Whitlow Smoke School  Nation


Instructions for EPA Method 9 Form,

EPA Method 9 Instructions

Before you read smoke or evaluate opacity, you need to understand the basic fundamentals. Before we start the smoke school certification test, we always have a mini-lecture (download mini-lecture) to explain the basic fundamentals of passing the certification test and how to read opacity in the field. I am simply amazed by the number of complaints we receive about state employees in every state who are using improper techniques to observe opacity. The problem is that they were trained improperly and they need to fix it. They should attend a Whitlow Smoke School and learn how ot do it the correct way. You have been brainwashed to think this is hard and you need an 8-hour classroom and a college degree to read smoke. I have attended about a thousand of these 8-hour classrooms and had to wake people up to pick up all the coffee cups from under the chairs. How in the heck can you learn something when you are sleeping. If I could do that, then maybe I would go out for my masters degree from Harvard and graduate simply come lordly. Reading opacity is easy. My dog, " DOG" can do it and he is a firehouse Dalmatian that I found roaming a state park in the backwoods of Kentucky. Dog gives 2 barks for 20% opacity and if he gives you three barks or more, then you are out of compliance. Who would a thunk it? He makes 40 bucks an hour just to look and bark.

Opacity is a judgment call just like umpiring home plate. It is an opinion based on the calibration of your naked eyeball at smoke school, preferably a Whitlow Smoke School. Once your eye calibrated every 6 months, all you need is a form, a stopwatch, a pen, a weather radio, and a clipboard. It would be great to have a golf scope, a Boudreaux level, and a Whitlow Ringelmann Chart. I will explain these later. Purchase a Ringelmann smoke chart

Once you have the proper supplies and equipment, then set up to read opacity. The best time to read opacity is when you can have the sun in the sky and directly behind your back. This would be early in the morning between 8 and 10 AM or in the afternoon between 3 and 6 PM. As a minimum, face the smokestack with your nose like a Mississippi bird dog. Hold out both hands to your side and the sun has to be behind your hands. Not on top of your bald head. So that eliminates the noon midday hours between 11 AM and 2 PM. You need a good contrasting background, clear blue sky is the best. You simply can not read black smoke with black sky for background and it is impossible to read white smoke with white clouds for a background. That would be worst than finding a preverbal needle in a haystack. Borrowing from the Bible, it is easier for a camel to pass through the eye of a needle than it is to read opacity without a contrasting background.  It is common horse sense. You need a cross sectional view of the smokestack plume, just like you cut up a toad frog to look at a specimen under a microscope in the 5th grade. This means if you are facing the smokestack, the wind has to be blowing through your right ear or your left ear. Some rednecks like me, look as if they had holler ears. Like I could shine my carbide light through a rednecks ears and light up a coon's eye at 50 yards. Takes one to know one. You need to get the winds from left to right or right to left as you are facing the smokestack like a Louisiana Bird Dog. That is ruling out the Louisiana yard dog, which is a 15 foot alligator named Billy Bob Caldwell.

You need to back off from the stack so you can get a 18 degree or less vertical angel. Get back about 3 stack heights from the stack. If you are standing on level ground, this would be the same height that is on some engineers blueprint. If you are standing on a hill or on a platform, then the height relative to where you are standing is appropriate. You just need to get that vertical angle at 18 degrees or less. If the winds are not correct or if you are too close, then you will read double the opacity that is really there. The maximum distance is a quarter of a mile. If you are in West Virginia, then you have a problem. Some smokestacks in West Virginia are a quarter of a mile high. If that is the case, just get back to a distance that feels comfy and hope for the best.

