For example, a
this case so that a new source Indicate the times at the beginning State regulation might specify that
layout sketch may be drawn. and the end of the actual observation opacity of a specific type of emission
l Difficulties encountered in plant period. The times may be expressed in source is not to exceed 20 percent for
entry. 1 ‘L-hour or 24-hour time (i.e., 8:35 more than 3 minutes in an hour. If
l Conditions that might interfere a.m. or 0835); however, 24-hour time more than 12 readings out of 240
with readings or cause them to tends to be less confusing. exceed 20 percent in an hour-long
be biased. Data Set (Required) - Spaces are observation period, that State may
l Drawing of unusual stack provided for entering an opacity consider that source out of
configuration (to show multiple reading every 15. s for up to a. 1 -hour compliance. For example.
stacks or stack in relation to roof observation period. The readings 14 readings out of 240 readings (1
line). should be in percent opacity and hour) are above 20 percent opacity
l Suspected changes to the made to the nearest 5 percent. The 14~15sperreading=210s
emissions or process during readings are entered from left to right = 3.5 minutes of readings above the
observation. for each numbered minute, beginning standard.
l Unusual process conditions. at the upper left corner of the left- Range of Opacity Readings (Required)
l Additional source identification hand column. labeled row “M 1” - Enter the highest and lowest opacity
information. (minute 1) and column “s 0” (0 readings taken during the specified
l Type of plant (if not specified seconds). The next readings are observation period.
elsewhere). entered consecutively in the spaces K. OBSERVER DA TA. Information
l Reasons for missed readings. labeled M 1. s 15; M 1, s 30; M 1. s required to valrdate the opacity data.
0 Other observers present. 45: M 2. s 0, M 2. s 15, etc.
If. for any reason. a reading is not ObserverP name {print)
H. COMPANY ACKNOWLEDGEMENT.
made for a particular 15-second
Company acknowledgement of. but
period. that space should be skipped
not necessarily agreement with. the Observer’s signature Date
opacity observations stated on the and an explanation should be provided
form. in the comments section. Also a dash
(-) should be placed in the space Organization
I have received a copy of these opacity which denotes that the space is not
lust an oversight.
Cerrrfied by Date
J. DA TA REDUC T/ON Baste analysts of
rhe opacrfy readmgs to allow r
prelrminary compliance appraisal m LIerifted by Date
accordance wrth EPA Reference
Method 9. L
ObserverS Name (Required) - Print Conditions should be recorded as they 2. Obtain a clear view of the
observer’s entire name. existed at the time of the observation. emission point with no
Observer’s Signature/Date The use of a 35-mm camera is interfering plumes.
(Recommended) - Self-explanatory. recommffnded to ensure good 3. Be sure that rectangular stacks
Organization (Required) - Provide the photographs. are read across the narrow axis
name of the agency or company that Each photograph should be identified and multiple stacks are read
employs the observer. with the date and time, the source. perpendicular to the line of
Certified By (Recommended) - Identify and the position from which the stacks.
the agency, company, or other photograph was taken. 4. Minimize the slant angle by
moving a sufficient distance from
organization that conducted the
“smoke school” or VE training and the stack or to an elevated
4.4 Special Observation Problems
certification course where the position (see Subsection 4.4.4).
The VE observer constantly should
observer obtained his/her most be aware that his/her observations 5. Find a contrasting background or
current certification. may be used as the basis of a a clear sky background.
Date (Required) - Provide the date of violation action and subject to 6. Finally, determine the best time
the most current certification. of day for observations based on
questioning as to the reliability of the
By (Recommended) - The the daily sun tracks at that
Verified observations. Therefore, he/she must
actual signature of someone who has also be aware that under some location.
verified the opacity readings and conditions or situa!/ons it may be Collaborative studies of the
calculations, usually the observer’s difficult or impossible to conduct a performances of trained observers
supervisor, or the individual who is technically defensible visible have indicated that. with the
responsible for his/her work. emissions observation. exception of the positive bias caused
Date (Recommended) - Provide the This section discusses some of the by having the improper sun angle,
date of verification. most prevalent difficult conditions or visible emission observation biases
special problems associated with the tend to be negative. Thus, if viewing
4.3.3 Facility Operating Data - It is visible emission observation. Each conditions are not ideal and a
strongly recommended that a VE discussion is directed toward defining negative bias (lower value) results,
inspection/observation conclude with the problem, indicating how it might opacity readings may not provide the
a source inspection if opacity values invalidate readings taken, and true measure of plume opacity
are in excess of the standard. The addressing possible solutions and/or required to correlate to mass
observer would first follow the plant ways to minimize the invalidating emissions or control equipment
entry procedure in Subsection 4.1 and effects. efficiency. However, readings that
then follow the indicated procedure to Not all of these discussions offer a indicate a violation can be regarded as
obtain facility operating data. complete solution for a particular the minimum opacity; therefore,
problem; thus, it is important for the documentation of the violation is
After the VE determination, it is individual observer to keep in niind
recommended that the following valid.
the purpose of the visible emission In situations where the observer
source information be determined: observation when considering exactly
1. Were the plant and the source of must make plume opacity readings
what action to take when faced with a when all the criteria for correct
interest operating normally at the special problem.
time of the VE evaluation? viewing cannot be met, all
2. Are there any control devices extenuating circumstances must be
4.4.1 Positional Requirements - documented on the VE evaluation
associated with the source?
3. Were the control devices Valid VE evaluations can be _ form- .
operating properly? conducted only when the sun is
4.42 Multiple Sources/Multiple
4. Have there been any recent properly positioned at the observer’s
Stacks - An observer is sometimes
changes in the operation of the back. Failure to adhere to this
compelled to evaluate a stack that
process or control devices? positioning can result in significant
discharges emissions from more than
5 Have any malfunctions or positive bias caused by forward light
one source or to evaluate a single
frequent upsets in the process or scatter in opacity readings. Because of
source that has more than one
control devices been noted and this overriding constraint. some times
emission point.
reported (if required by the and locations make it difficult for the
In the case where one stack serves
agency)? observer to meet other opacity reading
more than one emission source, the
6 Is the plant operator aware of criteria, e-g-. reading the narrow axis
observer may be abte to isolate the
excessive visible emissions and of a rectangular stack reading a
emissions from one source as a result
have any corrective steps been series of stacks across a short axis to
of intervals of operation, or by
taken to alleviate the problems? prevent multiple plume effects, and
requesting the facility’s cooperation in
obtaining a contrasting background.
.7 Are there any other sources of temporarily shutting down the other
visible emissions in close Plant topography also may generate source(s). Otherwise, the observer
proximity to the source in constraints that restrict viewing
should proceed with the VE
question that may interfere with positions to one or more locations.
observation and document the
reading the plume opacity or The observer will be aided in
situation completely on the VE
contribute to the appearance of determining the best observation
evaluation form.
the plume? location by following the criteria listed
below. In the case of multiple emission
4.3.4 Photographs - It is suggested points for a single source (e.g., in
that photographs be taken before and 1. Make sure that the emission positive-pressure bag houses and
after the observation IS made, not point is north of the observation multiple vents in roof monitors).
during the observation period. point. Section 2.1 of Method 9 directs the
April 1983 15 Section 3.1.2.4
observer to read multiple stacks suspended until the wind-caused When faced with a situation where
independently if it is possible to do so interferences have abated. there is a choice of backgrounds, the
while meeting sun position observer should always choose the
requirements. If it is necessary to get 4.4.4 Poor Lighting - Poor lighting one provldmg the highest contrast
an overall reading for the group of conditions for VE observations usually with the plume because it will permit
stacks, the following set of formulas involve one or mqre of the following: the most accurate opacity reading.
can be used to calculate this reading (1) a totally overcast sky, (2) early However. if a situation arises where
from the individual opacity values. morning or late afternoon hours, or (3) other constraints make it impossible
nighttime. Each of these three lighting to locate an observation point that
1 -&=T, conditions has the same net effect on provides a high contrast background;
100 the plume: they differ slightly only in the observer may read against a less
the cause of the poor illumination. contrasting one with confidenck that a
1 -&=Tz When the amount of available documented violation should be
100 sunlight is below a certain level, the legally defensible.
contrast between a white plume and 4.4.6 Reduced Visibility -
1 -ON=TN the background decreases. Therefore,
Environmental factors at the time of
loo readings are not recommended in observation also are of concern to
either the early morning hours (at or the visible emissions observer.
T, x T2 x ._.. TN = Tt approaching dawn) or la{~~~aft,qn,oon. Environmental considerations include
hours (at or approaching dusk). rain, snow, or other forms of
100x(1 -Tr)=Or Nighttime viewing obviously precipitation, and photochemical smog
represents the most severe of poor buildup, fog, sea spray, high humidity
lighting conditions. Some agencies levels. or any other cause of haze.
where have attempted, with mixed results, to These environmental factors create a
0, = % opacity of 1 st plume use night vision devices (light
visual obscuration that can increase
02= % opacity of 2nd plume intensification scopes) for plume
the apparent opacity of the plume, but
ON= % opacity of nth plume viewing and testing in the dark.
more commonly reduce the
T, = Transmittance of 1st plume Others have achieved better results by background contrast and thus
T2= Transmittance of 2nd plume placing a light behind the emissions,
decrease the apparent opacity.
TN= Transmittance of nth plume which provides a very high contrast In recognition of the problems that
TT= Total transmittance background. For this method, it is could result from reduced visibility
OT= % total opacity important to select a source of light of caused by environmental factors, the
moderate strength that does not amended Method 9 (November 12,
cause the iris of the eye to close.
4.4.3 High Winds - Occasionally the 1974) states, in paragraph 2.1 of the
crosswind conditions are unfavorable Procedures Section: “The qualified
during field observations of plume 4.4.5 Poor Background - The color observer shall stand at a distance
opacity. When the winds are strong contrast between the plume and the sufficient to provide a clear view of
enough to shear the emissions at the background against which it is viewed the emissions ._.*’ A “clear view”
stack outiet, it is difficult for the can affect the appearance of the must be interpreted as a view free
observer to make an accurate and fair plume as viewed by an observer. Field from obstacles or interferences. Most
VE observation. Strong crosswinds studies have corroborated predictions problems caused by reduced visibility
can have several effects on the of the plume opacity theory by can be- alleviated simply by making
plume: demonstrating that a plume is most. the observations on another day.
I. The -plume becomes essentially visible and has the greatest apparent
flattened and is no longer conical opacity when viewed against a 4.4.7 Tall Stacks/Slam Angie -
in shape thus the path length contrasting background. When an observer’s distance from the
and apparent opacity increases. stack approaches l/4 mile
Consistent with these findings is
2. The plume is torn into fragments (approximately 1300 feet, or a little
the fact that with a high contrast
and becomes difficult to obtain a over four football fields), the ambrent
background, the potential for positive
representative reading. light scattering may begin to have an
observer bias is the greatest.
3. The plume becomes diluted, and adverse effect on the contrast
However, field trials consisting of 769
the apparent opacity is lowered. between the plume and the
sets of 25 opacity readings each have
background. Also, if the sky is
shown that for more than 99 percenr
The observer can compensate overcast or hazy on the day of
of the sets, the positive observer error
somewhat for the effect of flattening observation. the farther the observer
was no greater than 7.5 percent
by reading the plume downwind of is from the emission point. the more
- opacity.2
the stack, after it has reformed into a the haze interferes with the view of
cone. The dilution effect of high Also consistent with these fmdmgs the plume and hence, the less reliable
winds, which lowers the apparent is the fact that as the contrast the readings.
opacity, presents more of a problem. between the plume and Its On the other hand. the
Because of the negative bias background decreases, the apparent recommendation that the observer
introduced, the effectiveness of opacity decreases; this greatly stand at leas1 fhree stack heights from
Method 9 as a control tool under increases the chance for a negative the stack being observed is intended
these conditions is diminished. If a observer bias. Under these condlttons, to ensure rhat the width of the Plume
violation is still observed under these the likelihood lessens of a facility as it is viewed is approximately the
conditions, it should be considered bemg cited for a vlolarion of an same as it is at the stack outlet. As
valid. It is recommended that opacity standard because of observer the observer gets closer to the stack
whenever feasible, VE observarions be error. and the vlewlng (slant) angle
increases, the observed path length actual opacity, the observer must have l Wet scrubbers,
also increases; this causes the a visual slant angle of 18’ or less. 0 Water-induced gas cooling prior
observed opacity to increase because to an emissions control device,
4.4.8 Steam Plumes - Under certain
the observer is reading through more and
conditions, water vapor present in an
emissions. These relationships are 0 Water-induced chemical reaction
effluent gas stream will condense to
shown in Figure 4.8. At an observer cooling.
form a visible water droplet or “steam”
distance of three stack heights, which Also. observation of steam plumes
plume. Because the NSPS (specifically
corresponds to a slant angle of 18O. will reveal that they are usually very
Method 9) and almost all SIP’s
the deviation of observed opacity from white. billowy, and have an abrupt
exclude condensed, uncombined point of dissipation. At the point of
actual opacity decreases to 1 percent
water vapor from opacity regulations,
opacity, which is considered dissipation, the opacity generally
the VE observer must be careful that
acceptable (see Section 3.12.6). decreases rapidly from a high value
he/she does not knowingly read a
The three-stack-heights relationship (usually 100%) to a low value.
plume at a point where condensed
only occurs if the observer and the Depending on the moisture and
water vapor is present and record the
base of the stack are in the same temperature conditions in the stack
value as representative of stack
horizontal plane. If the observer is on and in the ambient air, steam plumes
emissions. may be either “attached” or
a higher plane than the base of the Knowledge of the kind of process
stack. then the minimum distance for “detached.‘* An attached steam plume
that generates the emissions being forms within the stack and is visible
proper viewing can be reduced to less read and simple observation of-the -- -
than three stack heights; conversely, at the exit; a detached steam plume
resultant plume almost always allows
if the observer’s plane is lower than forms downwind of the stack exit and
the observer to determine if a steam
that of the stack base, then the does not appear to be connected to
plume is present. Steam plumes are
minimum suggested distance will be the stack. In cases when it is not clear
commonly associated with processes
greater than three stack heights (see whether a steam plume is present or
or control equipment that introduce
Figure 4.8). The real determining when an observer would like to
water vapor into the gas stream.
factor is the slant angle. To assure no predict the formation of a steam
These sources include:
more than a 1 percent opacity plume, the stack gas conditions may
0 Fuel combustion.
deviation of observed opacity from be used in conjunction with the
l Drying operations,
ambient relative humidity to make the
prediction (see Section 3.12.6).
When a steam plume is present, the
particulate plume is read at a point
where 1) no condensed water vapor
exists, and 2) the opacity is the
greatest. In the case of a detached
T
H
steam plume, this point is usually at
the stack exit, prior to the water vapor
condensation; in the case of an
attached steam plume, it is usually.
slightly downwind
steam plume dissipation
of the point of
(for
examples, see Figure 4.7). The observer
should always carefully document the
point chosen.-
1
- Y=H - 4.4.9 Secondary Plume Formation -
Some effluent gas streams contain
I- Y=3H a-! species that form visible mists or
plumes by a physical and/or chemical
reaction that occurs either at some
point in the stack or after the
emissrons come in contact with the
atmosphere. This situation is known
as secondary plume formation.
Examples of such secondary plume
formation include:
0 A change in the physical state of

a compound condensing from a
gas into a liquid, such as
vaporized hydrocarbon
condensing into an aerosol or a
solid.
0 A physiocochemical reaction
berween two or more gaseous for
12 some cases, liquid) species in
I- 5H - a plume, such as the
condensation of ammonia. sulfur
Figure 4.8. Observer distance. observed path length relarlonshrps. czoxide, and water vapor to form
particulate ammonium sulfite or point of steam dissipation. A detached Changes that may occur in the
the condensation of sulfur secondary plume will usually be read airborne particulate pattern over
trioxide and water vapor to form slightiy downwind of the area of time are important to note and to
sulfuric acid mist. formation, assuming there is no consider in selecting a viewing
0 A physiocochemical reaction interfering condensed water vapor. point.
between species in a plume and Under some conditions. a secondary 6. Select the line of sight and the
species in the atmosphere, such plume may not fully condense until viewing point in the emissions so
as the formation of Nz03. some distance downstream of the that, on the average, the densest
Secondary plumes are sometimes point of formation; in this case, the part of the emissions will be
found in the following processes (with observer simply looks for the densest observed. It is recommended that
these suspected secondary reactions): area of the plume and makes the all subsequent readings in a data
0 Coal- and oil-fired cement kilns reading at that point. It is especially set be taken at the same relative
(SO3 + H20 - H&O. mist) important in reading a secondary position to the emission source.
or [NH3 + SO2 + Hz0 - formation plume to describe fully the 7. The configuration of the emission
WH4k SOal point at which the reading was taken point or area may necessitate
0 Fossil-fuel-fired steam and the exact appearance of the taking readings at a. point
generators (SO2 + HnO - H2S04 plume. (Refer to Figure 4.7 for one downwind where the emissions
mist) example of where to read a secondary have assumed a more
0 Sulfuric acid manufacturing (SO3 plume.) . - conventional. plume shape.
+ +I20 - HzSO~ mist) 8. If the plume cannot be viewed
4.4.10 Fugitive Emissions - Fugitive through a nearly perpendicular
0 Plywood and particleboard wood emissions are those emissions that do
heating (organic vapor - organic angle, corrections may be
not emanate from a conventional necessary.
mist) . smoke stack or vent. Examples of
0 Glass manufacturing (inorganic these nonconventional emissions
vapor - organic aerosol). include: 4.4.17 Intermitrent Sources - Some
As in the case of steam plumes, 0 Dusty or unpaved roads sources release visible emissions
secondary plumes can be attached or 0 Stock or raw material piles under intermittently rather than
detached, depending on the specific windy conditions or when moved continuously; e.g., coke ovens. batch
condensation reaction and the by machinery operations, single chamber
ambient conditions. For example, a 0 Conveyor belts, pneumatic lifts, incinerators. malfunctioning control
secondary plume will be attached if a clamshells, and draglines equipment (in rapping, bag shaking.
reaction between plume species l Cutting, crushing, grinding, and etc.), boilers during soot blowing, and
occurs in the stack and the stack sizing of minerals or other process equipment during startup.
temperature is sufficiently low to materials Intermittent emissions may have a
cause condensation of the reaction 0 Plowing, tilling, and bulldozing high opacity for a short time and a
products to a visible liquid or solid 0 Open incineration low or negligible opacity at other
phase. A detached secondary phtme l Demolition activities times. This high-low cycle may be
will be evident when the reaction 0 Roof monitors or building vents, repeated at fairly regular intervals. If a
does not occur until the gas stream especially in foundries, iron and source is in violation {or in continuous
comes in contact with the steel facilities, and related compliance) of the applicable standard
atmosphere. The degree of industries. over the 6-minute averaging time
detachment depends on the ambient Because of the irregular shape of required by Method 9. it does not
conditions, the degree of mixing their emission-point or area, - pose a problem to the visible
between the effluent and the conducting a conventional Method 9 emissions observer. If the pollutant-
atmosphere. and the specific test on fugitive emissions may appear emitting operational cycle of a source
reaction(s) involved. difficult: however, it usually involves is less than 6 minutes in duration,
Secondary plumes may occur with only relatively minor adjustments. however, that source may be out of
or without an accompanying steam Commonly used procedures for compliance only for a portion of each
plume, and it is important that the observation of fugitive emissions are 6-minute averaging period, which will
observer be able to distinguish listed below: make it difficult or impossible to
between the two. Unlike steam 1. If possible, isolate the particular document a violation if the data is to
plumes, secondary plumes are often emission from other emissions be reduced to a 6-minute average.
persistent (they do not dissipate by choosing an appropriate If the source is not covered by a
rapidly), are usually bluish white (due position for observation. NSPS or a State Implementation Plan
to the fine particles present), and are 2. Adhere to the lighting that specifies the explicit use of
grainy rather than billowy. requirements of Method 9 by Method 9 or another specified
To read a secondary plume, the keeping the sun in the 140° modification to Method 9. another
observer must locate the densest sector to the observer’s back. technique for reading intermittent .
point of the plume where water vapor 3. Also adhere to Method 9 in emrssions of less than a B-minute
is not evident a.nd make the readings selecting a position with regard duration is to use Method 9
at that point. This point may occur in to wind direction and a procedures but reduce the averaging
several different areas. depending on contrasting background. time to about 3 minutes. This
the type of secondary plume. An 4. Whenever possible, select the reductron will allow the observer to
attached secondary plume will usually shortest path length through the tally the number of 3-minute
be read at the stack exit if an attached plume. violations that occur. Analysis of
steam plume is not present; if an 6. Before taking readings, view the many data sets has confirmed that
attached steam plume is present, the emission for several minutes to using this method sacrifices little Or
secondary plume must be read at the determine its characteristics. no accuracy
In all cases where sources are not Table4.2. Activity Matrix for Visible Emission Determination
subject to NSPS or other federally Action if
Frequency and
promulgated standard, the existing requirements
Acceptance method of
State regulations and specified opacity Activity limits measurement are not met
observation methods (if any) must be
used. Two other techniques that have Perimeter survey Completed per- Prior to. follow- N/A
been used to document intermittent imeter survey ing, and during
emissions are the “stopwatch” (if warranted)
technique (measuring the total the VE deter-
accumulated time that the opacity mination
exceeds the applicable standard) and Plant entry Observer should Entry prior to N/A
the time-aggregate data reporting follow protocol taking VE read-
technique (taking readings every 15 as suggested in ings only if
seconds, tallying the number of Subset 4.2 and necessary; entry
readings exceeding the standard. and adhere to con- atier VE readings
multiplying this number by 15 seconds fidentiality of to provide plant
to determine the amount of time the data representative
source is out of compliance during the with data and/or
observation period). Many State to obtain neces-
agencies use these latter techniques, sary plant pro-
and have adopted their methods in cess data
their SIP rules and regulations. EPA VE Determination
currently has studies underway to I. Position in accordance Take a position Follow instruc-
evaluatethe accuracy and’reliability of with Subset for observation tions under
these nonaveraging techniques. 4.3.1 as described in special problems
Subset 4.3.7 (Subset 4.4)
and document when a proper
on data form position cannot
be assumed
2. Observations Taken in accord- Make VE deter- As above
ance with Sub- mination as
set 4.3.7 described in
Subset 4.3.1
3. Field data: VE Completed data Complete data Complete miss-
observation form form form as per in- ing data {if
structions and possible) or give
examples in rationale for in-
Subset 4.3.2 complete data
4. Facifit y operating Pertinent pro- After VE obser- Data must be
data cess data vations. obtain obtained as soon
obtained facility data per as possible after
Subset 4.3.3 VE observation
Special observativn- NfA Refer-to Subs& N/A
problems 4.4 when condi-
tions do not per-
mit VE observa-
tion under pro-
per position, etc.
N/A = not applicable.
5.0 Postobservation Operations

Table 5.1 at the end of this section large quantities of data and to avoid data validator. All corrections must be
summarizes the quality assurance calculation errors. initialed. The file copy should be
activities for postobservation signed by the data validator.
operations. These activities include 5.2 Reporting Procedures inspection forms alone may not be
preparation of reports and data Recording opacity observation data adequate for documenting an
summaries and validation. on a three-part form is most enforceable violation and can be
convenient. One part can be given to supplemented by a narrative report. It
5.1 Data Summary the appropriate facility personnel is recommended that a summary
The opacity observations are immediately following the on-site field report be made containing the
recorded on data forms such as those observation if this is the agency policy following information:
shown in Figures 4.1 and 4.2. Figure or procedure, one part should be
5.1 is a summary data form for 1. Name and location of facility,
given to the Agency. and one pan
date and time of inspection,
manual calculations. This form and should be maintained in the
the calculation procedures are observer’s file:*he data form-shoufd- name of inspector, and name of
discussed in detail in Section 3.126. company officiaffs) contacted.
be completed on-site. and it should be
It is recommended, however, that a signed by the observer, the facility 2. Brief description of the specific
computer be used when reducing representative (if applicable), and the process information gathered,
Start/ To!81 (Aver8gelSt8fz 1 Total IA

no. 0 eci 0 aci
37 73 109 145 181
38 74 110 146 182
39 is 111 147 183
40 76 112 148 184
41 77 113 149 185
42 78 114 150 186
43 79 115 151 187
44 FE 80 116 152 I 188
9 45 * 1 81 ! 117 153 189 ! i
118 154 190
11
10 47
46 83
82 119 155 191 8 I
12 48 84 1 192 I
120 156
13 49 85 121 157 193
14 50 86 122 158 194
15 51 87 123 159 195 I
16 2; 88 124 160 196 ’
17
18 54 89
90 125 161 197 I
126 162 198 I
19 55 91 127 163 * 199
20 56 92 128 164 200
21 57 -93 129 165 201
730 166 202
22
23 59
58 z 131 167 203
24 60_ 96 132 1i 168 204 !
^- f I
Lb I 2 97 ! 733 169 205
26 i 98 134 170 206
27 t 63 99 ’ 135 171 207
136 172 208
29
28 64
65 E 137 173 209
30 66 102 138 774 ‘210
31 67 103 139 175 211
32 68 104 140 176 212
33 69 105 141 177 213
34 70 706 142 178 214
35 71 107 143 179 215
36 72 108 144 180 276
Maximum average 36.8 % Start number of+ minute I
Number of nanOYe~fapp;ng-g_gVerages in excess of standard 3 Lisring average -
Starr nrmher of rhese averages -I/r. - 80./75
Calculated by V. t. frOf;fi j Di rre /meviewed by J h. RE vEWF R Dare UJfl&r&
Figure 5.1 Visible emission summary data sheer.
particularly any unusual 5.3 Data Validation indication of equipment

occurrences. All opacity observation data damage/malfunction should be
3. Description of the equipment that obtained for compliance determination recorded on an equipment log and
was inspected and its operating should be validated by senior staff noted for purposes of data validation.
mode at the time of inspection. assigned this responsibility. Data The malfunctioning equipment should
4. Notation of any excessive validation procedures are described in be repaired. adjusted, or replaced so
emissions seen and References 16 and 17. These data that the equipment will be available
corresponding data from opacity should be checked to the extent for subsequent on-site field
continuous emissions monitor if possible for their completeness, the observations.
available. correctness of source, the emission
5. Explanation of excessive point and description, the background,
emissions. if available, and and the process and control
corrective actions being taken. equipment in use. The calculation of
6. Summary of emission points not the average opacities and highest
in compliance. average opacity also should be
7. Recommendations for followup checked. All calculation checks should
action. agree within acceptable roundoff
One copy of the report, an updated errors. If possible. any questionable
plot plan. photographs, and other data should be reviewed with-the--~-
peninent data should be placed in the observer. ideally the data validation
Agency file. Whenever a vioiation is should occur as soon as possible after
noted, it is EPA policy to notify the the observations are recorded so that
facility of the alieged violation and to questions may be resolved. Any other
permit them to review the evidence calculations made for the purpose of
against them in a meaningful way. supporting the data (e.g., the effect of
The importance of a good file cannot angle of observation on the observed
be overstated. This file represents the opacity) should also be verified. Note:
official Agency documentation of Any corrections in the data must be
compliance history, the latest forwarded to all interested parties so
information on the source’s operation that they may correct their records (a
and compliance status. The file also data form should have been given to
provides the means of communicating them after the opacity observations
source conditions to other staff were completed).
members. A thorough and accurate
historical record on source inspections 5.4 Equipment Check
and opacity readings is essential to A check of the equipment following
good operation and any necessary the opacity observations helps to
compliance/enforcement actions. ensure the quality of the data. Any
Table 5.1_ Activity Matrix for Postobservation Operations

Acceptance method of .. requiremenfs-
_ Data summary Completed data See Subsec Complete the
form 3.726 for in- data summary
structions for
calculations
Reporting procedures Completed re- Use 3-part form Complete the
pan and data as suggested in necessary data
forms Subsec 5.2 forms and re-
porting proce-
dure
Data validation A It checks Make data valid- Forward all
should agree ation check as corrections of
within accept- soon as possible the data/calcul-
able roundoff _ after VE obser- ations to the
error vation interested
parties
Equipment check A II equipmeml Check equip- Note on equip-
apparatus ment for ment log and
should be damage/mal- repair, adjust or
checked for sat- functions replace the
isfactory opera- equipment
tion after each
VE observation
day
6.0 Calculations
Three types of calculations are Determination of the running computer can bracket intervals tn
described in this section: (1) the average is generally performed by excess of the standard.
calcuiation of the average opacity for computer or by a hand calculator. The 6.1.2 Use of Hand Calculator for
the specified time period (usuahy 6 main purpose of the calculations is to Calculations - When a hand calculator
min. or 24 observations recorded at determine the number of 6-min is used, the calculation procedures
15-s intervals), (2) the calculation of periods in excess of the standard and are the same as those for the
the path length through the plume the greatest value for any 6-min computer, except that they must be
(seldom needed), and (3) the period. It is also suggested, but not performed manually. All data should
prediction of steam plume formation required, that the opacity readings be be recorded on the VE Summary Data
(seldom needed). In the first plotted on a graph showing percent Sheet (see Figure 6.2) if desired. To
calculation, the &min running (or opacity versus time, with a straight avoid calculating average opacity
rolling) averages may be required. To line connecting each subsequent values that are less than the standard,
minimize errors in the calculations, reading. the following procedure can be used.
another individual should check all The total value for the 24 readings
calculaions for each VE 6.1. I Use of Computer for should be calculated first, and the
determination for compliance. If a Calcutations - It is highly total opacity should be entered at
difference greater than a typical recommended that a computer ba Start no. 1.
roundoff error is detected, the used to calculate and plot data. Each succeeding total value can be
corrections should be made and Programming will vary with the obtained and recorded by adding the
initialed by the one making the language used by the particular difference between the value dropped
correction. Table 6.3 at the end of this computer, but the basic principle is as and the one added. These calculations
section summarizes the quality follows: can be performed easily without a
assuranoe activities for these Input: calculator. If desired, the average
calculations. 1. Enter all VE readings with their opacity reading could then be
corresponding start number or calculated only for those totals that
6.1 Calculation of Average identifying start time. exceed the total allowable opacity
Opacity’ Computatiorr limit (e.g., 20% x 24 = 480). Therefore,
C’ Figure 6.1 shows actual opacity 1. The first average opacity reading a total opacity of 480 or greater would
data taken at one company is obtained by averaging the first be an exceedance of a 20 percent
i (unspecified) for two 6-min periods. 24 opacity readings. opacity standard. Method 9 does,,
Note: Any corrections made by an 2. Each succeeding running however, require that the accuracy of
observer must be initialed and the average is obtained from the the method be taken into account
corrected value used in the previous one by adding the next when determining possible violations
computation of an average. The observation reading and of applicable opacity standard.
calculations can be checked by subtracting the first observation It is suggested that when the
obtaining the row and column in the series and then dividing by opacity standard has been exceeded
subtotals; the totals of these subtotals 24 (assuming 6-min running for any 24 consecutive readings, the
must be identical. average). data .be hand-plotted with each VE
Running 6-min averages are Printout reading versus its time interval. These
calculated from data on Figure 6.2 1. The computer should print all VE plots fit best on graph paper scaled 10
and reported as described below. readings with their iines to the inch. Each 15second
Running averages can include a time- corresponding number or time. reading can be plotted at l/2 spacing,
lapse break in opacity readings when This printing will ensure that all thereby allowing 20 readings per inch.
caused by an element that makes taking readings have been entered If desired, intervals of opacity in
a valid reading difficult (e.g., fugitive properly. excess of the standards can be
emissions, improper background, or 2. The computer should search all marked on this plot. It is much easier
process shutdown). Running averages averages and print the highest to visualize a trend in opacity with
should not contain time-lapse breaks average opacity and its time with such a graphical
in the readings as a result of the corresponding number or time presentation than with tabulated
observer’s desire not to take visible interval. numerical readings as shown in
emission data for personnel reasons 3. Starting at the first interval, the Figure 6.4.
when conditions exist that would computer should search for all
allow the observer to take valid nonoverlapping 6-minute periods
in excess of the standard. Each 6.2 Calculation of Path
opacity data (e.g., eye strain or no
desire to continue readings). Figure interval’s average opacity value Length Through the Plume
6.3 is included to provide an easy and corresponding number or The observer should be located so
reference between the VE reading time should be printed out thal only one plume diameter is being
time on Figure 6.1 and the start 4. Finally the computer should plot sghted through. In rare cases, the
number on Figure 6.2. The start VE readings versus time observer has no choice but to be
b, numbers are used to find the intervals. If the computer has a relarrvely close to the stack so that the
I. __ corresponding observation time for plotter, it should be used. If not. view is up through the plume rather
the beginning of the calculated six the values can be plotted without than across it. In these cases, this
minute average. connecting lines. If desired. the extra width of plume should be

AWIIRAL POWER ?LAEsr lSJULYl98L /330 l35J.2
ADDRESS \ C.cPI I
l/L OCEM Jw+D 1,,x1
(W###. \1 ”n ,,5
I I 30 0 15 30 45
1 30 35 55 5.5 3’
2 559 40 30 32
PHONE SOURCE ID NUMBER 3 35 35 3s 35 33
80+&5-510) NE05 4sia 4 30 35 5555 34

PROCESS EQUIPMENT
OIL m!ED t36lLc.E O~RER;G&DE 5 30 3yso 30 35
1 HEIGHT
START/@ ABOVE ’ GROUND
STOP r/ LEVEL1 1HEIGHT RELA TIVE TOOBSERVEij 9 - m..w- ,.-, &/55 (& - 39 1.
DISTANCE FROM OBSERVER 1 ‘O 15o)ys135 30 40 1
START 400’ STOP,/ START NhfE STOP ,/ 11 30 ~~~ 41

I
DESCRIBE EMISSIONS 1
START fQJ=--NG P&ESTOP l2 jo 30 30 30 42

-
” FUGITIVE
PLUME TYPE:
D tNTERMITTENT
CONTINUOUS rd
0 l413 44
43
WATER DROPLETS PRESENT: IF WATER DROPLET PLUME: 15
START /o ‘.t= =9?&%8(‘GTOP

DESCRIBE BACKGROUND
START tiui= STOP

WIND SPEED WIND DIRECTION
START /smph STOP w START sd STOP
AMEIENT TEMP.
STARTdS”f STOP /
source Lwout Sketch
. . . ..- -
--.. I
~l..-~ *“,+ = 1 Observers Position 1 A VERAGE 01
OBSERVER-S NAME (PRINT)
COMMENTS DA TE
15 JULY 8L 1
ORGANIZATION
3riW-tZ Art?fQ!U?-i~Ot~ COJTRDC@At=
Figure 6.1. Vtsibie emrssron observation form.

