Whitlow Smoke School

 

Mini-lecture at Field-training Site

RE:  Classroom Mini-lecture EPA Visible Emissions Smoke School Training

Thank you for choosing Whitlow Enterprises for you training needs. This letter is a mini-lecture for the basic fundamentals of how to read opacity in the field and how to pass the smoke school certification test. We will hold a complete visible emissions classroom lecture after we complete the testing here today. EPA recommends this classroom for all new attendees and every three years thereafter. Ask your instructor if you are registered for the classroom. Some companies have pre-paid for the classroom. Smoke school fees are non-refundable. If your company has not pre-paid, you may use your credit card today and receive a 5% discount for on-site payment. {Note to instructor- read this letter while you are showing the smoke school standards. Show each standard at least 3 times. You can finish the letter during the practice test.}

You should have the following items: yellow and white answer sheet, green practice sheet, white registration form, pink critique sheet, a Ringelmann smoke chart, 2 pens, and a clipboard. Place the forms on your clipboard in the order listed. Your instructor will give instructions for completing each form. Pay particular attention to your answer sheet. Make sure that you print the form clearly. Print your name twice on the form, once in all capitol letters and once in routine letters. Make sure to include your company name and mailing address. When you finish your answer sheet, make sure to fold the answer sheet over the clipboard to avoid any stay marks on the carbonless duplicate yellow copy. Check your yellow copy for stray marks and notify your instructor if you need a new answer sheet. You will receive a business card certificate today if you pass the test. We will mail out your computer certificate within 3 weeks. Notify us if you do not receive your certificate. If you are not receiving the Whitlow monthly emails, then send us an email smokeschool@yahoo.com to be added to the list. EPA requires us to maintain all test forms for 5 years. Please turn in all of your forms except for this letter, the Ringelmann smoke chart and the green practice sheet before you leave today. You will not receive your certificate unless you turn in both copies of your answer sheet. The topics of this mini-lecture are included in the frequently asked questions section of our webpage. EPA requires you to pass the smoke school certification test every 6 months to maintain certification. We will be back at this location every 6 months. You may register in advance on the schedule section of our website www.smokeschool.net.

Before we start the test your instructor will  give a demonstration on the basic fundamentals of opacity observations during the test and in the field. The instructor will teach you how to use the Ringelmann chart for black smoke, a compass, a Boudreaux level, and a golf scope. You may purchase these items at your local store, or from our website. We recommend that you conduct daily routine opacity observations of each potential source of visible emissions using an approved EPA Method 9 form (see attached ) available on the top right portion of our website. The instructions for making a Boudreaux level and how to complete the Method 9 form are also posted on the website. 

These are the keys to passing the test on the first run:

1.       Stand back at least 45 feet from the smokestack, at least 3 stack heights.

2.       Choose a contrasting background- you cannot read white smoke with white clouds in the background and you cannot read black smoke with black clouds in the background. The best background is clear blue sky. If you cannot find blue sky, then look for a green tree. Read the background, not the smoke.

3.       Face the smokestack with your nose pointing at the stack like a Mississippi birddog. Hold out both hands to your side. The sun should be behind your hands. (Demonstration) {Note to instructor-these demonstrations are on our smoke school classroom slide show. Learn them.}

4.       The wind should be blowing through one of your ears. The plume should be moving perpendicular to your line of view- from your left to your right or visa versa. The smoke can not be blowing at you or away from you. Holler scratch if the wind changes directions. We will repeat that reading. We may have to move the elbow or your position if the wind change is persistent.

5.       Do not look at the smoke until you hear the word read.

6.       Read the opacity at the densest part of the plume- the top of the smokestack or the fist 3 feet after the elbow.

7.       Look at the smoke for 3 seconds, and then stop looking- we may be moving the valve to go onto the next reading. Only look when you hear the word read.

8.       Always holler scratch if you get lost, confused, or the wind changes- keep us informed about the conditions

9.       Your first step in recording opacity is to determine the range of the opacity. The first range is from zero to 25%. The first smoke school standard is 25%- memorize what 25% looks like. {Note to instructor- Show 25% standard now.}  Since most permits require an average opacity of 20% or less, the most common range of opacity at your plant is zero to 25%. Any opacity beyond this range is cause for alarm. (Note: We teach you about ranges during the presentation of the smoke school standards and during the practice tests only. We do not use ranges during the actual opacity test.)

10.    The second range is 25% to 50%. 50% is the second smoke school standard. Memorize what 50% looks like. {Note to instructor- Show 50% standard now.}

11.    The third range is 50% to 75%. 75% is the third smoke school standard. Memorize what 75% looks like. {Note to instructor- Show 75% standard now. Remember not to leave the smoke at 75% very long because it will flood the firebox and melt the equipment}

12.    The fourth range is 75% to 100%. If you see smoke in your plant in this range, read the opacity over your shoulder because something is on fire and it is going to blow up. Run Forrest Run.

13.    After you determine the range of the smoke, record in the first test paper column the best answer in 15% intervals- 5, 10, 15, 25, etc.

14.    Always keep in mind the plus or minus 15% deviation required by EPA to pass the test. Remember there is no such thing as negative smoke. If it is barely coming out, then call it a five. In your head- choose the best readings, add 15- subtract 15- choose your answer appropriately. If you choose the answer 15%, then you have covered the actual opacity from 0% to 30%. This is important- remember this. Think of this as windows on your computer. You must be in the correct window of opportunity.