The best way to measure the vertical angle is with a Boudreaux level. This is a homemade device you can make for about 4 bucks. Or I could make one and sell it to you for 50 bucks. Brought yourself down to the drugstore and pick up one of them protractors what they used in grade school. Get yourself some yarn and a nut. Find a drill and a small drill bit. Drill out that predrilled hole in the top flat side of the protractor. Drill it though and through. Tie that yarn into that hole you done drilled. Hold that protractor up with the flat level side up. Take some scissors and snip off that yarn about 2 or 3 inches below the round side of the protractor. Tie a nut from your tool box onto that yarn so the nut will hang from the hole you drilled down past the round end of the protractor.  Hold the protractor level with the flat top side up and the nut hanging past the round part of the protractor. Look at the angle where the yarn intersects. This should be level at 90 degrees. Ok, now take a ballpoint pen out and snap off both ends of the pen. Pull out the ink cartridge, be careful or your fingers will turn black. Now you should have a holler cylinder. This is your scope. Tape your ballpoint pen scope up level with the flat top of the protractor. Use some electric tape. When you finish making the Boudreaux Level, it should look like this.


Now you are ready to use it. Back up about 3 stack heights, look at the top of the smokestack through the ballpoint pen scope. Find the densest point in the smoke plume. always read the opacity at the densest part of the plume where there is not any steam. Normally without steam this would be the top of the smoke stack unless there is a significant amount of visible turbulence. Read the opacity after the turbulence ends and before the smoke spreads out. This is your observation point. Scope in the observation point. Get your fingers out of the way so the yarn and nut can swing toward you as you peer up through the scope. Mark the thread. Subtract the angle you have marked from 90 degrees which is level. The difference is the vertical angle. The target is 18 degrees or less.

All of the above changes if you have steam or water vapor in the plume. If the plume is detached, not touching the smokestack then you can read the opacity before the steam starts. Or you can wait for the plume to cool down and the steam to dry up, then read the opacity at the end of the steam. If the steam is attached and touching the top of the smokestack, then you have no choice. You have to be patient and wait for the steam to cool down and evaporate. Read the opacity after the end of the steam plume. This could be 2 or 3 hundred yards down the road. So get into your picking up truck and go to the end of the steam. Set up your observation position treating the steam as if it were a part of the smokestack. Keeping in mind, height, distance, winds, sun, and background.

So in summary, sun behind your back, contrasting background, winds from left to right or visa versa, vertical angel of 18 degrees or less. When you get the correct observation point and observer position you are ready to start reading. Get out a stopwatch and click it. When you click, take your first reading. Look just for 2 or 3 seconds, don't stare- you will read double. Every 15 seconds take a peek at the opacity. Read it, write something down. Read it for 6 minutes, this is 24 readings in 6 minutes. Average it out. Add, total, divide by 24. This is the average opacity, write it down. Fill out the form, take a nap.

Remember this, the company you are working for takes a lot of pride in being in compliance. Remind that to your supervisor. Nine times out of 10 if you are reading opacity above your permit, then you are reading steam or something broke. Stop reading, fix it. Then read it again. You should take as a minimum a daily reading. One objective is to document compliance daily. The other objective is to catch trends early that indicate major problems are sure to come. If you read the opacity daily at 5% and all of a sudden it is running at 15% average, this should be a warning. It should be as plain a warning as the red light flashing on your oil pressure gauge on your picking up truck. Or if you are 40 miles form the nearest blacktop road and your gas gauge is on the big E mark. If you read smoke at about 90% opacity, read it over your shoulder as you are running on down the road. Something is on fire and it could blow up a city block when she goes. Run Forest run. I may not be a smart man but I know what love is and I know how to read opacity. Now you do.

General Instructions for Method 9 form:

You should print clearly or type this form. Type in the information that never changes before you make copies of this form. Use a separate form for each source. The purpose of the left side of the form is to prove you were standing in the right place and looking at the correct portion of the plume when you made the observations. Complete every line on the left side of the form. Write N/A if not applicable. Do not leave any lines blank. You should maintain this completed form for 5 years and make it readily available for state and federal environmental inspectors. You should also post your current classroom and field-test certificates. If you are an inspector, a consultant, or if you think the observations may be challenged, you should attach photographs to document your observations. Use a 35 MM camera and have your 12 exposure film developed uncut. You should have 12 photos on a single sheet of paper. Include photos of the plant signs, shadows, stopwatch and clock showing date and time, and several photos of the plume.