Visible Emission Summary Data Sheet
-
Szartl Total IAverage IStart Total Average Starr Toral Average itaft
no. Op8City OP8CilY I 70. Op8Cily Op8Cfty no. Op8Cify opactr y no.
-
7 085 36-B 37 73
2 g~$ 36-B 38 74
3 g00 36dG 39 75
I
4 &o 25% 40 76
5 $W 350 41 77
46 82
47 83
48 84
13 49 85
14 50 86 122 158 194
15 51 87 123 159 195
L
16 52 88 124 160 196
77 53 89 125 761 197
18 54 90 126 162 198
19 55 91 127 163 199

20 I 56 92 ~~-, ---I 128 164 200
21 57 93 129 165 201 I
22 58 94 130 166 202
23 59 95 131 767 203

24 60 .96 xi2 168 204
25 61 97 133 169 205
26 62 98 134 170 206

27 63 99 135 171 207
28 64 100 136 172 208
29 65 101 137 173 209

30 66 102 138 1 I 174
17741 I 1270
270 I I
31 67 103 139 175 271
32 68 roq 740 176 212
33 69 105 141 177 213
34 70 706 142 178 214

35 71 107 143 779 215
36 72 708 144 180 276
Maximum average 3 6 ‘0
Figure 6.2. Visrbie emrssion summary data shear

VlSl8LE EMISSION [ 3SERVATlON FORM

ADDRESS
1 1 2 3 4 31 121 122 123 124
CITY STA TE ZIP 2 5 6 7 8 32 125 126 127 128

I 3 9 to 11 12 33 129 130 131 132
PHONE SOURCE ID NUMBER
4 13 14 15 16 34 133 134 735 136
PROCESS EQUIPMENT OPERA TfNG MODE 5 17 t8 19 20 35 137 138 139 140
CONTROL EQUIPMENT OPERATING MODE 6 21 22 23 24 36 141 142 143 144
7 25 26 27 28 37 145 146 147 148

DESCRIBE EMISSION POINT
START STOP 8 W 30 31 32 38 149 150 151 t52
HEIGHT ABOVE GROUND LEVEL HEIGHTRELA TIVE TO OBSERVfi 9... 33 . .s. ...35 . -35. 39 153 154 155 156
START STOP START srop
to 37 33 39 40 40 157 158 159 160
DISTANCE FROM OBSERVER DIRECTION FROM OBSERVER
START STOP START STOP 11 41 42 43 44 41 161 162 163 154
DESCRIBE EMISSIONS 12 1 4551 461 471 481 42 i t65I 1561 1671 168
1 I I 1 I
START STOP 1
13 49 1 50 51 52 43 169 170 171 1 172
EMISSION COLOR PLUME TYPE: CONTINUOUS 0
START STOP FUGITIVE 0 INTERMITTENT 0 14 53 I 54 55 56 44 173 174 175 t 176
WATER DROPLETS PRESENT: IF WATER DROPLET PLUME: 15 57 58 59 50 45 177 178 179 180
NO0 YESD ATTACHED 0 DETACHED 0
16 61 62 63 64 46 181 182 183 184
POINT IN THE PLUME AT WHICH OPACITY WAS DETERMINED
START STOP 17 55 66 67 68 47 185 186 t87 188
DESCRIBE BACKGROUND 18 69 70 71 72 48 189 190 191 192
START STOP
19 73 74 75 76 49 ; 193 194 195 196
START STOP START 20 77 78 79 80 50 1 197 198 199 200
STOP
WIND SPEED WIND DIRECNON 2t 1 81 1 82 1 83 1 84 1 51 1 201 1 202 1 203 1 204 1
START STOP START STOP
2? 85 86 87 88 52 205 206 207 208
AMBIENT TEMP. WET BULB TEMP. RH.percenr
START STOP 23 89 90 91 92 53 209 210 217 ; 212
24 93. 94. 95.1. 96 I- 54 .2?3 214. 215 216

, I
1
Source Layour Sketch Draw North Arrow 25 1 97 1 98 ; 99 1 tw 1 55 1 277 1 218 I219 1 220
X Emission Point
0 . 26
27
101
105
102
106
103
107
104
108
56
57
22-~
225
222
226
223
227
224’
228
28 109 110 111 t12 58 ZS 230 231 232
29 113 114 115 116 59 233 234 235 236
30 117 118 119 120 60 237 238 239 240

Observers Posirion AVERAGE OPACITY FOR NUMBER OF READINGS ABOVE
Plume and =
HIGHEST PERIOD % WERE
----------- =E OF OPAClTY READINGS
Sun Locarron Lme MINIMUM MAXIMUM
.
OBSERVERS NAME (PRINTJ
COMMENTS OBSERVER’S SIGNATURE DA TE
ORGANIZA TION
I HAVE RECEIVED A COPY OF THESE OPACITY OBSERVATIONS CERTIFIED BY 1 DATE

SIGNA TURE
TITLE DA TE VERIFIED BY DA TE
I I
Figure 6.3. Opacity data form with slan numbers shown
the known height of the stack and the

distance from the observer to the base
of the stack.
Method 1 (when slant angle B is known)
1 - ( & ) = Tdquation 6-l

100
(1 - T:) x 100 = 0,
where
O,= observed opacity in %
T,= observed transmittance
F = cosine of B
O,= corrected opacity in %.
Method 2 (where distances are known)
Equation 6-2
1-( Q9 )=T,
100
(1 - Tz) x loo = OC
where
00= observed opacity in %
To = observed transmittance
F = cosine of 8
O,= corrected opacity in %
H = height of stack
Y = distance of observer from stack.
Note: Since the cokection is a
Time. minutes power function, the correction must
be made on each opacity reading and
Figure 6.4. Plot opecity versus time.
the corrected values used for
acknowledged and the individual data source. As an observer moves cioser calculations, in lieu of the correction
values may be adjusted to the base of the stack, the angle of being conducted on the reduced
mathematically in the final data report sight and the path length through the (averaged) data.
to show the increase in opacity plume both increase; this causes the Table 6.1 presents the opacity
reading due to the added path length. observed opacity to increase even corrected for slant angle or viewing
These adjusted opacity readings though the cross-plume opacity angle 8 versus the full range of
should be used in determining remains constant. This situation only opacity readings. For angles less than
averages in excess of the standard. applies when the opacity is read approximately 18O the adjustment is
The calculation of observed path through a venicalty rising plume and relatively insignificant.
length is shown in Appendix A of the ObSeNer is on the same plane as 6.3 Predicting Steam Plume
Reference 1 and is included here for the base of the stack.
the observer’s convenience. Figure The actual opacity may be Formation
6.5 shows how the slant angle varies calculated from the observed opacity; The psychrometric chart can be
with distance from an elevated if the slant angle B is known, or from used in conjunction with a simple
---- - Path Length through Plume
8 = Slanr Angle
1
2H+ -
3H/4
Figure 6.5. Variation of observation angle and parhlengrh wrth distance from an elevared source
Table 6.7. Opacity Correction for Slant Angle determines the values for the
Measured remaining three properties. For
example, by using a sling
opacity. slant anode 6. degrees
psychrometer to measure the wet and
O/O 0 10 20 30 40 50 60 dry bulb temperatures. one can
95 95 95 94 93 90 85 78 determine the relative humidity. the
90 90 90 89 86 83 77 68 absolute humidity, and the specific
85 85 85 83 87 77 71 62 volume of the air.
80 80 80 78 75 71 65 55 To predict the occurrence of a
75 75 75 73 70 65 59 50 visible steam plume, both the ambient
70 70 70 68 65 60 54 45 air conditions and the stack gas
65 65 64 63 60 55 49 47 conditions must be known or
calculated and located on the
z 60
55. 59
55 53
58 50
55 50
46 45
40 33
37 psychrometric chart. If any portion of
50 50 50 48 45 47 36 29 the line connecting the two points lies
45 45 45 43 40 37 32 26 to the left of the 100 percent relative
40 40 40 38 36 32 28 23 humidity iine. it is an indication that
35 35 35 37 28 24 19 the change of the exhaust gas from
30 30 30 si 27 24 27 16 the stack state conditions to the
25 2 -z 24 22 20 17 13 ambient air state will be accompanied
20‘ 79 18 16 13 17 by the condensation of the water
75 75 15 74 73 12 70 8 vapor present in the exhaust stream
70 70 70 9 9 8 7 5 and a resultant visible steam plume.
5 5 5 4 4 3 3 3 Obtaining the state point for the
0 0 0 0 0 0 0 0 ambient air conditions is relatively
simple; as previously indicated, the
equation to predict the formation of a wet and dry bulb temperatures, which
represented by the set of curved lines
visible water vapor (steam) plume. The originating in the lower left portion of will determine a unique state point,
psychrometric chart is a graphical the chart. can be measured by using a sling
representation of the solutions of Absolute humidity (humidity ratio) - psychrometer. Often the only data
various equations of the state of air The mass of water vapor per unit available for determining the state
and water vapor mixtures (see Figure mass of air; expressed as grains per point of the stack gas are the dry bulb
6.6). Both the ambient and stack pound or pound per pound; temperature of the exhaust gas
emission data points on the chart are represented by the vertical axes. stream and its moisture content.*
referred to as their “state point” and However. a relationship exists
represent one unique combination of Specific volume - The volume between the moisture content and the
occupied by a unit mass of air, humidity ratio (or absolute humidity),
the following five atmospheric
expressed as cubic feet per pound; as shown in the following equation:
properties.
represented by the diagonal lines
Dry bufb temperature - The actual
ambient temperature; represented by
running from lower right to upper left. HR = 0.62 (MC) Equation 6-3
The relationships shown in the chart 1 -MC
the horizontal axis.
differ with changes in barometric
Wet bulb temperature - The
pressure. The chart included in this where
temperature indicated by a “wet bulb”
section is for a barometric pressure of HR = humidity ratio.- in pound of water
thermometer ( a regular thermometer
29.92 inches of mercury. Therefore, vapor per pound of dry air
that has its bulb covered with a wet
with use of wet bulb dry bulb MC =z moisture content, expressed
wick and exposed to a moving air
technique, if the actual pressure is 100
stream); represented by the curved
less than about 29.5 inches of as a decimal.
axis on the left side of the chart
mercury, the humidity ratio should be The following sample problem
(saturation temperature).
calculated from the equation and not demonstrates the use of this
Relative humidity - The ratio of the
the chart. equation.
partial pressure of the water vapor to
the vapor pressure of water at the Plotting the values for any two of Given..
same temperature: values are Ambient conditions
the five atmospheric properties
Dry bulb temperature = 70°F
Table 6.2. Vapor Pressures of Waler a2 Saluration Wet bulb temperature = 60°F
Barometric pressure = 29.92 in Hg
Temp.. Water vapor pressure. in. Hu
Effluent gas conditions
OF 0 1 2 3 4 5 6 7 8 9 Dry bulb temperature = 1 60°F
30 0.1647 0.7716 0.1803 0.1878 0.7955 0.2035 0.2118 0.2203 0.2292 0.2383
Moisture content = 16.8% = 0.168
40 0.2478 0.2576 0.2677 0.2783 0.2891 0.3004 0.3120 0.3240 0.3364 0.3493
100
50 0.3626 0.3764 0.3906 0.4052 0.4203 0.4359 0.4520 0.4586 0.4858 0.5035
60 0.5218 0.5407 0.5601 0.5802
Find:
0.6009 0.6222 0 6442 0.6669 0.6903 0.7144
70 0.7392 0.7648 0.7912 0.8783 0.8462 0.8750 0.9046 0.9352 0.9666 Ambient reiatlve humidity
0.9989
80 1.032 1.066 1.102 7.138 1.175 7.273 1.253 1.293 1.335 1.378 Exhaust gas humidrty ratio
90 1422 I467 1.573 1.567 7.610 1.660 1.772 1.765 1.819 1.875 Determrne whether or not
100 1.932 7.992 2.052 2.114 2.178 2.243 2.310 2.379 2.449 2.527 condensed water (steam plume)
110 2.596 2.672 2.749 2.829 2.971 2.995 3.081 3.169 3.259 3.351 will form
120 3.446 3543 3.642 3 744 3.848 3.954 4.063 4.774 4.289 4.406
130 4.525 4 647 4 772 4.900 5.037 5.165 5.302 5.442 5.585 5.732 ‘These are usually oblalned from plant recordS
or are esrlmared from recent source ten data
Solution: where where

Plot ambient wet bulb and dry bulb VP = Vapor pressure of H20 using SVP = Saturated vapor pressure in in.
temperatures (see Figure 6.5). Equation 6-6 Hg at wet bulb temperature
Ambient relative humidity = 55%. P a~ = Barometric pressure (taken from Table 6.2)
Exhaust gas humrdity ratio = HR Td = Temperature of dry bulb
HR ~0.62 (MCI VP = SW - (3.57x10-“) (Paas) (Ta-T,) thermometer, OF
1 -MC (1 +T, - 32) T, = Temperature of wet bulb
a.62 (0.168) 1571 Equation 6-6 thermometer, OF.
1 - 0.168 Table 6.3 Activity Matrix for Calculations
~0.125 lb/lb dry air
P!ot humidity ratio and stack dry bulb Frequency and Action if
temperature (see Figure 6.6). Connect Acceptance method of requirements
the ambient state point and stack gas Calculation limits measurement are not met
state point with a straight line (see A veraoe-- ooacitv Data in Fig 6.7
-r----r For each com- Complete the
Figure 6.5). The line crosses the 100 completed and pliance test, data and initial
percent relative humidity line; thus, checked to with- perform inde- any changes in
formation of a visible water vapor in roundoff error pendent check calculations
plume is probable. of data form and
When the wet bulb/drv bulb calculations
technique is used and the barometric Running average Data in Fig 6.2 As above As above
pressure is less than 29.5 in. Hg, it is opacity
suggested that Equation 6-5 be used completed and
checked
to calculate the moisture content
bath length through No limits have For each com- Perform calcu-
PJW.
the plume been set pliance test with lations
MC =v.P. the slant angle
P .OI > 7 83 calculate
Equation 6-5
using Eq. 6- 7
Predidting steam No limits have Use psychro- Perform calcu-
plume been set metric chart and lations
+zzz-
750-Earometric Pressure 29.92
08
l - Srare Polnr for Ambtenr Condrtlons Dry Bulb Temoerature, OF

m - State POW for Stack Gas Cond/flons
Figure 6.6. Psychromemc char? for problem sofotron

7.0 Auditing Procedures

An audit is an independent first year of an observer and Record,‘* Figure 9.2 of Section 3.12.8.
assessment of data quality. whenever conditions tend to warrant In addition, the auditor should assess
independence is achieved by using them thereafter. Calculate %A using the visible emission inspection
observers and data analysts other Equation 7-l _ technique used by the auditee. This
than the original observer/anaiyst. %A = IVE (observer) - VE (auditor1 portion of the system audit is best
Routine DA checks for proper Equation 7-1 handled in conjunction with the
observer positioning and performance audit described in the
where
documentation are necessary to VE (observer) = average and in- previous Subsection 7.1.1. Therefore,
obtain good quality data. Table 7.1 at dividual VE the frequency of the system audit
the end of this section summarizes should coincide with the frequency of
reading(s) of the
the DA activities for auditing. observer being the performance audits of visible
Two performance audits are audited emissions. Some observations to be
recommended for VE readings: VE(auditor),= average and made by the auditor are listed in
1. Audit of observer by having an individual VE Figure 7.1:
experienced observer make reading(s) of the
independent readings. auditor.
2. Audit of data forms and
calculations. 7.7 -2 Performance Audit of Data
In addition, it is recommended that a Calculations - This
audit is an
systems audit be conducted by an independent check of all calculations
experienced observer at the same performed for the summary VE report.
time the performance audit of visible Every calculation should be checked
emissions is conducted. The two within round-off error. This audit
performance audits are described in should be conducted on at least 7
Subsection 7.1 and the systems audit percent of the annual numbers of VE
is described in Subsection 7.2. summary reports.
7.1 Performance Audits 7.2 System Audit

Performance audits are quantitative A system audii provides an on-site
evaluations of the quality of visible qualitative inspection and review of
emission data. the total inspection. This audit
includes a check of the “Record of
7.7.7 Performance Audit of Visible Visual Determination of Opacity,”
Emissions - In this audit, an Figure 9.1 of Section 3.129. and the
experienced observer goes with the top portion of the “Observation
observer being audited and both
observers take the readings
simulataneously (using the same time
piece) and complete the data forms as
independently as is practical. The Table 7.1. Activity Matrix for Auditing Procedures
audit is intended for observers in their Frequency and Action if
first year and observers who have not Acceptance method of requirements
made opacity observation in the field Audit limits measurement are nor met
in over a year. The differences Performance audit Individual obser- At least two Review obser-
between the two readings serve as a of visible emissions vations within times during the vation tech-
measure of accuracy assuming the i2C%; average first year; sim- niques
experienced observer reads the “true (absolute/ devia- ultaneous ob-
opacity.” Because this assumption is tion within servation and
not necessarily correct. the difference *100/o data recording
between the two readings is a
combined measure of accuracy of Performance audit Original and Seven percent Check and cor-
both observers. For a minimum of six of data calculations check caicula- of tests for rect all calcu-
tions agree compliance, per- lated results
minutes (24 readings), the average of
the absolute differences should be less within round-off form indepen- {averages)
than 10 percent. and no individual error dent check on
all calculations
differences should exceed 20 percent.
(The values of 10% and 20% System audit Conduct obser- At least two Explain to obser-
suggested for the limits are the vations as de- times during the ver the devia-
approximate results of combining- the scribed in this first year: use tions from rec-
allowable errors of the two observers; section of audit checklist ommended
e.g. (7.5)2 + (7.5)’ = 10.6%. and the Handbook (Fig 7.1) procedures,.
r 1 !j2 + 152 = 21.2%. This audit should note the devia-
be performed twice in a year for the tions on Fiq 7.1
Name of individual&j audited u i-y A. Lmf
Affiliation h&d $rk c~.& 7&w~f

I
.
u
Auditor name /I/J * erse I y Affiliation 7 eqion E f;DA
Date of audi! /2*.75- 82
Yes No Comment Operation
-- J 1. Equipment satisfactwy
--J 2. Data forms completed
--r/ 3. Post-notification (courtesy obligation] performed
-- J 4. Correct identification of point of emissions
L- 6. Plume associated with process generation point

_
4- 6. Credentials okay
J- 7. Observer acted in professional 8nd courteous manner
r/
-- 8. Proper observer position
--I/ 9. Opacity readings complete
--J 70. Ancillary measurements evaifable
J- n 25/b/ c/ /‘e9Uf.d 17. Camera used to validate sightings/source identification

/ /
--J 12. Facility personnel given a copy of raw data
-- 44 13. Mutiple sources/plumes/outlets
--J 14. Lighting conditions satisfactory
-- 16. Backgrqund conditions (raining. etc.J satisfactory
AL- 16. Slant angle recorded
-- r//A
17. Fugitive emissions
-- J 18 Time of day recorded
--J 79. Recertified within last 6 months
Figure 7. f . Method 9 checklist for auditors.

,.... _ ._...~.._-... --
8.0 Reference Method”

Method 9-Visual approaches zero as the color and 2. Procedures.
Determination of the Opacity luminescence contrast decrease The observer qualified in
of Emissions from Stationary toward zero. As a result, significant accordance with paragraph 3 of thts
negative bias and negative errors can method shall use the following
Sources be made when a plume is viewed procedures for visually determining
Many stationary sources discharge under less contrasting conditions. A the opacity of emissions:
visible emissions into the atmosphere; negative bias decreases rather than
these emissions are usually in the increases the possibility that a plant 2. I Position. The qualified observer
shape of a plume. This method operator will be cited for a violation of shall stand at a distance sufficient to
involves the determination of plume opacity standards due to observer provide a clear view of the emissions
opacity by qualified observers. The error. with the sun oriented in the 140°
method includes procedures for the Studies have been undertaken to sector to his back. Consistent with
training and certification of observers, determine the magnitude of positive. maintaining the above requirement,
and procedures to be used in the field errors which can be made by qualified the observer shall, as much as
for determination of plume opacity. observers while reading plumes under possible, make his observations from
The appearance of a plume as viewed contrasting conditions and using the a position such that his line of vision
by an observer depends upon a procedures set forth in this method. is approximately perpendicular to the
number of variables, some of which The results of these studies (field plume direction, and when observing
may be controllable and Some of trials) which involve a total of 769 opacity of emissions from rectangular
which may not be controllable in the sets of 25 readings each are as outlets (e.g. roof monitors, open
field. Variables which can be follows: baghouses. noncircular stacks),
controlled to an extent to which they approximately perpendicular to the
no longer exert a significant influence (1) For black plumes (133 sets at a longer axis of the outlet. The
upon plume appearance include: smoke generator). 100 percent observer’s line of sight should not
Angle of the observer with respect to of the sets were read with a include more than one plume at a
the plume; angle of the observer with positive error’ of less than 7.5 time when multiple stacks are
respect to the sun; point of percent opacity; 99 percent involved, and in any case the observer
observation of attached and detached were read with a positive error should make his observations with his
steam plume; and angle of the of less than 5 percent opacity. line of sight perpendicular to the
observer with respect to a plume (2) For white plumes (170 sets at a longer axis of such a set of multiple
emitted from a rectangular stack with smoke generator, 168 sets at a stacks (e.g. stub-stacks on
a large length to width ratio. The coal-fired power plant, 298 sets baghouses),
method includes specific criteria at a sulfuric acid plant), 99
applicable to these variables. percent of the sets were read 2.2 Field records. The observer
Other variables which may with a positive error of less than shall record the name of the plant,
not be controllable in the field are 7.5 percent opacity; 95 percent emission location, type facility,
luminescence and color contrast were read with a positive error 0bserver.s name and affiliation, and
between the plume and the of less than 5 percent opacity. the date on a field data sheet (Figure
background against which the plume The positive observational error 9-l). The time, estimated distance to
is viewed. These variables exert an associated with an average of twenty- the emission location, approximate
influence upon the appearance of a five readings is therefore established. wind direction. estimated wind speed,
plume as viewed by an observer, and The accuracy of the method must be description of the sky condition
can affect the ability of the observer taken into account when determining (presence and color of clouds]. and
to accurately assign opacity values to possible violations of applicable plume background are recorded on a
the observed plume. Studies of the opacity standards. field data sheet at the time opacity
theory of plume opacity and field readings are initiated and completed.
studies have demonstrated that a 1. Principle and applicability.
plume is most visible and presents the 2.3 Observarions. Opacity
greatest apparent opacity when 1.7 Principle. The opacity of observations shall be made at the pomt
viewed against a contrasting emissions from stationary sources is of greatest opacity in that portion of
background. It follows from this, and determined visually by a qualified the plume where condensed water
is confirmed by field trials, that the observer. vapor is not present. The observer
opacity of a plume. viewed under 7.2 Applicability. This method is shall not look continuously at the
conditions where a contrasting applicable for the determination of the plume. but instead shall observe the
background is present can be opacity of emissions from stationary plume momentarily at 15-second
assigned with the greatest degree of sources pursuant to 5 60.1 l(b) and for intervals
accuracy. However, the potential for a qualifying observers for visually
positive error is also the greatest determinrng opacity of emissions. 2.3.1. Attached steam plumes When
when a plume is viewed under such condensed water vapor is Present
contrasting conditions. Under wrthrn the plume as it emerges from
e ‘For a sec.posirwe error = average opacny
-. conditrons presenting a less the emlsson outlet, opacity
determmed bv observers’ 25 observarfons -
contrasting background, the apparent average opawv derermtned from observations shall be made beyond the
opacity of a plume is less and IranSm~SsOmeIer’S 25 recordrngs pornt In the plume at which
CompBnV Hours of Observation

Location Observer
Test Number Observer Certification Date
Date Observer Affiliation
Type Facility Point of Emissions
Control Device Height of Discharge Point
Summary of Average Opacity

Clod Time
Observer Location
Distance to Discharge
Direction from Discharge
Height of Observation Point
BackgroundDescription
Weather Conditions
Wind Direction
Wind Speed
Ambient Temperature
1 I I
Sky Conditions (clear. 1 1 1
overmst 70 clou&. etc.)
Readings ranged from -to- % opacity
Plume Description
Color The source was/was not in compliance with
- at the time evslu8tion was mede.
Distance Visible
Other Information
Figure 9.1 Record of Visual Determination of Opacity
Page - of-
condensed water vapor is no longer to the condensation of water vapor 2.5 Data Reduction. Opacity shall be
visible. The observer shall record the and the formation of the steam plume. determined as an average of 24
approximate distance from the consecutive observations recorded at
emission outlet to the point in the 2.4 Recording observations. Opacity 15-second intervals. Divide the
plume at which the observations are observations shall be recorded to the observations recorded on the record
made. nearest 5 percent at 15-second sheet into sets of 24 consecutive
intervals on an observational record observations. A set is composed of
sheet. (See Figure 9-2 for an any 24 consecutive observations. Sets
2.3.2 Detached steam plume. When example.) A minimum of 24 need not be consecutive in time and
water vapor in the plume condenses observations shall be recorded. Each in no case shall two sets overlap. For
and becomes visible at a distinct momentary observation recorded shall each set of 24 observations, calculate
distance from the emission outlet, the be deemed to represent the average the average by summing the opacity
opacity of emissions should be opacity of emissions for a 15second of the 24 observations and dividing
evaluated at the emission outlet prior period. this sum by 24. If an applicable
Company Observer
Location Type Facility
Test Number Point of Emissions
Date
(FR Dot. 74.26150 Filed 7 I- 1 l- 74. 8-45 aml

