An Alternative to EPA Method 9: Field Validation of a Digital Opacity Compliance System (DOCS)
Abstract
For most Department of Defense (DoD) installations, the prime method of determining compliance with air regulations (and usually the primary backup for in-stack instruments) relies on trained observers to visually estimate the opacity of a plume every 15 seconds for a specified period, then average those estimates to determine a single reading that is compared to permitted levels. This is known as Environmental Protection Agency (EPA) reference Method #9 (40 Code of Federal Regulations [CFR] 60, Appendix A, Method #9). [11] The sampling period may be as short as 6 minutes or as long as 1 hour. To qualify as a visual observer, an individual must attend a smoke school every 6 months. A smoke school consists of both classroom and field training, with a series of visual observations of a calibrated smoke source, constituting the qualification examination. That examination requires that the observer estimate the opacity of 25 white and 25 black smoke plumes within 15% accuracy for an individual observation and be within 7.5% overall. Sample opacity ranges from 0 to 100% in 5% increments. While Method #9 has an extensive history of use, it is both subjective and expensive in terms of dedicated work force. In addition to the cost of the school (approximately $350 per student and per diem/travel as needed), the 5 days of missed work add up significantly when multiplied by the number of students for example, 35 at Hill Air Force Base (AFB), 25 at Elmendorf AFB and the twice-yearly training requirement. The objective of the demonstration was to field a digital opacity compliance system (DOCS) to be usable as an alternative to certified EPA Method #9 observers. To accomplish this, a digital recording and analysis system for opacity compliance measurements was demonstrated and validated as an alternative to the current opacity measurement procedure (40 CFR 60, Appendix A, Method #9).
Document Details
- Document Type
- Technical Report
- Publication Date
- Nov 01, 2004
- Accession Number
- ADA603745
Entities
People
- Daniel A. Stone
- John C. Bosch Jr.
- Michael J. Calidonna
- Michael J. Mcfarland
- Paul E. Kerch
- Tomas J. Logan
Organizations
- Environmental Security Technology Certification Program