EPA Method 22: Visual Determination of Fugitive Emissions from Material Sources and Smoke Emissions from Flares

Please note: The image above was obtained from www.donnan.com via an internet search.

Purpose

This is a step by step guide for conducting EPA’s Method 22 “Visual Determination of Fugitive Emissions from Material Sources and Smoke Emissions from Flares.” Many industries are subject to federal and state fugitive dust regulations, and are clearly noted in regulations regarding industries with material transfers such as combustion ash conveyor systems or coal processing plants. Industries that flare gases, such as landfills, are subject to flare smoke regulations. Federal opacity limits are included in the Code of Federal Regulations, Title 40, Chapter 1 part 60, 61, and 62 (40 CFR Part 60, http://www.ecfr.gov/cgi-bin/text-idx?tpl=/ecfrbrowse/Title40/40cfr60_main_02.tpl), and state opacity limits can be found in that state’s administrative codes for air pollution or in their state implementation plan (SIP), available on the relevant EPA region’s website.

Fugitive dust and flare smoke regulations utilize Method 22 for assessments. Through this method, viewers position themselves such that they have an unobstructed view of the flare or point of potential fugitive emission, and assess whether or not there are visible emissions. If there are, the viewer uses a pair of watches to determine the percentage of time visible emissions were present during the observation period. There is no certification required to conduct Method 22, but it is highly recommended that viewers complete the lecture portion of a Smoke School class (such as https://www.aeromet.org/, http://www.eta-is-opacity.com/, or https://www.compliance-assurance.com/index.php). Note that this method can be used for indoor fugitive emissions as well as outdoor, as long as the indoor light source is recorded. The Activity posted here assumes outdoor fugitive emissions observations.

Materials

To conduct this method, you will need:

1. Your eyes. Make note if you wear glasses (and whether or not you wear them during the observations), if you use binoculars, or if you wear sunglasses during the observation (which is not advised since it diminishes contrast between smoke and background colors).

2. Two stop watches. Each should have incremental divisions of 0.5 seconds or less.

3. A Method 22 reporting sheet, which can be downloaded from most state DEQ offices, and is included on page 47 of the Visual Emissions Field Manual (https://www3.epa.gov/ttn/emc/methods/VEFieldManual.pdf).

In order to adequately document the observation scenario, you will also need to estimate the wind direction, wind speed, and distance to the fugitive emission or flare. This should be possible by referencing a local weather station and a map.

Methods

Please refer to the EPA’s Visible Emissions Field Manual for more information, and Apendix B for Method 22 specifically: https://www3.epa.gov/ttn/emc/methods/VEFieldManual.pdf.

Locate the emissions

1. Determine the location of likely fugitive emissions or flares.

2. Find a location from which to view the emissions where you are not looking into the sun; preferably the sun would be in a 140-degree range behind you.

3. Select a viewing location that is between 15 ft and 0.25 miles from the emission point.

4. Ensure that your view of the emissions is unobstructed.

Observe

1. Record the necessary information on your Method 22 reporting sheet, including the:

   • 1. company name
   • 1. site location
   • 1. company representative (if known)
   • 1. Industry
   • 1. processing unit (if applicable)
   • 1. your name (observer)
   • 1. your affiliation (if applicable)
   • 1. date
   • 1. wind speed (estimate; could be obtained from local weather station)
   • 1. wind direction (estimate; could be obtained from local weather station)
   • 1. sky conditions (e.g. scattered clouds)
   • 1. precipitation (e.g. if raining)

2. Sketch your observation scheme in, demonstrating your location, the location of the emissions, and the position of the sun.

3. Identify the appropriate observation period. Many states’ fugitive emissions rules allow visible fugitive emissions for up to 6 minutes of 1 hour. Thus, your total observation time may be one hour, but could be terminated after 6 minutes if visible emissions occurred during that entire period. If you select a one-hour observation period, you must take breaks every 15 or 20 minutes in order to rest your eyes. Each break should last 5-10 minutes.

4. Designate the purpose for each stopwatch: one will be used to record total observation time, and one will be used to record visible emissions time.