Figure 9.2 Observarron Record
Page - of -
standard specifies an averaging time diameter, on a full 0 to 700 percent 3.3.2.7 Light source. Verify from
requiring more than 24 observations, chart recorder scale. The smoke meter manufacturer’s data and from voltage
calculate the average for all optical design and performance shall measurements made at the lamp. as
observations made during the meet the specifications shown in installed, that the lamp is operated
specified time period. Record the Table 9-l. The smoke meter shall be within +5 percent of the nominal
average opacity on a record sheet. calibrated as prescribed in paragraph rated voltage.
(See Figure 9-1 for an example.) 3.3.1 prior to the conduct of each
3.3.2.2 Spectral response of
smoke reading test. At the
3. Qualifications and testing. photocell. Verify from manufacturer’s
completion of each test, the zero and
span drift shall be checked and if the data that the photocell has a photopic
3.1 Certification requirements. To response; i.e., the spectral sensitivity
receive certification as a qualified drift exceeds 11 percent opacity, the
of the cell shall closely approximate
observer, a candidate must be tested conditions shall be corrected prior to
the standard spectral-luminosity curve
conducting any subsequent test runs.
and demonstrate the ability to assign for photopic vision which is
opacity readings in 5 percent. The smoke meter shall be
referenced in (b) of Table 9-l.
increments to 25 different black demonstrated, at the time of
plumes and 25 different white installation, to meet the specifications 3.3.2.3 Angle of view. Check
plumes, with an error not to exceed listed in Table 9-l. This demonstration construction geometry to ensure that
15 percent opacity on any one reading shall be repeated following any the total angle of view of the smoke
and an average error not to exceed 7.5 subsequent repair or replacement‘of me- .‘plume. as seen by the photocell, does
percent opacity in each category. the photocell or associated electronic not exceed 15O. The total angle of
Candidates shall be tested according to circuitry including the chart recorder view may be calculated from: 8 = 2
the procedures described in paragraph or output meter, or every 6 months, tan-’ d/2L, where B = total angle of
3.2 Smoke generators used pursuant whichever occurs first. view; d = the sum of the photocell
to paragraph 3.2 shall be equipped diameter + the diameter of the limiting
Table S- I_ Smoke Meter Design and aperture; and L = the distance from
with a smoke meter which meets the Performance Specifica-
requirements of paragraph 3.3. the photocell to the limiting aperture.
tions
The certification shall be valid for a The limiting aperture is the point in
period of 6 months, at which time the Parameter: Specification the path between the photocell and
qualification procedure must be a. Light source Incandescent lamp the smoke plume where the angle of
repeated by any sbserver in order to operated at view is most restricted. In smoke
retain certificat;-:-. i * nominal rated generator smoke meters this is
voftage. normally an orifice plate.
3.2 Certification procedure. b. Spectral Photopic (day fight 3.3.2.4 Angle of projection. Check
The certification test consists of response of spectral response of construction geometry to ensure that
showing the candidate a complete run photocell. the human eye- the total angle of projection of the
of 50 plumes-25 black plumes and reference 4.3). lamp on the smoke plume does not
25 white plumes-generated by a c. Angie of view 75O maximum total exceed ISo. The total angle of
smoke generator. Plumes within each angfe- projection may be calculated from: B =
set of 25 black and 25 white runs d Angle of projec- 75O maximum total 2 tan-’ d/2L. where 8 = total angle of
shall be presented in random order. tion angle. projection; d = the sum of the length
The candidate assigns an opacity e. Calibration error &3% opacity. maxi- of the lamp filament + the diameter of
value to each plume and records his mum the limiting aperture; and L = the-
observation on a suitable form. At the f Zero and span f 1% opacity. 30 distance from the lamp to the limiting
completion of each run of 50 drift. minutes. aperture.
readings, the score of the candidate is o. Resoonse time ST seconds.
determined. If a candidate fails to
qualify, the complete run of 50 3.3.2.5 Calibration error. Using
readings must be repeated in any 3.3.1 Calibration. The smoke meter neutral-density filters of known
retest. The smoke test may be is calibrated after allowing a minimum opacity, check the error between the
of 30 minutes warmup by alternately actual response and the theoretical
administered as part of a smoke
school or training program, and may producing simulated opacity of 0 linear response of the smoke meter.
be preceded by training or percent and 100 percent. When stable This check is accomplished by first
familiarization runs of the smoke response at 0 percent or 100 percent calibrating the smoke meter according
generator during which candidates is noted. the smoke meter is adjusted to 3.3.1 and then inserting a series of
are shown black and white plumes of to produce an output of 0 percent or three neutral-density filters of
known opacity. 100 percent, as appropriate. This nominal opacity of 20, 50. and 75
calibration shall be repeated until percent in the smoke meter
stable 0 percent and 100 percent pathlength. Filters calibrated &thin
3.3 Smoke generator readings are produced without +2 percent shall be used. Care should
specifications. adjustment. Simulated 0 percent and be taken when inserting the filters to
100 percent opacity values may be prevent stray light from affectmg the
Any smoke generator used for the produced by alternately switching the meter. Make a total of five
purposes of paragraph 3.2 shall be power to the light source on and off nonconsecutive readings for each
equipped with a smoke meter while the smoke generator is not filter. The maximum error on any one
installed to measure opacity across producing smoke. reading shall be 3 percent opacity.
the diameter of the smoke generator
stack. The smoke meter output shall 3.3.2 Smoke meter evaluation. The 3.3.2.6 Zero and span drift.
display instack opacity based upon a smoke meter design and performance Determine the zero and span drift by
path length equal to the stack exit are to be evaluated as follows: calibratrng 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
i’ 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. 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.
4.7 Air Pollution Control District
.Rules and Regdations, Los Angeles
County Air Pollution Control District,
Regulation IV. Prohibitions, Rule 60.
4.2 Weisburd. Melvin L. Field
Operations and Enforcement Manual
for Air, U.S. Environmental. Protection
Agency, Research Triangle Park, NC.,
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.
c
9.0 References and Bibliography

1. Technical Assistance Document: 12. Weir, A, Jr., D.G. Jones, and
Quality Assurance Guideline for L.T. Paypay. Measurement of
Visible Emission Training Panicle Size and Other Factors
Programs, EPA-6OO/S4-83-011. Influencing Plume Opacity.
2. Federal Register, Volume 39, Paper presented at the
No. 219, November 12, 1974. International Conference on
Method 9 - Visual Environmental Sensing and
Determination of the Opacity of Assessment, Las Vegas, Nevada,
Emissions from Stationary September 14-l 9, 1975.
Sources (Appendix A). 13. U.S. Environmental Protection
3. Conner, W.D. Measurement of Agency. APTI Course 439
Opacity by Transmissometer and Visible Emissions Evaluation.
Smoke Readers. EPA Student Manual. EPA-450/3-
Memorandum ReDort. 1974. 78-106,.1978.-. .. . . . ..._ .
4. Conner, W.D., and J.R. 14. U.S. Environmental Protection
Hod&son. Optical Propenies Agency. APTI Course 439
and Visual Effects of Smoke Visible Emissions Evaluation.
Plumes. U.S. Environmental Instructor Manual. EPA-450/3-
Protection Agency. Office of Air 78- 105. 1978.
Programs, Edison Electric 15. U.S. Environmental Protection
Institute, and Public Health Agency. Guidelines for
Service. 1967. AP-30. Evaluation of Visible Emissions.
5. Coons, J.D.. et al. Development, EPA-34011 -75-007. 1975.
Calibration, and use of a Plume 16. U.S. Environmental Protection
Evaluation Training Unit. JAPCA Agency. Screening Procedures
15: 199-203, May 1965. for Ambient Air Quality Data.
6. Crider, W.L. and J.A. Tash. EPA-45012-78-037, July 1978.
Status Report: Study of Vision 17. Validation of Air Monitoring
Obscuration by Nonblack Data. EPA-600/4-80-030. June
Plumes. JAPCA 14161-165. 1980.
May 1964.
7. US. Environmental Protection
Agency. Evaluation of EPA
Smoke School Results. Emission
Standards and Engineering
Division, Office of Air Quality
Planning and Standards. October
9, 1974..
8. Evaluation and Collaborative
Study of Method for Visual
Determination of Opacity of
Emissions from Stationary
Sources. EPA-650/4-75-009.
9. Malmberg, K-6. EPA Visible
Emission inspection Procedures.
U.S. Environmental Protection
Agency, Washington. D.C.
August 1975.
10 Osborne, M.C., and M.R.
Midgett. Survey of
Transmissometer Used in
Conducting Visible Emissions
Training Courses. Environmental
Monitoring and Suppon
Laboratory. U.S. Environmental
Protection .Agency. March 1978.
11 Ringelmann, M. Method of
Estimating Smoke Produced by
Industrial Installations. Rev.
Technique, 268, June 1898.
10.0 Data Forms

Blank data forms are provided on
the following pages for the
convenience of the CA Handbook
user. No documentation is given on
these forms because it would detract
from their usefulness. Also, the titles
are placed at the top of the figures, as
is customary for a data form. These
forms are not required format, but are
intended as guides for the
development of an organizations’ own
program. To relate the form to the
text, a form number is also indicated
in the lower right-hand corner (e.g.,
Form M9-1.1, which implies that the
form is Figure 1 .l. in Section 3.12.1
of the Method 9 Handbook). Any
future revisions of this form can be
documented bv adding A, B. C (e.g.,
1 .lA, 1 .18). The data forms included
in this section are listed below.
Form Title
1.2 Sample Certification Test Form
2.1 Procurement Log
4.1 Visible Emission Observer’s
Plant Entry Checklist
4.1 Visible Emission Observer’s
Plant Entry Checklist (Reverse
Side)
4.2 Visible Emission Observation
Form
4.2 Visible Emission Observation
Form (Reverse Side)
5.1 z;ze; Emission Summary Data
6.2 Visible Emission Summan/ Data

Sheet (same as Figure 5.1)
7.1 Method 9 Checklist for Auditors
Sample Certification Tesr form
Affiliation Name ~ Run Number .-

Co&e location Sunglasses -
Date Sky Wind

Distance and direction fo stack
Reading
number Error
1 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 -
0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 -
i 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 -
4 0 5 10 75 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 -
5 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 -
6 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 -
7 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 -
8 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 -
9 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 -
10 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 -
. -.
11 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 -
12 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 -
13 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 -
14 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 loo -
15 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 -
16 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 -
17 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 -
18 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 loo -
79 0 5 70 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 -
20 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 -
0 5 70 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 loo -
;; 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 -
23 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 -
24 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 -
25 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 -
Deviation
Reading
number Error
1 0 5 10 75 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 -
2 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 -
3 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 -
4 0 5 10 75 20 25 30 35 40 45 50. 55. 60- 66 70 - 75 80 85 90 95 100 -
5 0 5 10 15 20 25 30 35 40 45 50 55 60’ 65 70 75 80 85 90 95 100 -
6 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100
0 5 10 75 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100
8’ 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 700
9 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100
10 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100
11 0 5 10 15 20 25 30 35 40 45 50 5s 60 65 70 75 80 85 90 95 100
12 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100
73 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100
14 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100
15 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100
16 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100
77 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100
18 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 --
19 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 --
20 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100
21 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100
22 0 5 10 ‘15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100
23 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100
24 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100
25 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100
Devrarron -
Qua liry A issuance Handbook M9- 1.2

Procurement Log
hem description Quantity

Purchase
order
number Vendor
r Ordered
Date
Received
r cost Disokition Comments
.._ .
Qualify Assurance Handbook M9-2.1

Visible Emission Observer’s Plant Entry Checklist
Source name and address Observer
Date of VE observation
Previous company contact lif appfkabfel
.. ._:.- __.
Title
Purpose of visit
Emission points at which VE observations to be conducted
Authority for entry (see reverse side}
Plant safety requirements
Cl Hardhat b Coveiafis .*
0 Safety glasses 0 Dusr mask suggested
0 Side shields (on glasses) 0 Respirator(s)
Specify
0 Goggles
0 Hearing protection
Specify 0 Other
0 Safety shoes (steel-toed) U Specify
0 Insulated shoes
0 Gloves
Company official contacted fan this visit)
Title
Qualily Assurance Handbook M9-4.1

Visible Emission Observeri Plant Checklist (Continued)
Authority for Plant Entry: Clean air Act. Section 7 14

(a}(2) the Administrator or his authorized representative upon presentation of his credentials .
(A) shall have a right of entry to. upon or through any premises of such person or in which any records required to be
maintained under paragraph (IJ of this section are located. and
(Bj may at reasonable times have access to, and copy of any records, inspect any monitoring equipment or methods
required under paragraph (7). and sample any emissions which such person is required to sample under
paragraph (7).
/bJ 17) Each State may develop and submit to the Administrator a procedure for carrying out this section in such State. if the
Administrator finds the State procedure is adequate. he may de&ate to such State any authority he has to carry out this
section.
(2) Nothing in this subsection shall prohibit the Administrator from carrying out this section in a State.
Ic) Any records. reports or information obtained under subsection/a)shallbe available to thepublicexcept that upon ashowing
satisfactory to the Administrator by any person that records, reports, or information. or particular part thereof. (other than
emission data) to which the Administrator has access under this section if made public would divulge methods or processes
entitled to protection as trade secrets of such person: the Administrator shafkonsider such record report. or information or
particular portion thereof confidential in accordance with the purposes of Section 7905 of Title, 78 of the United States
concerned with carrying out this Act or when relevant in any proceeding under this Act.‘*
Confidential information: Clean Air Act, Section 7 74 (see above} 41 Federal Register 36902, September 7, 7976
ff you befieve that any of the information required to be submitted pursuant to this request is entitled to be treated as
confidential, you may assert a claim of business confidentiality. covering a/l or any part of the information, by placing on /or
attaching to) the information a cover sheet. stamped or typed legend. or other suitable notice. employing language such as
“trade secret.” **proprietary.” or “company confidential.” Allegedly confidential portions of otherwise nonconfidentiai
information should be clearly identified. if you desire confidential treatment only until the occurrence of a certain event: the
notice shouldso state. information so covered by a claim will be disclosedby EPA only to the extent, andthrough the procedures.
set forth at 40 CFR. Part 2. Subpart 8 (47 Federal Register 36902. September 7. 7976.)
If no confidentiality claim accompanies this information when it is racaivadby EPA. it may be made available to the public by
EPA without further notice to you.
Quality Assurance Handbook M94.1

Visible Emission 2bservation Form

SOURCE NAME 08SER VA TON DA TE START TIME STOP TIME
llDDRESS
3-Y STATE ZIP
=‘HONE SOURCE ID NUMBER
‘ROCESS EQUIPMENT OPERA TNVG MOLIE
TONTROL EQUIPMENT OPERATING MODE
9ESCRlBE EMISSION POINT

START STOP
3ESCRlBE EMISSIONS
START STOP
FMISSION COLOR PLUME TYPE: CONTINUOUS n
START STOP FUGITIVE 0 INTERMITTENT Cl
WATER DROPLETS PRESENT: IF WA TER DROPLET PLUME:
NO0 YESO A TTACHED L3 DETACHED 0
POINT IN THE PLUME AT WHICH OPACITY WAS DETERMINED
START STOP
DESCRIBE BACKGROUND
START STOP
WIND SPEED WIND DIRECTION
I
22 ! 52
AMBIENT TEMP. WET BULB TEMP. RH.percent
START STOP 23 ! 53
24 / 54 .
source Layour Sketch Draw Norrh Arrow 25 i 55
26 / 56
X Emrssion Point 271 I I I 1 57 1 I I I

28 1 58
29 59
30 j 60
Plume and = Observers Posrtion 1 NUMBER OF READINGS ABOVf
AVERAGE OPACITY FOR
HIGHEST PERIOD % WERE
-------- RANGE OF OPACITY READINGS
Sun LocatIon Lme MINIMUM MA X/MUM
OBSERVER’S NAME (PRINTJ
COMMENTS OBSERVER’S SIGNA TURE DA TE
ORGANIZATION
I HAVE RECEIVED A COPY OF THESE OPACITY OBSERVA TlONS CERTlFlED BY DA TE

SIGNA TURE
TITLE DA TE VERIFIED BY DA TE
I I I
Qua!:ry Assurance Handbook M9-4.2

Vrsibfe Emission Observation form

This form is designed lo be used m con~unctron with EPA Method 9. “Visual Oetermrnarron of rhe Opacrty of Emissrons from Stazionary
Sources. -. Any deviatrons, unusual condirions. crrcumsrances. difficulOes. etc.. not dealt wrth elsewhere on the form shouldbe fully nored
in the section provided for commenzs. Following are brief descriprions of the zype of information that needs zo be entered on the form; for a
more detailed discussion of each pan of the form, refer 10 zhe “User’s Guide 10 rhe Visible Emission Observation Form. ”
*Source Name - full company name. parenz company or division ‘Sky Conditions - indicaze cloud cover by percenzage or by
informszion. I necessary. description {clear. scarrered. broken. overcasf. andcolor of cioudsl.
‘Address - streez (not mailing) address or physical iocarion ‘Windspeed - use Beaufort wind scale or hand-heldanomomezec
of facility where VE observazion is being made. be accuraze to i5 mph.
Phone - self-explanatory. *Wind Direction - direction wind is from: use compass; be

accurate zo eighz points.
Source ID Number - number from NEOS. CDS. agency file. ezc. ‘Ambient Temperature - in OF or OC.
‘Procass Equipment. Operating Mode - brief description of process “Wet Bulb Temperature - the wet bulb temperature from the
equipment (include ID no.) and operating rate. % capacizy utilization. sling psychrometer.
and/or mode (e.g.. charging. tapping).
‘Control Equipment. Operating Mode - specify control device type(s) “Relative Humidity - use sling psychrometer; use local U.S.
and % utilization. control efficiency. Weather Bureau only if nearby.
‘Describe Emission Point’- stack or emission point location, geometry. ‘Source Layout Sketch - include wind direction. associated
diameter. color; for idenzification.purposes. stacks, roads. and other landmarks to fully identify locazion of
emission point and observer position.
*Height Above Ground Level - szack or emission poinz height, from Draw North Arrow - poinz line of sighz in direction of emission
files or engineering drawings. point. place compass beside circle. and draw in arrow parallel
to compass needle.
*Height Refative to Observer - indicaze verzicalposizion of observation Sun Location Line - point line of sight in direction of emission
point relative to stack top. point. place pen upright on sun location line. and mark location
of sun when pen’s shadow crosses the observers position.
‘Distance From Observer - distance zo stack f 1 m; to determine, use “Comments - factual impb~azions. deviations. altercations.
rangetinder or map. and/or problems nor addressed elsewhere.
‘Direction From Observer - direczion zo stack use compass or map: Acknowledgment - signature. tizie. and date of company official
be accurate to eight points of compass. acknowledging receipz of a copy of VE observation form.
‘Describe Emissions - include plume behavior and other physical ‘Observation Date - date observations conducted.
characteristics /e.g.. looping. iacy, condensing. fumigating. secondary
particle formation. distance plume visible. etc.).
‘Emission Color - gray. brown. white. red. black, etc. ‘Start Time. Stop Time - beginning and end times of observation
period (e.g.. 1635 or 4135 p.m.).
Plume Type: ‘Data Ser.- percenz’opacizy zo nearest 5%; enter from left zo right
Continuous - opacity cycle >6 minutes starting in left column
Fugitive - no specifically designed ouzier
intermittent - opacity cycle C6 minuzes
-*Water Droplets Present - determine by observarion or use wet sling ‘Average Opacity for Highest Period - average of highest 24
psychrometer; water droplez plumes are very whtze. opaque. and consecurive opacizy readings.
billowy in appearance. and usually dissipate rapidly.
“If Water Droplet Plume: Number of Readings Above (Frequency CounZ) counf of Iota1
Aztached - forms prior IO extting szack number of readings aoove a designated opacity
Detached - forms after exrring Hack
“Point in the Plume at Which Opacizy was Determined - describe *Range of Opacity Readings:
physical location in plume where readings were made (e.g.. 4 in. above Minimum - lowesr reading
srack exit or 10 ft afzer disstparion of water plume). Maximum - highesr reading
‘Describe Background - objecz plume is read agamsi. include ‘Observer’s Name _ prmt in fulf.
azmospheric condirions (e.g.. hazy).
‘Background Color - blue. where. new leaf green. eic .Observer +s Signature. Date - srgn and daze afzer performIng fIna/
calcularions.
‘Organizazion observer’s employer.
‘Certifier. Daze - nan of “smoke school- cerrlfymgobserver and

‘Re~wred by Reference Method 9. orher #terns date of most recent ce ?if/carion
suggested
“Regu~ed by Method 9 only when particular Verifier. Daze - stgna:ure of person responsible for verlfVJng
factor could affect the readmg observer’s cafcufarmrr and dare of verifxazlon
Quallry Assurance Handbook M.9-4.2
Visible Emission Summary Data Sheet
Company Date Locarion _
Start time Emission point

- -
Start Total Average Start Total Average Start Total 4 verage Start Total Average Start Total Average
no. 0fJacity opactiv no. opacity opacity no. opacity opacitv no. opacity opacity no. opaciry opacity_
1 37 73 109 145
2 38 74 110 146
3 39 75 111 147
4 40 76 172 748
5 41 77
6 42 78
7I I I 43I I I 7gI
22 58 94 130 166
23 59 95 131 167
24 60 96 132 768
25 61 97 133 769
26 62 98 134 770
27 63 99 r35 177
736 172 208
737 173 209
138 774 210
31 67 103 139 775 211
32 68 104 740 176 212
33 69 105 141 177 213
142 178 274
143 779 215
144 180 916
Maximum average - % Part number of SIX minute average / _

Number of nonoverlapping averages in excess of standard - Listing star1 number of these averages
Calculated by Date Reviewed by - Date
Quality Assurance Handbook Mg-5.1
and M9-6.2
Method 9 Checklist for Auditors
Name of individual(s) audited
A ffifiarion
Auditor name A ffiiiation
Date of audit Auditor signature
-
fes
- No Commeffr Operation
- 1. Equipment satisfactory
2. Data forms completed
3. Post-notificafion (courtesy obligationj performed
4. Correct idenfification of point of emissions
5. Plume associated with process generation point
6. Credentiats okay
.*
7. Observer acted in professional and courteous manner
8. Proper observer position
9. Opacity readings complere
0. Ancillary measurements available
1. Camera used to validate sightings/source identific8tion
‘2. Facility personnel given a copy of raw data
3. Mutiple sources/piumes/outieIs
‘4. Lighting conditions satisfactory
‘5. Background conditions fraining. etc.) satisfactory
‘6. SLenr angk record&.
17. Fugitive emissions
r 8. Time of day recorded
- 79. Recertified within last 6 months
-
?eneral comments:
Quality Assurance Handbook M9-7.1

INSTRUCTIONS FOR USE OF
THE WSIBLE EMISSION OBSERVATION FORM
INTRODUCl-‘ION
FederalReferenceMethod 9 - Visible Determinationof the Opacity of Emissionsfrom Stationary

Sources(FederalRegister39 39872,November 12,1974) requiresthe recordingof certain specific
information in the field documentationof a visible emissionobservation.The required information
includesthe nameof the plant, the emissionlocation, the type of facility, the observer’sname and
affiiiation, the date,the time, the estimateddistanceto the emissionlocation, the approximatewind
direction, the estimatedwind speed,a descriptionof the sky conditions,the plume background,in
addition to a minimum of 24 opacity observations.
Field experiencegainedfrom pastuseof Method 9 in detemniningcomplianceof sourcessubjectto

opacity standardshasdemonstrateda needfor additionaldocumentationwhen making visible emis-
sions (VE) observations.TheattachedVisible EmissionsObservationForm was developedto assist
in the collection of informationrequiredby Method 9 and suggestedadditionalinformation. The
form was developedafter a review of the opacity forms in usein EPA RegionalOffices and State
and local air quality control agencies.The form includesnot only the datarequired by Method 9,
but also more descriptiveinformation on observationconditions.
The Visible EmissionsObservationForm as designedis a three-partform; the top copy (originat)

goesto the agencyfiles, the secondcopy is for the VE observer’sfile, and it is intendedthat the third
copy be given to the appropriatefacility personnelimmediatelyfollowing the onsite field observa-
tion if this is the agencypolicy or procedure. The forms are numberedserially with a 5-digit number
and eachcopy of the threepart form is imprinted with the samenumber. The form should be com-
pleted onsiteand signedby the observer. It is recommendedthat waterproof black ink always be
usedwith theseforms
The Visible EmissionsObservationfotm (seeFigure 1) can be functionally divided into 10 major

sections,with eachsectiondocumentingone or two aspectsof the opacity detetmination. An “addi-
tional information” sectionis includedfor notation of relevantinformation not covered elsewhereon
the fotm. Spacesfor temporalchangeentries(e.g. “start,” end” andthe “comments” section of the
data set) areusedto recordnew information when the observationconditionschangeduring the
observationperiod.
The following guidelinesdiscussthe major sectionsandeachdataelementfound on the VE observa-

tion Form. This includesa shortexplanationof eachsection’spurpose,an explanationof eachdata
element, a descriptionof the type of information beingsought,andin somecases,examplesof
appropriateentries. Discussionsare keyed to Figure 1 by correspondingcapital letters, and starred
items indicatethat the information is reouiredby Method 9.
Separatecotipanion forms includinga companynotification record andsheetsfor data reduction

calculationsare beingpreparedto accompanythe VE ObservationFomz To tie all theseforms
September 1993
together,all companionforms will include a spacefor recordingthe 5-d@ number(s) of the VE
ObservationForm(s) to which they relate. Eachcompanionform will be accompanied-bya set of
instructions,which like the instructionswhich follow, will addresseachdata elementon the fotm
andwill includeexamplesof appropriateentries.
A. COMPANY IDENTIFICATION. Providesinformationthat uniquelyidentifies the companyand

permits the observerto locateor make contactwith the company.
COMPANY NAME
STREET ADDRESS
STATE
PHONE (KEY CONTACT) souRcEIDNuh4BER
ComnanvNm* - Include the facility’s completename. For positiveidentification of the facility,

the patent companyname,division, or subsidiarynameshouldbe included.
Streetm* - Indicate the streetaddressof the facility (not the mailing addressor the home
office address)so that the exact physicallocationof the sourceis known. If necessary,the mailing
addressor homeoffice addressmay be listed elsewhere.
PhoneKev Contact) - List the phonenumberfor the appropriatecontactperson at the facility such
asthe plant manageror environmentalofficer.
SourceID Number - This spaceis provided for the useof agencypersonneland may be usedto enter
the numberthe agencyusesto identify that particularsource,suchasthe Statefile number, Compli-
anceData Systemnumber,or National EmissionData Systemnumber.
B. PROCESSAND CONTROL DEVICE TYPE. Includesa several-worddescriptor of the process

andcontrol device,indication of current processoperatingcapacityor mode, and operationalstatus
of control equipment. Note: This section,in particular,includesinformation that will probablyhave
to be obtainedfrom a plant official. EPA personnelaskinga plant official for information requires
the approvalof OMB, an active caseinvestigation,or a prominentdisclaimerthat the official is
underno obligation to answer. Sincea facility may considertheir productionrate or other process
information asp.mprietary,the inspectorshallspecificaliyinform them that they have the right to
requestthat this information be submittedsubjectto the “confidentialbusinessinformation” provi-
sionsof 40 CFR 2 SubpartB.
* Required by Reference Method 9; other items recommended.
September 1993
PROCESS EQUIPMENT OPERATING MODE
CONTROL EQUIPMENT OPERATING MODE
ProcessEquipment* - Enter a descriptionwhich clearly identifiesthe processequipmentand type of

facility that emitsthe plume or emissionsto be read. The descriptionshouldbe brief, but should
include asmuchinformation aspossible,as indicatedin the following examples:
- Coal-F&l Boiler - Unit 4/Power Plant
- #2 Oil-FiredBoiler/ChemicalPlant
- Wood WasteConicalIncinerator
- Paint SprayBooth/Auto Plant
-PrimaryCmsheratRockQuarry
- Fiber@assCuring Oven
- ReverbFurnace/CopperSmelter
- BasicOxygenFurnace/SteelMill
- CementPlantKiln
.
~trr!gM&- Dependingon the type of processequipment,this information may vary from a
quantificationof the current operatingrate or a descriptionof theportion of a batch-typeprocessfor
which the emissionopacity is beingread to an explanationof how the equipmentis currently operat-
ing suchas“upsetconditions,” “startup,” or “shutdown.” Other examplesinclude “90 percentcapac-
ity” for a boiler or “85 percentproductionrate” for the shakeoutareaof a grey iron foundry. For a
steelmaltingfurnace,entriesshouldinclude the exactpart of the processcycle for which readings
are beingmade,suchas “charging” or “tapping.” In most cases,this information will have to be
obtainedfrom a plant official
Control FouiDmen~- Specifythe type(s) of control equipmentbeingusedin the system after the
processequipmentin question(e.g., “hot-side electrostaticprecipitator”).
eratin Mode - Indicatethe mannerin which the control equipmentis being utilized at the time of
the opacityobservations(e.g., 1 field of 8 tripped on ESP,scrubberoperatingwithout water, shut
down, off line) andthe operatingmode (e.g., automatic,manual,bypass). This information should
be obtainedfrom a plant official.
C. EMISSION POINT IDENTIFICATION. Containsinformationuniquely identifying the emission

point andits spatialrelationshipwith the observer’sposition. It is recommendedthat distancesand
heightsin this sectionbe notedin consistentunits.
September 1993
DESCRIBE EMISSION POINT
HEIGHT ABOVE GROUND LEVEL HEIGHTRJL4TIVE TO OBSERVER
Start End
DISTANCE FROM OBSERVER DIRECTION FROM OBSERVER
Start End End
DescribeEmissionPaine - Describethe type andphysicalcharacteristicsof the emissionpoint The

descriptionmust be specificenoughso that the emissionoutlet canbe distinguishedfrom all others
at the source. The descriptionof the type of emissionpoint shouldaddresswhether it is (1) a specifi-
cally designedoutlet suchas tacks,vents,androof monitors(havingconfinedemissions)or (2) an.
emissionsourcehavingunconfinedemissionssuchasstoragepiles, chemicaltanks, and non-ducted
materialhandlingoperations.Descriptionof the physicalcharacteristicsof the emissionpoint
shouldincludethe appearance(suchas color, texture,etc.) andgeometry(size, shape,etc.) of the
stackor other outlet, andits location in relationto otherrecognizablefacility landmarks.
Any specialidentificationcodesthe agencyor sourceusesto identify a particular stack or outlet

shouldbe notedalongwith the description; the sourceof the codeshouldalsobe recorded. A
specialidentification codeshouldnot be usedaloneto describethe emissionpoint, sincethey are
sometimesincorrect andalso requirea secondaryreference. The observermust be certain of the
origin of the emissionsthat were beingread. A descriptionof the emissionpoint coupledwith the
identificationof the processequipmentandcontrol equipmentshouldaccomplishthat purpose.
Jieight Above GroundLevel * - Indicate the heightof the stackor other emissionoutlet from its
foundationbase. This information is usuallyavailablefrom agencyNes, engineeringdrawings,or
computerprintouts (suchas NEDS printouts). The informationmay alsobe obtainedby using a
combinationof a rangefinderandan Abneylevel or clinometer. The height may also be estimated
peig.htRelativeto Observer* - Indicatean estimateof the heightof the stack outlet (or of any other
type of emissionoutlet) abovethe positionof the observer.This measurementindicatesthe
observer’sposition in relation to the stackbase(i-e. higheror lower than the base)and is necessaryif
slant anglecalculationsare performed.
Distancefrom Observer* - Recordthe distancefrom thepoint of observationto the emissionoutlet.

