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Field methods • practical comparison

Method 9 vs. Method 22:
different measurements.

Method 9 estimates how much a plume obscures the background. Method 22 records how long visible emissions occur. Your rule or permit determines which measurement you need.

Compare the methods
Side by side

Compare the required procedures.

Comparison of EPA Method 9 and Method 22
QuestionMethod 9Method 22
What is measured?Visual opacity of emissions.Duration of visible emissions; frequency can be calculated from emission time.
How is it observed?Momentary opacity readings at specified intervals.Continuous observation, timing the period and the emissions.
Typical recordOpacity values, observation times, source and field conditions.Observation period, accumulated emission time, source and field conditions.
Observer qualificationRequires a qualified Method 9 observer.Method 9 certification is not required; the observer still needs training in visible-emission detection.
Typical applicationOpacity determinations from stationary sources under applicable standards.Fugitive emissions, and visible smoke from flares, where the applicable regulation calls for it.
Can one replace the other?Only when the applicable authority allows it.Only when the applicable authority allows it.

Based on EPA Method 9 and EPA Method 22. Check the applicable standard for the required method, observation duration, and reporting criteria.

Understanding the results

What does a 20% result mean?

Illustrative Method 9 reading
20% opacity

An observer assigns a 20% opacity reading at an observation moment. It describes how much the plume obscures the background. Emission duration is a separate measurement.

Illustrative Method 22 calculation
20% of the time

If visible emissions occur for 120 seconds during a 600-second observation period, the frequency is 120 ÷ 600 × 100 = 20%. This does not mean the plume has 20% opacity.

These are explanatory examples, not compliance determinations or prescribed observation periods.

Before you start

Check your rule or permit.

  1. Identify the source and rule. Find the method named in the applicable regulation, permit, or monitoring plan.
  2. Confirm the procedure. Check duration, conditions, recordkeeping, and how the result is evaluated.
  3. Prepare the observer. Arrange Method 9 qualification when needed, or the detection training required for Method 22.

Both methods depend on a suitable view of the emissions. Lighting, background, observer position, and condensed water vapor can affect what is visible.

Common questions.

Is Method 22 just a yes-or-no check?

No. It tracks emission time during continuous observation. Depending on the applicable requirement, the record may be used to calculate emission frequency.

Do I need smoke school for Method 22?

Method 22 does not require Method 9 certification. It does require an observer trained in detecting visible emissions and the conditions that influence detection.

Can I use Method 22 for an opacity limit?

Method 22 does not measure opacity. Use the method specified by your applicable requirement or an authorized alternative.

Need a Method 9 qualification pathway?

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