Visible Emission

Evaluation Procedures
Course

Student Manual
APT/ Course 325
Final Review Draft
Principal Author

Thomas H. Rose, Eastern Technical Associates

Style and Editing

Monica L. Loewy, The Leslie Group, Inc.

Peer Reviewers

Jay M. Willenberg, PE, Puget Sound Air Pollution Control Agency

Michael T. DeBusschere, PE, Private Consultant
Benjamin Jones, Oregon Department of Environmental Quality
Frank P. Terranglio, Portland State University

Grant Project Officer

Kirk E. Foster, U.S. Environmental Protection Agency

Developed By

Environmental Institute for Technology Transfer

University of Texas at Arlington
EPA Training Grant T-902743

Report # and Date

APTl/325-95-1
January 1995
Contents

Preface

Lesson 1 Historical Background l-l

Lesson 2 Principles of Visual Emissions Measurements 2-l

Lesson 3 Sources of Visible Emissions 3-l

Lesson 4 Meteorology 4-l

Lesson 5 Method 9 Requirements 5-l

Lesson 6 Other Methods 6-l

Lesson 7 Special Field Problems 7-l

Lesson 8 Documentation 8-l

Lesson 9 Equipment 9-l

Lesson 10 Field Training and Certification 10-l

Lesson 11 Presentation of Opacity Data in Court Cases 11-1

Lesson 12 Quality Assurance and Auditing 12-1

Answers to Review Questions A-l

Additional Readings B-l

1-2 l Course 325, Visible Emission Evaluation Procedures

,_,..,, -, ..(I., ” ._,“_. “__ ._ I_

Lesson 7

History

c
 History

Early History
Most early U.S. and English case law concerning air contami- Notes
nation fell under a part of the law commonIy referred to as
nuisance law. In the absence of specific regulations or laws
against air pollutants, someone wanting to stop pollution (for
example, smoke from factories) had to bring a tort (or injury)
case against the offender. Smoke in general was not necessari-
ly considered a nuisance, however. Each case had to stand on
its own merit and prove that smoke was a nuisance. An early
example of a successful court case in which air pollution was
ruled a nuisance was an English case in which a lead smelter
produced fumes that killed a neighbors corn.

Probably the earliest case upholding a municipal smoke-control

ordinance was the 1859 case City of New Orleans v. Lambert.
The Louisiana Supreme Court upheld an injunction against a
blacksmith shop because, in violation of a city ordinance, it
emitted offensive odors and smoke and was a nuisance. The
court upheld the police powers of the municipal government.

The problem of proving that smoke is an annoyance or is injuri-

ous to health in every case was well stated by Lord Romilly in
Grump v. Lambert in 1867: “The real question in all of these
cases is the question of fact, namely, whether the annoyance is
such as to materially interfere with the ordinary comforts of
human existence.”

Industrial development increased toward the end of the 19th

century. With increased industry came increased awareness of
the health, social, and physical costs of industrialization and
city crowding. Communities passed regulations that sought to
control air pollution itself rather than to control nuisances caused
by air pollution. In 1881 the first smoke control ordinances
were adopted in Chicago and Cincinnati. Court records from
the late 19th and early 20th centuries contain many examples of
city and state prosecutions of smoke ordinance violations.

Historical Background l 7-3

 Notes The proliferation of smoke ordinances set the stage for the
introduction of measurement science into the smoke-control
mechanism. Maximillian Ringelmann, a Belgian-born, Ger-
man-trained engineer working in France, developed a method
to quantify emissions according to the density of the observed
smoke. He developed the method, known as the Ringelmann
Chart, to assist in his studies of combustion efficiency. Using a
set of cards with patterns of black ink, he was able to categorize
the density of black smoke into four shades of darkness (see
Figure l-l).

1 2

Figure l-l. Ringelmann Cards

In 1899 the American Society of Mechanical Engineers recog-

nized the Ringelmann Chart as its official scale for determining
smoke density. In 1904 the U.S. Geological Survey used the
Ringelmann Chart in combustion studies for coal-fired sources,
giving it further credibility. Agencies and municipalities seek-
ing to improve the quality of the air quickly picked up the
Ringelmann system. By 1912.23 of the 28 cities in the United
States with populations of over 200.000 had adopted smoke
ordinances.

Ruling bodies soon recognized that the law of nuisance alone

was not adequate to prevent air contamination. What was
needed was a shift of emphasis away from individual com-
plaints toward community-wide concerns. In 1905 in the case

74 l Course 325, Visible Emission Evaluation Procedures

of Glucose Re3ning Company v. City of Chicago, the court Notes
upheld the view that “the emission of dense smoke in populous
communities is a public nuisance.” In Field v. Chicago the
court found that “smoke emitted from a tall chimney is carried
over a wide territory and that when dense, it deposits soot to
such an extent so to injure property and health wherever it
spreads.”

