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Will Whitlow Enterprises training and certificates stand up in court?
Whitlow Enterprises Smoke School EPA Method 9 and 22 visible emissions opacity certification programs follow EPA guidelines in accordance with 40 CFR 60 Appendix A. Whitlow smoke schools have been tested by court.
Example:
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. I do not know if the county employee was asleep during his classroom. I do not know if he attended a classroom- the EPA does not require classroom attendance. The EPA recommends classroom attendance. The employee could have attended another smoke school provider classroom. I personally have attended other smoke school providers classrooms many times. I saw a lot of people sleeping.
The point is in this particular Kentucky court case the county official conducting the opacity evaluation inspection 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.
A business size certificate wallet card for passing the certification test
A certificate on certificate paper for passing the certification test
A certificate for attending the classroom lecture
The moral of the story is that you should attend a Whitlow Enterprises smoke school and you should attend our classroom. We teach you what you need to learn about reading opacity. In the above court case, the court verdict was an embarrassment to the employee and to his agency. In the past as a Louisiana DEQ state air quality environmental inspector, I have been embarrassed in court a time or two. It does not feel good when my boss had his mouth yelling in my ear. It reminded me of Air Force Boot Camp. We will be happy to train your state and federal environmental employees with or without a state contract. Contact us email,snail,phone
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