This measurementmay be made by using a rangefinder.A mapmay also be used to estimatethe
distance.
This measurementmust be reasonablyaccuratewhenthe observeris closeto the stack (within 3

stackheights)becauseit may be usedin conjunctionwith the outlet heightrelative to the observerto
determinethe slant angleat which the observationsaremade. A precisedetermination of the slant
* Required by ReferenceMethod 9; other items recommended.
September 1993
anglebecomesimportant in calculatingthe positive biasinherentin opacity readingsmade when the
observeris within three stackheightsof the stack
Direction From Obse q * - Specifythe direction of the emissionpoint from the observer. It is
suggestedthat this berVdoneto the closestof the eight points of the compass(e.g. S, SE, NW, NE)
and that a compassbe usedto makethe determination. To accomplishthis: hold the compasswhile
facing the emissionpoint; rotate the compassuntil the North compasspoint lies directly beneaththe
needle(which will be pointing towardsmagneticNorth); then the point of the compassclosestto the
emissionoutlet will indicatethe direction (Figure 3). A map may alsobe usedto make this determi-
nation.
D. EMISSIONS DESCRIPTION. Includesinformation that definitely establisheswhat was ob-

servedwhile making the visible emissionsdetermination. Note: Items called for in this sectionmay
changea numberof times during the observationperiod, It.is recommendedthat thesechangesbe
notedin the Comment spacebesidethe appropriateopacityreadingsandreferenceto this be madein
the correspondingspacein this section.
DESCRIBE EMISSIONS
I
Start
EMISSION COLOR IF WATER DROPLET PLUME
Start Attached 0 Detached 0

POINT IN THE PLUME AT WHICH OPAClTY WAS DETERMINED
t _. )
LStan Find I
-
DescribeEmissions*- Include the physicalcharacteristicsand behaviorof the plume (not addressed

elsewhereon the form) and the distanceit is visible. Physicaldescriptionsmay include such things
as texture, gradation,and contents,examplesare “lacy,” “fluffy,” “copious,” “mushrooming,”
“spreadingover horizon,” and “detachednonwatervapor condensibles.”The standardplume termi-
nology illustratedin Figure4 may be usedto describeplumebehavior. The behavioris generally
usedto determinethe atmosphericstability on the day of the opacity observations.
Fmission Color* - Note the color of the emissions. The plume color can sometimes be useful in
determiningthe compositionof the emissionsand alsoservesto documentthe total contrast between
the plume and its backgroundas seenby the opacity observer. For emissionsthat changecolor a
numberof times during the observationperiod (suchasthosefrom a basicoxygen furnace), the color
changesshouldbe noted in the commentsspacenext to the opacityreadingsthemselves.
If Water Droplet Plume* - This box is only completedif visible water droplets are present. Check
“attached”if condensationof the moisturecontainedin the plume occurs within the stack and the
water droplet plume is visible at the stackexit. Check“detached”if condensationoccurs some
distancedownwind from the stackexit and the water droplet plume and the stack appearto be
unconnected.
i
\.
-
* Required by Reference Method 9; other items recommended.
September 1993
Plumescontainingcondensedwater vapor (“water dropletplumes” or “steamplumes”) are usually
very white andbillowy, andthen wispy at the point of dissipation,wherethe opacity decreases
rapidly from a high value (usually 100%) to zeroif thereis not residualopacitycontributedby the
contaminatein the plume.
To documentthe presenceor absenceof condensedwater vapor in the plume, two points must be
addressed.First, is sufficient moisture present(condensedor uncondensed)in the effluent to pro
ducewater dropletsat in-stackor ambientconditions.3 Second,if enoughmoistureis present,arethe
in-stackand ambientconditionssuchthat it will condenseeitherbeforeexiting the stack or after
exiting (when it meetswith the ambientair)? The first questioncanbe answeredby examiningthe
processtype and/orthe treatmentof the effluent gasafter the process. Somecommon sourcesor
moisturein the plumeare:
- Water producedby combustionfuels,

- Water from dryers,
- Water introducedby wet scrubbers,
- Water introducedfor gascooling prior to an electrostaticprecipitatoror other control
device,and
- Water usedto control temperatureof chemicalreactions.
If water is presentin the plume, data from a slingpsychrometer,which measuresrelative humidity,

in combinationwith the moisturecontentand temperatureof the effluent gascan be usedto predict
whetherthe formation of a steamplume is probable.
Point in the Plumeat Which Onacitv WasDetermined* - Describeasaccuratelyas possiblethe

physicallocationin the plume suchas the distancefrom the emissionpoint where the observations
were made. This is necessaryto establishthat nothinginterferedwith the observer’sclear view of
the contaminantplumeitself, suchas condensedwater vapor, it is alsoimportant in the caseof
secondaryplume formation. Therefore,the observermust specify l) if the readingswere madeprior
to water dropletplume formation or after water dropletplumedissipationand 2) the distancefrom
the emissionpoint and/orwater droplet plume. Descriptionssuchas “4 feet aboveoutlet” and “80
feet downstreamfrom outlet,” “10 feet after steamdissipation”are appropriate.Figure 5 shows
someexamplesof the correct location for makingopacityreadingsin various steamplume and
secondaryplume situations.
E. OBSERVATION CONDITIONS. Coversthe backgroundandambientweatherconditionsthat

occur during the observationperiod andcould affect observedopacity.
DESCRIBE PLUME BACKGROUND

Start End
Start End Start End
WIND SPqD WIND DIRECTION
Srart End Start End
AMBIENTTEMP WET BULB TEMP 1RH Percent
September 1993
.
scrtbePlumeBackmound* - Describethe backgroundthat the plume is obscuringand against
which the opacity is beingread. Whendes&bing the background,include characteristicssuchas
fi’ texture. Examplesof backgrounddescriptionsare “structure behindroof monitor,” “stand of pine
trees,” “edgeof jagged stony hill side,” “clear blue sky, ” “stack scaffolding,” and “building obscured
by haze.”
Backmund Color* - Describethe backgroundcolor including the shadeof the color (e.g., new leaf
green,conifer green,dark brick red, sky blue,and light gray stone). In general,the background
chosento read againstshouldcontrastwith the color of the plume.
..
slcv co ndrna* - Indicate the percentcloud cover of the sky. This information can be indicatedby
using straightpercentages(e.g., 10%overcast,100%overcast)or by description,as shownbelow:
Term Amount of Cloud Cover
clear < 10%

scattered 10%to 50%
Broken 50% to 90%
Overcast > 90%
Wind Sne&* - Record the wind speed.It is recommendedthat it be measuredor estimatedto + or -

5 miles per hour. The wind speedmay be measuredusing a hand-heldanemometer(if available),or
it canbe estimatedby usingthe BeaufortScaleof Wind SpeedEquivalentsshownin Table 1.
Q-. ;
-- TABLE 1. THE BEAUFORT SCALE OF WIND SPEEDEQUIVALENTS
drift but not by wind van
ordinary vanemovedby wind
motion; wind extendslight flag
es are-mov
d
a,
heardin telegraphwires; umbrellas
usedwith difficulty
September 1993
Wind Direction* - Indicatethe directionfrom which the wind is blowing. It is suggestedthat the
direction shouldbe estimatedto eight points of the compass.This canbeaccomplishedby observ-
ing which way the plumeis blowing. If this is not possible,the wind directionmay be determined
by observinga blowing flag or by noting the direction a few bladesof grassor handful of dust are
blown when tossedinto the air. Keepin mind that the wind direction at the observationpoint may
be different from that at the emissionpoint; the wind direction at the emissionpoint is the oneof
interest.
Ambient Temperature* - Theoutdoortemperatureat the plant site is measuredby a thermometer(in

degreesFahrenheitor centigrade).Be certainto note which temperaturescaleis used. The ambient
temperatureis usedin conjunctionwith the wet bulb temperaturewhenthereare indicationsof a
condensingwater dropletplume.
Wet Bulb Temperature- Recordthe wet bulb temperaturefrom the slingpsychrometer. This is done
when thereis a possibilityof a condensingwater droplet plume.
Relative Humidity - Enter therelativehumidity measuredby usinga slingpsychrometerin conjunc-

tion with a psychromeuicchart This information is usedto determineif water vapor in the plume
will condenseto form a steamplume.
F. OBSERVERPOSITION AND SOURCELAYOUT. Clearly identifiesthe observer’spositionin

relation to the emissionpoint, plant landmarks,topographicfeatures,sunposition, and wind direc-
tion,
souRcELAYouTsKETcH DrawNonhArrow
sun
Wind
e
\
0
X Emi!3sionPoint
I
Observer’s Position
Sun Location Line
September 1993
-etch * - This sketchshouldbe drawn as a rough plan view and shouldinclude as
many landmarksaspossible. At the very least,the sketchshouldlocatethe relative positionsof the
obsemedoutlet andassociatedbuildingsin sucha way that they will not be confusedwith others at a
later date, and clearly locatethe position of the observerwhile making the VE readings. The exact
landmarkswill dependon the specificsouse, but they might include:
- other stacks - Stockpiles

-Mills - Rail heads
- Roads - Tree lines
- Fences - Backgroundfor readings
- Buildings - Interfering plumesfrom other sources
To assistin subsequentanalysisof the readingconditions,sketchin the plume (indicatethe direction

of wind travel). The wind directionalsomust be indicatedin the previous section.
Draw North Arrow - To determinethe direction of north, point the line of sight in the sourcelayout
sketchin the direction of the actualemissionpoint, placethe compassnext to the circle and draw an
mow in the circle parallelto the compassneedle(which points north). A map may alsobe usedto
determined&e&on to north.
Sun’sLocation - It is impartant to verify this parameterbeforemaking any opacity readings. The

sun’slocation shouldbe within the 1400sectorindicatedin the layout sketch, this confirms that the
sun is within the 140”sectorto the observer’sback
To draw the sun’slocation, point the line of sight in the sourcelayout sketchin the direction of the
actual emissionpoir& move a pen upright alongthe “sun location line” until the shadowof the pen
falls acrossthe observer’sposition. Then draw the sunat the point where the pen touchesthe “sun
location line.”
ADDITIONAL INFORIvlATION - Includesconditionsand/or deviationsof a factual naturethat

have bearingon the opacity observationsand that cannotbe addressedelsewhereon the form
ADDITIONAL IIWORh4A’I’ION
Additional Information - Note conditionsor deviationsof a factual nature that cannotbe addressed
elsewhereon the form suchasin the commentssectionof the dataset. Thesemust be purely factual
in nature and specific to the particularsource. Examplesof information that may be included in this
section are:
- Description of unusualstackconfiguration (to show multiple stacksor stack in relation to
roof line); attachdrawing, if necessary.
- Referencesto attachments.
September 1993
- Observedor reportedchangesto the emissionsor processduring observationthat are not
notedin the commentsareaof the form.
- Additional sourceidenti.ficationinformation.
H. DATA SET. Opacity readingsfor the observationperiod,organizedby minute and second. This
sectionalsoincludesthe actualdateandstart and endtimesfor the observationperiod and space
next to eachminute of readingsfor noting relevantcomments.
I OBSERVATION DATE START TIME ENDTIME
COMMENTS
September 1993
ObservationDa* - Enter the date on which the opacity observationswere made.
&r-t Time. End Time* - Indicate the times at the beginningandthe endof the actual observation
period. The times may be expressedin K&houror 24hour ume (i.e., 8:35 am. or 0835); however,
24-hourtime tendsto be lessconfusing.
Data Set* - Spacesareprovided on oneform for enteringan opacity readingevery 15 secondsfor up

to a 30-minuteobservationperiod. If observationscontinuebeyond30 minutes, a secondform (and
third, etc.) shouldbe usedto record additionalreadings. The readingsshouldbe in percentopacity
and madeto the nearest5 percent. The readingsare enteredfrom left to right for eachnumbered
minute, beginningat the upper left cornerof the left-handcolumn, labeledrow ‘WIN 1” (minute 1)
andcolumn “SEC 0” (0 seconds).The next readingsare enteredconsecutivelyin the spaceslabeled
MIN 1, SEC 15; MIN 1, SEC 30; MIN 1, SEC 45; MIN 2, SEC0; MIN 2, SEC 15; etc.
If for anyreason,a readingis not madefor a particular 15-secondperiod, a dash (-) shouldbe placed
in the spaceshowingthat the spaceis not just an oversight. The commentsectionbesidethat read-
ing shouldbe usedfor an explanationof why the readingwas missed.
Comments- Spacesfor commentsareprovidednext to the datafor eachminute of opacity readings.

Theseareintendedto provide spaceto notechangingobservationconditionsand/orreasonsfor
missedreadingsin direct conjunctionwith the readingsthemselves.Items to be noted include:
- Changesin ambientconditionsfrom the time of the start of readings

(- - Changesin plume color, behavior,or other characteristics
- Presenceof interfering plumeshm other sources
- Changesin observerposition andindicationthat a new form is initiated
- Conditionsthat might interfere with readingsor causethem to be biasedhigh or low
- Unusualprocessconditions
- Reasonsfor missedreadings
I. OBSERVERDATA. Information requiredto validatethe opacity data.

OBSERVER’S NAME (PRINT)
OBSERVER’S SIGNATURE DATE
.ORGANJZATION
CERTIFIED BY DATE
(
j_
* Requiredby ReferenceMethod 9; other items recommended.
September 1993
Observer’sName* - Print observer’sentire name.
Observer’sSignatuq - Self-explanatory.
m - Enter the date on which the form was signed

. .
IorganlzatloI1*- Providethe nameof the agencyor companythat employsthe observer.
Cenified - Identify the agency,company,or other organizationthat conductedthe “smoke

school” or VE training andcertificationcoursewherethe observerobtainedhis/hercurrent certifica-
tion.
&g* - Providethe dateof the currentcertification.
J. FORMS INTERRELATION. Providesspacefor recordinganotherVE ObservationFOIIII

numberso that forms concerningthe sameobservationcanbeinterrelated.
I CQNTINUED ON VEO FORM NUMBER

I I I I I I
continued on VEO Form Number- Fill in the S-digitnumberof theVE ObservationForm, if any,
where the observationsfrom the form in useare continued.Eachform of a seriesthat hasa form
coming after it will havethe numberof the next form notedin this section.
* Requiredby ReferenceMethod 9; otheritems recommended.
September 1993
APPENDIX D Cement Kilns
Baghouses:
Samples of Pre-inspection Worksheet,

Inspection Checklist,
and
Troubleshooting Guidelines
Ott 1996 Page D - 1

Pre-InsDection Worksheet
SourceID No. SIC

Inspector(s) Date
InspectionAnnounced?
A. General Plant Data from District File
Plant name,address,andphonenumber
Name of plant contact,titk, andphonenumber
Type of process
Allowable emissionrate andop@ty
Date baghouseinstallationapproved
Prior complaintsor episodesof excessemissions
Last inspectiondate
Purposeof inspection
B. ProcessInformation
Confidential? Yes No-
Personsupplyingprocessinformation and title
D-2 June 1994

‘.
Product(s)
Productionrate(s)
Raw materialsused
Portionof processcontrolledby baghouse
Averageuncontrolledemissionrate or concentration(indicatewhether obtainedfrom stack

test, massbalance,AP-42 emissionfactor, other, etc.)
Date of last stacktest and averageemissionrate obtained
Is cleanedeffluent recirculatedbackinto plant? Yes No____
Dust Characteristics
Is material toxic or otherwisehazardousor doesit require specialhandling?

Yes. No Describe
Moisture contentor other gaseousconstituents
Abrasivenessor other properties
Particlesize’data- indicatehow measured
June 1994 D-3

E. Collection System(s)
Baehouse
Manufacturer
Type or trade name
Model No.
No. of Compartments
Bags/ compartment
Baglxd
Total cloth area
Em
Manufacturer
Model No.
Bladetype
Belt or direct drive
Powerrating
Positiveor negative
. pressure
liza&k
Manufacturer
Material
Woven or felted
Weave
Weight
Permeability
Operatingtemp. range
Surfacetreatment
Coatingupon startup
Guaranteedlife
Actual life
Clean& Svstem itI% ii2 it3

Method
Frequency
Actuatedby
Anticollapserings
. Wire meshcages
F. Dust handling system(s)
Type of dust transportsystem
Fateof collectedmaterial
June 1994
‘.
InsDection Checklist
This checklistis designedto serveasan exampleof the informationgathering processthat a

regulatoryagencyinspectormay follow in order to make a compliance determination. District
inspectorsmay wish to usethis checklistas a guidein drawingup their own baghouseinspection
sheets.
Step1 Observethe StackEffluent

Step2 Checkthe ContinuousEmissionMonitors
step 3 Measurethe Fan OperatingParameters
Step4 RecordandEvaluateBaghouseParameterMonitors
Step5 InspectBaghouseExterior
Step6 InspectDust CaptureSystem
‘step 7 EvaluateProcessOperatingRecords
Step8 Internal Inspection
Step9 Review of OperatingRecords
June 1994 D-5

VLSI&E EMSSON 08SEWATiON FORM .
I -. i .. . . - . -7 I I. I- I-I-.
4 I I I I
4 t I I I
ta 1
w
n I
-
Iwm- I
I- X--
.
Opacity moni,tor readings
Operating: Yes W--

Minimum, %
Average,70
Maximum, %
Spikes(Characterizefrequency,duration,intensity)
Calibration spikes (Characterizelevels,frequency)
Calibrated according to required schedule: Yes No-
Gas temperature
0, inlet level, %: Baseline Present.

0, outlet level, %: Baseline Present
Difference in presht valuesgreater than l%? Yes No-
(Tf “Yes” inleakageis probablyoccurring)
CO, inlet level, % : Baseline Present

CO,outlet level, %: Baseline Present
Comments
.’
June 1994 D-7

Steu 3 Measure the Fan ODerating Parametea
Baseline l?tylll.Change.
1. Increasein total static pressureacrossfan
2. Electric current drawn by fan motor
3. Fanwheel rotation speed(rpm)
4. Gastemperatureat fan inlet
5. Flue gasoxygenlevel at fan inlet
A. Baselineand presentvaluesof Parameters1,2, 3, differ by lessthan 10%: Yes- No-

B. BaselineandPresentvaluesfor Parameter4 differ by lessthan 20 OF: Yes- No-
(If answ& to questions A and B are both ‘Yes’ then mass emissionshave probably not
changedsignificantly.)
Massemissionsmay haveincreasedsignificantly: Yes No
(Increased oxygen levelsin flue gasindicate air inleakage.)
(Reducedgastemperature and increasedelectric current indicate air inleakage.)
Air inleakagemay be significant: Yes No-
D-8 June 1994

&yu 4 Record and Evaluate BaPhouseParameter Monitor ReadingS
Baseline Present Comments
Temperature
Pressuredrop
Gasvolume flow
Moisture content
Compressedair pressure
Reveke air pressure
Air-to-cloth ratio, gross
A/C ratio, net

(2 compartmentsoff-line)
Effkiency
Emissionrate
June 1994 D-9

SteD5 TnsDectBayhouseExterior
I Check the following items:
Accessdoors
Top accesshatches
Expansionjoints.
Ducts
Condition of exterior housing
Look and listen for the following:
0 Air inleakage 0 Air leakageor fugitive emissions

0 Corrosion 0 Warping
0 Missing parts 0 Unusualnoises
0 Unusualodors 0 Elevatedtemperatures
0 Loosebolts
1
u cleanirw svstem;
Air reservoirpressure: Baseline Present

Valves-actuating:Yes No-
Compressedair system:
Aftercoolers: Yes No-
Automatic condensatetrap: Yes No-
Filters: Yes No-
Water or rust depositspresentin system? Yes No-
Water or other materialretainedin oil traps,if any? Yes No-
D-10 June 1994

Steu 6 Ash Handling Procedures
Vibrators: Yes No -
Operating: Yes No-
Heaters: Yes No-

Operating: Yes No
Level indicators / alarms: Yes No-

Operating: Yes No-
Transport equipment: Screws Pneumatic Other

Operatiug: Yes No
Evidenceof inleakage
ComrLents
: .
:
Baselineor Present
Permitted Value Yalues
Processweight :
Gasflow tite
Excessair
Gas temperature
Pressuredrop acrossbaghouse
Moisture content
Flue gasanalysis(% 02, CO,, ...) _’
Comments:
June 1994
Sten 8 Internal Insnection (Ontional)
Internal inspection should be scheduledfor a time when plant is shut down.
Caution: Before performing internalinspection,personnelshouldensurethat all safety

measuresare observed.
The inspector may be able to peer into a baghousewhile it is operating. Permission from the
operator must be obtained first. Make sure compartment is isolated.
View from clean-sideaccesshatch:
Clean-sidedust deposits?Yes No- Comments
Poor bagtension? Yes No- Comments
View from dirty-side accesshatch (usecaution!):
Bagsbeingblinded? Yes No- Comments

,’
i
1.
Any holesin bagsvisible? Yes No- Comments
When conducting a full internal inspection, the following items should also be checked:
Inlet plenum -
Baffles
Solenoidvalves
Poppetvalves
Bag clamps
Mechanicallinkages
Thicknessof dust layer in bags
Pinholesin any bags?
More than l/4 inch dust layer on floor plates?

Bags wearingprematurely?
Perform screwdriverrip test on bagsremovedfrom service. Results:
1
D-12 June 1994

.
SteD9 RevewODerating Records
. iremen& . .
P-rdk=uzReau P=ords KeDtSatdacfor~lv
Opacity meter Yes No- Comments
Baghouseinlet gastemperature Yes No- Comments
Baghouseoutlet gastemperature Yes No- Comments
Pressuredrop acrossbaghouse Yes No- Comments
Yes No- Comments
Yes No Comments
Yes No- Comments
Yes NO Comments
Yes No- Comments
Maintenance LOPSKq&
Location of failed bags Yes No- Comments

Bag replacementfrequency Yes No- Comments
Causeof bagfailure Yes No- Comments
Yes No--- Comments
Yes No- Comments
Yes No- Comments
Yes No- Comments
Percentof time baghousehasbeenfully operationalwhenpmcessis in operation:
Has a detailedmaintenanceschedulebeeninstituted?
Is maintenancescheduleasrecomendedby baghousemanufactureror by plant?
How long arerecordskept on ffie? .
Are spareparts kept on hand?
June 1994 D-13

_* Which of the following problem areas have led to periods of excessemissionsor causedthe
{ processto be shut down?
Problemareq Duration Frequency
Insufficient dust pickup

and/ortransport(fugitive emissions)
Duct abrasionor corrosion
Temperatureexctisions,
high or low
Moisture
Fan abrasion,vibration, etc.
Grossbag failure
Inadequatebagtension
Bag chafingor abrasion
Pressureloss
Compartmentisolationdampers
Cleaningmechanism
Visible em&ions
Pluggedhoppers
Hopper fzes .
Dust dischargesystem
‘,
i” If frequent breakdowns have occurred, can the source show maintenancerecords to
demonstrate they have made good fai+efforts to treat causesof operating problems?
D-14 June 1994

ConclusionsI RecommendatioQ
.’
. .
Compliancestatus
Need for further action
Corrective actions to be taken
..
Time required to rectify problems
Need for follow-tip inspection
Inspector’s signature
Date
Approved by
Title
,
‘
June 1994 D-115

,--I. .-.
(:’
Troubleshootina Guidelines for Common Baahouse ODeratiDaProblems l1
Problem or Symptom Probable Cause Remedy
1. Visibledischarge/dust
in clean a. Bagsimproperlyinstalled 0 Check baginstallationprocedures;
air plenum repairas necessary.
b. Bag clampstoo loose 0 Tighten bagclamps.
c. Tom or damagedbags 0 Replaceor tie off andreplaceat later date.
d. Leakageat tubesheet 0 Checktubesheetjoints; repair as

(field assembledunits) necessary.
e. Venturi fastenerslooseor 0 Repairasnecessary

missing(PJ)
f. Insufficient filter cake 0 Allow moredust to build up on bagsby

cleaninglessfrequently. Use a precoat
(startuponly).
g. Bagstoo porous 0 Sendbagout for permeabilitytest and

consultwith manufacturer.r
h. Inadequatebagtension l Checktensionand/orspringsfor
compressionto properlength.
2. Excessivepressuredrop a. Gasflow too high . 0 Checkfan speedanddamperpositions;

(a differentialpressureof 1 to adjustto specifiedratings. Checksystem
6 in. W.C. canbe considered design. Checkisolationdampers,valves,
normal) . linkageandseals. Checkair supplyon
pneumaticoperators.
june 1994 E-2

.
oubleshooting Guidelines for Common Baahouse Operatma Problems (contd.]
Problem or Symptom ProbableCause ‘. ,, Remedy
‘. b. Improperbagcleaningaction. 0 Refer to problem6;

‘.
c. Improperdustdischargefrom 0 Checksealaroundslidegate(or in
hopper airlock); resealif leakageis occurring.
Ensurecontinuousdust removalfrom
hoppers.
d. Moistureblindingof filter bags l Correctcauseof excessmoistureand

replacebags. Recoveryof bagis ..
sometimespossibleby runningcleaning
system(without moving air through
collector)from 1 to 30 hours.
e. Cloggingof filter bags 0 Eliminateoil or staticchargesfrom

collector. Control airflow during startup.
.Checkfor excessiveoperatingtemperature,
Checkto seethat dustcharacteristics
havenot changed.If usinglaundered
*. bags,checkfor shrinkage.
f. Staticelectricityin collector 0 Increaserelativehumidity if possible.

Usegroundedfilter bags.
g. Excessivedust in cleanair 0 Cleanplenum,checkbagsfor dirt on

plenum(candiminishcleaning cleanside; cleanor replacebags.
effectivenessby pluggingthe
.’
June 1994 ” E-3

/----.
Troubleshooting GuidelInes for Common Baahouse Operatina Problems (contd.)
h. Insufficient blowring air (RI) l Checkdrive beltson blower, blower speed,

blower rotation; replaceinlet blower filter;
checkblowring hose; checkblowring for
0 Checkbeltson reversingmotor; check

for brokenchainsor chainoff sprocket;
checksheavesor sprocketsfor looseset
screws,check settingof tripper pins;
checktripper leverfor bend,looseness,
j. Incorrectpressurereading 0 Cleanout pressuretaps; checkhoses

for leaks; checkfor properfluid in
manometer;checkdiaphragmin gauge.
3; High bagfailurerate
a. Deterioration/decomposition a. Improperbagmaterialfor dust l Analyzedust andcheckwith manufacturer.

chemicalcomposition Treat with neutralizerprior to collector.
b. Operatingbelow aciddewpoint 0 Increasegastemperature.Bypass

collectorduring startup/shutdown.
b. Wearingout/abrasion a. Baffle plateworn out 0 Replacebaffle plate.
b. Excessivedustloadingand/or 0 Install primary collectorupstreamof

largeabrasivemetallicparticles baghouse.
June ‘994
Troubleshootina Guidelines ‘for Common Baahouse Operatina Problems kontd.)
c. Cleaningcycle too frequent 0 Increasecleaninginterval.

. U’J)
d. Shakingtoo violent (S) 0 Decreaseshakingfrequencyand/or
amplitude.
e. Inlet air not properlybaffled 0 Consultmanufacturer.

from bags
f. Pulsepressuretoo high (PJ) 0 Reducepressure.
g. Bag cageshavebarbs(PJ) 0 Remove-orsmoothebarbs.
c. Burningor acceleratedfabric a. Stratificationof hot andcold 0 Install baffles to createturbulence.

deterioration gases
b. Sparksenteringcollect,or 0 Install sparkarrestor.
c. Failureof coolingor dilution 0 Checkdesignwith manufacturer.

system.
d. Excessivetemperature 0 Reduceoperatingtemperatureor use

filter bagsof highertemperaturerating.
1. Other a, Hopper bridging l Materialbuildupinto the bagareacan

overstressfilter elements.Locatecause
of bridgingandcorrect; cleanout hopper.
June 1994 E-5

.-f--y --\,
Troubleshootina Guidelines for Common Baghouse Operating Problems [contd.l
41 Filtering actionimpaired a. Impropercleaningsystem 0 Refer to Item 6.

operation.
b. Excessivemoistureentering 0 Refer to item 2.d.

collectorblinding bags.
c. Incorrectgasflow 0 Refer to Item 5.
d. Incorrectbagmaterialfor.gas l Replacewith bagsof propermaterialfor

composition type of dust.
e. Gastemperaturehigherthan 0 Refer to Item 3.c.d.

specified.
f. Staticelectricity buildupin 0 Refer to Item 2.f.

collector
5. Gasflow throughsystembelow a. Incorrectfan speed , . 0 Checkrotation, correctif wrong,

a designratingflow fan amperage. or direction changesheaveratio.
b. High differential pressuredrop l Refer to Item 2.
c. Fan beltsslipping 0 Checktension.onfan beltsandadjust

if necessary.
d. Air leakage‘in gassystem l Checkaccessdoors,plenum,manifolds,

ductwork; repair leaks.
Jtune ‘994
oubleshooting Guidelines for Common Baahouse Operatina Problems [contd.)
:
Problem 6r Symptom Probable Cause Remedy
e. Leakagein dust collection 0 Checkfor hopperor dischargesystem

system leakage;repairasnecessary.
f. Blockedgassystem 0 Checkbagsfor blinding,obstructionin

duct passages,or closeddamper;clean
or repair asnecessary.
g. Fanandmotor sheavesreversed 0 Checkdrawingsandreversesheaves.
h. Systemstaticpressuretoo high l Measurestaticpressureon both sidesof

fan anddiscusswith designerof duct
velocity andconfiguration.
i. Excessivemoisture 0 Refer to Item 2.d.
j. Infrequentcleaning l Refer to Item 6.
6. Impropercleaningsystem \
operation
‘.
a. Blowring reversingswitch a. Worn camsor rollers 0 Repairor replaceswitch assembly. I
failure (RI)
b. Improperlyset tripper level l Adjust arc of movementfor aproximately
60” aboveor belowhorizontal;uneven
‘. arc will causeswitch to work in only one
direction. ..
.. ‘.
c. Dirt in switch l Checkto seethat enclosureis properly
installed’
E-7
June 1994
oubleshootina Guidelines for Common Baahouse Operating Problems (contd.)
b. Inability to maintaincompressed a. Faulty or undersizedcompressor 0 Checkcompressormanual. Pressure

shouldnormally be maintained
between80 to 110psig.
b. Leakageor restrictionin main l Locateandrepair leak‘orrestriction.
c. Defectivetimer operation 0 Make sureall valvesare beingactivated.