At this pain< the relationship between legislation and common

law becomes important:

l Legislation is all the statutes, laws, rules, regulations,

etc. passed by ruling bodies. Legislation is also called
statutory law.

l Common law is the body of court interpretations and

rulings that enhance, modify, and temper these legisla-
tive actions.

l Until statutory law has had its day in court and with-
stood the challenge, it is not fully established.

The need for enlarging the scope of the public nuisance defini-
tion was formally recognized in the Missouri case of State v.
Tower in 1904:

“It was entirely competent for the Legislature to take

cognizance of the fact, known to all men, that the emis-
sion and discharge of dense smoke in the atmosphere of
a large and populous city is of itself a nuisance . . . and
one calculated to interfere with the health and comfort
of the inhabitants thereof, and to declare it a nuisance
per se . . . . We have no hesitancy in holding that it was
entirely competent for the Legislature to declare the
emission of dense smoke in the open air in a city of
100,000 inhabitants a nuisance per se.”

Refinement In Law
Other specific problems regarding regulations of air pollutants
had to be addressed in the courts. One problem was how
liberal a view the courts had toward air pollution regulations.
Several cases speak to that issue. In Penn Dixie Cement Corp.
v. City of Kingsport in 1949 the court found that public health

Historical Background l 7-5

 Notes is the responsibility of the government. To that end all reason-
able ordinances to protect public health have been sustained.

Legislators have wide discretion in determining what is a nui-

sance and also what is regulated under police power. The
courts do not interfere unless the law results in unnecessary
hardship. The courts can look behind the law to determine
whether the law is reasonable. In Moses v. United States the
court agreed that adapting regulations to meet specific condi-
tions is within the province of legislatures. The courts can
interfere only when regulation is not within police power and
only when private rights have been violated. This case raised
the issue of reasonableness. Any statute or ordinance must be
reasonable and must regulate something injurious to health,
safety, and welfare. “Reasonable” is a word subject to various
interpretations and this latitude of interpretation has generated
many cases. The following case review illustrates the courts’
general interpretation of “reasonable.”

What is reasonable depends on the circumstances. In the 1884

case of Harmon v. Chicago in the Illinois Supreme Court, the
defendant argued that it was unreasonable to require the bum-
ing of expensive, clean fuel, such as anthracite coal, in place of
locally available bituminous coal. “Not so,” said the court.
Although the holding in this case recognized that regulations
could be inconvenient or costly, the court’s place is not to
address such issues. Cities have the authority to regulate.

Other decisions have held the following messages:

l In 1851 it was stated that the inconvenience must be

real, not imaginary, and must interfere with ordinary
COmf0I-t.

l In 1937 the courts found that the loss of even one

night’s sleep is not a trivial matter (hdreae v. Selfiidge).

After the parameters of “reasonable” had been determined, courts

upheld regulations, as in the following examples:

l In Peopk v. Lewis (Michigan, 1891) it was found not

unreasonable to exempt certain classes (residences and
steamboats) from regulations.

1-6 l Course 325, Visible Emission Evaluation Procedures

 l In 1899 in the case of City of Brooklyn v. Nassau Elect Notes
RR a penalty of $100 for burning soft coal was collected
from Nassau Elect RR because of their violation of a
statute.

l Cincinnati v. Burkhardt (1908) upheld the use of a

color scale to measure smoke.

l In 1910 a Rochester, New York, statute upheld the use

of the RingeImann scale. This statute prohibited smoke
from 5 a.m. to 7:30 a.m., presumably to protect com-
muters, and allowed dense smoke for only 5 minutes in
every four-consecutive-hour period.

In the early 1900s legislatures and municipalities were still

wrestling with the problem of air pollution. In 1916 a much-
cited case-Northwestern Laundry v. Des Moines-was filed
in the U.S. District Court in Iowa. This case, against the city
smoke inspectors and the smoke abatement board, sought to
enjoin or block the enforcement of a Des Moines regulation
that declared dense smoke in portions of the city a public nui-
sance. The plaintiff claimed that the ordinance was void for the
following reasons:

l Due process was guaranteed under the 14th Amendment.

l The Ringelmann Chart was arbitrary.

l The standard required the remodeling of almost all the

plaintiffs furnaces.

l In the permitting requirements for new construction,

inspectors and abatement commissioners had discretion
to require and prescribe requirements.

The court dismissed the case, saying:

So far as the federal Constitution is concerned, we have

no doubt the state may by itself, or through authorized
municipalities, declare the emission of dense smoke in
cities or populous neighborhoods a nuisance and sub-
ject to restraint as such; and that the harshness of such
legislation, or its effect upon business interests, short of
a merely arbitrary enactment, are not valid constitution-

Historical Background l 1-7

 Notes al objections. Nor is there any valid federal constitu-
tional objection in the fact that the regulation may re-
quire the discontinuance of the use of property, or subject
the occupant to large expense in complying with the
terms of the law or ordinance.

