Updates to Alabama’s Stack Test Protocol and Report Requirements
Posted: July 5th, 2018Authors: Stacy A.
The Alabama Department of Environmental Management (ADEM) published updated guidance, Emissions Test Protocol and Test Report Requirements, dated May 18, 2018. The document summarizes requirements for stack testing protocols and test reports, but does not supersede any established regulations or United States Environmental Protection Agency (U.S. EPA) test methods. The guidance document does not apply to testing of emissions units with no applicable emissions limits; however, if the testing of these units shows that the facility may be exceeding underlying facility standards (i.e., facility-wide emissions limits, state regulations, etc.), then this information should be conveyed to ADEM. The following is a summary of the updates that have been made to the emissions testing requirements. Please note that changes from previous requirements have been bolded.
Pretest Protocol Submission
ADEM previously required a pretest protocol submission addressing emissions testing designed to formally measure compliance against an emissions limit to be submitted at least 10 days in advance of testing. With the May 2018 update, the pretest protocol is required to be submitted at least 15 business days in advance of all compliance tests; however, the information that ADEM requires to be included as part of the pretest protocol has not been changed. The information to be included in the pretest protocol submissions is as follows:
- Name, location, and facility number;
- Description of the source(s) to be tested, associated permit number(s), and a description of the processes to be tested including the feed rate, operating parameters used to control or influence the operations, and the rated capacity;
- Date(s) of the test(s);
- Pollutant(s) being tested, the U.S. EPA test method(s), length of runs, and complete description of the sampling train to be used including the type of probe lining, type of media filter, probe cleaning method, solvent used for sample recovery, instrument spans, sample analysis procedures, and any other relevant information;
- Detailed description of any proposed modifications to the U.S. EPA test method(s) and prior approval documentation if applicable;
- Applicable regulations and pollutant emissions limits;
- Name, telephone number, and email of the testing firm and contact; and
- If audits are required, there must be a statement indicating that audits will be ordered from one of the approved audit providers and will be available for inspection on-site.
Due to the number of protocol submissions received by ADEM, facilities may not always receive a response concerning their submitted pretest protocol. As such, ADEM has stated that if a facility receives no further information requests from ADEM, then the protocol has been deemed approved.
In addition, all deviations from U.S. EPA test methods and/or regulations must be approved by ADEM’s Emissions Measurement Section (EMS) and permit writer. Deviations are not automatically approved and must be resubmitted for approval for all future tests; however, for future tests, the deviation can be limited to a statement in the protocol that implies nothing has changed since the previous approval. Changes that would dictate a new explanation for the test method deviation would be changes regarding the process being tested, reference test methods, etc.
Test Report Submittals
ADEM previously required that all test reports for formal tests used to formally measure compliance against an emissions limit be submitted to the Air Division within 30 days of the actual completion of the test. The May 2018 update has clarified that the test report submitted to the Air Division must be in unbound, hardcopy form and must be submitted within 30 calendar days. The May 2018 update provides a sample test report format, which details all the information that must be included in the test report.
In addition, the results of all tests performed for engineering or compliance purposes must be reported to the Air Division regardless of the compliance status indicated by the results. This includes all test runs, regardless if they are valid or not. The summary of results of engineering tests that are completed as “practice runs” for an upcoming formal compliance test must be submitted to ADEM. Unlike a formal compliance test, ADEM is specifically interested in the results of these tests only and a formal test report or test protocol is not required. ADEM may request more information from the facility for engineering tests on a case-by-case basis.
If you have questions on the updated protocol or report requirements for stack tests in Alabama, please don’t hesitate to reach out to me at 678.460.0324 x213 or firstname.lastname@example.org. Thanks for reading!