Specific Instructions for the left side of the form:

COMPANY NAME and Location: List Company name and physical street address

PROCESS EQUIPMENT: Name and number of process equipment you are monitoring

OPERATING MODE: Was the process equipment operating or not? If so, what rate and/ or percent capacity

CONTROL EQUIPMENT: List any control equipment for the above process equipment- Bag-house, scrubber, etc and provide number if known.

OPERATING MODE: Was the above control equipment operating? At what % efficiency or utilization?

DESCRIBE EMISSION POINT: State weather the emission point was a round smokestack opening, a rectangular bag-house vent, etc and give the diameter or the length or width. Describe any other source.

HEIGHT OF EMISSION POINT: Height of the above emission point from the ground under it- either actual height from blueprint or educated guess.

HEIGHT OF EMISSION POINT RELATIVE TO OBSERVER: Height of emissions point from your eyeballs

START: Complete the information that you observed when you started observations.

END: Usually the end information is the same as the start information during a 6-minute reading. Record "same" in the end box. If you are reading over 6 minutes, record the conditions at the end of your monitoring. If the wind changes, you have to pause your readings. Keep the winds blowing through one of your ears. Explain any pauses in the comments section.

DISTANCE TO EMISSION POINT: The distance from your eyeball to the above emissions point. You can use a golf scope or a range finder or take an educated guess. Your position should be at least 3 times further away from the emission point as the height of the emissions point relative to your observer position. You observation position can be up to a quarter of a mile from the emissions point. Note, if you know the vertical angle (see vertical angle below) you can calculate the distance to emissions point. Click here to see the calculations.

DIRECTION TO EMISSION PT. (DEGREES (0-360)): Use a compass

VERTICAL ANGLE TO OBSERVATION POINT: The observation point is the point in the plume that you are observing. The observation point should be at least twice the diameter of the stack or twice the distance of the shortest side of a rectangular vent. If steam was present, the observation point would be after the steam evaporates or in a point in the plume where steam is not present. You should observe the densest part of the plume. Use a Boudreaux level or an Abney Level. Shoot for an 18 degree or less vertical angle, To achieve this you observation position must be at a distance equal or beyond 3 stack heights.

 If you don't want to buy an Abney level and you wish to be accurate, you can use a homemade Boudreaux Level you can make from an art protractor from Wall-mart. Tie a thick thread or twine to the center of  the straight side of the protractor. Hold the protractor with the straight side up. Let the thread extend past the arch of the protractor. Cut the thread so it exceeds past the arch. Tie a washer or a nut to the thread. If you hold the protractor with the straight side up and level with the ground, the thread will pass through the 90 degree line on the arch side of the protractor. Now tape a straight hollow tube along the top edge of the straight side of the protractor. Make sure the tube is level with the top of the protractor. Once you have built your Boudreaux Level, keep it with you when you read opacity. Click here for photographs of a Boudreaux Level. Now look at the observation point through the tube which is level with the top of the straight edge of the protractor. The thread and washer will now be tilting toward your chin. Looking at the observation point through the tube, grip the thread with your thumb and hold it in place. Now look at the point where the thread passes the arch of the protractor. It should be 72 degrees or more. Subtract the degree the thread hits from 90 degrees. The answer is the vertical angle. It should be 18 degrees or less.

DIRECTION TO OBSERVATION POINT: Use a compass to identify the direction of the observation point from the observer position.

DISTANCE & DIRECTION TO OBSERVATION POINT FROM EMISSION POINT: Use a compass, and a range finder or an educated guess

DESCRIBE EMISSIONS: See page 9 of the workbook. Was the plume lofting, fanning, etc? Did the plume have steam present?