This landmark decision has been cited as a precedent in numer-

ous cases. The courts consider the problem settled. For exam-
ple, in 1950 in the Board of Health of Weehawken Township,
Hudson County (NJ v. New York Central Railroad the court
referred to the Des Moines case and stated that there were no
constitutional restraints against the state’s regulating dense smoke
injurious to the common welfare.

Historic Events 1945 To 1970

1945: Air pollution control began in the city of Los Angeles.
In the same year, Los Angeles developed the equivalent opaci-
ty concept that extended smoke density measurements to white
smoke, allowing for control of a larger number of air pollution
sources.

1950: California passed California Rule 50A, which was based

on the Ringelmann system, to limit smoke. This rule eventual-
ly was copied by almost all states and found its way into feder-
al new source performance standards (NSPS) promulgated 20
years later.

1953: Los Angeles County started its smoke-school program

for black smoke. The program was the beginning of standard-
ization of visible emission observation programs nationwide.

1955: The federal government enacted the 1955 Air Pollution

Control Act, the frst of a series of air pollution control acts to
be passed by the federal government.

1963: Momentum increased with the passage by Congress of

the f%st Clean Air Act. Part of the Act provided grants to air
pollution control agencies.

1965: The Clean Air Act was amended to include Title 2,

Motor Vehicle Emissions Standards. This legislation recog-
nized that automobiles presented a pollution problem in many
areas of the country.

l-8 l Course 325, Visible Emission Evaluation Procedures

1967: The Federal Air Quality Act was passed, moving the Notes
responsibility for automobile emission controls to the federal
government. The Act also required states to establish Air Qual-
ity Regions and to adopt Ambient Air Quality Standards, a
precursor to the modem State Implementation Plans (SIPS).

1968: The federal government published AP-30, a joint indus-

try and government study of opacity, leading the way for strong
emphasis on opacity as a federal regulatory tool.

1970 (Earth Year): A new wave of environmental activity

swept the country. Intensive media attention heralded the in-
crease of public support for pollution control agencies and their
efforts to protect the public. The National Environmental Poli-
cy Act was passed on January 1, 1970. It signified a federal
commitment to use all practical means to promote the general
welfare and to attain harmony with the environment. A new set
of Clean Air Act Amendments also was established in 1970.

Creation Of EPA
EPA was created in 1970 out of federal agencies that included
the National Air Pollution Control Administration from the
Public Health Service, Water Pollution Control from the De-
partment of Agriculture, and Solid Waste and Radiation from
the Public Health Service. EPA was created to consolidate
environmental activities at the federal level and to support state
and local control and research efforts.

In 1971 EPA promulgated national ambient air quality stan-

dards for the following pollutants:

l Sulli.~ dioxide
l Nitrogen dioxide
. Particulate matter
l Photochemical oxidants
l Carbon monoxide

Selected Cases
The cases described below either set important precedents or
serve as examples of key legal principles.

Historical Background l 7-9

 Notes Ln 1973 EPA proposed a new Portland cement standard of IO-
percent opacity for emissions horn Portland cement plants. The
Portland Cement Association sued the EPA Administration on
the grounds that the accuracy of the opacity method was not
adequate to support the standard. EPA spent the next year
conducting field studies on the method. As a result of those
field studies, EPA:

l Raised the opacity limit for Portland cement plants horn

10 to 20 percent.

l Revised the data reduction scheme of Method 9 to

averaging.

l Established more specific observation and training

requirements.

These revisions resulted in the first modem version of Method

9. Since its promulgation, the method has undergone only one
minor change: it now requires a sketch that indicates the rela-
tive positions of the observer, the sun, and the source.

The concept of free and open fields was settled in the Western
Alfalfa case (1976). This case is important because it estab
lished the right of an inspector to go onto the property of a
company as long as the inspector stays in areas that are accessi-
ble to the public and does not cross a barrier or go through a
gate.

Inspectors who were denied entry to a plant in New York filed

a court case (known as the Dormer Hanna case) that ended in a
landmark decision. Its implications were serious. The source
was a coke oven battery being regulated under rules in the state
implementation plan (SIP), and both EPA and the state were
involved in the case. The source was being regulated under a
time aggregation rule patterned after California Rule 50A. Emis-
sions from the battery were timed with a stopwatch in accor-
dance with historical precedents in New York and Pennsylvania

Inspectors were denied entry by the source on the following

grounds:

. In the absence of a promulgated state measurement

method, the method of measurement must be Federal

l-10 l Course 325, Visible Emission Evaluation Procedures

 Reference Method 9 as found in the new source perfor- Notes
mance standards (NSPS).

l Because the inspectors intended to use a time aggrega-

tion technique rather than Method 9, they had no usable
method.

The court upheld the company position and denied entry to

EPA inspectors. This case focused attention on the differences
between Federal Reference Methods and SIP methods that were
used by states and EPA without being offCally promulgated
within the agencies.

