ASTM D7520-09 “Digital Camera Opacity Technique” was approved in October of 2009, requiring system certification of DOCS II. Certification to ASTM D7520-09 included the addition of start-up calibration testing and the ability to pass (6) six smoke schools within a (6) month period of time, reporting all attempts. DOCS II was certified to ASTM D7520-09 in December of 2009 having passed 6 smoke schools in two days sequentially. However, it became apparent that different back grounds should be used versus a strict interpretation of the ASTM D7520-09 standard. DOCS II was tested using a variety of homogeneously colored backgrounds to include the basic color spectrum of Red, Green and Blue as backgrounds. Again, DOCS II passed every attempt and complex analysis took shape as a means to compare between a Zero (back ground) image with a second (foreground) image to allow for analysis of pictures so close to the emission that a background is not available within the frame, as well as, a means to increase accuracy when vegetation, or mountain sides (multi colored) backgrounds were the only option, e.g. versus homogenously colored backgrounds (Blue Sky, etc.). The USEPA signed out a letter dated April 2010 that formed the bases of US EPA Alternative Method 082 allowing ASTM D7520-09, with the additional certification requirements of (6) different backgrounds and (4) different Analyst, and a self test/calibration, that required each of the 300 certification images (6 x 50) to be re-analyzed upon start up with zero variance from the opacities calculated upon certification. DOCS II certified to EPA Alternative Method 082 in April of 2011, just prior to the first DOCS II Analyst and Operator training event.

The first DOCS II training event was held in Salt Lake City, UT in April 2011. Carbon County, UT who had certified a specific camera (Nikon 3100), Hill Air Force Base, Utah Department of Environmental Quality and Eastern Technical Associates attended the event. The weather was brutal, wind, rain, snow but the picture quality which was the focus of the training was perfect. All participants certified and Carbon County immediately put DOCS II into production, monitoring dust generation on the Nine Mile Canyon Petroglyphs Preservation project. Carbon County had done their homework and had already mapped out the scenes (areas) of the road that would be monitored, the cameras to use for the task and the backgrounds. Thus DOCS II in a standalone kit has operated well for Carbon County as their focus has always been on picture quality with the addition of DOCS II opacity analysis being nice to have. Hill AFB being a Title V source, had the additional burden of incorporating the use of DOCS II Kits into permit conditions which would seem a simple task but without publication of EPA ALT 082 in the Federal Register, the resistance to change proved to be insurmountable with the available funding. The training for this group was heavy focused on picture quality given the weather conditions and the presence of Carbon County photographers who added significantly to the group. All Ten 10 attendees certified as DOCS II Analyst. EPA ALT 082 was published in the Federal Register February, 2012. EPA ALT 082 can be used in Lieu of EPA Method 9 for all sub sections of 40CFR sub parts 60, 61, 63.