Field demonstration of visible opacity photographic systems

The Digital Opacity Compliance System (DOCS) is an innovative method that uses digital imaging technology to quantify visible opacity of stationary sources. DOCS, which has been demonstrated at pilot and full scale as a technically defensible and economically attractive alternative to U.S. Environmental Protection Agency (EPA) Reference Method 9 (Method 9), uses commercial-off-the-shelf (COTS) digital cameras in combination with a user-friendly computer software package to determine opacity. To date, all DOCS field testing has been conducted using two models of digital cameras, notably, Kodak Models DC265 and DC290, both of which are no longer commercially available. To ensure that field-validated digital cameras will be available to future DOCS users, a suite of new digital cameras was evaluated with the opacity determination software including the following: (1) Sony Model Cybershot Model DSC-WI, (2) Nikon Model Coolpix 5200, (3) Fuji Finepix Model E500, and (4) Kodak Model DX6490. Within the opacity range of regulatory interest, that is, 0-40%, the Sony Cybershot Model DSC-WI and Nikon Coolpix Model 5200 digital cameras were found to generate plume photographs of which the DOCS opacity analysis yielded results that were statistically equivalent to the previously field-validated Kodak Model DC290. In contrast, the Fuji Finepix Model E500 generated plume photographs of which the DOCS opacity analysis were, on average, 2.2% less than those generated by the Kodak Model DC290 photographs, a difference that was determined to be statistically significant. Over the same opacity range, photographs taken by the Kodak Model DX6490 yielded DOCS opacity readings that were found to be statistically equivalent to a Method 9-certified transmissometer. Based on the results from the current digital camera validation testing approach, EPA has developed a new camera-based visible opacity measurement method titled "Determination of Visible Emission Opacity from Stationary Sources Using Computer-Based Photographic Analysis Systems." The proposed method is expected to be promulgated after closure of the public comment period.