Typical Regulation
A typical regulation might read as follows:

No source shall suffer or permit to emit into the

atmosphere an emission with an opacity equal to or
greater than 20percentfor 3 minutes in any I hour.

It is important to analyze the elements of the regulation to

ensure that the full meaning of the rule is understood.

No source shalI su#er or permit

The source cannot purposely or accidentally create an emission.

to emit into the atmosphere an emission

Emission into the atmosphere includes emissions into the air

inside a building if all the inside air is not captured by hoods or
ductwork and processed by control equipment. Thus, even
hgitive emissions from building leaks are included in emissions.

with an opacity equal to or greater than 20percent

The most common opacity standard is 20 percent (in other

words, the opacity reading must be less than 20 percent). Some
SIPS still have 40-percent regulations. Some of the NSPS are
down to 3 percent or less.

for 3 minutes in any I hour.

Historical Background l 7- 11
 Notes This is the time exemption allowing for startup, etc. Even if
the regulation is for 3 minutes. a &minute average is necessary
to prove a violation unless an alternative method is clearly
specific and has been through formal promulgation.

1-72 l Course 325, Visible Emission Evaluation Procedures

 I
Review Questions I
I I
I 1. In early U.S. and English case law, smoke was dealt with as a . I
I I
I 2. Who developed the first method used to quantity emissions according to the density I
I of the smoke?
I
I I
I 3. A 1949 court case determined that public health is the responsibility of . I
I I
4. In 1937 in Andreae v. Selfridge the courts found that the loss of even I
I was not a trivial matter. I
I I
5. In the landmark case, the court ruled that the state can declare the I
/ emission of black smoke a public nuisance. I
I I
I 6. In what year did the federal government pass the first Air Pollution Control Act? I
I I
I 7. What Act in what year first included automobile emission regulations? I
I I
I 8. In 1970 what federal agency was formed from the National Air Pollution Control I
I Administration from the Public Health Service, Water Pollution Control from the I
I Department of Agriculture, and Solid Waste and Radiation from the Public Health I
I Service? I
I I
I 9. The Donner Hanna case established the right of an inspector to enter the property of I
I a company as long as the inspector . I
I I
I 10. The Donner Hanna case focused attention on the differences between Federal I
I Reference Methods and . I
I I
I 11. Match the following: I
I I
I A) Ruling bodies 1) Until it has had its day in court and withstood the I
I challenge, it is not fully established. I
I I
I B) Common law 2) Pass statutes, laws, rules, regulations, etc. I
I I
I C) Statutory law 3) Body of court interpretations and rulings that I
I enhance, modify, and temper laws. I
I I
L -----------------A--e-B--------- J

Historical Background l 1-13

Lesson 2

Principles Of Visual
Emissions Measurement
Principles Of Visual Emissions
Measurement
This lesson defines basic concepts related to opacity and Notes
discusses the scientific principles associated with measuring
opacity and the practical application of those principles.

Ringelmann Method
As outlined in Lesson 1, the system of visible emissions evalu-
ation evolved from a concept developed by Maximillian
Ringelmann in the late 1800s. Ringelmann used a chart of
calibrated black grids on a white background to measure dark
or black smoke emissions from coal-fired boilers. The grids
ranged from approximately 20-percent ink coverage for a
Ringelmann #1 through loo-percent ink coverage, or solid black.
for a Ringelmann #5 (see Figure 2.1). The observer simply
compared the shade of the smoke with the shade of the card.

Figure 2-l. Ringelmann Chart

Principles of Visual Emissions Measurement l 2-3

 Notes
Equivalent Opacity
In the early 1950s. the Ringelmann concept was expanded to
include colors of smoke other than black by introducing “equiv-
alent opacity.” Equivalent opacity is the opacity equivalent to
the obscuring power of black smoke characterized by a specific
Ringelmann grid. Thus, a Ringelmann #I was equivalent to
20-percent opacity. The major difficulty in the equivalent opacity
system was not the scientific basis of the system but that opaci-
ty witnesses frequently could not explain to a court how white
was equivalent to black.

The federal government has discontinued using the Ringelmann

numbers in EPA Method 9 procedures for new source perfor-
mance standards (NSPS). Although current procedures are
based solely on opacity. some state regulations (notably Cah-
fornia’s) still specify the use of- the Ringelmann Chart to evaiu-
ate black and gray plumes. The general trend, however, is
toward reading all visible emissions in percent opacity.

Opacity And Transmission Of Light

Plume opacity is defined as one of the following:

l The degree to which light transmission through the di-

ameter of a plume is reduced.

l The degree to which the visibility of a background

viewed through the diameter of a plume is obscured.

When light strikes an object or substance, the light is either

reflected, absorbed. or transmitted. The amount of light that is
reflected and absorbed determines the opacity of the substance.
Simply put, in the observation of a pollutant plume, opacity is
the obscuring power of the plume.