Checkfor sticking timer relayor pulse
d. Improper operationof solenoid

or diaphragmvalves in wiring which cancausevalvesto
stick open. Cleanandcheckpilot plunger.
NOTE: Steadyrush of air indicatesopenvalve; no air pulse

indicatespluggedvalve. Solenoidvalvesrequirea
minimum of 5 psig to close. A long compressedair
3run after the shutoff valve.hascloggedcanpreventthe
required5 psigfrom developing. The solutionwould
be provisionof reservoirand shutoff valve nearthe
e. Compressedair consumption 0 Reducecleaningcycle,durationof pulse,

or supplypressure,if possible.
Troubleshootina Guidelines $or Common Baahouse Operatina Problems (contd.1
f. Pluggeddryer 0 Replacedessicantor bypassdryer if

permitted.
g. Supplyline too small l Consultdesign.
h. Compressorworn l Replacerings.
c. Reducedcompressedair a. Pulsing(solenoid)valves not 0 Checkdiaphragms,springs,andpilot

consumption(PJ) working valves.
b. Failedtimer 0 Check terminaloutputs.
d.’ Inadequatecleaning(S) a. Defectiveshakermechanism l Check shakerspeed,amplitude,andbag

tension; adjustif required. Checkfor
brokenlinkageandlost pinsconnecting
linkage.
7. Moisturein baghouse a. Insufficientpreheating 0 Run systemwith hot air prior to starting

processgasflow.
b. Systemnot purgedafter 0 Keepfan runningfor 5 to 10minutes

shutdown after processis shutdown.
c. Wall temperaturebelow 0 Raisegastemperature,insulateunit,

dewpoint install auxiliary heaters.Lower dewpoint
by keepingmoistureout of system.
d. Cold spotsthroughinsulation l Eliminatedirect metallinesthrough

insuation.
June 1994 E-9

Trloub eshootma
’ Guide Ii nes for Common Baghouse Werating Prob lems (contd. 1
0 Checkautomaticdrains,installaftercooler,
f. Repressuringair causing 0 Preheatrepressuringair; useprocessgas

condensation(RA) as sourceof repressuringair.
g. Moisturein compressedair line 0 Make surecooleror water trap is

.
8. Insufficient dustpickup at a. Leaksin ductwork, accessdoors,

emissionpoints and/orhopperdischargevalves.
b. High differential pressure 0 Refer to Item 2.
c. Slippingfan beltsor fan rotating 0 Checkfan andrepairasnecessary.

in wrongdirection.
d. Cloggedduct or closedor 0 Checkall ductwork anddamperpositions

partiallyclosedgateor damper andoperation.
e. Duct sizeor run otherthan 0 Checkdesignspecificationswith

manufacturer. Closeopenareasaround
dust source. Checkfor crossdrafts that
overcomesuction.
9. Fanproblems-- excessivewear, a. Improperfan 0 Checkwith fan manufacturertosee if

noise,vibration,or motor fan is of properdesignfor application.
overloading
June 1994 E -.:y,:-

J
‘.‘..&$2
Troubleshooting Guidelines for Common Baahouse Operatina Problems (contd.)
‘,

*.
b. Fan speedtoo high 0 Consultfan manufiicturer.
c. Dust buildupon fan blades. 0 Cleanfan andcheckfor water,
*. d. Improper fan wheel l Checkwith manufacturer.

..
e. Sheavesnot balanced l Have sheavesdynamicallybalanced.
f. Worn bearings .. 0 Replacebearings.
g. Air volume too high 0 Refer to Item 2.a.
h. Motor not sizedfor cold start 0 Dampenfan at startup,reducefan speed,

provideheatfaster, or replacemotor.
..
10. Hopper/dustdischargesystem
failure or excessivewear
a. High screwconveyoror a. Screwconveyoror airlock 0 Measurehourly collectionof dust and

wear undersized consultmanufacturer. ..
b. Conveyoror airlock speedtoo l Checkandreducespeed.

high
c. Thermalexpansion l Consultmanufacturer.
b. 13equ;~a;crr+vconveyoror / a. Undersizedequipment 0 Consult manufacturer.
June 1994 E-11

oubleshootina Guidelines for Common Baahouse Qr>eratina Problems (contd.)
b. Misalignedscrewconveyor l Checkandalign.
c. Overloadingcomponents l Checksiiing anddesignof all components

versusdust deliveryrates.
cl High pneumaticconveyor a. Blower set too fast l Checkandreducespeed.

wear
b. Undersizedpiping l Reviewdesign-- slow down blower or

increasepipe size.
d. Pneumaticconveyorpipes a. Elbowsdesignedwith too short 0 Replacewith long radiuselbows.

plugging a radius
b. Overloadingpneumatic 0 Review design.

conveyor
c. Slugloadingof dust . 0 Feeddust gradually.
d. Moisturein dust 0 Refer to Item 7.
e. Material bridgingin hopper a. Moisturein baghouse 0 Refer to Item 7.
b. Dust beingstoredin hopper 0 Ensurethat dust is removedcontinuously.
c. Insuficienthopperslope 0 Rework or replacehoppers.
d. Conveyoropeningtoo small 0 Usea’wide flared trough.
June 1994
oubleshootina Guidelines for Common Baahouse ODeratina Problems kontd,)
.I Pioblem or Symptom ProbableCause Remedy
f. Excessivecorrosionof a. Air inleakagethroughdefective 0 Properinspectiona’ndmaintenance.

baghousestru&re, bag gaskets
mountings,wire cages
b. Missingor damagedinsulation 0 Replaceandrepairinsulation.
c. Frequentdewpointexcursions 0 Heat tracing and/orgastemperature

elevation.
PJ = pulsejet
RA = reverseair
RJ = reversejet
S = shaker
June 1994 E-13

Tvpical Maintenance Schedule for a Fabric Filter Svstem 5plgs2op
*ls22,23 ,.c-c.
,.. .+
>:
.:.
_-
Inspection
Frequency Component Procedure.
Daily Stackandopacity meter Checkexhaustfor visible dust
Manometer Checkandrecordfabric pressure

lossandfan staticpressure.
Watch for trends.
Compressedair system Checkfor air leakage(low

pressure).Checkvalves.
Collector .Observeall dials,meters,

charts,andgaugesetc. on
control panelandlisten to
systemfor properlyoperating
subsystems.
Dampervalves Check.all isolation,bypass,and

cleaningdampervalvesfor
synchronizationandproper
operationbasedupon
manufacturerguidelines.
Rotatingequipment Checkfor signsof jamming,

anddrives leakage,brokenparts,wear, etc.
weekly Filter bags Checkfor tears,holes,

abrasion,properfastening,bag
tension,dust accumulationon
surfaceor in creasesandfolds.
Cleaningsystem Checkcleaningsequenceand
cycle timesfor proper valve and
timer operation. Check
compressedair lines including
oilers andfilters. Inspect
shakermechanismsfor proper .
operation.
Hoppers Checkfor bridgingor plugging.

Inspectscrewconveyorflighting
for properoperationand
lubrication.
June 1994
Typical Maintenance Schedule for a Fabric Filter Svstem (contd.]
Inspection
Frequency Component Procedure
Monthly Shaker mechanism Inspect for loose bolts.
FaNs) Check for corrosion and material

buildup and check V-belt drives
and chains for tension and wear.
.
Monitor(s) Check accuracy of all indicating
equipment.
Quarterly Inlet plenum Check baffle plate for wear, if

appreciable wear is evident,
replace. Check for dust deposits.
Access doors Check all gaskets.
Shaker mechanism Tube m (tube hooks suspended

from a tubular assembly):
inspect nylon bushings in shaker
bars and clevis (hanger)
assembly for wear.
Channel shakers (tube hooks
suspended from a channel bar
assembly): inspect drill
bushings in tie bars, shaker
bars, and connecting rods for
WCU.
Semi-annually Motors, fans; etc. Lubricate all electric motors,

speedreducers, exhaust and
reverse air fans, and similar
equipment.
Annually Collector Check all bolts and welds.

Inspect entire collector
thoroughly, clean and touch up .
paint where necessary.
June 1994
APPENDIX E Cement Kilns
Electrostatic Precipitators:
Sample Inspection Checklist

and
Summary of Common Problems
Ott 1996 PageE-

(”
InsDection Checklist
This checklist is designed to serve as an example of the information gathering process that a regula-
tory agency inspector may follow in order to make a compliance determination. District inspectors
may wish to use this checklist as a guide in drawing up their own electrostatic precipitator inspection
sheets.
Step 1 Stack Effluent

Step 2 Continuous Emission Monitors
Step 3 Fan Operating Parameters
Step 4 ESP Performance Analysis from Electrical Readings
Step 5 External Inspection
Step 6 Ash Handling Procedures
Step 7 Process Operating Conditions
Step 8 Internal Inspection
Step 9 Review Operating Records
VlSIBLE EMISSION OBSERVATION FORM
No.
PROCESS- opQuTp(GmoE 5
I
9 -
7I 1 I- I- I -
I I I
10
11
r
17
I
/ 18
/
19 I
I4 I- I I I
t3 I I I I
x Em-Pomt
29 I
29
30
$teo 2 Continuous Emission Monitory
Opacity monitor readings
Operating: Yes- No-

Minimum, %
Average, %
iMaximum, %
Spikes (Characterize frequency, duration, intensity)
Calibration spikes (Characterize levels, frequency)
Calibrated according to required schedule: Yes- No-
,,‘. Gas temperature

i,
Comments
f
‘_
Sjeu 3 Fan Ooeratin? Parameters
Parameter Baseline Presen_ Change. 9%

1. Increasein total static pressure acrossfan
2. Electric current drawn by fan motor
3. Fan wheel rotation speed (rpm)
4. Gas temperature at fan inlet
5. Flue gas oxygen level at fan inlet
A. Baseline and Present values of Parameters 1,2,3 differ by less than 10%: Yes- No-
B. Baseline and Present values for differ by less than 20 “F: Yes- No-
(If answers to questions A and B are both ‘Yes’ then mass emissions have probably not
changed significantly.)
Mass emissions may have increased significantly: Yes- No-
(Increased oxygen levels in flue gas indicate air inleakage.)

(Reduced gas temperature and increased electric current indicate air inleakage.)
Air inleakage may be significant: Yes- No-
Generaily, the inspector performs Steps 4 onwards to confirm the evaluations of Steps i - 3.
The inspector may skip over to Step 9 if the answers to the following 3 questions are ‘Yes.’
1. Gas flowrate has increased or decreasedsubstantially: Yes- No_,

Basis for determination: Opacity - Steps 1,2
Gas temperature - Steps 2,3
System PressureDrop - Step 3
Fan Motor Current - Step 3
2. Mass loading has increased: Yes- No-

System PressureDrop - Step 3
3. Particle outlet size distribution has changed: Yes- No-

Color of plume - Step 1
Steo 4 ESP Performance Analvsis from Electrical Readin=
Compare V, A and sparkrate values for all T-Rs with baseline values.
Note all inoperative meters
‘-R >resent Iaselinf Yesent aseiine Yesent ,aseline resent 3aseline ?resent iaselinc
et rimary Vimary rimaq ‘rimary Spark Spark Sec. Sec. Sec. Sec.
TO. roltage v’oltage &rent h-rent Rate Rate Jo1tags Voltage Current Curren
Any bus sections not operating at design levels?

ESP Lavouf
Inspector should identify T-R sets that power bus sections.
Ev a Iuat ino of ESP Performance Bv Corona Power Method
Electrical Parameters
1. What is K, for this faciIity?
2. What is C (Coefficient of Proportionality) for this facility?
C = (emission level) / (penetration)
Use values from a previous source test
3. What is the volume ffowrate for each chamber?
4. Is particulate resistivity moderate to high? Yes- No
5. Is power input to ESP less than 1OOOW per 1000 ACFM? Yes- No-
If the answers to either questions 4 or 5 above are ‘No,’ you cannot determine ESP perform-
ance by the Corona Power method.
If the ESP has secondary voltage and secondarycurrent meters, fill out Table A. If not, use primary
voltage and primary current values and fill out Table B.
Table A
Chamber A Chamber B
11
PC=Total Corona Power 1 1 P-= Total Corona Power I

Table B
Chamber A Chamber B
1T-R 1 Primary 1 Primary 1 Corona 1 T-R Primary Primary Corona
I I
Set
#
Current
mA
Voltage
kV
Set
#
Current
mA
Voltage
kV
Power
mAxkV
I I I I I’
P,= Total Corona Power I P,= Total Corona Power 1 1
Do permit conditions require a minimum power level to the ESP or to each chamber?
p = e -.06KI(PclV)
I
E.L. = Pt x C
I
Specific Kl Penetration C Emission
Corona Pt Level
I PC I Rate Power
A
B
c
Combined calculated emission level values for all chambers ducted to the same stack:
Allowable maximum emission level for this facility:
Is calculated E.L. value greater than allowable maximum emission level? Yes- No-
If yes, a source test should be ordered to determine emission level more exactly.
Comments:
Insulators:
Evidence of tracking: Yes- No-
Corrosion of insulator qornpqtqzt: Yes- No-
Fan working properly: Yes- No-

,
__
Air filters for c.ompartment clogged: Yes- NO-
Heater working; Yes? NO-
Rappers all operating:
Air Infiltration Comments Corrosion Comments

Yes No Yes No
Access doors
Top accesshatches
Expansion joints
Rapper shafts
Fugitive emissions from ESP or ductwork: Yes- No-
Comments
Steo 6 Ash Handlinv Procedure3
t._
’
Vibrators: Yes- No
Operating: Yes- No-
Heaters: Yes No-

Operating: Yes No-
Level indicators / alarms: Yes- No-

Operating: Yes- No-
Transport equipment: Screws- Pneumatic- Other-

Operating: Yes- No-
Evidence of inleakage
Comments
Steu 7 Process heratim= Conditions
Baseline or Present
Permitted Value3 Values
Gas flow rate
Excess air
Gas temperature
Pressuredrop across ESP
Moisture content
Soot blowing intervals
Flue gas analysis (% 0,, CO,, ...)
Comments
Sten 8 Internal Iusmction
For information to be gathered when conducting an internal inspection, see checklist provi’ded
for operators of ESPs for their annual internal inspection, in appendix D of CAP ESP manual.
t o 9 Review Onerating Records.
t*. Se
Recordkeeoing Reauirements Records Keot Satisfactorilv
Opacity meter
ESP inlet gas temperature
ESP outlet gas temperature
Pressuredrop across ESP
If frequent breakdowns have occurred, can the source show maintenance records to demon-
strate they have made good faith efforts to treat causes of operating problems?
Inspection findings:
Compliance determination:
Maintenance recommendations:
Ic Precmtor Baseline Cornparisof13
PossibleOperating Problems AverageBaseline Observed Location * Abnormal

(SpecifyValue) (SpecifyValue) (Check)
I. ELECTRICAL
A. ParticleResistiviu
1. Peakvoltagelow (down E
5-10 kV)
2. Rappingintensity E
(increased)
3. Temp.changed(a 50“F) E
4. Sparkrate increased E
(k 50 sparks/min)
5. Opacityhigh E
B. Transformer-Rectifier
setproblems
1, No secondarycurrent N/A E
2. No penthousepurge N/A N/A E
3. Voltagezero,currenthigh N/A N/A E
4. Opacityhigh E
C. Insulatorfailure
1, Peakvoltagelow E
2. Penthousepurge(not used) N/A N/A
3. Pentousetemp.high (&20 “F)
4. Opacityhigh
5. Cracksvisible N/A N/A
‘E is external,I is internal.
,“-’
j3P Baseline ComgEyison fcontd . 1
PossibleOperating Problems AverageBaseline Observed Location a Abnormal

I. ELECTRICAL(continued)
D. Brokendischargewires
1. Depositson wires N/A N/A I
2, Violent matterfluctuating N/A N/A E
3. Hopperlevel indicatornot N/A N/A E
used
4. Sparkrate high & 50 sparks/ E
min.)
5. Opacityhigh E
6. Brokendischargewires N/A N/A I
II. GASFLOW
A. Excessivevelocity
1. Flow ratehigh E
2, Voltageshigh, currents,iow E
3. Opacityhigh E
B. ponuniformdistribution
1. Flow rate increased E
2. Secondarycurrentsnonparallel N/A N/A E
3. Hopperleveldifferences I
on parallelbranches
4. Rapperson distribution E or I
platesnot used
aE is external,I is internal.
PossibleOperating Problems AverageBaseline Observed iocation * Abnormal
III. .MECHANICAL
A. mper Problems
1. Puffs visible N/A N/A E
2. Peakvoltagechanges,secondary E
currentconstant
3. Sparkratechanged E
4. Dust sticky N/A N/A E
B. lfleppersolidsremoval
1, Brokendischargewires N/A N/A I
2. Massloadingprobably N/A N/A E
increased
3. Nonuniformgasdistribution N/A N/A E
4. Hoppersnot emptied N/A N/A E
continuously
5. Level indicaorsnot used N/A N/A E
6. Heatersnot used N/A N/A E
7. Vibratorsnot used N/A I E
8. Hoppersnot insulated N/A -EL E
9, Corrosionaroundoutlet valves N/A N/A I
10. Hopperslopec 60” ’ N/A N/A E
11. Hoppersfull or bridged N/A N/A I
C. Collectionplatewarpageand
misalipnment
1. Changein air load N/A N/A E
2. Repeatedhopperoverflow N/A N/A E or I
3. Air inleakage N/A N/A E
4. Misalignmentvisible N/A N/A I
1.E is external, I is internal.

:-
BSPl%wtline Cowwison (cantd,)
PossibleOp&atiing Problems AverageBaseline Observed Location ” Abnormal

IV. EFFLUENTCHARACTERISTICS
A. Mass.loadinpincrea$eS
1. Opticityhigh E -___
2. Inlet section,secondaiy E
currents,low
3. Hopperunloadingfrequency E -
in&eased
aE is external,I is internal.
‘Effect on Preventive
Malfunction Cause ESPEfficiency CorrectiveAction
Measures
Poorelectrode Poordesign Realignelectrodes. Checkhoppers

Candrasticallyaffect
alignment Ash buildupon frameandhoppers performanceandlower Correctgasflow. frequentlyfor proper
Poorgasflow efficiency operation
Brokenelectrodes Wire notrappedclean,causes Reductionin efficiency Replaceelectrode. Boilerproblems:

anarc thatembrittlesandbums dueto reducedpower checkfor insufficient
throughthe wire input, bussection excessair, insufficien
unavailability pressurereadingon
gages,fouledscreen
tubes,andfouledair
preheater
Clinkeredwire. Causes:poorflow Inspecthoppers;
area,distributionthroughunit is checkelectrodes
uneven;excessfree carbondueto frequentlyfor wear;
excessair abovecombustion inspectrapperstie-
requirements or fan capacity quently.
insufficientfor demandrequired;
wiresnot properlycentered;ash
buildupresultingin bentframe,
sameasabove;clinkerbridgesthe
platesandwire shortsout; ash
buildup,pushesbottleweightup
causingsagin thewire; “J” hooks
haveimproperclearances to the
hangingwire; bottleweighthangs
upduringcoolingcausinga buck-
ledwire; andashbuildupon bottle
weightto the frameformsa clinker
andbumsoff thewire.
/_--\
/-‘,
Sufygry of Problel]ls Associated Wims lcontd .)
Effect on Preventive
Malfunction Cause ESPEfficiency Corrective Action
Measures
Distortedor skewed Ash buildupin hoppers Reducedefficiency Repairor replace Checkhoppersfre-

electrodeplates Gasflow irregularities plates. quentlyfor proper
High tempera&es Correctgasflow. operation;check
electrodeplates
duringoutages.
Vibratingor swinging Unevengas.flow DecEasein effi- Repairelectrode. Checkelectrode

electrodes Brokenelectrodes ciencydueto re- frequentlyfor wear.
ducedpowerinput
Inadequate
levelof High dustresistivity Reductionin effi- Cleanelectrodes; Checkrangeof
powerinput(voltage Excessiveashon electrodes ciency gasconditioningor voltagesfrequently
too low) Unusuallyfine particlesize alterationsin to makesurethey
Inadequatepowersupply temperatureto arecorrect.
Inadequatesectionalization reduceresistivity; In situ resistivity
Improperrectifier andcontroloperation increasesectionali- measurements.
Misalignmentof electrodes zation.
Backcorona Ashaccumulationon electrodescauses Reductionin effi- Sameasabove Sameasabove

excessivesparking,requiringreductionin ciency
voltagecharge.
Brokenor cracked Ashbuildupduringoperationcauses Reductionin effi- Cleanor replace Checkfrequently;

nsulatoror flower pot leakageto ground. ciency insulatorsand cleananddry as
lushingleakage Moisturegatheredduringshutdownor bushings needed;checkfor
low-loadoperation adequatepressuriza-
tion of top housing.
Summarv of Problems Associated With ESPs lcontd.)
Malfunction Cause ESPEfficency Corrective action Measures
4ir inleakage From dustconveyor Lower efficiency- Sealleaks Identify early by

hroughhoppers dustreentrained increasein ash
throughESP concentrationat
bottomof exit to
ESP
iir inleakage Flangeexpansion,impropersealingof Sameasabove,also Sealleaks Checkfrequently
hroughESPshell inspectionhatches causesintense for corrosionarounl
sparking. inspectiondoorsani
for flangeexpansioi
;as bypassaround Poordesign- improperisolationof active Only a smalldropin Baffling to direct Identify early by
3SP:deadpassage portionof ESP eficiencyunless gasinto activeESP measurement of gas
boveplatesand severe settion flow in suspected
ensionframe Uea
Zorrosion Temperaturegoesbelowdew point Negligibleuntil Maintainflue gas Energizeprecipita-

precipitatorinterior temperatureabove tor after processhas
plugsor platesare Jewpoint. jeenon line for
eatenaway;air leaks impleperiodto
maydevelopcausing *aiseflue gastem-
significantdropsin leratureaboveacid
performance. iew point.
rv of Problems Associated With ESPs kontdJ
Effect on Corrective Action Preventive

Malfunction Measures
ESP Efficiency
lopperpluggage Wires,platesandinsulatorsfouledbe- Reductionin effi- Provideproperflow Frequent.checksfor

ciency of ash adequateoperation
causeof low temperature /
of hoppers;provide
Inadequate :hopperinsulation
heatersand/or
Impropermaintenance
thermalinsulationtc
Processleakscausingexcessmoisture
avoidmoisture
Ash-conveyingsystemmalfunction:
condensation.
- gas‘leakage
- blowermalfunctions
- solenoid,valves
Materialdroppedinto hopperfrom bottle
weights
Solenoidandtimer malfunction
Suction,blowerfilternot changed
nadequate rapping, Ash.buildup Resultingbuildupon Adjustrapperswith Frequentchecksfor

ribratorsfail Poordesign electrodesmay opticaldustmeasur- adequate
I operation
Rappersmisadjusted reduceefficiency ing instrumentin of rappers
ESPexit stream
tappingtoo intense Poordesign Reentraiusashand Sameasabove

/ Sameasabove;
Rappersmisadjusted reducesefficiency reducevibratingor
Improperrappingforce impactforce
L
y of Problems Associm With ESPs kontd.1
Malfunctions Cause ESPEfficiency Corrective Action Measures
Zontrolfailures Powerfailurein primary system Reducedefficiency Findsourceof Paycloseattention

Transformeror rectifier failure: failureandrepairor to daily readingsof
- insulationbreakdownin transformer replace controlroom instru
- arcingin transformerbetweenhigh- mentationto spot
voltageswitchcontacts deviationsfrom
- leaksor shortsin high-voltagestructure normalreadings
- insulatingfield contamination
iparking Inspectiondoor ajar Reducedefficiency Closeinspection Regularpreventive

Boilerleaks doors;repairleaks maintenance will
Pluggingof hoppers in boiler;unplug alleviatethese
Dirty insulators hoppers;clean problems.
insulators
APPENDIX F Cement Kilns
SAMPLES OF
PERMIT TO OPERATE
AND
AUTHORITY TO CONSTRUCT
Ott 1996 PageF-1

Crushing & Storage (Group #l)
BOO0137- Crushing System (010)

COO0136
COO0138
coo0 140
coo1713
COO1714 } Fabric Dust Collector
coo1715
COO1716
COO3888
BOO0135 - Rock Transfer System (020)

coo1717
COO1718
COO1719 } Fabric Dust Collector
coo1773
coo2222
--. MOJAVE DESERT
AIR QUALITY MANAGEMENT DISTRICT BOO0137
15428CIVICXlVE, VICTDRV!LLE.!:A ?2!P2 161P! 245-1661
If construction is not completed by the expiration date of this permit, it may be renewed for one additional Year
upon payment of applicable fees. Any additional extension will require the written approval of the Air Pollution
Control Officer. This Authority to Constract array serve as a tapmary Permit to Operate provided the APLPM is given
prior notice of such intent to operate. Rowever. this Authority to Construct is not valid if the Permit to Opctatc
is denied.
EXPIRES L.4S-l' DAY OF: .\UGUST 1995 Page 1 of 2
LEGAL OWJIER-OROPERATOR: 1012) EGUIPMENT-LOCATION: (0003)
DESCRIPTION:
CRUSHING SYSTEM (010) consisting of:
HP
36-011 thru 022 Belt Conveyor (12) 602.5
36-031 thru 036 Vibratory Screen (6 @ 15 HP) 90.0
36-040 Air ComPressor 5.0
36-041 Primary Crusher (1600 Tph) 354.0
36-042 Surge Bin -w-w-
36-051.052 Secondary Crusher [2 Hammer Mill (N&S)] (1000 Tph) 1600.0
36-053 Wobbler Feeder 20.0
Wobbler Oiler 1.5
36-0587059 Pump (2) 27.5
36-070 Air Compressor 5.0
36-103 Blower 5.0
36-323 Vibrator 5.0
41-031 Belt Conveyor (111 100.0
1-A ?:I-. New Conveyor. 440 ft 100.0
1-B New Conveyor, 460 ft 50.0
1-c New Conveyor, 1560ft 50.0
l-D New Conveyor. 160 ft 30.0
41-044.045 Sample System. Roil Xill So. 1. AC No. 2 43.0
41-141 Stacker 130.0
36-025 Clay Feeder 10.0
41-092 Air Compressor $0. 3 7.5
i\'ew Water spray system over piles numbers 1 & 2.
Primary Crusher Bin Ind, 2 @ 0.5 HP 1.0
Surge Bin Feeders 2 @ 40 HP ea. 80.0
Total 3317.0
CONTROL: COO0136(41-025) 10 HP COO0138(36-001) 25 HP
COO0140(36-002) 50 HP COO1713(.36-003) 60 HP
COO1714(36-004) 15 HP COO1715(41-026) 4 HP
COO1716(41-027) 5 HP COO38S8(Later ) 40 HP
Rules and R
32bI/CbQ 300/018 469E/3828H

SIC/ Emission. Location
process Type/ID UTH (Km1
n .A
MOJAVE DESERT
AIR QUALITY MANAGEMENT DISTRICT COOOl36
15418 CIVIC DRIVE, VICTORVILIE, CA 92392 [619! 2rS-i661
PERMIT TO OPERATE
Operation under this petrit aP6t be conducted in corgliaoce with all information included with the initial
application, initial permit conditions, and conditions contained herein. The equipment must be siotained and kept
in good operating condition at all times. This Permit to Operate or copy must be posted on or within g meters oi
equipPent. If copy is posted, original must be raintainedon site in central file available for inspection at all
tirts.
EXPIRES LAST DAY OF: AUGUST 1995 Paee 1 of 1
LEGAL OWNER OR OPERATOR: (012) EQUIPMENT LOCATION: (0003)
-__- ---
. :!
DESCRIPTION: --
AIR POLLUTION CONTROL serving Crushing System (OlO), valid District permit B000137.
consisting of:
41-025 Fabric Dust Collector DC-S, “Xor-Blo”. 156A-lo’, 5!600 ACFM. 2.0 A/C* Stack 0.7’1
x 44’H, 70’ F., fan size 40.
Total HP = 10
CONDITIONS:
1. The owner/operator (o/o) shall operate this control equipment in strict accord wit1
,,,- manufacturer’s specification and/or sound engineering principles.
: -IA* The o/o shall maintain a log of all inspections, repairs and maintenance on thiz
equipment and submit it to the District upon request. The log shall be kept for E
minimum period of 2 years.
3. The o/o shall maintain on-site. as a minimum. an inventory of replacement bags that
assures compliance with applicable Rules of District Regulation IV.
Fee Schedu
This permit hose allowed by law, including
Division 26
or other governmen
7 /,-/L?I/
3?01/540 30s/018 469E/3828~ -
SIC/ Emission. Locat ion ‘AJicl‘ I I
PI-OC.%SS Type/ID UTH (Km) Air Pollution Control Officer ’ dec i-S-94
,
MOJAVE DESERT
AIR QUALITY MANAGEMENT DISTRICT cooo13s
1!:28 CiVIC DRIVE.VICTORVILLE,
CA 92?92 (619) 245-1661
PERMIT TO OPERATE
Operation under this permit must be conducted in corpIimct with all infomtion included with the initial
application, initial permit conditions, and conditions contained herein. The equiprent must be maintained and kept
in good operating condition at all times. This Permit to Operate or cop, must be posted on or within 8 meters of
equipsent. If copy is posted, original must be maintainedon site in central file available for inspection at all
times.
EXPIRES LAST DAY OF: .AUGUST 1995 Paee 1 of 1
--.- . . . .__ ._ _.___ _. & 1

