Life cycle cost evaluation of the digital opacity compliance system

The US Environmental Protection Agency (EPA) has established EPA Reference Method 9 (Method 9) as the preferred enforcement approach for verifying compliance with federal visible opacity standards. While Method 9 has an extensive history of successful employment, reliance on human observers to quantify visible emissions is inherently subjective, a characteristic that exposes Method 9 results to claims of inaccuracy, bias and, in some cases, outright fraud.The Digital Opacity Compliance System (DOCS), which employs commercial-off-the-shelf digital photography coupled with simple computer processing, is a new approach for quantifying visible opacity. The DOCS technology has been previously demonstrated to meet and, in many cases, surpass the Method 9 accuracy and reliability standards (McFarland et al., 2006). Beyond its performance relative to Method 9, DOCS provides a permanent visual record of opacity, a vital feature in legal compliance challenges.In recent DOCS field testing, the opacity analysis of two hundred and forty one (241) regulated air emissions from the following industrial processes: 1) industrial scrubbers, 2) emergency generators, 3) asphalt paving, 4) steel production and 5) incineration indicated that Method 9 and DOCS were statistically equivalent at the 99% confidence level. However, a life cycle cost analysis demonstrated that implementation of DOCS could potentially save a facility $15,732 per trained opacity observer compared to utilization of Method 9.     

Assessment of manure phosphorus export through turfgrass sod production in Erath County, Texas

A best management practice (BMP) for exporting manure phosphorus (P) in turfgrass sod from the North Bosque River (NBR) watershed in central Texas was assessed using a geographic information system (GIS). The NBR watershed has a mandate to reduce the total annual P load to the NBR by 50% as a result of total maximum daily load regulation. Since dairy waste applications to fields are identified as the major nonpoint source of P to the river, innovative BMPs, such as export of manure P in turfgrass, will be needed to achieve the 50% reduction. However, methods are needed to evaluate the feasibility of these innovative management practices prior to their implementation. A geospatial database of suitable turfgrass production sites was developed for Erath County using GIS. Erath County largely encompasses the upper portion of the NBR watershed. Information from field experiments, production practices, and ground-truthing was used to search, analyze, and verify a geospatial database developed from national and regional sources. The integration and analyses of large databases supports the search by turf producers for sites suitable for turfgrass sod production in Erath County. In addition, GIS enables researchers and regulators to estimate manure P exports and reduced P loading due to implementation of the manure export BMP on a county scale. Under optimal conditions 198,000 kg manure P yr(-1) could be used and 114,840 kg manure P yr(-1) exported from the NBR watershed through implementation of a system using dairy manure to produce turfgrass sod. This is the equivalent of the manure P applied from 10,032 dairy cows yr(-1) and exported from 5808 dairy cows yr(-1). Application of GIS to large-scale planning and decision-making transcends traditional field-scale applications in precision agriculture.     

ESTIMATION OF SOIL MOISTURE WITH API ALGORITHMS AND MICROWAVE EMISSION1

Large area soil moisture estimations are required to describe input to cloud prediction models, rainfall distribution models, and global crop yield models. Satellite mounted microwave sensor systems that as yet can only detect moisture at the surface have been suggested as a means of acquiring large area estimates. Relations previously discovered between microwave emission at the 1.55 cm wavelength and surface moisture as represented by an antecedent precipitation index were used to provide a pseudo infiltration estimation. Infiltration estimates based on surface wetness on a daily basis were then used to calculate the soil moisture in the surface 0–23 cm of the soil by use of a modified antecedent precipitation index. Reasonably good results were obtained (R²= 0.7162) when predicted soil moisture for the surface 23 cm was compared to measured moisture. Where the technique was modified to use only an estimate of surface moisture each three days an R² value of 0.7116 resulted for the same data set. Correlations between predicted and actual soil moisture fall off rapidly for repeat observations more than three days apart. The algorithms developed in this study may be used over relatively flat agricultural lands to provide improved estimates of soil moisture to a depth greater than the depth of penetration for the sensor.     