In terms of physical optics, opacity is related to transmittance

(I/I,) through the plume. Percent opacity and percent
transmittance always total 100 percent. Percent opacity is defined
by the following equation:

2-4 l Course 325, Visible Emission Evaluation Procedures

 Percent opacity = (1 - I/I,) x 100 Notes

in which: I, = the incident light flux (the light that enters

the plume)
I = the light flux leaving the plume along the
same path

Many factors influence plume opacity readings: particle densi-

ty, particle refractive index, particle size distribution. particle
color, plume background, pathlength, distance and relative ele-
vation to stack exit, sun angle, and lighting conditions.

Light And Particles

The wavelengths of visible light in the electromagnetic spec-
trum range from 400 nanometers (nm) for blue light to 700 nm
for red light. Below 400 nm is the ultraviolet (UV) frequency,
and above 700 nm is the inf?ared (IR) frequency (see Figure
2.2). Human vision peaks in the middle of the visible range, at
550 nm, a yellowish-green color. This color is seen the best.
and not coincidentally, it is also the best background for light-
colored plumes.

400 nm 550 nm 700 nm

Blue Yellow Red
Green

Figure 2-2. Electromagnetic Spectrum

Opacity is a function of the interaction between light over this

visible spectrum and particles. This interaction is affected by
properties of both the particles and the light that include:

l Number and size of the particles

l Particle shape
. Particle color
l Index of refraction of the particles

Principles of Visual Emissions Measurement l 2-5

 Notes l Spectral characteristics of the light
l Light direction
l Amount of light

When light hits a particle, one of two things can happen: the
light can either be transmitted through the particle, or it can be
affected by the particle. Mechanisms by which the particles
affect light include absorption and scattering. Light scattering
mechanisms include reflection, refraction, Rayleigh scattering,
and Mie scattering. These mechanisms are affected in turn by
the particle and light properties defined above.

Transmission

The least likely but simplest interaction of a particle and light is

transmission, which involves light passing completely through
the particle in its initial direction. For light to be transmitted
through a particle, the light must hit the front and back surfaces
of the particle exactly perpendicular and the particle must be
clear. Even in the rare cases that meet these conditions, light
will be attenuated (weakened) as a consequence of absorption.

Absorption

If a particle has any color or is black, it will absorb a certain

amount of light as the light enters the particle. The energy of
the light is converted to heat in the particle. The energy simply
warms the particle, just as a black seat cover in a car is heated
by the summer sun. Black particles absorb all colors of light,
whereas colored particles absorb only specific wavelengths of
light.

Scattered Light

Scattered light is light diverted from its original path of trans-

mission. The two main light-scattering mechanisms for large
particles are reflection and refraction (see Figure 2-3). For
smaller particles, the main light-scattering mechanisms are
Rayleigh and Mie scattering. The observed opacity of colored
particles depends strongly on the light-scattering properties of
those particles, not on the absorption of light entering the parti-
cles.

2-6 l Course 325, Visible Emission Evaluation Procedures

 Notes

Reflection Refraction

Figure 2-3. Large-Particle Light-Scattering

Reflection

Reflection occurs when light “bounces off’ a surface rather

than passing through it. The surface color and texture of a
particle determine its reflective quality. A white particle re-
flects light more readily than does a black particle. Even a
black particle can reflect light if the surface is smooth, howev-
er. An everyday example of reflection from black materials is
the mirror effect of well-polished black marble.

Refraction

Simple refraction is the bending of light as it goes through a

transparent medium. Lenses, such as those used in eyeglasses,
work by refraction. When a light wave hits the curved surface
of a particle, the light wave turns toward the particle center.
Subsequently, the light leaves the particle along a different line
than that of its entrance.

Rayleigh Scattering

When particle size is significantly smaller than the wavelength

of light, the light is widely scattered (see Figure 2-4a). Rayleigh
scattering is important for extremely small particles because
they scatter much of the light away at large angles fi-om the
forward direction. Rayleigh scattering is responsible for the
typically blue color of the sky: blue light is scattered out horn
the light coming directly from the sun. Extremely small particles
create a bluish plume even if the individual particles are actually
colorless. Fine particles are often referred to as blue smoke in
the control-equipment industry.

Principles of Visual Emissions Measurement l 2-7

 Notes

‘\.-_
,^.
,L.l
One wavelength One wavelength
__-^‘;
-3 3
Destructive Constructive
interference interference

Figure 2-4. Small-Particle Light-Scattering: Rayleigh (a)

and Mie (b)

Mie Scattering

When particle size and the wavelength of light are approxi-

mately the same, Mie scattering occurs (see Figure 2-4b). Light
waves reflecting off the inside surfaces of a particle can either
add together constructively or subtract destructively as they
move from the separate locations within the particle. Light can
also be refracted Corn the edges of the particle and contribute to
the scattering interference patterns. Visible light scattering from
emission particles below 1 ,um falls within the Mie scattering
range.