15.    Do not look back at the smoke until you hear the word read again.

16.    Do not stare at the plume between readings- This causes optical illusions and confusion

17.    Do not second guess- read it and record it- your first impression is always right. If I had listened to my momma, I would not have been married 12 times. "This girl is not right for you."

18.    Never change an answer unless you have to.

 

What are the basic fundamentals for reading smoke at your plant?

1.  How to choose an observation position- where to stand

A.      Sun to your back

B.      How to use a clipboard and a pen to make a shadow to prove you had the sun to your back. Stand the pen on the dot for the observation position on the Method 9 form. The pen should make a shadow on the form. Lay the pen down on the shadow. The pen should point to the sun. Draw a circle with an X on the sun line on the form to represent the sun position. (Demonstration)

C.      Winds blowing perpendicular to your line of view- from your left to your right- not coming at you or going away from you

D.      Get back at least 3 stack heights to obtain a vertical angle of 18 degrees or less

E.       How to make and use a Boudreaux Level to determine your vertical angle (Demonstration)

F.       How to use a compass for determining compass direction to stack and wind direction. (Demonstration)

G.      Choose an observation position that allows a contrasting background. You cannot read white smoke with white clouds in the background. You cannot read black smoke with black clouds in the background.

H.      How to use a Ringelmann smoke chart for black smoke (Demonstration)

2. How to choose the correct observation point- where to look at and observe the plume

A.      The densest part of the plume

B.      No steam- at the tip of the smokestack before the plume spreads

C.      Attached steam- touching the smokestack- observe at the end of the steam plume- the densest part of the plume after the steam ends or evaporates

D.      Detached steam- not touching the smokestack- read before the steam starts or after the steam ends

Recording Observations. Opacity observations shall be recorded to
the nearest 5 percent at 15-second intervals on an observational record
sheet. (See Figure 9-2 for an example.) A minimum of 24 observations
shall be recorded. Each momentary observation recorded shall be deemed
to represent the average opacity of emissions for a 15-second period.

Data Reduction. Opacity shall be determined as an average of 24
consecutive observations recorded at 15-second intervals. Divide the
observations recorded on the record sheet into sets of 24 consecutive
observations. A set is composed of any 24 consecutive observations.
Sets need not be consecutive in time and in no case shall two sets
overlap. For each set of 24 observations, calculate the average by
summing the opacity of the 24 observations and dividing this sum by 24.
If an applicable standard specifies an averaging time requiring more
than 24 observations, calculate the average for all observations made
during the specified time period. Record the average opacity on a
record sheet.

4. What do you do if your observation evaluation is out of compliance?

A.      Notify your operator and plant manager immediately

B.      Get permission to shut down the process and fix the problem

C.      Conduct another evaluation after the problem is corrected

5. What to do if you are still in compliance but you notice a significant change in opacity

Your company is concerned about clean air. They have invested thousands of dollars on control equipment to achieve compliance.  If your operator is following correct procedures and the control equipment is maintained, your opacity readings should be within your permit. If your opacity readings exceed your permit, then someone failed to follow procedures, the control equipment is not working properly, or you did not follow these opacity reading fundamentals. A responsible opacity evaluator should take observations on a daily basis. The opacity should be about the same everyday. Any significant change from one observation to another indicates a problem with the pollution control equipment. Think of this as the check engine soon light on your vehicle. It should set off an alarm in your mind. Investigate the problem and fix it. Maintain a log of all routine maintenance of your source, pollution control equipment, and daily routine opacity observations. The observation log should include the date of the observation, the source, and comments such as smoke or no smoke or dust or no dust. If you see any dust or smoke at all, you must complete a full 6-minute Method 9 observation and record it on the EPA Method 9 Form within 24 hours. Record the average opacity reading on the log. Make this log available for all state and federal inspectors along with your current smoke school certificates and your Method 9 Forms. Always accompany inspectors and make joint opacity readings. Notify Whitlow Enterprises immediately of you receive a notice of violation. We will be available to assist you.

You always have a choice for smoke school providers. Thank you for choosing the best. At this time we will present the smoke school standards and have several practice runs. Be sure to alert the instructor if you do not understand how to take the test. After the practice test we will start the real certification test. During the practice test and the certification test, one instructor will be monitoring the crowd to make sure that all of you are following the correct procedures. The test will last about 90 minutes. Stop the test and holler scratch if you have any problems. After the test, please examine your yellow test copy for stray marks and turn in the yellow copy. After the test if complete, one instructor will begin cooking your lunch. We like to serve your meal hot. While one instructor is cooking the other instructor will call out the correct answers slowly. Record the correct answers on the middle line of the white test form. Record the deviation or difference on the third line. There cannot be anything on the third line above 15%. Sum up the third deviation line to determine the total deviation for black and white smoke. The total deviation for each must not exceed 184. If you met the above requirement then you passed the test. Please do not cheat. These papers are audited by the EPA. Be sure to turn in your test papers and get your business card certificates before you leave.

Before you turn in your test papers we will have a competition to see who made the highest score on the black smoke and the white smoke. We will hand out T-shirts, hats, knifes, my novel, and other prizes to the people who make the highest scores. You may also purchase these items from the instructor or from our website. We will also have drawings for cash and prize items. Make sure to get a ticket. After the drawings we will serve you a lunch. We will present other smoke school test runs after lunch. Please do not leave until you pass the test. If you passed the test you can stay for additional practice tests. We will start the classroom after lunch. Please follow the instructor to the classroom site. The classroom will last from 2-3 hours depending on discussions. Thank you again for choosing Whitlow.

 Sincerely,

George A Whitlow

George A Whitlow

CEO

 

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