DESCRIPTION:
AIR POLLUTION CONTROL serving Crushing System (010). valid District permit B000137,
consisting of:
36-001 Fabric Dust Collector DC-l. "Nor-Blo" 390A-25, 14,000 ACFM, 3.0 A/C. Stack 2.O'D
x lO'H, 90' F., fan size 60.
Total HP = 25
CONDITIONS:
1. The owner/operator (o/o) shall operate this control equipment in strict accord with
manufacturer's specification and/or sound engineering principles.
7i.
The o/o shall maintain a log of all inspections, repairs and maintenance on this
equipment and submit it to the District upon request. The log shall be kept for a
mitiimum period of 2 years.
3. The o/o shall maintain on-site, as a minimum, an inventor37 of replacement bags that
3201/s10 300/o 18 -169Ef382XN

SIC/ Emission. Locat ion
ptocesa Type/ID UTH (Km)
f ,e a
..
MOJAVE DESERT
AIR QUALITY MANAGEMENT DISTRICT coo01 40
15428 CI:‘IC CIRIVE,VICTORVILLE.
CA 92192 [6191 2:5-!661
PERMIT TO OPERATE
Operation under this permit must be conducted in coqliance with all information included with the initial
application. initial permit conditions, andconditions contained herein. The equipment must be maintained and kept
in good operating condition at all times. This Permit to Operate or copy must be posted On or within g meters of
equip9ent. If copy is posted, original must be slaintained on site in central file available for inspection at all
times.
EXPIRES L.\ST D.jY OF: ?IUGUST 1995 Paee 1 of 1
LEGAL OWNER OR OPERATOR:_ (Ol.21 EQUIPMENT LOCATION: (0003)
1
DESCRIPTION: .- -.--.- -___

AIR POLLUTION CONTROL serving Crushing Svstem
_ (0101. valid District permit B000137,
consisting of:
36-002 Fabric Dust Collector DC-2, “Nor-Blo” G24A-40’, 22.000 ACFM, 3.0 A/C, Stack 2.6’D
x 57’H, 90’ F.. fan size 80.
Total HP = 50
CONDITIONS:
1_. The owner/operator (o/o) shall operate this control equipment in strict accord with
manufacturer’s specification and/or sound engineering principles.
3
L, The..o/o shall maintain a log of all inspections, repairs and maintenance on this
3. The o/o shall maintain on-site, as a minimum. an inventory of replacement bags that
32411540 3oo/a18 469E/3828N

SIC/ Emission, Locat ion
process TYPWID UTH (Km)
I .+a,
MOJAVE DESERT
AIR QUALITY MANAGEMENT DISTRICT coo1713
15428CIVIC DRIVE!;rICTORVILLE,
Ct 92192 (6:31 2:S-:.661
PERMIT TO OPERATE
Operation under this permit must be conducted in cotpliance with all information inclodtd with the initial
application, initial permit conditions, and conditione contained herein. The equipment suet be maintained and kept
in sood operating condition at all timee. This Permit to Operate or copy suet be posted on or within 8 meters of
equipment. If copy is posted, original must be aaintainedon site in central file available for inspection at all
times.
EXPIRES LAST DAY OF: AUGUST 1995 Page 1 of 1
LEGAL OWNER OR OPERATOR:-@l2) EQUIPMENT L(+jTxON:(0003)
.., I
i
DESCRIPTION:
AIR POLLUTION CONTROL serving Crushing System (OlO), valid District permit B000137,
consisting of:
36-003 Fabric Dust Collector DC-3, “Nor-Blot’ 624A-40’, 22,000 ACFM? 3.0 A/C, Stack 2.6’D
x 57’H, 90’ F.. fan size SO.
HP = 50
Includes AS Blower $2 10
Total HP = 60
CONDITIONS:
.
9d. The o/o shall maintain a log of all inspections, repairs and maintenance on this
3. The O/O shall maintain on-site. as a minimum. an inventory of replacement bags that
ired by Rule
3241/540 300/018 469E/3828H

process TSPC/ID UTM (Km)
MOJAVE DESERT
15428 C!V!C DRIVE.L'ICTORVILLE,
CA 92382 (E!9) 245-1661
PERMIT TO OPERATE
Operation Wider this permit must be conducted in compliance with all information included with the initial
application, initial permit conditions . and conditions contained herein. The equipment must be maintained and kept
in good operating condition at all times. This Permit to Operate or copy must be posted on or within 8 Peters of
equipment. If Copy iS posted, original must be saintainedon site in central file available for inspection at all
times.
EXPIRES LAST DAY OF: AUGUST 1995 Paee 1 of 1
LEGAL OWNER OR OPERATOR: (012) EQUIPMENT
_- LQCATION: (0003)
!
DESCRIPTION: _..--- -
AIR POLLUTION CONTROL serving Crushing System (OlO), valid D%ict permit B000137,
consisting of:
36-004 Fabric Dust Collector DC-4, “Nor-Blo” 234A-15’: 6$600 ACFM. 2.3 A/C, 90” F., fan
size 45.
Total HP = 15
CONDITIONS:
3-. The o/o shall maintain a log of all inspections, repairs and maintenance on this
3. The o/o shall maintain on-site, as a minimum, an inventory of replacement bags that
Division 26 of the Rcalth and Gaiety code of the sta this District
This permit canmat be construed as permission to tes or regulations of this
Kove-ntal agencies. This Permit t on date &ove or an earlier
renewal fee required by Rule
3241/SbO 300/018 469E/3SZ%H

process Type/ID UTH ~KIQ)
d.n ,
MOJAVE DESERT
15428
CIVICGBIVE:V!CTOEVILLE,
CA92392(619)::5-1561
PERMIT TO OPERATE
OpeZXtiOn Ulder this
WInit must be conducted in colpliance with all information included with the initial
application, initial permit conditions + andconditions contained herein. The equipment must be mrintainedand kept
in good operating condition at all times. This Permit to Operate or copy must be posted on or within 8 meters of
equipment. If ~4~7 is posted, original must be raintainedon site in central file available for inspection at all
times.
EXPiRES LAST DAY OF: 3UGUST 1995 PaPe 1 of 1
LEG&& OWNER
-.-- OR QPERATOR: (012) EQUIp.MENT LOCATION: (0003)
I
i
DESCRIPTION:
AIR POLLUTION CONTROL serving Crushing System (OlO), valid District permit B000137,
consisting of:
4 l-026 Fabric Dust Collector DC-6, “MicroPul” 30-9’, 2,000 ACFM, 7.0 A/C, Stack 0.7'D X
44’H, 90’ F. and 2 hp Rotary Feeder
Total HP = 4
CONDITIONS:
2. The o/o shall maintain a log of all inspections, repairs and maintenance on this
3241 t.540 300/018 469E/382XN

process TYPWD UTY (Km)
MOJAVE DESERT
AIR QUALITY UAGEMENT DISTRICT COO1716
15428CIVIC DRIVE, VICTORVILLE,
CA 92392 !6!9! 2iS-1661
PERMIT TO OPERATE
Operation under this permit must be conducted in compliance with all information included with the initial
application, initial permit conditions, andconditions contained herein. The equipment mubt be maintained and kept
in good operating condition at all times. This Permit to Operateor copy must be posted on or within 8 meters of
equipment. If copy is posted, original mast be maintainedon site in central file available for inspection at all
times.
---.- LOCATION:
--.-~~-.-_. - (0003)
-
DESCRIPTION:
AIR POLLUTION CONTROL serving Crushing System (OlO), valid District permit BOOOl37,
consisting of:
41-027 Fabric Dust Collector DC-7, “Volkes” 16/15/F6, 1,780 ACFM, 9.0 A/C, 90’ F., fan
size F-6
Total HP = 5
CONDITIONS:
3
ir. The o/o shall maintain a log of all inspections, repairs and maintenance on this
This permit Cannot be const lationa of this

mmental agencies. T e or an earlier
f eqQiprent is moved, altered, or chang
3241/540 300/018 46%/3828H

process Type/ID In?4 (Km)
A
MOJAVE DESERT ‘-'
AIR QUALITY MANAGEMENT DISTRXCT coo3sss
15428 CIVIC GRIVE,VICTORVILLE, CA 92392 (619) 245-1661
If construction is not completed by the expiration date of this permit, it may be renewed for one Bdditional Jest
upon payment of applicable fees. Any additional extension will require the written approval of the Air Pollution
Control Officer. This Authority to Construct may serve as a tewporary Permit to Operate provided the APCO is given
prior notice of such intent to operate. However. this Authority to Construct is not valid if the Permit to Operate
-.
IS denied.
LEGAL OyET OR OPERATOR: (012) EQUIPMENT LOCATION: (0003)
DESCRIPTION: AIR POLLUTION CONTROL (Baghouse) which serves the Crushing System (OlO),
valid District permit 8000137, and has the pre-construction parameters of a 40 hp motor
powering the fan. This fan induces a flow rate of approximately 3000 ACFM, with cotton bags
(coated) with an Air:Cloth ratio of approximately 6:l.
CONDITIONS:
1. The owner/operator (o/o) shall operate this control equipment in. strict accord with
3-. The o/o shall maintain a log of all inspections, repairs and maintenance on this
equipment. The log shall be kept on-site for a minimum of 2 years and provided to
District personnel on request.
ensures compliance with applicable Rules of District Regulation IV.
f-.
3241/540 300/000 469E/3828N

SIC/ Emission, Location
process Tw=/ID UTM [Km)
MOJAVE DESERT
AIR QUALITY MANAGEMENT DISTRICT BOO01 35
:5!28 fJI','ic Zi;yE, ';~CT~~vi~LE.c.i 92j92 :j13! :::-15i!
PERMIT TO OPERATE
Operation under this permit must be conducted in compliance with ali information included with the initiai
application, initial permit conditions, andconditions contained herein. The equipment rust be maintained and kept
in good operating condition at all times. This Permit to Operateor copy must be posted on or within 8 meters of
equipKnt. If copy is pasted, orisinai must be maintainedon site in central file available for inspection at all
times.
EXPIRES L.4ST DAY OF: .AUGUST 1995 PaF2e 1 of 1
!
DESCRIPTION: __ _---
ROCK TRANSFER SYSTEM (020), consisting of:
HP
41-032 thru 035 Belt Conveyors: 4:l @ 100 & 3 @ 40 HP 220.0
42-1’3.124 Stacker Trailers Nos. 1.2 on Belts 11.12
12-135 Transfer Car 15.0
43-136 Jr. Reclaimer serving Belt No. 11 5.0
42-140 Hopper. Additive with belt 5.0
-12-145 Rock Reclaimer off Belt No. 11 172.5
42-034 Belt Conveyor Xo. 4. Raw Feed 15.0
12-301.302 Bin, RM 1 & 2: Bin, RM 3,&S & 6 ----
Total: 332.5
CONTROL: COO1717 (41-021) 10.0 HP COO171S (31-022) 10.0 HP

COO1719 (42-022) 50.0 HP coo1773 (41-02s) 7.5 HP
. coo2222 (41-029) 7.5 HP
L.
CONDITIONS:
1. This equipment shall not be operated unless it is vented to operating air pollution
control equipment covered by all 5 District valid permits COO171’. COO171S. COO1719.
COO1773 and COO2222
7
-. The owner/operator (o/of shall comply with all District Rules and Regulations including?
but not limited to. malfunction/breakdown notifications.
4
J. The o/o shall have a continuing program of maintenance/inspections in accord with
manufacturer’s recommendations and specifications which ensures compliance with
District Rules.
*
?. repairs and maintenance on this
The o/o shall maintain a log of all inspections.
f California and the

statutes or rey .
ation date above
renewal fee req
-
SIC/ Emission. Locat ion ChaJles L.&m 1 /
process Type/ID urn (Km) Air P llution Control Officer dec 7-I-94
/22
MOJAVE DESERT
AIR QUALITY MANAGEMENT DISTRICT c00171’
15428 CIV!C XIVE. :ICTGF.VILLE,c“I\ ?23S2 !6!9! ?CS-1551
PERMIT TO OPERATE
Operation UIXLZZ this permit must be condncted in compliance with all information included with the initial
application. initial permit conditions, and conditions contained herein. The equipment must be maintained and kept
in g-d operating condition at all times. This Permit to Operate or copy must be posted on or within 8 meters Of
equipment. If copy is posted, originai must be aaintainedon site in central file available for inspection at aI1
times.
EXPIRES LAST D.4Y OF: .4UGUST 1995 Paee 1 of 1
LEGAL OWNER OR OPERATOR:
- -m-w. (012) EQUIPMENT LOCATION:(0003)
_
i
J
DESCRIPTION: --.--.
AIR POLLUTION CONTROL serving Rock Transfer System (020), District permit B000135,
consisting of:
41-021 Fabric Dust Collector DC-l. “Nor-Blo” 156A-10; 2.750 ACFM. 15.0 A/C, Stack 1.2’D
x 32’H, 12O’F., fan size 40.
Total HP = 10
CONDITIONS:
2. The o/o shall maintain a log of all inspections. repairs and maintenance on this
-.: The o/o shall maintain on-site as a minimum. an inventory of replacement bags that
assures compliance with applicable Rules of District Regulation I\‘.
This permit c-t be construed as

or other gave -tai agencies. T xpimtion date above Or a2l earlier
3241/CJO 300/018 469E/3828?r

SIC/ Emission. Locar ion
process TYP=/ID ml4 (Km)
MOJAVE DESERT
AIR QUALITY MANAGEMENT DISTRICT coo1”1s
15428 CiSIC BiiiVE. 4ICTOP,VILi,E.
iA ?2392 .!6i91 1!.!-16il
PERMIT TO OPERATE
Operation under this permit must be conducted in compliance with all information included with the initial
application, initial permit conditions. andconditions contained herein. The equipment must be maintained sod kept
equipment. If copy is posted, original must be maintainedon site in central file available for inspection at all
tiacs.
EXPIRES L.4ST D.4Y OF: .4UGUST 1995 Paee 1 of 1
LEGAL OWNER OR OPERATOR: (012) EQUIPMENT LOCATION: (00031
, .
DESCRIPTION:
AIR POLLUTION CONTROL serving Rock Transfer System (020). valid District permit B000135,
consisting of:
11-022 Fabric Dust Collector DC-Z, “Nor-Blo” 156A-10: 3.130 ACFM. 17.0 X/C, Stack 1.2’0
x 30’H. 150’F.. fan size 40.
Total HP = 10
CONDITIONS :
The o/o shall maintain a log of all inspections, repairs and maintenance on this
3. The o/o shall maintain on-site. as a minimum, an inventory of replacement bags that
Fee Schedule: 7(H): Ratine: 1.0 A

This permit does not authorize the emission of contaminants in excess of those ailowed by 1~. including
Division 26 of the Health and Safety Code of the S of California and the Rules sod Reylations Of this District.
3’41/540 300/018 469E/3S28N

process Type/ID UTH (Km)
MOJAVE DESERT
AIR QUALITY MANAGEMENT DISTRICT Cools 19
15428 CiV!C DRIVE! ViCTBRVILLE. CA 92392 1619] ??T-1661
PERMIT TO OPERATE
Operation an&t this permit rust be condncted in compliance with all information included with the initial
application, initial permit conditions, andconditions contained herein. The equipment must be maintained and kept
equipment. If copy is posted, original must be aaintaincd on site in central file available for inspection at all
times.
LEGAL OWNER OR OPERATOR:&21 EQUIPMENT LOCATION: (0003)
., .
DESCRIPTION: -. -~~
AIR POLLUTION CONTROL serving Rock Transfer System (020), valid District permit B000135,
consisting of:
42-022 Fabric Dust Collector DC-22: “Nor-Blo” J63A-30; 5,620 ACFM, 1.0 A/C, Stack 2.0’0
x 55’H1 90’F.. fan size 70.
Total HP = 50
CONDITIONS:
i.9 The o/o shall maintain a log of all inspections, repairs and maintenance on this
equipment and submit it to the District upon request, The log shall be kept for a
mftiimum period of 2 years.
3. The o/o shall maintain on-site. as a minimum. an inventory of replacement bags that
Fee Schedule: 7(H): Rating: 1.0

ntsrinanttz in excess of those alIorcd b
Rules and Regulation
3241/540 300/018 469Ef3828N

SIC/ Emission, Locar ion
p-OCtZSS Type/ID m-x (Km) tlon Control Officer
n
MOJAVE DESERT
15428 CiV:C DRIVE, VICTORV!LIE,Ch 92392 (6191 245-1661
PERMIT TO OPERATE
Operation under this permit rust be conducted in compliance with all information included with tbe initia
application, initial permit conditions. andconditions contained herein. The equipment rust be maintained and kep
in good operating condition at all times. Thi6 Permit to Operate or copy must be posted on or within 8 meters 0
equipment. If copy is posted, original mast be vrintainedon site in central file available for inspection at al
times.
EXPIRES LAST DAY OF: .\UGUST 1995 Pace 1 of
_-.-.. LOCATION: (0003)
DESCRIPTION:’
AIR POLLUTION CONTROL serving Rock Transfer System (020), valid District permit 8000135
consisting of:
41-025 Fabric Dust Collector DC-22, “Volkes” 30/10/F6* , 2,250 ACFM, S.0 A/C, SO’ F., fal
size F-6.
Total HP = 7.5
CONDITIONS:
1. The owner/operator (o/o) shall operate this control equipment in strict accord wit:
7-. The o/o shall maintain a log of all inspections repairs and maintenance on thi
equipment and submit it to the District upon request. The log shall be kept for
3. The o/o shall maintain on-site, as a minimum, an inventory of replacement bags tha
lth and Safety Co& of the California and the Rules ulations of this Districl
324l/L40 300/018 469E/382SN

SIC/ Emission, Locat ion rle! L. Fryxeli - I / ’
process Type/ID VIM (Km) Air P llution Control Officer dec 7-l-94
i.
MOJAVE DESERT
AIR QUALITY MANAGEMENT DLSTRICT coo”‘1----
15429C;V!C DBIVE,:17TORVILLE,Cb 92392 !a191 :::-1661
PERMIT TO OPERATE
Operation under this permit must be conducted in capliance with all information included rith the initial
application. initial permit conditions. sndwnditions contained herein. The equipmzot must be raintsined snd kept
in good operating conditioo at all times. This Permit to Operate or copy must be posted on or within 8 meters of
equipment. If COPY is posted, original rust be maintainedon site in central file available for inspection at all
times.
.
DESCRIPTION:
AIR POLLUTION CONTROL serving Rock Transfer System (0201, valid District permit B000135,
consisting of:
41-029 Fabric Dust Collector DC-g, “Volkes” 30/10/F& 2,250 ACFM, S.0 A/C, SO’ F., fan
size F-6.
Total HP = 7.5
CONDITIONS:
2. The .0/o shall maintain a log of all inspections, repairs and maintenance on this
3. The o/o shall maintain on-site. as a minimum, an inventory of replacement bags that
or other governmen
date if equipment is
3241/540 300/018 469EI3828N

SIC/ Emission. Locar ion
ptoCe66 Type/ID UTN (Km) Air Pollution Control Officer dec l-l-94
I
i
APPENDIX G Cement Kilns
REFERENCES
Bogue, Robert H., The Chemistry of PortlandCement,ReinholdPublishing
Corp., New York, NY, SecondEdition, 1955.
Kreichelt, T. E., Kemnitz, D. A., and Cuffe, S. T., AtmosphericEmissions

from the Manufactureof PortlandCement,U.S. Departmentof Health,
Education,andWelfare, PublicHealth Service,Cincinnati,OH, 1967.
Mitsubishi Cement Corporation, Tour guidedby DouglasC. Shumway,

EnvironmentalManager,LucerneValley, CA, 1996.
Peray, Kurt E., CementManufacturer’sHandbook,ChemicalPublishingCo.,

Inc., New York, NY, 1979.
Southdown Victorville Cement Plant, We Make SouthwesternCement,and

Tour guidedby JohnB. Blythe, EnvironmentalManager,Victorville,
CA, 1996.
Wit-t, J. C., M.E., Ph.D., PortlandCementTechnolo-q,ChemicalPublishing

Co., Inc., New York, NY, SecondEdition, 1966.
Ott 1996 Page G - 1

,’
f
Compilation
of
Air Pollutant Emission Factors
AP-42
Ott 1996 Page H - 1

11.6 Portland Cement Sfanufacturing
11.6.1 ProcessDescription’-’
Portland cement is a fine powder, gray or white in color, that consistsof a mixture of
hydraulic cement materials comprising primarily calcium silicates, aluminates and aluminoferrites.
More than 30 raw materials are known to be used in the manufactureof portland cement, and these
materials can be divided into four distinct categories: calcareous,siliceous, argillaceous, and
ferrifrous. These materials are chemically combined through pyroprocessingand subjectedto
subsequentmechanical processing operationsto form gray and white Portland cement. Gray portland
cement is used for structural applications and is the more common type of cement produced. White
portland cement has lower iron and manganesecontentsthan gray Portland cement and is used
primarily for decorative purposes. Portland cementmanufacturing plants are part of hydraulic cement
manuf&uring, which also includes natural, masonry, and pozzolanic cement. The sixdigit Source
Classification Code (SCC) for portland cementplants with wet processkilns is 345-06, and the
six-digit SCC for plants with dry processkilns is 3-05-007.
Portland cement accountsfor 95 percentof the hydraulic cementproduction in the United

States. The balance of domestic cement production is primarily masonry cement. Both of these
materials are produced in portland cement manufacturing plants. A diagram of the process, which
encompassesproduction of both portland and masonry cement, is shown in Figure 11.6-l. As shown
in the figure, the process can be divided into the following primary components: raw materials
acquisition and handling, kiln feed preparation, pyroprocessing, and finished cement grinding. Each
of these process components is describedbriefly below. The primary focus of this discussion is on
pyroprocessing operations, which constitute the core of a portland cementplant.
The initial production step in portland cement manufacturing is raw materials acquisition.
Calcium, the element of highest concentrationin portland cement, is obtainedfrom a variety of
calcareous raw materials, including limestone, chalk, marl, sea shells, aragonite,and an impure
limestone known as “natural cement rock”. Typically, these raw materials are obtainedfrom ‘open-
face quarries, but underground mines or dredging operationsare also used. Raw materials vary from
facility to facility. Some quarries produce relatively pure limestone that requires the use of additional
raw materials to provide the correct chemical blend in the raw mix. In other quarries, all or part of
the noncalcarious constituents are found naturally in the limestone. Occasionally, pockets of pyrite,
which can significantly increaseemissions of sulfur dioxide (SO-J, are found in deposits of limestone,
clays, and shales used as raw materials for portland cement. Becausea large fraction (approximately
one third) of the mass of this primary material is lost as carbon dioxide (CO,) in the kiln, portland
cement plants are located close to a calcareousraw material source wheneverpossible. Other
elements included in the raw mix are silicon, aluminum, and iron. These materials are obtained from
ores and minerals such as sand, shale, clay, and iron ore. Again, thesematerials are most commonly
from*open-pit quarries or mines, but they may be dredgedor excavatedfrom underwater deposits.
Either gypsum or natural anhydrite, both of which are forms of calcium sulfate, is introduced
to the process during the finish grinding operationsdescribed below. Thee materials, also excavated
from quarries or mines, are generally purchasedfrom an external source, rather than obtained directly
from a captive operation by the cement plant. The portland cement manufacturing industry is relying
increasingly on replacing virgin materials with waste materials or byproducts from other
manufacturing operations, to the extent that such replacementcan be implemented without adverseiy
l/95 Mineral Products Industry 11.6-l

affecting plant operations, product quality or the environment. Materials that have beenused include
fly ash, mill scale, and metal smelting slags.
The secondstep in Portland cementmanufactureis preparing the raw mix, or kiln feed, for
the pyroprocessing operation. Raw material preparationincludes a variety of blending and sizing
operations that are designed to provide a feed with appropriatechemical and physical properties. ‘The
. raw material processing operations differ somewhatfor wet and dry processes,as describedbelow.
Cement raw materials are receivedwith an initial moisture contentvarying from 1 to more
than 50 percent. If the facility uses dry processkilns, this moisture is usually reducedto less than
1 percent before or during grinding. Drying alone can be accomplishedin impact dryers, drum
dryers, paddle-equippedrapid dryers, air separators,or autogenousmills. However, drying can also
be accomplished during grinding in bail-and-tubemills or roller mills. While thermal energy for
drying can be supplied by exhaust gasesfrom separate,diiect-fired coal, oil, or gas burners, the most
efficient and widely used source of heatfor drying i’s the hot exit gasesfrom the pyroprocessing
system.
Materials transport associatedwith dry raw milling systems can be accomplished by a variety
of mechanisms, including screw conveyors, belt conveyors, drag conveyors, bucket elevators, air
slide conveyors, and pneumatic conveying systems. The dry raw mix is pneumatically blended and
stored in specialIy constructed siios until it is fed to the pyroprocessingsystem.
In the wet process, water is addedto the raw mill during the grinding of the raw materials in
ball or tube mills, thereby producing a pumpable slurry, or slip, of approximately 65 percent solids.
The slurry is agitated, blended, and stored in various kinds and sizes of cylindrical tanks or slurry
basins until it is fed to the pyroprocessing system.
The heart of the portland cementmanufacturingprocessis the pyroprocessing system. This

system transforms the raw mix into ciiiers, which.are gray, glass-hard,spherically shapednodules
that range from 0.32 to 5.1 centimeters (cm) (0.125 to 2.0 inches [in.]) in diameter. The chemical
reactions and physical processesthat constitutethe transformation are quite complex, but they can be
viewed conceptually as the following sequentialevents:
1. Evaporation of free water
2. Evolution of combined water in the argillaceous components;
3. Calcination of the calcium carbonate(CaCO$ to calcium oxide (CaO);
4. Reaction of CaO with silica to form dicalcium silicate;
5. Reaction of CaO with the aluminum and iron-bearing constituentsto form the liquid
phase;
6. Formation of the clinker nodules;
7. Evaporation of volatile constituents(e. g., sodium, potassium, chlorides, and sulfates);

and
8. Reaction of excess CaO with dicalcium silicate to form tricalcium silicate.
l/95 Mineral Products Industry 11.6-3

This sequenceof eventsmay be conveniently divided into four stages,as a function of
location and temperatureof the materials in the rotary kiln.
1. Evaporation of uncombined water from raw materials, as material temperature increasesto

100*c (212°F);
2. Dehydration, as the material temperature increasesfrom 100°C to approximately 430°C

(800°F) to form oxides of silicon, aluminum, and iron;
3. Cal&ration, during which carbon dioxide (CO9 is evolved, between900°C (1650°F) and
982°C (18OO”F),to form CaO; and
4. Reaction, of the oxides in the burning zone of the rotary kiln, to form cement clinker at
temperaturesof approximately 1510°C (275OOF).
Rotary kilns are long, CyIindricaI, slightly inclined furnacesthat are Iined with regactory to
protect the steel shell andretain heat within the kiln. The raw material mix enters the kiln at the
elevated end, and the combustion fuels generally are introduced into the lower end of the kiln in a
countercurrent manner. The materials are continuously and slowiy moved to the lower end by
rotation of the kiln. As they move down the kiln, the raw materials are changedto cementitious or
hydrauhc minerals as a result of the increasing temperature within the kiln. The most commonly used
kiln fuels are coal, natural gas, and occasionally oil. The use of supplementalfuels such as waste
solvents, scrap rubber, and petroleum coke has expandedin recent years.
Five different processesare used in the portland cement industry to accompiish the
pyroprocessing step: the wet process, the dry process (long dry process),the semidry process, the
dry process with a preheater,and the dry process.with a preheaterlprecaiciner. Each of these
processesaccompkhes the physical/chemicaI steps defined above. However, the processesvary with
respectto equipment design, method of operation, and fuei consumption. Generally, fuel
consumption decreasesin the order of the processeslisted. The paragraphsbelow briefly describe the
process,starting with the wet process and then noting differences in the other processes.
In the wet processand long dry process, all of the pyroprocessingactivity occurs in the rotary
kiln. Depending on the processtype, kiIns have length-to-diameter ratios in the range of 15:l to
40: 1. While some wet processkilns may be as long as 210 m (700 ft), many wet process kilns and
all dry process kilns are shorter. Wet process and long dry process pyroprocessingsystems consist
solely of the simpie rotary kiin. .UsuaIly, a system of chains is provided at the feed end of the k&r in
the drying or preheatzonesto improve heat transfer from the hot gasesto the solid materials. As the
kiln rotates, the chains are raised and exposedto the hot gases. Further kiln rotation causesthe hot
chains to fall into the cooler mater& at the bottom of the kiln, thereby transferring the heat to the
104.
Dry process pyroprocessingsystems have been improved in thermal efficiency and productive
capacity through the addition of one or more cyclone-type preheatervesselsin the gas stream exiting
the rotary kiln. This system is called the preheater process. The vesselsare arrangedverticahy, in
series, and are supponedby a structure known as the preheater tower. Hot exhaust gasesfrom the
rotary kiln pass countercurrently through the downward-moving raw materials in the preheater
vessels. Co.mparedto the simple rotary kiln, the heat transfer rate is significa.ntIy increased, the
degree of heat utilization is greater, and the process time is markedly reducedby the intimate contact
of the solid particles with the hot gases. The improved heat transfer allows the length of the rotary
kiln to be reduced. The hot gasesfrom the preheater tower are often used as a source of heat for
11.6-4 EMISSION FACTORS l/95

drying raw materials in the raw mill. Becausethe catchf?om the mechanical collectors, fabric filters,
and/or electrostatic precipitators (ESP) that follow the raw mill is returnedto the process, these
devices are considered to be production machinesas well as pollution control devices.
Additional thermal efficiencies and productivity gains have been achievedby diverting some
fuel to a calciner vessel at the baseof the preheatertower. This system is called the
pr.eheater/precalcinerprocess. While a substantialamount of fuel is used in the precalciner, at least
40 percent of the thermal energy is required in the rotary kiln. The amount of fuel that is introduced
to the calciner is determined by the availability and sourceof the oxygen for combustion in the
calciner. Calciner systems sometimes use lower-quality fuels (e. g., less-volatile matter) as a means
of improving process economics.
Preheater and precalciner kiln systems often have an alkali bypass system between the feed
end of the rotary kiln and the preheatertower to remove the undesirablevolatile constituents.
Otherwise, the volatile constituentscondensein thepreheatertower and subsequentlyrecirculate to
the kiln. Buildup of thesecondensedmaterials can restrict processand gas flows. The aikati content
of portland cement is often limited by product specificationsbecauseexcessivealkali metals (i. e.,
sodium and potassium) can causedeleterious reactionsin concrete. In a bypasssystem, a portion of
the kiln exit gas stream is withdrawn and quickly cooled by air or water to condensethe volatile
constituents to fine particles. The solid particles, containing the undesirablevolatile constituents, are
removed from the gas stream and thus the processby fabric filters and ESPs.
The semidry processis a variation of the dry process. In the semidry process, the water is
added to the dry raw mix in a pelletizer to form moist nodulesor pellets. The pellets then are
conveyed on a moving grate preheaterbefore being fed to the rotary kiln. The pellets are dried and
partially calcined by hot kiln exhaustgasespassingthrough the moving grate.
Regardless of the type of pyroprocessused, the last componentof the pyroprocessing system
is the clinker cooler. This processstep recoupsup to 30 percentof the heat input to tine kiln system,
locks in desirable product qualities by freezing mineralogy, and makes it possible to handle the cooled
clinker with conventional conveying equipment. The more common types of clinker coolers are
(1) reciprocating grate, (2) planetary, and (3) rotary. In thesecoolers, the clinker is cooled from
about 1100°C to 93°C (2000°F to 200°F) by ambient air that passesthrough the clinker and into the
rotary kiln for use as combustion air. However, in the reciprocatinggrate cooler, lower clinker
discharge temperaturesare achievedby passing an additional quantity of air through the clinker.
Because this additional air cannotbe utilized in the kiln for efficient combustion, it is vented to the
atmosphere, used for drying coal or raw materials, or used as a combustion air source for the
precalciner.
The final step in portland cement manufacturinginvolves a sequenceof blending and grinding
operations that transforms clinker to finished portland cement. Up to 5 percent gypsum or natural
anhydrite is added to the clinker during grinding to control the cement setting time, and other
specialty chemicals are addedas neededto impart specific product properties. This finish milling is
accomplished almost exclusively in ball or tube mills. Typically, finishing is conducted in a closed-
circuit system, with product sizing by air separation.
11.6.2 Emissions And Controls1*3-7
Particulate matter (PM and PM-lo), nitrogen oxides (NO,), sulfur dioxide (SO,), carbon
monoxide (CO), and CO, are the primary emissionsin the manufactureof portland cement. Small
quantities of volatile organic compounds(VOC), ammonia (NHs), chlorine, and hydrogen chloride
l/95 Mineral ProductsIndustry 11.6-5

