First Name | Shawn |
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Last Name | Dolan |
Email Address | sdolan50@msn.com |
Affiliation | |
Subject | Opacity Measurement Ocean Going Vessels at Berth and Anchor |
Comment | In review of the proposed enhanced regulatory vision of Ocean going vessels at berth and anchor. Opacity is clearly the fastest and most efficient means for CARB and other Port enforcement to identify potential non-compliance events. However, the proposed regulation continues to perpetuate the 1970 vintage Method 9, human means to measure opacity using calibrated eyes. Most other states have realized that enforcement of human measured opacity violations has become very difficult do to the variations inherent to human eye sight, e.g. vision is a function of rest, eye pressure, sobriety, and many other factors to include the use of allergy, inflammation, and other medications, such as Erectile enhancement and disfunction medications used widely throughout California. Due to these reductions in vision consistency, many states have abandon Method 9 as unenforceable, LA DEQ and AZ DEQ as examples. US EPA has promulgated a Broadly Applicable Alternative Method 082, (Digital Camera Method), which uses common consumer grade digital cameras and computer software to perform stand off Opacity Measurements, create validated error free Visible Emission Observations, bringing credibility back to the stand off measurement of Opacity from Stationary, Mobile and Fugitive Sources. In fact the FerroAlloy NESHAP at https://www.regulations.gov/document?D=EPA-HQ-OAR-2010-0895-0280 defines the Digital Camera Method USEPA Broadly Applicable Alternative Method 082 and its supporting ASTM D7520-16 standard as the Best Available Technology for the measurement and analysis of process fugitive emissions, (roof vents) and source opacity. Suggest that CARB insure the Best Available Technology for the measurement of Opacity NOT be excluded from the community and enforcement tool box, by specifically calling out the Legacy Method 9 and thus effectively eliminating the ability to use the best measurement technology. The Digital Camera Method, preserves pictorial evidence of the opacity event, verifies method procedural compliance, e.g. sun behind the camera, perpendicular to plume travel and a reading every 15 seconds for the observation period, (normally 6 minutes). Why would the most progressive Air Pollution control agency in world use out dated methods, that drive absorbent litigation cost, do to the reliance entirely on human honesty. The Digital Camera Method is commercially available today, it has been reviewed and validated to be as accurate and more consistent and repeatable than Method 9 by the CARB smoke school program. 2011-2013, and recognized by CAPCOA as the Best Available Opacity Measurement capability. Thank you, I hope CARB finds the wisdom in including the Best Available Technology for Stand off Opacity measurement, (The Digital Camera Method, ASTM D7520-16 and/or US EPA Broadly Applicable Alternative Method 82). Most all citizens carry cell phones with cameras these days and the ability to find and measure opacity sources is as simple as snapping a picture and uploading it to a cloud based platform for results. All 617 identified communities could benefit from a simple to use and operate, not training required means to measure opacity. |
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Date and Time Comment Was Submitted | 2019-12-05 07:19:04 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.