Fugitive emissions opacity determination using the digital opacity compliance system (DOCS)

Maintenance of Department of Defense (DoD) weapon systems, conducting battlefield training exercises as well as meeting military construction and/or demolition schedules, invariably generate fugitive air emissions, many of which are visible. Although there is no codified federal method for quantifying fugitive emissions opacity, many state and local air regulatory agencies have instituted enforceable fugitive emission opacity standards at DoD facilities. The current study focused on comparing the performance of the digital opacity compliance system (DOCS) with U.S. Environment Protection Agency Method 9 (Method 9) certified human observers in quantifying the visible opacity associated with fugitive emissions produced using a commercial fog generator. By systematically repositioning both DOCS cameras and Method 9-certified observers during field testing, differences in method performance as a function of observational locations were documented. At both the 30- and 300-ft off-set distances, opacity levels reported by the DOCS technology and Method 9-certified smoke readers were found to be statistically different at the 99% confidence level. Alternatively, at the 90- and 150-ft off-set distances, results suggested that there was an insignificant difference at the 99% confidence level between the two methods. Comparing the magnitude of the each method's standard deviation suggested that, at the 30-ft off-set distance, the DOCS technology was consistently more precise than Method 9-certified readers regardless of the observer's downwind distance. However, at the 90, 150, and 300-ft off-set distances, method precision seemed to vary as a function of both off-set and downwind distance. The primary factor affecting the consistency in opacity measurements appeared to be the impact of ground-level air turbulence on fog plume dispersion and transport. Field observations demonstrated that localized wind shear played a critical and decisive role in how and to what extent fugitive emissions opacity could be determined, regardless of the method selected.     

Forecasting COH Levels at Six Outlying Sampling Stations in Allegheny County Using Statistical Correlations Derived from the Downtown Station

Verification of forecasts of COH levels at the Downtown Sampling Station using our objective forecast method developed in conjunction with the Allegheny County Bureau of Air Pollution Control gave excellent results. The next step was to expand the area of forecast coverage.

COH data taken from July 1968 through June 1969 from six sampling stations located roughly in a large concentric arc around the Downtown Station were studied. Three of the stations are located in river valleys near large industrial plants and the other three are located on higher terrain in suburban areas.

COH levels of Low, Moderate, High, and Very High (where Low = 0–0.9, Moderate = 1.0–1.9, High = 2.0–3.0, and Very High = >3.0) were used.

The total number of occurrences of High and Very High COHS at the Downtown Station was 10.7% of the total data sample. This was more than twice the frequency of any of the outlying stations.

An evaluation of the statistical frequencies indicate the Downtown Station can safely be used as a “control station” in forecasting Low or Moderate COH levels for the six surrounding stations. However, the occurrence of High or Very High COH levels at the six outlying stations do not occur with a high enough statistical consistency to be predicted by using the forecast value of the Downtown Station.

The valley stations exhibit the characteristics of separate sub air basins particularly during a period in which morning inversions occur for two or more consecutive days and the average daily wind speed does not exceed 4 m/sec.

The results show it is possible to forecast only Low or Moderate COH levels for each of the six outlying stations by using statistical correlations derived from the Downtown Station. Separate objective forecasts which relate the pollution buildup in each valley sub air basin must be used when High or Very High COHS are forecast at the Downtown Station.     

Validation of the Digital Opacity Compliance System under Regulatory Enforcement Conditions

Abstract

U.S. Environmental Protection Agency (EPA) Emission Measurement Center in conjunction with EPA Regions VI and VIII, the state of Utah, and the U.S. Department of Defense have conducted a series of long-term pilot and field tests to determine the accuracy and reliability of a visible opacity monitoring system consisting of a conventional digital camera and a separate computer software application for plume opacity determination. This technology, known as the Digital Opacity Compliance System (DOCS), has been successfully demonstrated at EPA-sponsored Method-9 “smoke schools,” as well as at a number of government and commercially operated industrial facilities.