(HCl), also may be emitted. Emissions may also include residual materials from the fud and raw
materials or products of incomplete combustion that are consideredto be hazardous. Becausesome
facilities bum waste fuels, particulariy spent solvents in the kiln, thesesystems also may emit small
quantities of additional hazardousorganic pollutants. Also, raw material feeds and fueis wically
contain trace amounts of heavy metals that may be emitted as a particulateor vapor-
Sources of PM at cement plants inchtde (1) quarrying and crushing, (2) raw material storage,
(3) grinding and blending (m the dry processonly), (4) clinker production, (5) finish grinding, and
(6) packagkg and loading. The largest emission source of PM within cement plants is the
pyroprocessing system that includes the kiln and clinker cooler exhauststacks. Often, dust from the
kiln is collected and recycled.into the kiln, thereby producing clinker from the dust- ‘However, if the
alkali content of the raw materials is too high, some or all of the dust is discardedor leached before
being returned to the kiln. In many instances,the maximum a3lowablecement al&ii content of
0.6 percent (calculated as sodium oxide) restricts the amount of dust that can be recycled. Bypass
systems sometimes have a separateexhauststack.’ Additional sourcesof PM are raw matefial storage
piles, conveyors, storagesilos, and unloading facilities. Emissions from portland cement pIants
constructed or modified after August 17, 1971 are regulated to limit PM emissions from portland
cement lciins to 0.15 kg/Mg (0.30 lb/ton) of feed (dry basis), and to limit PM emissions f?om clinker
coolers to 0.050 kg/iMg (0.10 lb/ton) of feed (dry basis).
Oxides of nitrcgen are generatedduring fuel combustion by oxidation of chemically-bound

nitrogen in the fuel and by thermal fixation of nitrogen in the combustion air. As flame temperature
increases,the amount of thermally generatedNOx increases. The amount of NOx generatedfrom fuel
increaseswith the quantity of nitrogen in the fnel. In the cement manu&uring process, NOX is
generatedin both the burning xone of the kiln and the burning zone of a precalcining vessel- Fuel
use affects the quantity and type of NOx generated- For example, in the kiln, natural gas combustion
with a high flame temperature and low fuel nitrogerrgeneratesa larger quantity of NO.Xthan does oi1
or mai, which have higher f%el nitrogen but which bum with lower flame temperatures- The
opposite may be true in a precalciner. Types of fueIs used vary acrossthe industry. Historically,
some combination of coal, oil, and natural gas was used, but over the last 15 years, most plants have
stiitched to coal, which generatesless NOx than does oil or gas. However, in recent years a number
of plants have switched to systems that bum a combination of coaI and waste fuel. The effect of
waste fuel use on NOx emissions is not clearly estabIished.
Sulfur dioxide may be generatedboth from the sulfur compoundsin the raw materials and
from sulks in the fuel. The sulfur contentof both raw materials and fuels varies from plant to plant
and with geographic location. However, the alkaline natureof the cementprovides for direct
absorption of SO2 into. the product, thereby mitigating the quantity of SO2 emissions in the exhaust
stream. Depending on tbe.processand the sourceof the sulfur, SO, absorption rangesfrom about
70 percent to more than 95 percent.
The CO* emissions from portland cement manufacturing are generatedby two mechanisms.
As witb most high-temperature, ener-g-intensiveindustrial processes,combusting fuels to generate
process energy releasessubstantial quantities of CO*. Substantialquantities of CO2 aIso are
generatedthrough caicining of limestone or other caIcareousmaterial. This calcining process
thermally decomposesCaCOs to CaO and COz. Typically, portland cement contains the equivalent
of about 63-S percent CaO. Consequently,about I. 135 units of CaCOs are required to produce 1
unit of cement, and the amount of CO2 releasedin the calcining process is about 500 kilograms (kg)
per Mg of portland cement produced (1,000 pounds [lbj per ton of cement). Total CO* emissions
from the pyroprocessdependon energy consumptionand generally faI1 in the range of O-85 to
1.35 Mg of CO2 per Mg of clinker.
116-6 EMISSION FACTORS 1195

(” In addition to CO2 emissions, fuel combustion at portland cement plants can emit a wide
rangeof pollutants in smaller quantities. If the combustion reactionsdo not reach completion, CO
e and volatile organic pollutants, typically measuredas total organic compounds (TOC), VOC, or
organic condensableparticulate, can be emitted. Incomplete combustion also can lead to emissions of
specific hazardous organic air pollutants, although thesepollutants are generalIy emitted at
substantially lower levels than CO or TOC.
Emissions of metal compoundsfrom portland cementkilm can be grouped into three general
classes: volatile metals, including mercury (Hg) andthallium (Tl); semivolatile metals, including
antimony (Sb), cadmium (Cd), lead (Pb), selenium (Se), zinc (Zn), potassium (IQ and sodium @la);
and refractory or nonvolatile metals, includmg barium (Ba), chromium (Cr), arsenic (As), nickel (Ni),
vanadium (V), manganese(Mn), copper (Cu), and silver (Ag). Although the partitioning of these
metal groups is a&cted by kiln operating conditions, the ret&tory metals tend to concentratein the
clinker, while the volatile and semivolatile metals tend to be dischargedthrough the primary exhaust
stack and the bypass stack, respectively.
Fugitive dust sources in the industry include quarrying and mining operations, vehicle traffic
during mineral extraction and at the manuf&uring site, raw materials storagepiles, and.clinker
storagepiles. The measures used to control emissionsfrom thesefugitive dust sourcesare
comparable to those used throughout the mineral products industries. Vehicle traffic controls include
paving and road wetting. Controls that are applied to other opendust sourcesinclude water sprays
with and without surfactants, chemical dust suppressants,wind screens,and process modifications to
reducedrop heights or enclose storageoperations. Additional information on these control measures
can be found in Chapter 13 of APA2, “Miscellaneous Sources”.
Process fugitive emission sources include materiaIshandling and transfer, raw miIling
operations in dry process facilities, and finish milling operations. Typically, emissions from these
processesare captured by a ventilation system and collected in fabric filters. Some facilities use an
air pollution control system comprising one or more mechanicalcollectors with a fabric filter in
series. Because the dust from theseunits is returnedto the process,they are consideredto be process
units as well as air pollution control devices. The industry usesshaker, reverse air, and pulse jet
filters as well as some cartridge units, but most newer facilities use pulse jet filters. For process
fugitive operations, the different systems are reportedto achievetypical outlet PM loadings of
45 milligrams per cubic meter (mg/m3) (0.02 grains per actual cubic foot @/a&J).
In the pyroprocessing units, PM emissions are controlled by fabric filters (reverseair, pulse
jet, or pulse plenum) and electrostatic precipitators (ESP). Typical control measuresfor the kiln
exhaustare reverse air fabric filters with an air-to-cloth ratio of 0.41: 1 m3/min/m2 (l-5:1 a&n/@)
and ESP with a net surface collection area of 1,140 to 1,620 mz/l ,000 m3 (350 to 500 ft?/l,OOO ft?).
These systems are reported to achieve outlet PM loadmgs of 45 mg/m3 (0.02 gr/acf). Clinker cooler
systems are controlled most frequently with pulse jet or pulse plenum fabric filters. A few gravel bed
filters also have been used to control clinker cooier emissions. Typical outlet PM loadings are
identical to those reported for kilns.
Cement kiln systems have highly alkaline internal environmentsthat can absorbup to
95 percent 0f.potentia.l SO, emissions. However, in systemsthat have sulfide sulfur (pyrites) in the
kiln feed, the sulfur absor$.ion rate may be as low as 70 percentwithout unique design considerations
or changesin raw materials. The cement kiln system itself has beendetermined to provide substantial
SO2 control. Fabric filters on cement kilns are also reportedto absorb S02. Generally, substantial
control is not achieved. An absorbing reagent(e. g., CaO) must be present in the filter cake for SO2
capture to occur- Without the presenceof water, which is undesirablein the operation of a fabric
1195 Mineral Products Industry 11-6-7

flker, CaCOJ is not an absorbing reagent. It has beenobservedthat as much as 50 percent of the
SO* can be removed from the pyroprocessing system exhaustgaseswhen this gas stream is used in a
raw miI1 for ha r-very and drying. In this case,moisture~andcakium carbonateare
. simukmeously present for sufficient time to accompiishthe chemicaI reaction with SO*.
Tables 116-l and 116-2 present emission factors for PM emissionsfrom portland cement
manufacturing kiIns and clinker cooIers. Tab& 11.6-3 and Il.64 presentemission factors for PM .
emissions from raw materiaI and product processingand handIing. ParticIe size distributions for
emissions from wet processand dry process hiIns are presentedjn Table 11.64, and Table 116-6
presentsthe particle size diiiutions for emissionsfrom cIinker cooiers. Emission factors for SOz,
NOx, CO, Cq, and TOC emissions from pordand cementkiIns are summarized in Tables 116-7 and
11.68. Table 116-9 m emission factors for other pollutant emissions from portIand cement
kilns.
Because of differences in the suIfirr contentof the raw materiaI and fueI and in process
operations, a mass baIancefor suIfur may yield a more representativeemission factor for a specific
faciIi~~than the Sq emission factors presentedin Tables 116-7 and 11.6-8. In addition, CO2
emission factors estimated using a mass baIanceon carbonmay be more representativefor a specific
faciIiv than the CO2 emission ktors presentedin Tables 11-6-7 and 11.64~
1l-6-8 EMISSION FACTORS I195

Table1 I .6-l (Metric Units). EMlSSION FACTORS FOR PORTLAND CEMENT MANUFACTURING
KILNS ANDCLINKER COOLERS*
Fiimbleb Condcnsabiec
EMISSION EMISSION EMISSION EMISSION

FACTOR FACTOR FACTOR FACTOR
Process PM RATING PM-10 RATING inorganic RATING Organic RATING
Wet prncess kiln 6Sd D l6= D ND ND

‘(SCC 3.05-007-06)
\Vcl process kiln with @SP 0,38f C 0,336 D 0.076h D ND

(SCC 3-05-007-06)
We1 prnccss kih will1 hbric filler a.2d E ND O*ld E ND

(SCC ~.OS-007.06)
Wet process kiln with cooling tower,

~nulliclonc, mid ESP O.lok E ND 0*14k E ND
(SCC 3-05-007-06)
Dry proms kiln with ESP 0.50”’ D “ND 0. 19n’ D ND

(SCC 3-05-006-06)
Dry process kiln with fabric fihcr 0.10” D 0,084f’ D 0.45” D ND

(SCC 3-05-006-06)
Prchcatcr kiln 13oq D ND ND ND

(SCC 3.05-006-22)
Prehcatcr kiln with ESP O*lY D ND ND. ND

(SCC 3-05-006-22)
Prchcatcr kiln with fabric filter 0.133 C ND 0.017’ D ND

(SCC 3-05.006-22)
Prcl~c~~~cr/~)rccnlcincr kill) wilh ESP 0.024” D ND ND ND

(XC 3-05-006-23)
Prclmtcdprccdciner process kiln

wilh fabric filler 0.10” D ND ND ND
(SCC 3-05-006-23)
Pr~l~c~lcr/l)rcc~fci~e~ process kiln

will1 PM controls ND ND 0.078’ D ND
(XC 3-05-006-23)
Table1I ,6-l (cont.),
25
Filtmbleb Condcnsablec
EMISSION EMISSION EMfSSION EMISSION
FACTOR FA$TOR FJACTOR FACTOR
Process PM RATINU PM-IO RATING Inorganic RATING Organic RATING
Clinker cooler with ESP 0.048’ D ND O.OO38x D ND
(SCC 3-OS-006-14)
$Xnker cooker with fabric iilter 0.068y D ND O&084= D ND
(SCC 3-05-006-14)
Clinker cooler with gravel bed liltcr O#llU D 0.084bb D 0.0045c~ D ND
(SCC 3-OS-006-14)
* Factorsrepresent uncontrolledemissions unless,otherwisenoted. Factorsarekg/Mg of clinkerproduced,unlbssnoted, SCC = Source
!i? Classification
Code. ND = no data. ESP= electrostatic precipitator,
b FilterablePM is that collectedon or beforethe tilter of an EPAMethod5 (or equivalent)samplingtrain,
ii ’ Condensable PM is that collectedin the impingerportionof a PM samplingtrain,’
g ’ References 20,26,
’ Referenties3,20,26,
2
f References 8-9,18,20,25-26,32,34-36,4 l-44,60,64.
9 IZReferences 3,8-9,!8,20,25-26,32,34-36,4 l-44,60,64.
0
iTI ‘I Referencesg-9,20,64.
j Reference14,
k Reference 2I,
m‘References 19,21,
n Reference 23,
!) References 3,23.
q Reference17.
r Reference 3I,
’ References 17,47-50,6l.
’ Reference 5I,
” Reference 37. 4
v References 30,33,5I ,56-59,63 ’ References

9,l2,30,
w References 30,33,37,5I ,59. aaReferences
22,29,3 I
x Reference 8. bbReferences
3,22,29,31
c “References22,29
si Y References 9,12,27,30,33.
Table 1 I .6-2 (English Units), EMISSION FACTORS FOR PORTLAND CEMENT MANUFACTURING
KILNS AND CLINKER COOLERSa
Fillerableb Condensable’
EMISSION EMISSION EMISSION EMKX3iON

Process PM MTING PM-10 RATING Inorganic RATING Ofganie RATING
Wet process kiln id D 31e D ND ND’

(SCC 3~05-007-06)
Wet process kiln wilh ESP 0.77f CT 0.65g D O,l5h D ND

(XC 3-05-007-06)
Wet process kiln with fabric iiller 0.4d E ND 0.2ti E ND

(XC 3-05-007-06)
Wet process kiln with cooling tower, 0*2& E ND 0.29k E ND

multiclone, and ESP
(SCC 3-05-007-06)
Dry process kiln with ESP I-0”’ D ND 0.38m . D ND

(SCC 3-OSGO6-06)
Dry process kiln wilh fnbric filler 0.20" D O#lV D 0.89n D ND

(SCC 3-05.006-06)
Prehcntcr kiln 25oq D ND ND ND

(SCC 3-05-006-22)
Prchcntcr kiln with ESP 0.26* D ND ND ND

(XC 3-05-006-22)
Prchcatcr kiln with fabric filter 0.25' c ND 0.033' D ND

(SCC 3-05-006-22)
Prcheater/precalcincr kiln with ESP 0.048" D ND ND ’ ND

(SCC 3-05-006-23)
Prchcatcr/precnlciner process kiln

will1 fabric filler 0.21” D ND ND ND
(SCC 3-05-006-23)
Preheatcr/prccalciner process kiln

~$11 PM cootrois ND ND 0.16"' D ND
(SCC 3-05-006-23)
Table I l.6-2 (cont.).
Fillerableb Condensable’
EMISSION EMISSION EMISSION EMISSION
Process PM RATING PM-10 RATING Inorganic RATING Organic RATING
Clinker cooler with ESP O.O96x D ND o*oo7sx D ND
.
(SCC 3-OS-006-14)
Clinker cooker with rubric filter 0*13y D ND o.o17z D .ND
(SCC 3-05-006-14)
Clinker cooler with gravel bed filter 0#2lM D ’ 0.16bb D oao90~c D ND
(SCC 3-05-006-14)
* Factorsrepresentuncontrolled emissions unlessotherwisenoted. Factorsarelb/tonof clinkerproducedunlessnoted. SCC = Source
ClassificationCode, ND = no data. ESP= electrostatic precipitator,
u FilterablePM is that collectedon or beforethe filter of an EPAMethod5 (or equivalent) samplingtrain,
t2 ’ Condensable PM is that collectedin the impingerportionof a PM samplingtrain.
g ’ References 20,26. ,
’ References 3,20,26,
2 ’ References 8-9,18,20,25-26,32,34-36,41-44,60,64,
Q g References 3,8-g,l&20,25-26,32,34-36,4l-44,60,64.
0
iz t’ References 8-9,20,64.
j Reference14.
k Reference 2I.
mReferences 19,21.
” Reference 23,
t’ References 3,23,
q Reference17.
r Reference 31,
’ References l7,47-50,61.
t Reference 51.
u Reference 37. 4
’ References 30,33,51,56-59,63
w References 30,33,37,51,59.
’ Reference 8. aaReferences
22,29,31
r Y References 9,12,27,30,33. bbReferences
3,22,29,31
t5i “References22,29
zReferences 9,l2,30.
Table 11-6-3 (Metric Units)- EMISSION FACTORS FOR PORTLAND CEMENT
MANUFACTURING UW MATERIAL AND PRODUCT PROCESSING AND HANDLINGa
FiIterableb
EMISSION EMISSION
FACTOR FACTOR
Pm. PM RATING PM-IO RATING
Raw IxlilI with f&-k fiIter 0.006F D ND
(SCC 3-woo6-13)
kaw mill feed kit with fabric filter O&X6* E ND
(SCC 3&-o&24)
Rawmill weighhopperwith fabric filter o-010= E ND
(SCC 3G-o06-25)
EZawmill air sqarator with fabric filter 0.016=
, E ND
(SCC 3-&QO6-26)
Finish *ding mill with fabric flter 0.0042f . D ND -
(SCC 3x&oo6-17, 3-o.s-oo7-17)
Fii grinding mill feed belt with kbric iwr o.oo12* E ND
(SCC 3-0%X6-27, 3-0%X)7-27)
Finish mg mill weigh hopperwith fabric filter o.oo47= E ND
(SCC 3&-W%28, 3&%X)7-28)
Finish grindingmill air sepaxatorwith fabric flter 0.016 D W
(SCC345406-29, 34soo7-29)
Primarylimestonecrushingwith falnic filter o.ooo5o E ND
(SCC 3-05wj-o!@
Pkuary limestone screening with fabric filter 0.ooo11 E ND
(SCC 3JwO6-1.p
Limestone transfer with fabric filter 1.5 x lo-s E ND
(SCC 3-05--12)’
Smndary limestone screening and crushing with
fabsicfilter OwooOl6 E ND
(SCC 3-05-006-10 + -11, 3-05-007-10 + -11p
a Factors representuncontrolled emissions, unless otherwise noted. Factors are kg/Mg of material
&process, uniess noted. SCC = Source Classification Code. ND = no data.
Filterable PM is that collected on or before the filter of an EPA Method 5 (or equivalent)sampling
train.
’ References15,X-57.
’ Reference57.
’ Reference15-
’ References10,12,15,X-57.
g References10,15.
h Reference 16. AltemativeIy, emission factors from Section I I. 19.2, “Crushed Stone Processing”,
can be used for similar processesand equipment.
l/95 Mineral Products Industry 11.6-13

Table 1l-6-4 (English Units). EMISSION FACTORS FOR PORTLAND CEMENT
MANUFACTURING R4W MATERIAL AND PRODUCT PROCESSING AND HANDLINGa
Filtenbleb
EMISSION. EMISSION
FADOR FACTOR
PM RATING PM-10 RATING
0.012 D ND
Raw mill feedhe1twith fabric filter 0.003ld E ND

(SCC 3ABlO6-24)
Raw mill weighhoppexwith f&k mter o.ow E ND
(SCC 3aGoo6-25)
Raw mill air sepzator with fabric filter 0.032 E ND-
(SCC 3&MO6-26)
Finish grinding mill with fhhric rilter O.OOSOf E ND
(SCC 3-05-cx36-17, 3xsoo7-17)
Finish grinding mill feedbelt with fabric filter 0.0024d E ND
(SCC 345-006-27, 345-007-27)
Finish grinding mill weigh hopper with fabric filter 0.0094= E .ND
(SCC 345-006-28, 3aXNI7-28)
Finish grindingmill air seprator with fhbric fik ~0.02s D ND
(SCC 3454Xx-29, 345407-29)
Primate liine crushingwith f&k filter 0.0010 E ND
(SCC 345-006a)h
Primary limestone screening with fabric ftlter 0.00022 E ND
(SCC 3-05x)06-I 1p
Limestonetransferwith fabric filter 2.9 x 10-S E ND
(SCC 3AI5AIC%l2)!’
Second limestone smeening and crushing with
fahlic filter o.ooo31 E ND
(SCC 3xl5-006-IO + -11, 3-05-m7~10 + -1l)h
a Factors representuncontroikd emissions, unless otherwisenoted. Factors are lb/ton of material
processed,unless noted. SCC = Source Classification Code. ND = no data.
’ Filterable PM is that collected on or before the filter of an EPA Method 5 (or equivalent) sampling
train.
c References1556-57.
’ Reference57.
’ Reference 15.
’ ReferencesIO, 12,X56-57.
s References10,15.
’ Reference 16- Alternatively, emission factors from the Section 1I. 19.2, “Crushed Stone
Processing”, can be used for similar processesand equipment.
11.6-14 EMISSION FACTORS 1I95

Table 11*6-5. SUMMARY OF AVENGE PARTICLE SIZE DISTRIBJJTION
FOR PORTLAND CEMENT KILNSa
Cumulative Mass Percent Equal To Or Less Than Stated Size

uncontrolled Controlled
Wet process Dry process
Particle Wet process Dry process. With ESP With FF
Size, pm (SCC 3-05-007-06) (SCC 3-05-006-06) (SCC 3-05-QO7-06) (SCC 3-05X)6-06)
2.5 7 18 64 45
5.0 20 ND 83 77
10.0 24 42 ’ 85 84
15.0 35 44 91 89-
20.0 57 ND 98 . 100
a Reference3. SCC = Source Classification Code. ND = no data.
Table 11-M. SUMMARY OF AVERAGE PARTICLE SIZE DISTRIBUTION

FOR PORTLAND CEMENT CLINKER COOLERS=
I Cumulative Mass Percent Ewal To Or Less Than Stated Size
Particle Size, Km I Uncontrolled

(SCC 3xHK)6-14, 3-05a7-14)
With Gravel Bed Filter
I (SCC 3-05-006-14, 3-05-007-14)
2.5 0.54 40
5.0 1.5 64
10.0 8.6 76
15.0 21 84
20.0 34 89
a Reference3. SCC = Source Classification Code.
1195 Mineral Products Industry 11.6-E

Table I I ,6-7 (Metric Units), EMISSION FACTORS FOR PORTLAND CEMENT MANUFACTURINGa
EMISSION @MISSION EMISSION @MISSION EMISSION

FACTOR FACTOR FACTOR FACTOR FACTOR,
Process SOzb RATING NOx RATING co RATING CO$ RATING TOC RATING
Wet process kiln 4.1d C 3.70 D O.OGOf D i,loo~ D .O.Ol4f D

(SW 3-05-007-06)
Long dry process kiln 4.9h D 3-d D O.llk I? 9OOm D o.o14a E
(SW 3~05-006~06)
Prchealcr process kilu 0.27f’ D 2.4q D 0.4!Y D 900’ C omo’ D
(SCC 3.05.00622)
Prci~~~ter/~)recnlcincr kiln 0.54” D 2.1” D l.gw D 900x E 0,059y D
(SCC 3-05-006-23)
Prcl~ca~cr~rrecnlciner kiln with
spray lnwcr OS@ ND
(SCC 3-05-006-23)
I I
fi pacfors represent uncontroliti emissions unless otherwise noted. Factors are kg/Mg ot Clinker produced, unless noted. XC = Source
Classification Code* ND = no data,
3 ” Mass balance on sulfur may yield a more representative emission factor for a specitic facility than the SO2 emission factors presented in
this table.
’ Mass balance on carbon may yield a more representative emission factor for a specitic facility than the CO2 emission factors presented in
this table.
’ References 20,25-26,32,34-36,41-44,60,64.
’ References 2G,34-36,43,64, ,
’ Reference 64,
s References 252632,34-36,44,60,64.
t’ References I t,l9,39,40.
j References I I ,38-40,65.
k References 39,65,
lx1References I I ,2 I ,23,65.
’ References 40,65. TGC as measured by Method 25A or equivalent.
1’ References 47-50,
q References 48-50.
c ’ Reference 49,
si ’ References 24,3 I ,47-50,6 I.
,-.
Table 11.6-7 (cont.).
t Reference 49; total organic compounds as’ measured by Method 25A or equivalent.
IJ References 28,30,33,37,53,56-59.
” References 28,30,33,37,45,56-59.
w References 28,30,37,56-58,63.
x References 24,3 I ,47-50,61. Based on test data for preheater kilns; should be considered an upper limit.
Y References 30,33,56,63; total organic compounds as measured using Method 25A or equivalent.
’ Reference 54.
Table 1 I.68 (English Units). EMISStON FACTORS FOR PORTLAND CEMENT MANUFACTURINGa
EMISSION EMISSION E!MlSSiON EMISSION EMISSION

FACTOR FACTOR FACTOR FACTOR FACTOR
Process RATINQ RATING RATING co*c RATING TOC RATiNG
W~I prowesskiln D 2,100~ D 0.02ar
(SCC 3-05-00746)
Long ky prows kiln 6.d 0.21k I ,800”’ 0.028”
(XC 3-05-00646)
Prcheatcr process kiln 4.M 0.98’ 1,800’ 0.18’
(SCC 3-05406-22)
Prcheater/predciner kiln 3.7w I ,f.loox 0.127
(SCC 3-05-006-23)
Prcheatedprecalciner kiln
, with spray tower ND ND ND ND
[ (SCC 3-05-006-23)
E a Factors represent uncontrolled emissions unless otherwise noted, Factors are lb/ton of clinker produced, unless noted.
2
w - SCC = Source Classification Cod,e, ND = no data.
5 ’ Mass balance on su!fur may yield a more representative emission factor for a specific facility than the SO2 emission factors presented
q in this table,
’ Mass balance on carbon may yield a more representative emission factor for a specific facility than the CC& emission factors
ii presented in this table,
’ References 20,25-26,32,34-36,41-44,60,64.
’ References 26,34-36,43,64,
r Reference 64,
a References X-26,32,34-36,44,60,64,
” References I i,l9,39-40,
j References I I ,38-40,65.
’ References 39,65,
, m References I I ,21,23,65.
I1 References 40,65, TOC as measured by Method 25A or equivalent.
1’ References 47-50.
q References 48-50.
’ Reference 49,
Y ’ Riferences 24,3 I ,47-50,6l.
k5i l Reference 49; total organic compounds as measured by Method 2SA or equivalent.
‘T’able 1 I .6-8 (cont.).
’ References Z&30,33,37,53,56-59.
” References 28,30,33,37,45, and 56 to 59.
w References 28,30,37,56-58,63.
x References 24,3 I ,47-50,6l. Based on test data for preheater kilns; should be considered an upper limit.
Y References 30,33,56,63; total organic compounds as measured using Method 25A or equivalent,
’ Reference 54.
Table 11.6-9 (Metric And English Units).* SUMMARY OF NONCRITERIA POLLUTANT
EMISSION FACTORS FOR PORTLAND CEh4ENT KILNSa
(SCC 34WO6-O6,34&OO74S,34&0O6-22,3-O54KK-23)
Average Emission Factor EMISSION

