Who needs smoke school field training

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Who needs to take smoke school field training and how often.

Federal, state and local permits and regulations require routine visible emissions evaluations by certified opacity observers. Regulations require the field training and certification test every 6 months to maintain certification. Over the past 20 years I have heard many rumors that The EPA plans to make the certificates valid for 2 years. Every once in a blue moon, I call the main smoke school contact person at EPA to ask them about the rumors. In my humble opinion, the 2-year certification test would put all of us smoke school providers out of the business. We all depend on your return visit for certification. We all need you. The EPA has recently informed me to ignore rumors about 2-year certification. The EPA said they have no plans to ever change smoke school. The field training is required every 6 months and EPA recommends the classroom lecture every three years. Some states require the lecture every three years.

A couple of years ago, I was involved in a Kentucky court case disputing an opacity evaluation by a county environmental official. The lawyer for the plant attended our classroom and field training session in order to learn enough about smoke school and opacity to prepare for a defense against the county. The county environmental official read the opacity of steam coming form the smokestack. He did not choose an observation point after the steam evaporated. The steam cools down after it travels a considerable distance from the smokestack. The observation point should be after the steam evaporates. You should read the opacity of any emissions at an observation point that is the densest part of the plume after the steam evaporates. The county official read the opacity at 80% and it should have been zero.

After attending our Whitlow Smoke School, the lawyer and the court visited the plant to conduct opacity evaluations. They chose the proper observation point and read the opacity correctly at zero percent. The plant won the case. Something about the case caused me some alarm. The county official had my signature on his certificate presented as evidence in court. This made me realize a fallacy in the certification process. When I sign my name to the certificate, I am actually stating that the employee simply passed the smoke school test. Since the EPA does not require the attendance at the lecture, and nothing guarantees that participants are alert during the classroom, the certificate does not mean that the attendee knows how to read opacity in the field. I always take a lot of pride in who I am and what we do. Therefore, I want to make sure that every single person that takes my test and passes it gets a certificate. I also want to make sure the attendee knows how to read opacity in the field. Therefore, before every smoke school we have a mini lesson on reading opacity during smoke school and during field evaluations. We hand out three types of certificates.