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Who needs to be trained to evaluate opacity in compliance with EPA Method 9 and 22
Federal and state employees that are required to evaluate opacity as part of an inspection to determine compliance with air quality permits and regulations.
Industrial plant staff
If your company is concerned about clean air and pollution control you need to be trained. If you are concerned about state or federal inspectors seeing your smokestack and deciding to come spend the day with you- then you need to be trained. If you are concerned about issues such as job security, environmental complaints to the state inspectors, class action lawsuits, falling profits, falling stock markets, then you need to be certified.
If your plant has a smokestack or a bag house then you need to be trained and certified. Your smokestack is the flag that can be seen for miles and it indicates to inspectors and the public the overall condition of your plant. Air quality permits and inspectors often require you to have routine opacity readings conducted by certified personnel if your plant has the potential to produce smoke, dust, or other visible emissions from any source including bag houses, smokestacks, incinerators, diesel exhaust pipes, and fugitive emissions sources such as roof vents, windows, doors, road dust, stock piles, conveyor belts, flares, silos, hoppers, transfer points, and sandblasting. We strongly recommend that you maintain a staff of certified evaluators to read the opacity of each source at least once during every daylight shift. A small plant should have at least 4 certified evaluators. You should consider training your environmental staff as well as safety, operators, and security. We offer discounts for multiple attendees from each plant. We also offer a nighttime certification training at our offices in Odon Indiana and West Monroe only We will consider a night time certification during a private school at your plant.
Let me give you a horror story. In 1984 when I first hired on as a Louisiana Department of Environmental Quality (LDEQ) air quality inspector, we were involved in a class action lawsuit against a commercial hazardous waste incineration plant. The plant was located near Scotlandville, an economically deprived neighborhood in North Baton Rouge, Louisiana.
The lawsuit lasted several years and went to trial about every month or so. The national and local media made field-days out of the trails. The lawyers for the public were after blood. About 2 weeks before every trial date, the attorneys passed out camcorders and tape recorders to several residents in the area. The residents formed a vigilante-like plant watch and surrounded the plant about 2 weeks before each trial date. It reminded me of the times I lived in tornado alley for 6 years while stationed in Oklahoma in the Air Force back in the 70s. Volunteer residents formed a tornado watch that surrounded the town of Altus whenever the national weather service predicted tornado formation in the area. The tornado watchers had cameras and CB radios and alerted the Air Force Base weather team whenever they spotted anything that looked like a tornado. The weather boys would sound the alarm to take cover. We spent many a spring nights in the storm shelter at our trailer park. No telling how many lives were saved by this courageous bunch of volunteers.
The residents around the plant in Baton Rouge surrounded the hazardous waste plant starting about 2 weeks before a trial date. Their mission was to collect evidence to be used against the plant during the trial. They knew that LDEQ had to respond to investigate all complaints against the plant. They all called the LDEQ hotline steadily during these watch periods. Our phone never stopped ringing.
It was my misfortune to be on call one night when these complaints started rolling in at about midnight. Following instructions, I notified my immediate supervisor and the head of LDEQ when I received the first of many complaints during the weeks before the trial. The three of us met at an all night fishing bait shop and convenience store across the street from the plant. Our job was just to gather the facts, just like Joe Friday. We are not supposed to take sides. The security guard at the plant kept us waiting for what seemed like a long time to me. You should not keep the state inspectors waiting at the gate for long periods of time. We become pretty suspicious, just like Joe Friday.
Finally we were allowed to enter the plant. We were driving down the long and winding gravel road that led from the gate to the incinerator operation building and control room. We looked to our left as we were driving and we noticed that the wet scrubber for the incinerator was not working. Instead of the huge plume of white steam, we saw a huge plume of black smoke coming from the smokestack. We got out of the light blue state owned station wagon with the LDEQ sticker on the door. Incidentally a plant manager once asked me if I had any friends. I thought about it and said I can't think of a single friend. He said it is no wonder, because nobody wants to see that sticker on a door of a truck coming through the plant gate.
Back on this particular night we stopped the station wagon and stood up outside to read the opacity. This presented us with a problem. We did not expect to find any violations. In the past most of the complaints had been about odor. We had determined that the odor sources were usually related to stagnant water waste ponds at the plant. We usually turned these complaints over to the water protection branch. On this particular night, none of us brought an EPA Method 9 form. We did not document the opacity reading for the required six minutes. We just stood there a few minutes and looked up at the black plume and noticed that it blacked out the stars and it blacked out the security lights at the plant. We all agreed that the plume was 100% opacity. Let this be a warning. Always keep the following items in a briefcase ready to read opacity.
2 ink pens that write
Back to the opacity inspection of 1984. We did not have any of the above, so we just improvised. We observed the opacity a few minutes and agreed that it was 100%, so we decided to walk into the control room to try to document other violations that led to the high opacity. We were shocked at what we found. Here was an incinerator plant that had been on national news for several years. We knew that the control equipment was not working. We knew the opacity was 100%. Personally, I was afraid for my life. I was not sure exactly what they were burning, but I assumed that it was hazardous and extremely toxic. I could smell something awful and I could see clearly that everything was out of control. It reminded me of the movie China Syndrome (Michael Douglas and Jane Fonda) about a meltdown at a nuclear power plant.
The operator was not in the control room. The incinerator was set on manual control and yet the operator was not in the room. Elvis had left the building. We took a tour of the control room for inspection purposes. By now, I was about ready to make a run for it. I figured everything was about to blow up. After about 15 minutes the operator came into the room. He was wet and he said he had been out washing trucks. Several minutes passed before the on-call environmental contact arrived. We spent several hours with them in the control room. I think I got home at 5AM.
As a result of that surprise middle of the night inspection we noted several problems- many that ended up in violations:
Incinerator set on manual but no operator present
Failure to maintain pollution control equipment
Failure to use pollution control equipment
No Standard Operator Procedures (SOPs) posted
Failure to follow SOPS
Failure to use manufacturers instructions
Failure to train operators
No visible emissions opacity certifications posted
No documentation of opacity evaluations
Opacity levels of 100% black smoke
Failure to follow regulations
Failure to comply with permit requirements.
Reluctantly we all had to appear in court for the class action lawsuit. I had to go down to the Salvation Army to get a suit and tie. The trial resulted in the following:
The plant lost the 9 million dollar class action suit.
LDEQ initially fined the plant 4 million dollars. Later the Governor reduced the fine to purchasing an air conditioner for a local school.
The plant operator with 20 years experience with the company was fired.
The plant manager was fired.
The environmental personnel at the plant were all fired.
The value of the company and plant's stock market fell to the bottom.
The plant was sold to another company.
The secretary of LDEQ was not satisfied, she wanted to permanently shut down the plant by revoking the permit to operate.
Governor Edwin Edwards fired the secretary of LDEQ for refusing to back down from revoking the permit.
The Louisiana Attorney General and the East Baron Rouge District Attorney began to suspect that Governor Edwards was politically involved with the plant.
They ordered the State Police and the National Guard to forcibly enter the plant and remove all documentation from the plant for future evidence of corruption.
The US Martial Office joined in on suspicions of corruption by the Governor.
They eventually had the Governor placed in prison for violations relating to gaming. We do not have gambling here in Louisiana, we have gaming.
So partner, here is the moral lesson. Get certified, read your opacity routinely, and document your evaluations. Keep your certificates and documentation handy. You never know when some unexpected visitor just might drop by to spend the day with you.
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|EPA Method 9 Visible Emissions Form|