Pollulant TyPeOf 7 c FACTOR
N83llC control kiWis Ibhxl RATING Ref~ccs
Inorganic POIIW
SiIver (A& FF 3*1x10-7 6. lxlv’ D 63
Al&urn (Al) ESP OBO65 O-013 E 65
ibsalic (As). ESP 6.5~10~ 1.3x10-5 E 65
Arsenic (As) FF 6.0x1@ 1.2xlc+ D 63
Barium t-1 ESP 0.00018 OdOO35 D 64
-034 FF * o.ooo23 OBOO46 D 63
Bedi- tw FF 3.3x10-7 6.6xlcr’ D- 63
caIcium (ca) ESP ox? O-24 E 65
cadmium (Cd) BP 4.2x10d 8.3x& D 64
cadmium WI FF Llxlti 22x1@ D 63
Chloride (CI) ESP 0.34 0.68 E 25.42-44
chIolidc (Cl) FF 0.0011 o-W21 D 63
Chromium (Cr) ESP 3.9x& 7.7x& E 64
Chromium (Cr) FF 7.0x10-5 oBJO14 D 63
cqq= GUI FF O-W26 0.0053 E 62
FIuoridc (F) ESP OJOO45 0.00090 E 43
km @I ESP 0.0085 0.017 E 65
Ii~dmiw ch~~ri& t-H’3 E!SP 0.025 0349 E 41,6!j
Hydrogen cl&xi& (HCl) FF O-073 0.14 D 59,63
M-w mi9 ESP O.OWll 0.00022 D 64
M=--Y GW FF l2xlo-5 2.4x& D 11,63
Potassium (K) ESP OdO90 0.0X8 D 25,4243
M=w== we ESP oJwo43 O-00086 E *65
Ammonia (NH3) FF 0.0051 0.010 E 59
Ammonium (Mid ESP O-054 b.11 D 25,424
bbare W$. ESP 0.0023 * 0.0046 E 43
Sodium (Na) ESP 0.020 0.038 D 25,424
-PW ESP O.OW36 o.OW71 D 64
Lead O’W FF 3.8~10-~ 7.5x10-5 D 63
SuIfur trioxide (S03) ESP 0.042 0.086 E 25
suIfur tioxide (SO3) FP 0.0073 0.014 D 24,30,50
Suifare (SO.+) ESP 0.10 0.20 D 25,42-44
Sulf* (SO&J FF O-W36 0.w72 D 30,33,52
1l-6-20 EMISSION FACTORS l/95

Tde 11A-9 (coma).
Average Emiision Faar EMISSION

Polllltalx TypeOf u FACTOR
NlUTlC Con&d W&z I lb/ton IUTING RCiXenceS
Selenium (Se) ESP 7-5x10-5 0.00015 E 65
Seknium (Se) FF . O.OGOlO 0.oGG20 E 62
ThaIIium (Th) FF 2.7x10A 5.4x1@ D 63
Titanium m ESP G.GOGl9 0.00037 E 65
zinc (zn) ESP omG27 0.00054 D 64
zinc (2) FF G.ml? oaOO34 D 63
kglulic Pollutants
2AsRNb I NalllC ,
m22469 1,2,3,4,6,7,8 HpCDD FF l.lxlc+ 2-2x10-~0 E - 62
c3 benzcnes ESP l.3x10A 2-6xlG& E 6s
cq4 benzene E-SP 3ax10h 6.0x1@ E f3
C6 benzen= ESP 4.6x10-’ 9.2x10-’ E 65
2G8-96-8 accnapiShyhc FF se9xlo-5 0.GOG12 E 62
s7-64-1 acetone ESP G.GOOl9 0.00037 D 64
lW52-7 benzaldehydc ESP l.2xlo-5 2.4x10-5 E 45
7143-2 imlzerle ESP G.GGl6 oxQ31 D 64
7143-2 berlxcne FP G.GGSG O-G16 E 62
benzo(a)anthxaccne FP 2.1x10a 4-3xlti E 62
9-I-32-8 ba=ddiv= FF 6.5~10~ 1*3x10-7 E. 62
205-99-2 benzo(b)fluolanthene FF 2.8x10-’ 5-6x1@’ E 62
191-24-2 bcnzo(g,h.i)perykne FF 3.9x10* 7.8x1@ E 62
2G74x-9 benzo(k)fluoranthene FF 7.7x10a l.SxlG-’ E 62
65-85-G bezuoic acid ESP O.OGl8 0.0035 D 64
95-524 biphenyl ESP 3*lx10d 6.1xlGd E 65
117-81-7 bis(2+thyihexy~)phthalak BP 4.8x10-’ 9.sxlo-5 D 64
74-83-g bromomethane ESP 2.2x10-5 4.3~lG-~ E 64
75-154 carbon disulfide ESP 5sxlo-5 OSGGol I D 64. -
log-9G-7 cilIorobenzenc ESP 8.0~10~ 1.6xlV5 D 64
74-87-3 chloromeihane ESP G.GGGl9 GmO38 E 64
X8-01-9 chrysene FF KlxlO~ L6xIG-7 E 62
84-74-2 di-n-butylphthaiatc =I? 2.lxlo-5 ~.IxIG-~ D 64
53-70-3 dl&enz(a,h)anthracene FF 3.1x10-7 6.3x10-’ E 62
101414 ethylbenzene ESP 9SxlO~ 1s9xlo-5 D 64
206-u-O fluoranthenc FF 4-4x10d 8.8xlGA E 62
86-73-7 fluorene FF 9.4xlG-6 I .9xlG-5 E 62
m-oo-G formaldehyde FF G.GGG-23 O.GGG46 E 62
1I95 Mineral Pmdwts Industry 1l-6-21

Table I l-6-9 (corn-).
Polhltant Average Emission Factor EMISSION

TypeOf . FACTOR
CASRNb Name Control W’h% lblton RATING Reikreqces
I
freon 113 ESP 25xlcr~ 5.0x10-~ E 65
193-39-5 indeno(l,2&cd)pyme FF 4.3x10: 8*7xlO~ E 62
78-93-3 methyl ethyi ketone ESP 1.5x10-~ 3.0x10-5 E
75-09-2 me&ylene chioride ESP 030025 omo49 E 65
methylnaphthakne ESP 2.1x1@ 42x10~ E 65
91-20-3 naphthaiene v OdJOO8S 0.0017 E 62
91-20-3 naphthakie ESP 0.00011 0.00022 D 64
85-01-S phenantbrene FF omo2o o.ooo39 E 62
108-95-2 phenol ESP ’ 5.5x10-5 0.ooo11 Dw 64
X29- pyrene FF 2.2x10d ” 4.4x10d E 62
100-42-5 Wn= ESP 7.5x10-7 1.5x104 E 65
108-88-3 tduene JZSP 0.ooo10 o%Q19 D 64
total HpCDD FF 2.ox10-~~ 3.9x10-10 E 62
3268-87-9 total OCDD FF l.oxlo-9 2.0x10-9 E 62
total PCDD FF 1.4x10-9 2.7xW9 E k2
132-64-g t&al PCDF FF 1.4x10-to 2-9x10-~0 - E 62
132-64-g wal TCDF FF 1.4x10-10 2.9x10-*0 E 62
1330-2G7 xylems ESP 6.5~10-~ o.ooo13 D 64
a Factors are kg/Mg and lb/ton of clinker produced. SCC = Source Classification Code.
ESP = electrostaticprecipitators FF = fabric filter.
b Chemical Abstract Service Registry Number (organic compounds on3y).
ReferencesFor Section 11.6
W. L. Greer, et al., “Portland Cement”, Air PoIhtion Engineeting Man&, A. J. Buonicore

and W. T. Davis (eds.), Van NostrandReinhold, NY, 1992.
2. U. S. And Gmdan Podznd Gment Industry Plant Infomation Swnma~, December 31,
1990, Portland Cement Association, Washington, DC, August 1991.
3- J. S. Kinsey, L&z And CemenrI’usny - Source &ego? Repon, Volw II, EPAal7-87-
007, U. S. Environmental Protection Agency, Cincinnati, OH, February 1987.
4. Written communication from RobertW. Crolius, Portland Cement Association, Washington,

DC, to Ron Myers, U- S. Environmental Protection Agency, ResearchTriangle Park, NC.
March 11, 1992.
5. Written communication from Walter Greer, Ash Grove Cement Company, Overland Park,
KS, to Ron Myers, U- S. Environmental Protection Agency, ResearchTriangle Park, NC,
September 30, 1993.
I l-6-22 EMISSION FACTORS l/9.5

6. Written communication from John Wheeler, Capitol Cement, San Antonio, TX, to Ron
i Myers, U. S. Environmental Protection Agency, ResearchTriangIe Park, NC, September 21,
1993.
7. Written communication from F. L. Streitman, ESSROC Materials, Inceqorated, Nazareth,

PA, to Ron Myers, U. S. Environmental Protection Agency, ResearchTriangle Park, NC,
September29, 1993.
8. Emissions From Wet ProcessGment Kin And Clinker Choler At Mule Indumies, Inc., EJ73
Test No. 7 1-MMXIl, U. S. EnviromnentaI Protection Agency, ResearchTriangIe Park, NC,
March 1972.
9. Emissions From Wet ProcessGment Kin And C&&r Cooler At I&ai Cement Gxnpny,
ETB Test No. 71-MMa3, U. S. EnviromnentaI Protection Agency, ResearchTriangle Park,
NC, March 1972.
IO. Emissions From Wet ProcessGment Kiln And Finish A4iII SystemsAt Ideai &tent Gmpny,
ETB Test No. 7 1-MM-O4, U. S. Environmental Protection Agency, ResearchTriangle Park,
NC, March 1972.
11. Emissions From Dv ProcessCbnem Kiln At Dragon Cment Gmpany, E’TB Test No.
7 l-MM-05 U. S. EnvironmentaI Protection Agency, ResearchTriangie Park, NC, March
1972.
12. Emissions From Wet ProcessClinker Choler And Finish Ml1 SystemsAt I&al Cbnent
c Gxnpany, ETB Test No. 71-MM-&j, U. S. EnvironmentaJ Protection Agency, Research
Triangle Park, NC, March 1972.
13. Emissions From Wet ProcessCbnent Kiln At Giant Portbnd Cement, ETB Test No.
71-MM-O7, U. S. EnvironmentaI Protection Agency, ResearchTriangle Park, NC, March
1972.
14. Emissions From Wet ProcessGment Kiln At Oregon Portbmd Gment, ETB Test No.
71-MM-15, U. S. Environmental Protection Agency, ResearchTriangle Park, NC, March
1972.
15. Emissions From Dry ProcessRaw h4ill And Finish Mill SystemsAt Ideai Cement Company,
ETB Test No. 71-MMa2, U. S. Environmental Protection Agency, ResearchTriangle Park,
NC, April 1972.
16- Part I, Air Pollution Emission.Test: AI~ZOM Po&and G?menr,EPA Project Report No.
74STN-1, U. S. Environmental Protection Agency, ResearchTriangle Park, NC, June 1974.
17. * Charactetiation Of Inhaiabie PaMzulate Maner Emissions From A Dry Process Gment
Plara, EPA Contract Xo- 68-Q2-3158,Midwest ResearchInstitute, Kansas City, MO,
February 1983-
18. Utaractekuion Of Inhalable Particulate Matter Emissions From A Wet Process Cement
Plant, EPA Contract No. 68-02-3158, Midwest ResearchInstitute, Ktias City, MO, August
1983.
l/95 Mineral Products Industry 116-23

19. Pam&late fiission Tesring At tine Star Industries’ Na&eth PLanr, Lone Star Industries,
Inc., Houston, TX, January 1978.
20. P&&ate Emissions Testing At brie Star huiusm.es’ GreencastlePlant, Lone &u
Industries, Inc., Houston, TX, July 1977.
21. Gas ProcessSurvey At Lune Star Gzment, Inc. ‘s RoanokeNo. 5 Kiin System, Lone Star
Cement, Inc., Cloverdale, VA, October 1979.
22. Test Repom Stack Analysis For Parbdate Emissions: sinker CoolersiGravel Bed Filter,
Mease Engineering Associates, Port Matilda, PA, January 1993.
23. SourceEmissions Survq Of OkMwma C2men.tampany’s Kiin Number 3 Stack, Mullins

Environmental Testing Co., Inc., Addison, TX, March 1980.
24. SourceEmissions Survey Oftine Star Industries, Inc.: Kik.r I, 2, a& 3, Mullins
Environmental Testing Co., Inc-, Addison, TX, June 1980.
SourceCrtissiom Swvq Of L,one Star Indusm-es,Inc., Mullins Environmental Testing Co.,

Inc., Addison, TX, November 1981.
26. Stack Emission Survey And Precipitator Eficiency TestingAt Bonner Springs Plant, Lone Star
Industries, Inc., Houston, TX, November 1981.
27. NSPS Pamblaze Emission &mpliance Tesr: No. 8 Kiln, Interpoll, Inc., Blaine, MN, March
1983.
28. Annuai Gwzpliance Tesr: Mojave Plant, Pape & Steiner Environmental Services, Bakersfield,
CA, May 1983.
29. Source Emissions Survey Of Lehigh Potiland Cement Corripany,Mullins Environmental

Testing Co., Inc., Addison, TX, August 1983.
30- Anm& &mpliance Test: Mojave Plant, Pape & Steiner Environmental Services, Bakersfield,
CA, May 1984.
31. P~bdate Cbmpliance Test: Lehigh Ponland GzmentGwnpany, CH2M Hill, Montgomery,
AL, October 1984.
32- (ZbmplianceTest Results: Pamb&te & Sui? Oxide Emissions AI Lehigh Portland (2men.t
Gqrxrny, KVB, Inc., Irvine, CA, December 1984.
33- Annual&mpliance Test: Mojave Planz, Pape & Steiner Environmental Sewices, Bakersfield,
,
CA, May 1985-
34. Stack Tesufor Paniculare, S02, NO= And Visible EmissionsAt Lone Srar F7orida Holding,
Znc, South Florida Environmental Services, Inc, West Palm Beach, FL, Auawt 1985.
35. ~mpliance Stack Test At tine Star Florida/Pennsuco, Inc, South Flokda Environmental
Services, Inc., West Palm Beach, FL: July 1981.
116-24 EMISSION FACTORS 1195

36. Preliminaq StackTestAt Lone Star Florida./Pennsuco,Inc., South Florida EnvironmentaI
q Services, Inc., West PaIm Beach, FL, July 1981.
37. Quarterly Testing For tine Star CzmemAt Davenspon,Cbigontia,Pape & Steiner
Environmental Services, Bakersfield, CA, September 1985.
38. Written’Communication from David S. Cahn, CaIMat Co., El Monte, CA, to Frank Noonan,
U. S. Environmental Protection Agency, ResearchTriangle Park, NC, June 2, 1987.
39. Technical Repon On 7he Demonstration Of l&e. Feasi&liq Of NOx Emissions Reduction At
Riverside G?mem awa?ty, CresfmorePht (Pms Z-V), Riverside Cement Company,
Riverside, CA, and Quantitative Applications, Stone Mountain, GA, January 1986.
40. Emission Study Qf lEe C&tent Kiin No. 20 BaghouseCollector At 7he Alpena Plant, Great
L&s Division, L@irge &poration, Clayton EnvironmentaI Consultants, Inc., Novi, MI,
March 1989.
41. Baseline And Soivent Fuels Stack Emissions TestAt AlphaPohnd Gment Gmpany In
Ckmenton, New York, Energy & ResourceRecovery Corp., Albany, NY, January 1982.
42. Stationary Sowce Sampiing Report Of Lone Star Industries, New Orieans, Louisiana, Entropy
EnvironmentaIists, Inc., ResearchTriangle Park, NC, May 1982.
43. Stationq Source Sam@ing Repon Of tine Star Indu.&es, New Orleans, Lmisiana, Entropy
EnviinmentaIists, Inc., ResearchTriangle Park, NC, May 1982.
44. Source.&issions Sunvy Of Kiin No. 1 At Lone Star Industries, Inc., New Orl&ns,
L.otiti, MuIIins Environmenu+ITesting Company, Incv Addison?TXs March 1984.
45. Written Communication from Richard Cooke, Ash Grove Cement West, Inc., Durkee, OR, to
Frank Noonan, U. S. EnvironmentaI Protection Agency, ResearchTriangle Park, NC,
May 13, 1987.
46. Sourcemissions Survey Of Tm Gzmenzampany Of Buda, Texas, Mullins Environmental

Testing Co., Inc.; Addison, TX, September1986.
47. Detemzinution of Pa.&culate and Suljiu Dioxide Emissions From l7zeKiln And All&i
BaghouseStacks At SouthwesternPo~iand Cbnent ampany, Pollution Control Science, Inc.,
Miamisburg, OH, June 1986.
48. Written Communication from Douglas MacIver, SouthwesternPortiand Cement CompanyY

Victonille, CA, to John Croom, Quantitative Applications, Inc., Stone Mountain, GA,
October 23, 1989.
49. SourceEmissionsSurveyOf SouthwesternPortLu2d Gment Cbmpany,KOSMOS Cement

Division, MetCo EnvironmentaI, Dallas, TX, June 1989.
SO. Written Communication ftom John Mummett, SouthwesternPortland Cement Company,

Amarillo, TX, to Bill Stewart, Texas Air Control Board, Austin, TX, April 14, 1983.
l/95 Minerai ProductsIndustry 11.6-25

51. Written Communication from StephenSheridan, Ash Grove Cement West, Inc., Portland,
OR, to John Groom, Quantitative Applications, Inc., Stone Mountain, GA, January 15, 1980-
52. Written Communication from David Cahn, CaiMat Co., Los AngeIes, CA, to John CroomY
Quantitative Applications, Inc., Stone Mountain, GA, December 18, 1989-
53. Source Emissions bnpliance Test Repon On ?he Kiln Stack At Marquette Gzment
Mar@hwing Company, Gqe Girardeau, Mi&sou& Performance Testing &c Consultants,
Inc., Kansas City, MO, February 1982.
54. AssessmentOf Suljiu Levels At Lone Star Industries In Gape Girardeau, Missouri, lCVl3,
Elmsford, NY, January 1984.
55. Written Communication from Douglas MacIver, Southwestern Portland Cement Company,
Nephi, UT, to Brent Bradford, Utah Air Conservation Committee, Salt Lake City, UT,
July 13, 1984.
56. Pevomuance Gmmee T&g At SouthwesternPotiiand Cement, Pape & Steiner

Environmental Services, Bakersfieid, CA, February 1985.
57. Gmpkznce Testing At SouthwesternPortland Cemenz,Pape & Steiner Environmental

Services, Bakersfield, CA, April 1985-
58. fission Tests On Qw Plant No- 2 K.&r At SouthwesternPortland ament, Pape& Steiner
Environmental Sewices, Bakersfield, CA, March 1987.
59. Emission Tests On 7JzeNo. 2 Kiln Baghouse At Southwesteb Ponland &me?~, Pape&
Steiner Environmental Setices, BakersfieId, CA, April 1987.
.60. Compliance Stack Test Of Gwler No. 3 At IATE Star F7orida, Inc., South morida
Environmental Services, Inc., Belle Glade, FL, July 1980.
6lm Stack Emissions Survey wL.one Star Indusm~es,Inc-, Portland CementPlant At M~QVZ&
Zxas, Ecology Audits, Ix, Dallas, TX, September 1979.
62. i%issions Testing Repon Gmducted At Kaiser Gzment, GxpemYw, Gllifornia, For KZser
Gzment, W&w Creek, C&fomiu, liUA ?Jzen?wAnalytical, Inc., Richmond, CA, April 30,
1990.
63. Cbfzcation Of GxnpZianceStack Emission Test Program At Lone Star Industries, Inc., Cape
Girardeau, Missouri, Ap?il &. Jwze 1992, Air Pollution Characterizationand Control, Ltd.,
Tolland, CT, January 1993.
64. Source Emissions Survey Of Essrock Marerials, Inc., Eastern Division Qment Group, Kilns
Number.1 And 2 Stack, Fred&ick, Maryland, Volwne 1 @rap), Metco Environmental,
Addison, TX, November 1991-
65. Me Branscome, et al., Evalu&on Of Waste Gxnbustion In A Dry-process Cbnem Kiin At

Lone Star Zndustries,Oglesby,Illinois, ResearchTriangle Institute, ResearchTriangle Park,
NC, December 1984.
11.6-26 EMISSION FACTORS l/95

APPENDIX I
A Place
For
YOUR District Regulations
Ott 1996 Page I - 1

INDEX
Symbols Chainof Custody 400 - 11
Changes100 - 6
t no entries Checklists400 - 1
A Xrcular RecordingCharts 500 - 2
zo 200 - 20, 300 - 12
AbateNuisance 500 - 12 ComplianceAssistance 100- 3
Adoptingand EnforcingRegulations500- 1 ComplianceAssistanceSection 100- 6
Adoptionand Emorcementof Rule/Regs 500 - 11 ComplianceDivision 100 - 3
Agencies 100- 2 ComputerizedDatabase500 - 2
Air Contaminants- ThreatenedRelease500 - 17 Conditionsfor Operation 500 - 2
Air Pollution Control District, (APCD) 100- 2, Zonditionsfor Permits 500 - 2
500 - 1 Zraftsmanship200 - 1
Air Pollution Control Officer, Powers,Duties 500 - Zuffs 400 - 13
15
Air Pollution Control SystemRecordkeeping500 - D
2 1epartrnentof PesticideRegulation 100- 3
Air Quality ManagementDistrict (AQMD) 500- 1 %parnnentof Toxic Substances Control 100- 3
Air Quality Standards100- 7 Xstrict Requirements300 - 13,400 - 1, 500 - 1
Air ResourcesBoard(ARB) 100- 2, 500 - 1 documentFalsification 500 - 2 1, 500 - 23
Ambient Air Quality Standards100- 9 Xtctwork 400 - 7
Amendment 100- 6
APCD 100- 2 E
AQMD 500 - 1 %r Plugs 400 - 12
ARB 100-2, 500- 1 %rly Forms 200 - 1
Assyrians 200 - 1
Zgypt 200 - 1
Authority to Construct 500 - 1
ZmissionFactors 300 - 21
B Zmissions 100- 7
ZPAReferenceMethod 9 500 - 4
Babylonians200 - 1 EquipmentBreakdown 500- 5
Baghouse400 - 8 EquipmentCheck 400 - 3
Bitumen 200 - 1 EquipmentMalfunction 500 - 5
Breakdown 500 - 5
BreakdownandVariances 500 - 1 F
Breakdown,Repaired 500 - 7
Faceshield400 - 13
Bureauof Air Sanitation 100 - 2
Facility InspectionProcedures400 - 4
Buried Alive 400 - 12
Facility InspectionRecordkeeping 500 - 2
C Failure to SupplyInformation 500 - 18
FalseStatements500 - 18
California Air ResourcesBoard 100- 2 Fan 400-8
California CleanAir Act 100 - 7 File Review 400 - 2
California EnvironmentalProtectionAgency 100- Focus 100- 4
2
California EPA 100- 2 G
California Health and SafetyCode(HSC) 500 - 1
GeneralViolations,Civil 500 - 22
CAP loo- 3
Gloves 400 - 12
Cautions 400 - 12
Gypsum 200 - 1
CCAA 100-7
Index - 1
H
Hard Hat 400 - 12 Negligence,Criminal 500 - 20
Hazards,Specific 400 - 12 Negligenceor Actual Injury, Civil 500 - 23
Health 100-3, 100-7 NewSourcePerformance Standards@SPS)300- 13
Health and SafetyCode(HSC) 500 - 1,500 -9 Nile River 200 - 1
Health Concerns 100- 7 Noise 400 - 12
High VoltageLines 400 - 12 Noticeof Violation, (NOV) 400 - 11
History 200- 1 NOV 400-11
Holes, Cracks 400 - 8 Nuisance 500- 1
HSC 500 - 1
0
I Office of EnvironmentalHealth HazardAssessment
IdentificationCards 400 - 3 100-3
ImorrnationDisclosure 500 - 18 OpacityStandards500 - 13
lmovative Publications 100- 3 Opportunitiesto PreventAir Pollution 300 - 12
InspectionAids 400 - 1 Ordersfor Abatement 500 - 25
InspectorSaGety400 - 12 Overview 100- 5
IntegratedWasteManagementBoard 100- 3 Ozone 100- 7,100 - 8
Introduction 500 - 1
Inventory of Emissions 100- 8
P
ParticleSize 300 - 14
J ParticlesLessThan 10 Microns 100- 8
no entries ParticulateMatter (PMlO) 100- 7, 100- 8
ParticulateMatter Checklist 400 - 6
K ParticulateMatter EmissionLirnits 500- 4
no entries ParticulateMatter Emissions 500 - 1
Penalties,Civil 500 - 25
L Penalties,Criminal 500 - 19
Lime 200 - 1 PermitChecklist 400 - 6
Local and StateAgency Responsibilities500 - 10 PermitIssuance- Requirements500 - 14
Lungs 400 - 12 Permit Suspension500 - 18
Permit System 500 - 13
M Perrnitto Operate 500 - 2
PlantTowers 400 - 8
MaintenanceProgram 300 - 13,500 - 2 PM10 Standard 100- 8
MalIunction 500 - 5
PossibleSourcesof Emissions 300 - 12
ManualAmendments,Maintenance 100- 6
Post-inspectionProcedures400 - 11
Material S&ety Data Sheets400 - 4
Pre-entryand Entry 400 - 3
Mechanizationof Plants 200 - 5, 200 - 5
Pre-inspection400 - 1,400 - 2
Molasses200 - 1
Pre-inspectionMeeting 400 - 4
Monitoring 500 - 2
PublicRoads 400 - 6
Monitoring andRecordkeeping500 - 2
PublicRoads(Trackout) 300 - 13
Mortar 200 - 1
Motor VehiclePollutionControl Board 100- 2 Q
MSDS 400 - 4
MVPCB 100- 2 Quartet- of TechnicalManuals 100 - 1
Index- 2
R W
I
[ RCRA (ResourceRecoveryand ConservationAct) WasteChargingRate Requirements500 - 2
200 - 18 Water ResourcesControl Board 100- 3
Recordkeeping500 - 2 Willful Intent, Civil 500 - 22
Recoveryof Civil Penalties500 - 25 Wind Readings400 - 6
RecyclingSystem 400 - 8
X
RefusedEntry 400 - 3
RegulationReview 400 - 2 no entries
Right of Entry 400 - 3,500 - 12
Y
Ringelmann500 - 13, A - 1 no entries
RingelmannChart 500 - 4
Roadwaysin Plants 300 - 13 Z
Romans 200 - 1 no entries
Rule Violationsof RecordkeepingRequirements
500-2
Rules,Adoption 500 - 11
S
Sdety Glasses400 - 12
ShortVariance 500 - 8
SlakedLime 200 - 1
sox 200 - 20, 300 - 12
Standardsfor Air Quality 100- 7
Statuteof Limitations 500 - 25
Statiites 500- 1
StatutoryAuthority 100 - 3
StorageBins 400 - 8
Strip Charts 500 - 2
T
Tenacity 200 - 1
TrackingCard 100 - 6
U
no entries
V
Variance- FindingsRequired 500 - 18
Vehicle EmissionStandards 100- 2
Verbatim, Sections,Health & SafetyCode 500 - 8
Violating Orderof Abatement 500 - 22
Visible Emissions400 - 8,500 - 1,500 - 3
voc 100-7
Volatile OrganicCompound 100- 7
Index - 3

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ACKNOWLEDGEMENTS

DouglasShumway EnvironmentalManager,Mitsubishi CementCorporation

Contributing ARB Staff

Table 100.1 Ambient Air Quality Standards ......................................................................... 100-9

101 WHAT THIS MANUAL IS ABOUT

You can learn about:

Aggregates,AsphaltHot Mix Facilities, and ConcreteBatch Plants,although

102 WHAT ARE CEMENT KILNS?

A cementkiln facility quarrys,crushes,andgrindsthe raw materials,measures,

103 CALIFORNIA AIR RESOURCES BOARD

On the other hand,Califomia leadsthe nationin programsto cleanup the air. In

Next camethe California EPA. In July, 1991, the California Environmental

Cabinetlevel agency,theseentities: the Departmentof PesticideRegulation,the

1. Conductsinspections,in cooperationwith the air districts to ensure

2. Developssuggested rules andregulationsto assistlocal air districts in

3. Establishesair quality standardsto protectthe healthof the vulnerable

4. Evaluatesthe effectivenessof pollutant control strategiesandprograms

5. Monitors air quality throughoutthe State.

The ARB’s pastefforts andthe cooperationof industryandthe public have

104 COMPLIANCE ASSISTANCE PROGRAM

andby encouragingcooperationbetweenregulatorsand industry. Toward this

Enforcementauditsof someindustrialsourceshave shownnoncompliancerates

If We Basedon the ideathat emissionsourceoperatorswill comply with air quality

Throughthe developmentanddistribution of theserule-specificpublications,

Handbooks. Easy-to-read,colorfully illustratedhandbooksare developedfor

Pamphlets. Quick-referencepamphletscontaindetailedflow charts,checklists,

Technical Manuals. Detailedtechnicalinspectionmanualsaredeveloped

104.1 FOCUS / TARGET AUDIENCE FOR THIS MANUAL

The primary focus of the ComplianceAssistanceProgramis to improve the

This technicalmanualis targetedfor corporateandindustrial managersandtheir

104.2 MANUAL DESIGN

This cementkiln manualis designedto assistyou, the inspectorsin government

This manualcomplementsan existingtrio of CAP Manuals. Together,they can

This manualprovidesboth an overviewand detailedinformation, alongwith

Section 100 providesoverviews of air pollution problemsin California,the

Section 300, Process and Control, describesin more detailthe various

Section 400 describesInspection Procedures for assuringcompliance,includ-

Section 500 presentsthe Legal Requirements of the laws andregulations

The Glossary containsa collectionof terms usedin the manualandthe industry.

(EPAMethod 5); C containsVisible EmissionsEvaluationprocedures;

TheIndex at the endof the manualcanhelpyou to find topics.

104.3 MANUAL MAINTENANCE

Thismanualis a dynamic,living documentthat relies on your experienceand

Whenwe receiveyour proposedamendment,we will review it, contactothersto

Page100-6 Ott 1996

105 CALIFORNIA CLEAN AIR ACT

106 AIR POLLUTION HEALTH CONCERNS

Volatile organic compoundsare precursorsto both ozone,a serious concern,

106.1 VOLATILE ORGANIC COMPOUND (VOC) AND PM10

A volatile organiccompound(VOC) is a carbonsubstancewhich canbe a cause

lower atmosphereduring a seriesof chemicalreactionsbetweenvolatile organic

voc, PM10 levelsarethe result of both direct andindirect sources.Direct sources

For the year 1991, the ARB emissionsinventory showsthat cementkilns in

106.2 STANDARDS FOR OZONE AND PARTICULATE MATTER (PMIO)

Ozoneis a strongrespiratoryirritant that canimpair the normalfunction of the

Particulatematter with equivalentaerodynamicdiameterssmallerthan 10

Air Quality To protect California’spopulationfrom the harmful effects of ozoneandPMlO,

Page 100 - 8 Ott 1996

Table 100.1 Ambient Air Quality Standards

Ambient Air Quality Standards

Pollutant Averaging Time State Std. Federal Std.

Ozone 1 hour 0.09 ppm 0.12ppm

24 hours 50 j.&m3 150pg/m3