Particle Size

Given that particles decrease light transmission by both scatter-

ing and direct absorption, particle size plays a significant role in
opacity. Particles with diameters approximately equal to the
wavelength of visible light (0.4 to 0.7 microns) have the great-
est scattering effect and cause the highest opacity. These parti-
cles, PM,0 particles, are in the respirable range.

Variables Influencing Opacity

Observations
The appearance of a plume as viewed by an observer depends
on a number of variables, some of which might be controllable

2-8 l Course 325, Visible Emission Evaluation Procedures

 and some of which might not be controllable in the field. Notes
Variables that might not be controllable in the field are lumi-
nous contrast and color contrast between the plume and the
background against which the plume is viewed. These vari-
ables influence the appearance of a plume as viewed by an
observer and can affect the ability of the observer to assign
accurate opacity values to the plume. Studies of the theory of
plume opacity and field studies have demonstrated that a plume
is most visible and presents the greatest apparent opacity when
it is viewed against a contrasting background.

Color contrast is the difference in color between two objects.

For instance, red and orange are different colors but the differ-
ence between them is not nearly as great as that between red
and blue. If the plume color is identical to the background
color, the visible emissions observer will have difftculty distin-
guishing between the plume and the background. One manu-
facturer reportedly used this principle to lower its apparent
opacity by painting its facility the same color as its particulate
emissions. This tactic deprived the observers of backgounds
of a contrasting color. To the degree possible, the observer
should maximize the color contrast between the plume and the
background to get the most accurate readings.

Luminous contrast is the difference in light emanating from

two objects, for example, a black plume against a light sky.
Two objects that have the same color can show up against each
other because of these differences in lighting levels. This effect
is important in the case of forward scatter, in which plumes
become more luminous than their background. Luminous con-
trast is vital to a color-blind observer. Also, luminous contrast
is the primary tool for observing a light-colored plume against a
light-colored sky.

When reading light-colored plumes, it is useful to have a pat-

terned background as a target. The degree to which the pattern
is obscured is another tool to assist in determining the opacity.
Patterned backgrounds can include trees, buildings, towers, pow-
er poles, mountains, or even other stacks at the source.

t
Selecting The Background

All the factors discussed above are important in selecting the

proper background for an opacity determination.

Principles of Visual Emissions Measurement l 2-9

 Notes For black smoke, a light-colored background is best and light-
blue sky is excellent (see Figure 2-5). Because the black smoke
does not scatter the light, it is not necessary or desirable to use a
textured or patterned background.

For white smoke, a dark-colored background with texture or a

pattern is best (see Figure 3-5). The observer is often faced
with only a blue sky background because of stack height. Gen-
erally, the deeper the blue, the more accurate the observations.

A black plume should be read against a light background.

A white plume should be read against a dark, textured

background.

Figure 2-5. Plume Background

During all observations, it is important that the observer look

through the smoke at the background and also at the back-
ground without the smoke. The observer should compare the

Z-70 l Course 325, Visible Emission Evaluation Procedures

background appearances under both conditions and not focus Notes
only on the appearance of the background through the emis-
sions. The observer should remember that the goal in deter-
mining opacity values is to judge how much the unobscured
background is changed by the emissions.

Mass Emissions/Opacity Relationship

Generally, denser plumes have more particles and, consequent-
ly, higher mass emissions. When Method 9 was promulgated.
the relationship between opacity and mass emissions was not
well developed. Today, opacity can be predicted if sufficient
information about the emissions is available. Factors that affect
the mass emissions/opacity relationship include:

. The number of particles

l The particle size distribution
l The pathlength through the plume
l The density of the particles
l The spectral characteristics of the light
l The index of refraction of the particle
l The opacity of the plume in terms of transmission

The relationship can be described by the following equation:

c _ K R W)
P
in which: C = mass concentration
K = particle size distribution
R = particle density
T = equivalenttransmittance
P = pathlength through the plume

As the pathlength through the plume increases, the opacity

increases because the number of particles between the source of
light and the detector or observer has increased.

The natural log, In, of the equivalent transmittance, which is

referred to as optical density, is also directly proportional to
particle concentration. All other factors being equal, opacity is
a diction of the number of particles in a specified size distribu-
tion per unit volume of gas. Particle density is used to convert
particle concentration to mass concentration.

Principles of Visual Emissions Measurement l 2- 17

 I I
I Review Questions I
I I
I 1. A Ringelmann #2 would have what percent ink coverage? I
I I
I 2. What was the major difficulty with the concept of equivalent opacity? I
I I
I 3. Define opacity. I
I I
I 4. In the following picture, what is the opacity of substance A? I
I I
I I
I I
I 1 I
I 5. Name four properties that affect opacity. I
I I
I 6. Match the foilowing.
I
A) Absorption
I
I
I B) Refraction
I
I
I c) Transmission
I
I
I D) Rayleigh scattering
I
I
I E) Reflection
I
I
I F) Mie scattering

i 7. The difference between the color of two objects is the . 1

I I
I The difference in the light emanating from two objects is the . 1
I I
I 8. An observer should (maximize/minimize) the luminous contrast and color 1
I contrast between plume and background. I
I I
I 9. An excellent background for black smoke is
I - I
An excellent background for white smoke is
I ’ I
I I
J
L ------------------A-------------

