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Exploring Alternative Opacity Measurement Methods to EPA Method 9 for Air Quality Compliance

This document discusses the limitations of EPA Method 9, an essential tool in air quality compliance that assesses opacity for pollutants. Frequent retraining requirements, reliance on human observation, and lack of robust post-observation data are significant drawbacks. Promising alternatives like digital camera-based measurement methods are explored, which offer easier training, better data, and potential cost savings. The discussion highlights partnerships with various agencies, including EPA and DOD, to develop a more efficient opacity measurement system that could enhance compliance and air quality standards.

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Exploring Alternative Opacity Measurement Methods to EPA Method 9 for Air Quality Compliance

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  1. Developing an Alternative to EPA Method 9 Bill Gillespie Virginia Department of Environmental Quality Northern Regional Office William.Gillespie@deq.virginia.gov (703) 583-3828 December 7, 2010

  2. The Current Method: EPA Method 9 • It has been a very important air compliance tool. • The method has reduced opacity, reduced PM, and improved air quality. • It has been tested in the courts and is a “tried and true” method. • Method 9 is incorporated in many rules. • States want Method 9 to remain in place as a tool in the air compliance “tool box.”

  3. Some Limitations/Problems with Method 9 • Requires frequent training (field certifications every 6 months) • Relies on the human eye as its sensor. • Does not provide good post-observation data/evidence. • Younger and tech-savvy staff are disappointed we still rely on a visual method….

  4. Compliance Inspectors Calibrating their Eyes… Photograph courtesy of Eastern Technical Associates, Inc.

  5. Some New Opacity Measurement Methods Hold Promise • Digital camera-based methods • Benefits: • Very similar to Method 9 (easily learned) • Uses a camera as its sensor (not the human eye) • Provides good post observation data for analysis and review • Provides better evidence (a picture is worth…) • Does not require re-certification training every 6 months • Is an ASTM standard

  6. Some New Opacity Measurement Techniques Hold Promise • Digital camera-based methods • Disadvantages: • Some states have been unable to run commercially available DOCS II software • Software is poorly supported • Software doesn’t provide enough user controls or raw data for user evaluation • ASTM method cannot be used on stacks >7 feet in inside diameter • Not a formal EPA Method • Bottom line: DOCS method is not fully developed

  7. Potential Cost Savings of an Alternate Method • Virginia spends about $9,000 per year certifying inspectors to perform Method 9 • The annual cost of certifying inspectors from state and local agencies nationwide is being estimated • The Department of Defense estimated large savings ($15.3 million annually!) if DOD could adopt a system like DOCS • There are potential savings for stack testers and the regulated community

  8. Some Potential Partners in Developing an Alternative Method • EPA • State and local agencies • DOD • Source Evaluation Society • NASA • Others?

  9. Let’s stop doing this… Photograph courtesy of Eastern Technical Associates, Inc.

  10. …and start doing computer analysis at our desks…. Photograph courtesy of Eastern Technical Associates, Inc.

  11. References • EPA Method 9 http://www.epa.gov/ttn/emc/promgate.html • Digital Opacity Compliance System (DOCS) http://www.serdp.org/ (Search for: “An Alternative to EPA Method 9”) • DOCS II by Virtual Technology LLC http://www.virtuallc.com/virtuallc/index.asp • ASTM’s Digital Camera Opacity Technique (DCOT) http://www.astm.org/Standards/D7520.htm

  12. Disclaimer • The views expressed in this presentation do not reflect the official views, policy or position of the Commonwealth of Virginia.

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