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Easy Simple Smoke School EPA Visible Emissions Training by Uncle George and Whitlow Enterprises

I have a pet peeve. I can't stand it when someone takes something simple as smoke school and opacity readings and tries to make something hard out of it. Many of my customers come to smoke school just because of a Title Five Permit. Many plants use natural gas fuel and they have no visible emissions at all. They have to record opacity readings and most of those readings are zero. I just tell them to read their opacity according to their permits or I recommend a daily reading. They read the opacity for 6 minutes as required by EPA Method 9 once every 15 seconds for six consecutive minutes. I advise them if they don't see anything, just record zero. The average of zero is zero, no matter how hard you try. So you document that you have a zero opacity from the source and you have documented that you are in compliance with Method 9. Now let me ask you something. Does it take a college degree to read an opacity of zero? Keep life simple. Other folks use other fuels but they have 50 bazillion dollars invested in pollution control equipment. The permit says they have to have an average opacity of 10% or maybe 20%. Hell, if you see smoke coming out of a plant at 75% you better call the fire department. Something is burning up. Get out. Run for your life. Forget opacity, run.

For goodness sakes, reading opacity at low levels is simple. Don't make it complicated. My goodness. Most smoke school providers act like they are on a quota system. We have to fail maybe 50% of the people on each run or the EPA will come down on us like stink on a road kill rotten skunk pole cat. Heck, come to smoke school and get three hours credit at Texas A&M. Right up there by changing a light bulb. We need to make this opacity reading hard. Lets try and trick them up. Give them a 30% opacity reading and then follow it by a 80% reading. Then go back to 10%. Confuse them. Mess em up. Make them fail. Hell, they are paying, don't matter if they pass or fail. They will be back. Friends the human eyeball and the brain just can't take all these deviations. It is trickery and confusion. Full of optical illusions. It does not serve any single purpose except to make a quota system and make you fail. Smoke from a smokestack just don't act like that. If you have three days to kill, then go to somebody else's smoke school. They need all the customers money can buy.

If I'm lying I'm Dying. My momma just did not raise me like that. I gotta keep life simple. Reading opacity is simple at low levels. I focus our schools on low levels, at 50% or below. It is realistic. I have to show a few readings above 50% to maintain our EPA Federal Audit requirements. But we focus on low readings and we do not jump around from high to low. Smoke from a smokestack do not jump around and try and trick you up and neither do we. We make you experts on reading low level opacity readings. You will be such an expert that when you fall asleep at night and dream you see your neighbor's house on fire. You want bother to call the fire department. You sill simply roll over and say, "Darn, I think that is 75%."

I have been getting a lot of complaints from customers about state employees and federal employees who are not reading opacity correctly. I'm not knocking state employees or federal employees. I have been both a state environmental employee and a federal environmental employees in my life. Most inspectors are good people and they know what they are doing. But there are some bad apples out there. My momma used to say that one bad apple spoils the whole barrel. Some inspectors are reading the opacity of steam in a steam plume. They don't know about reading the opacity at the end of the steam. You have  50 bazillion dollars invested in pollution control equipment and at the end of the steam the opacity usually is below 20%. I must have looked at a  bazillion smokestacks in my life and that is just the way it is. It is simple, wait till the end of the steam and read the opacity, 20%.  I have also received many reports of inspectors looking into the sun to take opacity readings, or reading opacity with the wind blowing at you or away from you. The simple truth is, you have to read the opacity at the densest part of the plume, at the smokestack or at the end of the steam. Face the densest part, with the sun to you back and the wind blowing from your left to your right, perpendicular to your ears. The wind has to be blowing through one of your ears. I know there are some of you who I could take coon hunting with my carbide light. I could shine my carbide light through your left ear and the light would shine through your right ear and light up a coons eye at 50 yards. But I forgive you. Get the densest part of the plume that excludes steam. Get the sun behind you and the wind blowing through your ears. Also get back a little. Get back a minimum of 3 stack heights or a maximum of a quarter of a mile. This will give you the correct vertical angle or cross sectional view of the stack. Get set up correctly, get out your stopwatch and take a reading every 15 seconds. It is simple. Read it every 15 seconds for six minutes. Why are people doing it wrong? Someone tried to make the classroom too hard. Eight hours is just too long for something as simple as reading opacity. People fall asleep and don't learn nothing. Another problem lies with the EPA itself. They should make the classroom mandatory every 3 years. Folks if you are a state employee, and you are reading opacity wrong, and you are writing up plants because you don't have a clue as to what you are doing. Then you are an embarrassment to your department and to your state. You need to come to a Whitlow Smoke School and learn to do it correctly.

