# Presentation: 430634

## An Alternative to EPA Method 9AFRL

- Captain Michael J. Calidonna

## Overview

- Current method
- Problems with current method
- Proposed Method
- Progress

## Current Method

- EPA method 9 opacity measurement
- Smoke School
- In-stack instruments / transmissometer
- Recurring training
- Visual estimation of opacity every 15 seconds
- Training valid for six months
- $350 per student / loss of man days	& travel rqmts
- 	 (105 man days at Hill AFB alone)

## Current Method

- “Ringleman” Number
- Calibration run
- Observers must estimate the opacity
- 25 Black; 25 White
- Within +/-7.5% for an individual reading
- Absolutely correct 26% of the time
- Samples range from 0 to 100% at 5% increments

## Problems with current method

- Smoke school  is doing the best job possible with the current technology
- Not reproducible results
- No Historical record
- Expert testimonies needed
-  unsupported by technical documentation

## Problems with current method

- Seems Subjective
- Permitted values currently range from 20-30 %
- Humans have difficulty differentiating between 15%; 20%; 25% etc.
- Two experts can be correct when one says 20% the other says 30%
- Fines based on estimates of opacity may range up to $10,000 per day

## Problems with current method

- Smoke reader	A = 20%
- 				B = 30%

## Problems with current method

- Regulated at the lowest detection levels
- No longer working with “black” emissions
- Human is expected to differentiate between modestly gray and slightly grayer
- Human is also expected to differentiate between steam and particulate emissions

## Need for a change

- Technology has moved forward
- Higher resolution devices available
- Commercially available hardware
- Scientific approach available

## Proposed Method

- Digital technology
- Near real time image processing
- COTS cameras
- Highly portable

## Proposed Method

- Objective Measurements
- Permanent pictures
- Reproducible results
- Algorithm protects integrity of pictures

## The Process

**Photographs Taken Using **
**Kodak DC265 Digital Camera**

**Commercial Computer Used to Processes Images With SCIENTECH Proprietary Software.  Sofgtware Determines Opacity,  Displays Results**

**Dust Processing Displayed for Immediate Action**

**Method 9 Results Displayed, Can Be Printed, Stored on Disk**

**If computer is taken to the field site, Method 9 can be done in 10 min--**
**from set up to final report.**

## Proposed Method

## Proposed Method

## Problems with current method

- Smoke reader	A = 20%							B = 30%

## Problems with current  method

- Both are correct
- If the allowable opacity is 25% there is a problem
- If the limit is 30% operations can continue
- What is it really by our method??

## Proposed  method

## Proposed method

## Proposed  method

- Level of testing
- 4 or 5 sites throughout the continental US
- Pacific Northwest
- High Desert
- Southern US
- Mid West
-  3 Testings per year -- all seasons
-  3 Days of testing per site

## Potential Savings

- DoD currently spends 6.9 million dollars on annual smoke school training
- Return on investment ~ 3 years
- Avoid fines / maintain compliance
- Avoidable future litigation costs

## Previous Investments

- Feasibility study, sponsored by SCIENTECH, providing 10K to Space Dynamics Lab
- Concept development and demonstration funded through NASA.  8 Month effort 80K
- Prototype development through AFRL 32.5K
- Hill AFB 44K camera validation

## Statistical Summary of Utah Smoke School vs DOCS Evaluation

| Smoke Color / Measurement Approach | 
Opacity Range | 
Average Percent Deviation | 
Number of Samples | 
99% Confidence Interval |
| --- | --- | --- | --- | --- |
| Black – DOCS
Black - Observers | 0 – 100%   
0 – 100% | 6.58
7.45 | 2357
280 | 6.1 – 7.0
6.0 – 8.8 |
| White – DOCS
White - Observers |    0 – 100%
   0 – 100% | 10.08
8.55 | 2410
282 | 9.5 – 10.7
7.1 – 10.0 |
| Black – DOCS
Black - Observers |    0 – 60%
   0 – 60% | 5.70
5.82 | 1972
225 | 5.3 – 6.1
4.5 – 7.1 |
| White – DOCS
White - Observers |    0 – 60%
   0 – 60% | 6.7
8.17 | 1900
224 | 6.2 – 7.2
6.6 – 9.8 |
| Black – DOCS
Black - Observers |    0 – 40%
   0 – 40% | 5.44
4.77 | 1759
194 | 5.0 - 5.9
3.5 – 6.1 |
| White – DOCS
White - Observers |   0 – 40%
  0 – 40% | 5.90
7.39 | 1689
199 | 5.4 – 6.4
5.7 – 9.0 |

## Interim Results of Utah Measurements

_**Method 9 requires 7.5% or less opacity deviation for certification**_
**Black Plumes (2357 plumes evaluated) - Passed**
- Average DOCS opacity deviation of 6.58% vs 7.45% certified
- readers
**White Plumes (2410 plumes evaluated) – Failed **
- Average DOCS opacity deviation of 10.08% vs 8.55% for certified
- readers
**White Plumes in 0 – 60% Opacity Range - Passed**
- Average DOCS opacity deviation of 6.70% vs 8.17% for certified
- readers

##          DOCS Field Vehicle Alaska Trip – Near Healy AK

## DOCS Field Crew – Pipeline Pump Station #7

## Healy AK Coal Fired Power Plant

## Williams Power Plant Near Fairbanks

## Anchorage Municipal Sludge Incinerator

## Conclusion

- Current method
- Problems with current method
- Proposed Method
- Progress

## Bottom Line

- EPA -- Senior scientists endorsement
- “Anticipate,with successful demonstration and validation of techniques, approval for national use”