Fugitive emissions and flare observations
Method 22 answers a simpler question than Method 9: are visible emissions present, and for how long? Learn what the method requires, how it compares with Method 9, and how to train your observers.
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Method 22 is the method behind "no visible emissions" limits. It is simpler than Method 9, but it still has rules on distance, lighting and timing.
EPA Method 22, Visual Determination of Fugitive Emissions from Material Sources and Smoke Emissions from Flares, determines whether visible emissions are present. The observer records how long emissions are seen during the observation period instead of assigning an opacity percentage.
Method 22 is common for fugitive emissions from material handling, storage piles, roads, conveyors and building openings, and for smoke from flares. Flare rules, for example, can limit visible emissions to a set number of minutes in a two-hour period.
The observer uses two timers: one for the full observation period and one that runs only while emissions are visible. Position, lighting and background are recorded, and long observations include regular rest breaks to keep the reading reliable.
Method 22 does not use the smoke-generator qualification test that Method 9 does. Observers still need training on the general procedures for determining the presence of visible emissions, equivalent to the classroom portion of Method 9 training.
Method 22 observations are made from 15 feet to 0.25 mile from the source. The sun does not have to be at your back. For indoor observations or other light sources, the light must be documented and at least 100 lux. Because the observer watches continuously, a rest break is taken every 15 to 20 minutes.
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Method 9 measures how opaque a plume is, in 5% increments, and requires a certified observer. Method 22 only records whether emissions are visible and for how long. It requires training, but not the six-month smoke-generator certification.
No. Method 22 requires training in the general procedures for observing visible emissions, equivalent to the classroom part of Method 9 training. Many facilities train the same observers in both methods.
Yes. Opaque trains observers in EPA Methods 9, 22 and 203, at public classes and at private onsite schools.
Your air permit or the applicable regulation names the test method. Check with your environmental professional or regulator if you are unsure.
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