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Comment 30 for To Consider Proposed Control Measure for Ocean-Going Vessels At Berth (ogvatberth2019) - 45 Day.

First NameShawn
Last NameDolan
Email Addresssdolan50@msn.com
Affiliation
SubjectOpacity 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.
  

Attachment
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Date and Time Comment Was Submitted 2019-12-05 07:19:04

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