EMISSION COLOR: Black, white etc

WATER DROPLET PLUME: Was steam present in the plume? An attached plume is attached to the top of the smokestack. Check one- attached, detached, or none.

DESCRIBE PLUME BACKGROUND: Clear blue sky, sky with white clouds, sky with black clouds, trees with green leaves, blue building, mountain, etc.

BACKGROUND COLOR: The background color must be a different or contrasting color than the emissions. If you cannot get a contrasting color you should make an entry in your logbook such as, "I could not read the opacity today because I could not find a contrasting color in the background."

SKY CONDITIONS: Clear, partly cloudy, cloudy, etc. Describe the color of the clouds.

Weather conditions: You can use the Internet, a weather radio, weather data recorded at your plant, a thermometer or a sling psychomotor.

WIND SPEED: miles or knots

WIND DIRECTION: Must be perpendicular to your position. The plume cannot be blowing toward you or away from you.

AMBIENT TEMP: Outside air temperature

WET BULB TEMP RH percent: You can use a sling psychomotor or a weather radio to get the relative humidity.

Source layout sketch: This is critical to prove you were in the right place at the right time. Remember the sun has to be towards your back. The sun has to be within the 140-degree angle shown on the form. The wind must be blowing to your left or right.

In the circle, draw an arrow pointing north. Check true north or magnetic compass north.

Indicate the height of the emissions point and the distance from you to the emissions point.

Draw a diagram showing circle or a rectangle that represents the stack or emissions point and lines showing the flow of the plume through the "X" representing the observations point.

Draw an arrow indicating the wind direction.

Draw a circle with a "+" indicating the sun. The sun must be within the 140-degree angle shown on the form. Face the observation point and hold both hands straight out to your side. The sun must be behind your hands. Stand a ball point pen straight up on the dot that represents observer’s position. If you are standing in the correct place at the correct time, your pen should cast a shadow over the top of your paper. Lay the pen down on the shadow and the point of the pen should point to the sun. Remember your mamma used to say stare at the sun and go blind.

Specific Instructions for the right side of the form:

Record the date, the time you started and the time you ended the observations. The observation period should equal the minutes and seconds you record using a stopwatch. You should use a stopwatch to complete this form. You should take one 2-second opacity reading starting every 15 seconds. Do not stare at the plume. Do not look at the plume between readings. You should record 4 readings every minute. Record your first reading in minute number 1 and second number 0. Record your readings from left to right and top to bottom.

You should record readings for a minimum of 6 minutes. You can record readings for 30 minutes on one form. Attach additional forms if reading more than 30 minutes. You can use any consecutive 6-minute readings to document a violation. Draw lines representing the worst case readings for any 6-minute set.

Comments Section: Record the minimum opacity, and the maximum opacity. Figure the average opacity by dividing the sum of the readings in a set by the number of readings you made during the set. You should record 24 readings in each 6-minute set. Record the average opacity reading in the comment section. Record the allowed opacity, and note if a violation occurred. You should notify your supervisor immediately if a violation occurred. Record when the supervisor was notified in the comments section.

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.


If a violation occurred, the supervisor should consider shutting down the process until the problem is corrected. Record the time the process was shut down in the comment section. The supervisor should consider notifying the state or local environmental agency of upset conditions and appropriate actions taken. In the comments section, record the time the agency was notified and who took the call.

In the comments section also note any changes to operating conditions, observation conditions, or plume conditions. If possible, you should maintain radio contact with the plant operator during observations. Explain reasons for any missed readings.

Bottom right of form

Print your name clearly, signature, the date and company name or organization

CERTIFIED BY: Whitlow Enterprises

DATE: Date on your smoke school certificate. The certificate is valid for 6 months. You have to retake the method 9 certification every 6 months to maintain certification. See www.smokeschool.net to sign up for the next class.

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