When you read visible emissions opacity, if all else fails- read the instructions

I received a complaint last week from a crematory. The complaint concerned one of the environmental companies that we certify with smoke school. In all reality, our certificate only means that you passed the test. As you know, the EPA in all of their infinite wisdom does not require the classroom. It is optional. Besides, you may have slept through a 8 hour classroom from one of the other providers.   You should take one of our 2 hour refreshers classrooms (6 hours required in Texas). EPA recommends the classroom every third year. See our schedule for details.

The crematory owner hired a consultant to read the opacity from the incinerator. The incinerator fell under the regulation that I feel like needs to be revised. They have a requirement of an average no greater than 5% over any consecutive 6 minutes of opacity reading. The normal limit is 20% average and this is realistic. The problem with the 5% average is that all opacity readings is at 5% intervals. There is no such thing as 2.5%. All inspectors feel like if they see smoke at all, then it is 5%.

The crematory owner paid a consultant maybe $100 per hour. Allegedly, the consultant left the crematory and said the opacity looked good. My opinion is that when he got back to the office he read the permit and discovered for the first time the 5% opacity requirement. The average opacity level was 7.5%. Then he wrote the report and sent a copy to the DEQ. “ Look officer. I did run that red light and I was actually driving 65 in a 45 speed zone. I was weaving across the yellow line because I spilt my Jack Daniels and was eating a Mickey D’s cheeseburger, talking on the cell phone, and sending a text message at the same time that I was driving. I was not wearing my seat belt because I am too fat. Give me 3 tickets, I deserve them. I deserve a gold medal too.” This really did happen to me last month driving to the Shreveport smoke school. The medication I was taking makes you tell the truth. I need to give some pills to the best politicians money can buy.

I made the conclusion about the consultant’s not doing his homework based on some of my own personal mistakes back when I was an inspector. I had a backlog of inspections and tried to catch up by doing 6 inspections a week. I did not take the time to read the permits and the manuals. I took the word of my supervisor and the reports of the previous inspections of the plants. I left the plant manager with the impression that all was copasetic. Then when I got back to the office, the shit hit the fan when I read the permit. The next thing you know, I was writing a Notice of Violation demanding that the plant manager come by the office so we could assess a penalty. At the meeting my boss Gus Vonbodunger would learn that the plant manager tried to tell me that he had a scheduled shut down. That is when Gus asked for forgiveness and sent the manager back home. Then Gus got into my left ear Marine Corp style” WHITLOW!”.

I talked to the consultant and he said that DEQ was at the opacity reading breathing down his neck, and that he had no choice except to write the report. The crematory guy denied this, so nobody except the hairdresser will ever know the real truth.

I had to dig out the consultant’s smoke school test papers for the previous year so I could go to the Salvation Army to buy a suit and prepare to go to my favorite places- COURT. Apparently the wind was blowing in all directions and we had to scratch several answers. You have to keep the winds perpendicular to your line of view to read smoke or you will be seeing double exposure. The consultant had made several scratch marks that blacked out on the yellow copy of his test paper. It was difficult to read his answers. Please make a single line scratch through the answer because you never know when these test papers will show up in court. Like everything else, I have to keep these papers available for 5 years.

Lessons to be learned from the incident at the crematory:

1.     Remember that your job working for the plant is to document compliance. If you work for the state, your job is to document a violation. There is a difference.

2.     Know what your permit says. Read it, Highlight and memorize any paragraph with the words visible emissions or opacity in it. Find the minimum limits and the frequency of how often you are supposed to read the opacity. We recommend that you take a spot check of your opacity at least once a day 24/7 for each daylight shift. Read each source.

3.     Do not rely on information passed on from your supervisor or previous EHS personnel. Do your own homework. Your name is on the bottom of the form. If it is worth doing at all, do it right the first time.

4.     Write SOP’s based on manufacture instructions and your permit. Make sure all employees know and follow SOPs.

5.     Keep a green log book for each source and the control equipment. The log book should include cleaning and maintenance required by manufacturer, results of daily spot opacity checks. "I read the smoke or dust today and saw nothing. Steam Is not pollution. I read the opacity today and saw smoke. See the attached 6 minute method 9 form."

6.     Download the method 9 form. Save it to your computer. Type in the information that never changes. Save it again and print copies. Follow the instructions. Make sure you are standing in the right place at the right time.

7.     Read the method 9 form instructions. Learn how to correctly fill out a method 9 form. Do not leave any blanks. Treat it as if it will go to court.

8.     Maintain constant communications with your operator, before, during, and after opacity readings. You should not be documenting a violation if something is broken. Fix it, repair it, shred the evidence, and read the opacity after the problem is solved.

9.     Follow the chain of command, notify your plant manager ASAP if the problem cannot be fixed.

10. Somebody has to file an upset report with the DEQ. Document everything. As Yogi Berra says, It ain’t over until it is over.”

What do you do when EPA shows up

Friday Night Surprise The EPA is Waiting- Contributed by Robert Conselman

The court case and why I think it is important to simplify the opacity certification test.