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.