2-12 l Course 325, Visible Emission Evaluation Procedures

 _-m---s------- _----_------------

[ Review Questions ;
I
1 10. If one has sufficient information (such as number and size of particles, plume 1
I pathlength, etc.) one can predict . I
I I
I 11. If the pathlength increases, the opacity . I
I
i,-,-,,,,,,----------------------J

Principles of Vwal Emissions Measurement l 2-73

lesson 3

Sources Of Visible
Emissions
 Sources Of Visible
Emissions
A wide range of industries produce visible emissions. This Notes
lesson discusses the types of emissions and their causes, emis-
sion sources, emission components, plumes, and visible emis-
sions control equipment.

Emissions
Visible emissions come in many shades, but they are usually
categorized as either black or white (non-black) emissions. Black
particles absorb visible light; white, or non-black, particles scat-
ter visible light.

Black emissions are produced when solid fuels or residual oils

are burned under poor combustion conditions in an oxygen-
deficient environment. Unburned carbon particles cause a visi-
ble black plume, as do magnesium dioxide, hematite, and some
material-handling processes.

White (non-black) emissions are produced as a by-product of

combustion, either as the result of hydrocarbon vaporization,
excess combustion air, or loss of flame. Also, white emissions
occur as a result of a condensation reaction or as fine dust from
material handling.

Emission Sources
Visible emissions are introduced into the atmosphere by stacks,
vents, conveyor lines, and other non-point sources, such as
storage piles and unpaved roads.

stacks

Many sources send their emissions into the atmosphere

through smokestacks. A stack is a pipe or funnel through
which smoke and gases are discharged. Stacks vary in

Sources of Visible Emissions l 3-3

 Notes height and diameter; the opacity of the plume can be influ-
enced by these characteristics.

Tall stacks influence readings by increasing the sun/slant angle

and by eliminating the possibility of a high-contrast background.
When a white plume is observed. a contrasting background,
such as trees or a hillside. is desirable. Sometimes, however,
the sky is the only background for a tall stack. If the sky is
overcast, this can cause a negative bias of readings. especially
with light-colored plumes.

Wide stacks or large-diameter stacks can cause a higher-than-

expected opacity ratio because of the increased pathlength
through the plume.

Emissions Ii-om non-circular stacks, including oval, rectangu-

lar, and square stacks, should be read across the narrowest axis
of the plume. The observer should pre-select the time of day
and pay close attention to wind conditions at the time of the
observation, because these factors can severely limit the ob-
server’s ability to read the stacks correctly from the best posi-
tion.

Readings of emissions exhausted horizontally are strongly limited

by wind direction. which could cause difficulty in making accurate
readings. For example. an emission port facing west would be
unreadable with a west wind, and the plume could be sheared off
by either a north or south wind. Sun angle also might be difficult
to reconcile, depending on the direction of the emission port and
on the visual interference presented by the stack itself. The ob-
server should ascertain the appropriate meteorological conditions,
as well as the proper time of day for acceptable sun angle, before
performing visible emissions observations.

Fugitive Emissions

Fugitive emissions come from non-specific point or area sourc-

es that include:

l Roof monitors
l Unpaved roads
l Gaps in duct work
l Doors
l Storage piles
l Conveyors

3-4 l Course 325, Visible Emission Evaluation Procedures

 Notes
Particles that comprise fugitive emissions are often larger than
those found in a stack gas stream and, therefore. tend to settle
out of the cloud more rapidly.

Studies have shown, however, that fugitive dust plumes also

have a signifxant PM-10 dust-particle component. Fugitive emis-
sions are caused by many mechanical processes, such as:

l Crushing
l Drilling
l Sanding
l Vehicle movement
l Grinding
l Sweeping
l Demolishing
l Material handling

Visible Emission Components

Visible emissions contain a variety of particles in sizes ranging
from 0.1 micrometer (pm) to 200 vm. Particles are categorized
aS:

l Smoke
l soot

Fly ash
l

Dust
l

l Fumes
l Mist
9 Gas
l Condensed vapor

Smoke is a visible effluent resulting from incomplete combus-

tion. Smoke consists mostly of soot, fly ash, and other solid or
liquid particles.

Soot consists principally of carbon particles that contain at-

tached or absorbed tars and other hydrocarbons. Soot is formed
by the incomplete combustion of carbonaceous material and is
the principal cause of the blackness of a smoke plume. Soot
particles are generally quite fine (lpm or less).

