An Alternative to EPA Method 9 - Field Validation of a Digital Recording and Analysis System for Opacity Compliance Measurements (SI-0119)   


Purpose:

All Department of Defense (DoD) installations/facilities located in the United States are subject to Title V of the 1990 Clean Air Act. While a variety of sources are covered under Title V, the most common include those that produce visible emissions. Each state has local regulatory agencies, usually specified in the Title V operating permit, which set criteria limiting the amount of visual opacity allowed from each source. While some large sources may be equipped with instruments to determine source opacity (e.g. a transmissometer located in a smokestack), these instruments are costly to acquire and maintain. They also require an alternative method to determine opacity be in place in the case of instrument failure. For the overwhelming majority of sites, the primary method of determining compliance with regulations is the Title V, Method 9, Visual Observation of Emissions. Method 9 relies on trained observers to determine compliance by visually estimating the opacity once every 15 seconds for a specified period of time and then averaging those estimates to determine a single reading that is then compared to permitted levels. This project will provide a cost-effective, objective, forensically reproducible, legally defensible alternative to EPA Method 9.

Description:

A digital recording and analysis system for opacity compliance measurements will be demonstrated and validated as an alternative to the current visual opacity measurement procedure. This system uses a commercial-off-the-shelf digital camera to capture images of a smoke plume. These images are then downloaded to a standard personal computer where they are analyzed to determine opacity. The system produces accurate opacity readings and provides a permanent digital record of the image for future reference. The focus of this project will be to produce a measurement data set that spans a wide range of climatic conditions and source types. The EPA Emissions Measurements Center (EMC) in Research Triangle Park, NC has been contacted to ensure that the data set will be structured to meet their specifications. The data acquisition and analysis plan will be closely coordinated with the EMC to ensure data integrity and sufficiency in order to facilitate certification of the method.

Benefit

All federal, public, and private industrial facilities are subject to Title V compliance regulations for opacity. With the exception of a relatively small number of stacks where the expense of fixed in-stack monitoring is justified, opacity compliance measurements are obtained using Method 9. Within the DoD, there are currently 385 active military installations in the United States requiring opacity measurements. This project will decrease the cost of opacity measurements and provide a forensically reliable, reproducible data source.
(Anticipated Project Completion - 2006)

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Program Manager, Sustainable Infrastructure
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Arlington, VA 22203
Telephone: (703) 696-2125
Fax: (703) 696-2114
E-mail: SI@estcp.org

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