All yawl inspectors, show a little pride in yourself. Remember who raised you. Show pride in your family. Show pride for your organization and your state. Treat the people you meet along the road with just a little more respect. Do your homework before you enter the plant. Read the permit, read the regulations. Set up your camera with the correct date and time. Your job is to collect evidence, just the facts. If the clock on the camera shows the incorrect time, then the evidence is not correct. Take good notes and record your interviews on tape. If you intend to read opacity, arrive in the plant early in the morning or late in the afternoon. You need to set up with the sun to your back. Not on top of your bald head. Do not read black smoke with black clouds for a background. Do not read white smoke with white clouds for a background. Blue skies offer the best contrasting background. Show up on a clear day. You must have a contrasting background to read smoke. There are no exceptions. Reading smoke is an opinion, a judgment call, just like umpiring home plate. In order to make a call, you must follow the instructions. Sun to your back, winds blowing through your left ear or right ear. At least three stack heights back from the emissions point or the end of the steam. Do not read the opacity of the steam. Let it dissipate. Steam looks like a white fluffy cloud. Let the certified smoke readers from the plant assist you in reading. Share opinions. Remember the overall goal of an inspection is to achieve clean air. Sometimes you can get just as much accomplished with a warning than with the pen. If you do your homework before you enter a plant you will not need to tell a lie before you leave. I simply hate it when an inspector tells me they did not see any problems during an inspection, and then they send me a nasty letter full of notices of violations.

My advice to industrial plants. Get plenty of people certified in opacity readings to loosen your workload. Baffle the state and feds with your paperwork. Make a good first impression. Meet the inspectors promptly when they show up. Don't keep them waiting. Do your homework. Have your paperwork ready. Ladies and gentlemen- fill your hands. That is what John Wayne used to say

 

Show the smoke school certificates for your people. Show your daily readings of opacity. Show your records of bag house and other pollution control equipment. Document, document, it ain't over until it is over. Have the paperwork. Be confident. Answer any questions that you are sure of the answers. Never admit guilt. Show remorse. If you don't know the answer, then say, "I just don't know." Be polite, get them in, show them what they want to see, and get them out. If the inspectors want to read opacity, then go out there and read it with them. Make sure the inspector is standing in the correct location. Make sure they are reading visible emissions and not steam. Make suggestions. The time to argue about a traffic ticket is before they get out the ticket book. Once you have a violation on paper, it is hard to get rid of it. If you get a violation, call us immediately. Get a lawyer. We are available for court.

I like a simple life. I wonder who thunk up the idea that we had to hide all the electrical receptacles in the house. I hate moving the gun rack every time I need to plug in my computer. I don't like checking into a hotel room and moving the bed to plug in my computer. Who is is that decided they needed to add that little third round prong to an electrical plug. The one you have to cut off with a hack saw to plug in your skill saw. Now they have come up with a plug that has one of the dashes larger than the other. I guess they think we are too dumb and may plug it in backwards and make the clock run backwards. All i know is you have to get the joints on the PVC electrical fittings glued correctly or all of your electricity will leak out on the ground and trip all the breakers. Cut it, stick it, glue it. That is what my momma always used to say.

I had four 57 Chevrolets in my life. I brought them and sold them for $50 each. I could change the fan belts. I could change the oil. Today I drive a 2005 Ford Excursion with a diesel engine. I can't even find the dipstick. I remember when gasoline was 30 cents a gallon. What is it now, almost 3 bucks. What the heck happened. Give me back that simple life. But let me keep my GPS and internet so I will know where I am going. Let me keep those 9 cell phones so I can keep up with everyone. I love the simple life.

You can't find a coffee shop no more. They call it something else. I was in the mall the other day and I just had to get a cup of coffee. I saw a sign that says Boutique. They pronounced it Bo -ti Que. I said lookie here, I done found me a coffee shop. I went on inside, it was a ladies dress shop. People were in there changing clothes. Where is the coffee shop? On down the mall. They don't have cafes any more. What has life come to. Well letz keep life simple and letz keep smoke school simple. If you are tired of being a quota, and you want a simple some school. Just look at our Schedule. If you can' t find a good location, then think of this. Private Custom-made On-site Smoke Schools. You just might have fun and learn something about opacity reading.

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