Results from the current DOCS regulatory pilot study demonstrated that, under regulatory enforcement conditions, the average difference in opacity measurement between the DOCS technology and EPA Reference Method 9 (Method 9) was 1.12%. This opacity difference, which was computed from the evaluation of 241 regulated air sources, was found to be statistically significant at the 99% confidence level. In evaluating only those sources for which a nonzero visible opacity level was recorded, the average difference in opacity measurement between the DOCS technology and Method 9 was 1.20%. These results suggest that the two opacity measurement methods are essentially equivalent when measuring the opacity of visible emissions.

Given the costs and technical limitations associated with use of Method 9, there is a recognized need to develop accurate, reproducible, and scientifically defensible alternatives to the use of human observers. The use of digital imaging/processing brings current technology to bear on this important regulatory issue. Digital technology offers increased accuracy, a permanent record of measurement events, lower costs, and a scientifically defensible approach for opacity determination.     

Development of a hazardous air pollutants monitoring program using the Data Quality Objectives process

To effectively reduce the environmental compliance costs associated with meeting hazardous air pollutant emission requirements, the U.S. Environmental Protection Agency's Data Quality Objective (DQO) process has been proposed as a suitable framework for establishing a defensible monitoring program. Through the use of a hazardous materials pilot study, the variability in the composite vapor pressure for regulated handwipe cleaning solvents was established. These results served as inputs to the DQO process, which identified that for facility decision-makers to claim with a 99% confidence level that the facility is in compliance with the National Emission Standards for Hazardous Air Pollutants (NESHAP), a minimum of 12 handwipe cleaning solvent compliance samples (taken at random every 6 months) must have a composite vapor pressure equal to or below the regulatory limit of 45 mmHg at 20 degrees C. Implementation of the DQO-based compliance-sampling plan eliminates the need for an affected facility to sample all regulated handwipe cleaning solvents while still maintaining a reasonably high level of confidence in the compliance status of its regulated sources. The approach described for designing a defensible compliance sampling plan can be extended to other aspects of the aerospace NESHAP rule, including compliance sampling for surface coating, chemical depainting, and hazardous waste disposal.     

Seasonal fluctuations in the photosynthetic capacity of photosystem II in symbiotic dinoflagellates in the Caribbean reef-building coral <Emphasis Type="Italic">Montastraea</Emphasis>

The photosynthetic capacity of photosystem II (PS II) in symbiotic dinoflagellates (Symbiodinium sp.), as measured by analysis of chlorophyll fluorescence, was investigated in the primary Caribbean reef-building corals, Montastraea annularis and Montastraea faveolata, for 5 years and Montastraea franksi over 2 years in the Bahamas. Significant seasonal fluctuations in the quantum yield of charge separation (F_v/F_m) of PS II were found in all species at all depths, with the highest photosynthetic capacity consistently recorded between mid-winter and early spring and the lowest photosynthetic capacity occurring in the mid to late summer. Corals residing in shallow depths of 1-2 m showed the greatest fluctuations in F_v/F_m, whereas deeper corals (3-4 and 14 m depths) had consistently higher values of F_v/F_m. Densities of symbiotic dinoflagellates and photosynthetic pigments followed a similar pattern. Fluctuations of photosynthetic capacity showed a strong correlation with seasonal patterns of water temperature and light. Such seasonal shifts in photosynthetic capacity are most likely due to several biochemical processes in the algae that lead to alterations of both photoprotection and photodamage. While symbiont density changed significantly on a seasonal basis, visual signs of coral bleaching were noted only in the fall of 1995 and the spring and summer of 1998. Comparisons of photosynthetic capacity and the decrease in the number of symbionts and their subsequent recovery indicated that symbiont populations in this study had the ability to recover quickly following bleaching events, as long as continued physical perturbation (e.g. thermal stress) did not shorten the recovery phase. Large-scale bleaching events are best viewed as the end points of seasonal physiological variation in which photosynthetic capacity and density of symbiotic dinoflagellates are reduced to a lower level than during "non-bleaching" years.