Sources of Visible Emissions l 3-5

,_. .- - .- _ ._ .” _... ., - ,.. _

 Notes Fly ash, which is unburned material from fuel combustion,
consists of particles small enough to remain suspended in the
air. A pure fly ash plume is light-brown or cream colored. If a
system achieves nearly complete combustion, fly ash is prima-
rily inorganic material. The quantity of inorganic fly ash emit-
ted depends on the fLel’s ash content. Distillate fuels do not
contain appreciable amounts of ash. Residual oils can have an
ash content of up to 0.3 percent by weight. but the ash content
for oil grades 4 and 5 cannot exceed 0.1 percent.

Dust consists of solid particles. generally greater than 1 pm in

diameter, released into the air by processes such as drilling,
crushing, and grinding. Because these particles are larger than
smoke or fume particles, they tend to settle to the ground more
quickly.

Fumes consist of metal or metal oxide particles less than 1 pm

in diameter. These minute particles are created when vapors
generated by high-temperature metallurgical processes condense.
Fumes are common in metallurgical industries such as steel
and aluminum production.

Mist consists of liquid droplets. A pollutant could be the pri-

mary material that forms the droplet, or it could be suspended
or dissolved in droplets of a different material. Typical droplets
have diameters of about 10 pm and range Corn 2 to 200 pm in
diameter. It can be difficult to distinguish pollutant-containing
mists from innocuous water droplets that are generated from
steam condensation.

Gas is a fluid, like air, that has neither specific shape nor vol-
ume but tends to expand indefinitely. Two visible pollutant
gases are nitrogen dioxide (NO?). which is brown to yellow,
and chlorine, which is greenish yellow.

Vapor is the gaseous phase of a substance that. at normal tem-

perature and pressure. is a liquid or solid, such as vapor from
gasoline. Most vapors have no color, but they can ref?act light.
In doing so, they alter the image of a background pattern.

3-6 l Course 325, Visible Emission Evaluation Procedures

 Notes
Condensing And Reacting Plumes
Plumes that form in the atmosphere are generally called con-
densing plumes. The visible material in a condensing plume
could be particles or droplets generated either by homogeneous
condensation of gases or as products of chemical reactions. In
some cases, both mechanisms are involved.

Condensing Steam Plumes

The classic condensing plume is the steam plume. Sources of
water that can cause steam plumes include:
Drying operations that remove water by evaporation
l

from foods, chemicals, detergents, paper, pharmaceuti-

cals, ores, etc.

. Combustion of hydrogen or hydrocarbon tiels, particu-

larly natural gas. If wet organic material is burned,
water vapor is generated by both evaporation and com-
bustion reactions.

l Air pollution control devices that use water to suppress

dust generation or to remove gases or particles from the
gas stream (e.g., spray chambers, spray towers, venturi
scrubbers).

l Evaporation of water to remove combustion or chemical-

reaction heat from a process (e.g., forced- and natural-
draft cooling towers, operations for cooling hot gases to
protect pollution control equipment, removal of the heat
generated in the thermal process of producing phosphoric
acid).

l Thermal processes that break down and release chemi-

cally bonded water, such as cement production.

Reacting Plumes
Some gases can be mixed under dry conditions without react-
ing with one another, but when these same gases are mixed
with water droplets, they react and generate a reaction product
that dissolves in the droplet. When the water evaporates, the
reaction product remains as a solid particle. For example. when

Sources of Visible Emissions l 3-7

 Notes sulfur oxides. ammonia gases. and water vapor mix in the same
gas stream,the suifkr dioxide and ammonia react on the surface
of the water droplets and an aqueous solution with dissolved
ammonium sulfate is generated. The water evaporates back
into the atmosphere. leaving an ammonium bisulfate particle.
This reaction can occur in kilns at cement plants and brick-
manufacturing plants.

Control Equipment
The basic control devices for particulate emissions are classi-
fied as:

l Mechanical collectors
l Wet scrubbers
l Fabric filters
l Electrostatic precipitators
l Afterburners

Mechanical Collectors

Settling chambers and cyclones are mechanical particulate-matter

collectors. In settling chambers, the gas stream is slowed down
through a chamber so that particles can settle out. Although
their design is simple, collection chambers require large spaces
and have low collection efficiencies for small particles. A
cyclone separates the particulate matter from the gas stream via
inertial force. The gas stream containing the particles is forced
in a circular path. The denser particles migrate to the outside
walls and then slide down the walls into a collection bin. Wa-
ter is used on the walls of some cyclones to wet down the
particles and help them slide to the bottom. Neither settling
chambers nor cyclones efficiently collect the smaller particles
responsible for most visible plumes.

A more efficient version of the cyclone is the centrifugal wash-

er or scrubber. In the centrifugal scrubber. the particle-laden
air stream is impinged on a stream of water droplets, which trap
the particles. The water droplets containing the particles are
then denser and larger than the particles and can be more easily
collected by cyclonic action. Because the centrifugal scrubber
adds moisture to the air stream, there is often a condensing
plume of water droplets (steam plume) at or beyond the lip of
the stack.

3-8 l Course 325, Visible Emission Evaluation Procedures