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Whitlow Smoke School
WHAT SHOULD OUR PLANT DO TO PREPARE FOR A STATE OR FEDERAL VISIBLE EMISSIONS INSPECTION
When you are driving down the road in your picking-up truck and the check engine light comes on, then you should cover it with duck tape and ignore it. Most inspectors try to visit each plant once a year. They will come more frequently if there is a history of complaints. You are required to document compliance with all air quality laws, regulations, and permits. The primary goal of the inspector is to review your operating permits, review your documentation of compliance, and to inspect your emissions sources and control equipment. This is their job and it is not anything personal against you or your company. It is essential that you have a good relationship with your inspectors. This is one reason that I have always loved smoke school. I have been an inspector, I have attended many smoke schools for certification to do my job, and I have conducted very many smoke schools. During smoke school we always give you plenty of time to mingle with the other plants and the inspectors for your plants. This is your opportunity to meet each other on mutual grounds, ask questions, and make discussions about environmental issues.
You should be prepared to greet inspectors professionally and on friendly terms. You should have the following visible emissions documentation readily available:
ü Your operating permits with any comments pertaining to opacity and or visible emissions highlighted. You should be thoroughly familiar with these requirements. See below.
ü The visible emissions classroom certificates of all visible emissions evaluators- classroom recommended every 3 years
ü The visible emissions field-test and method 9 certificates- valid for 6 months after certification date
ü A logbook for all emissions sources and control equipment- see description below
ü Completed EPA Method 9 forms or other approved forms for recording visible emissions evaluations
How to review your permit for visible emissions documenting compliance:
v Search the permit for words pertaining to opacity or visible emissions
v Find out the requirements for each source. Is there an average opacity requirement, is there a maximum opacity allowed, or is any visible emissions at all allowed for the process. Click here for a permit example
v Your job is then to document your compliance with the permit requirements.
v Your permit usually dictates a minimum frequency for reading opacity of each source. We say ignore the minimum and read each source a minimum of at least one six minute reading of each source for every daylight shift. We recommend reading smoke or dust early in the morning around 8 AM and again late in the afternoon around 4 pm before dark. The sun has to be behind your back for accuracy. You should develop a habit of at least looking at your plume every time you walk outside. You want to see if your check engine soon light is on. If it is then fix it.
v Your permit dictates your actions if you discover discrepancies.
v If you have any questions at all about your permit, now is the time to ask your inspector. Pick up the phone and call them.
v We here at Whitlow Enterprises are available for visible emissions audits of your permit.
How to complete a logbook for visible emissions compliance:
v Include sections for each process that may produce visible emissions smoke and dust.
v Include each source- it may be a smokestack, a bag house, a dust collector vent, a roof vent, a transfer point, and in some cases a window or a door, and may include road dust.
v Document the date and time of your evaluation. Back up your logbook with Method 9 forms or other approved forms for visible emissions.
v Document that you are meeting your minimum frequency requirement for visible emissions observations.
v If you miss a required evaluation, then document why you missed it. Examples- It was raining or it was snowing and I could not get a contrasting background for reading white smoke. The source was not operating today because of maintenance.
v Document your average and maximum opacity observed
v Document your corrective actions if you observed any opacity that is over your permit.
v Document your opacity after the corrections were made.
v Document any and all maintenance and repairs to any source or any control equipment that affects your opacity.
Remember to review your permit to make sure that it is accurate. Make sure all of your sources are listed. The highest penalty ever issued to a company was a violation because the company neglected to include 25 sources on the permit. This violation in Southeast Louisiana also led to indictments of company and state officials. Remember to remove any sources from your permit if they are pickled. This also could lead to a violation and a penalty.