5. Set both stopwatches to 00:00. Record these zero values on the first line of your observations section in the Method 22 report form.

6. Start your observation-time stopwatch.

7. Record the clock time (e.g. 9:18 am).

8. When you observe visible emissions or smoke in a flare, start your second stopwatch, which you had designated as the emissions-time stopwatch.

9. When the visible emissions cease, stop your emissions-time stopwatch. Note the accumulated time on the recording sheet.

10. When visible emissions occur again, start the emissions-time stopwatch again.

11. Repeat stopping and starting the emissions-time stopwatch as appropriate for when you see visible emissions. Record each start and stop time (accumulated) on the recording sheet.

12. After 15-20 minutes, you must take a break to rest your eyes. When you do this, stop both stopwatches and record the accumulated time on each.

13. Rest for 5-10 minutes.

14. To resume your observation period, note the clock time (e.g. 9:44 am) and the accumulated times on each stopwatch. Start the observations-time stopwatch again.

15. If your view of the emissions point becomes obstructed at any time, stop both stopwatches and record the incident on your recording sheet.16. If your view of the emissions point becomes obstructed at any time, stop both stopwatches and record the incident on your recording sheet.

16. Continue to record observation-time and visible-emissions time stopwatch information, taking breaks every 15-20 minutes, until your total observation period (e.g. 60 minutes) has elapsed.

17. At the end of your observation period, record the total observations-time accumulated, the total emissions-time accumulated, and the clock time.

Calculate Visible Emissions Time

1. To determine the number of minutes in which visible emissions were present during your observation period, simply identify the final emissions-time stopwatch accumulated time.

2. To determine the percentage of time during the observation period that visible emissions were present:

   • 1. Convert the accumulated observation time from minutes into seconds. To do this, multiply the minutes by 60, and add any remaining seconds. For example, if your observation time was 38 minutes 40.6 seconds (38:40.6), then your observation time would be (38x60)+40.6 = 2320.6 seconds.
   • 1. Convert the accumulated emissions-time from minutes into seconds. To do this, multiply the minutes by 60, and add any remaining seconds. For example, if your emissions time was 6 minutes 13.2 seconds (06:13.2), then your observation time would be (6x60)+13.2 = 373.2 seconds.
   • 1. Divide the emissions-time seconds by the observation-time seconds. Using the example numbers above, divide 373.2 by 2320.6 to reveal: 373.2/2320.6 = 0.1608.
   • 1. To report the time fraction, simply report the decimal value from step C. To report the percentage time visible emissions were present, multiply the decimal value from step C by 100 (e.g. 0.1608 x 100 = 16.08%).

Report Results

The exact process for reporting your Visual Determination of Fugitive Emissions monitoring results varies from state to state. It is highly recommended to contact your state environmental agency (e.g. your state DEQ or DNR) to discuss their preferred reporting process from community members, as information on their websites is often catered to industries who must conduct these tests to demonstrate compliance.

Generally, required documents that must be submitted to the appropriate division within your state environmental agency (usually termed the Division of Air Quality or something similar) include:

1. the Method 22 reporting form

2. Possibly documentation demonstrating your familiarity with visual emissions monitoring theory (e.g. record of completion for a Smoke School lecture course)

3. Possibly information regarding the company’s permit number

Be prepared to explain and defend your observations, including your estimated distance and whether or not fugitive emissions arose from the point at which you claim rather than other windblown disturbances. Pictures can be very useful to demonstrate your location and add credence to your estimates and source identification.

Resources

Please refer to the EPA’s Visible Emissions Field Manual for more information regarding Methods 9 and 22: https://www3.epa.gov/ttn/emc/methods/VEFieldManual.pdf

A useful summary of fugitive dust control by the Michigan DEQ can be found at: http://www.michigan.gov/documents/deq/deq-ead-caap-genpub-FugDustMan_313656_7.pdf

Further information about particulate matter and visible emissions on Public Lab’s website can be found at: https://publiclab.org/wiki/visual-pm