Most facilities are required to conduct source testing at some point during their operation. The technical objectives of source testing programs can be unclear, serve multiple objectives, and the data is highly transparent across regulatory agencies and the public. The stakes are high, and quality is of the utmost importance.
In a 2009 document published by the U.S. EPA, source testing was characterized as follows:
Stack testing is an important tool used to determine a facility’s compliance with emission limits, or capture or control efficiencies established pursuant to the CAA. This tool has not always been consistently applied or utilized across the country by the U.S. Environmental Protection Agency (EPA or Agency), or delegated state/local agencies.
It’s important when doing source testing to consider – Why are we doing the testing? How else could the data be used? Who owns the completion of the emissions test program? Are we doing it correctly? These questions along with the frequency of testing and staff turnover can make source testing feel like an overwhelming task. The key to a successful source testing program is being prepared with the knowledge of a facility’s processes, the applicable regulations surrounding those processes, and the testing methods required by the applicable regulations.
ALL4’s Source Testing Program Management Services
ALL4’s source testing support services range from work product reviews to program management and can include the following:
- Designing a source testing program to achieve various goals (compliance, operational flexibility, information gathering, control system evaluation)
- Commenting on proposed source testing requirements in regulations or permits
- Requesting approval for alternate testing methods
- Negotiating the content of a source testing program with the agency
- Requesting source testing deferrals
- Preparing language for requests for proposals from source testing contractors
- Review and/or development of a source testing protocol outlining the methods and protocols to be followed during the testing program
- Development of a source testing plan to outline the timeline of the testing and what resources are needed for each step (i.e., when does environmental need to be involved vs. operations, etc.)
- Providing onsite stack testing support and program management (working with the source testing contractor to allow facility environmental staff to focus on their core duties)
- Acting as the point of contact for the state or Federal agency
- Evaluating the data collected and assessing results of the source testing program
- Legacy knowledge transfer by providing the continuity of staff from one source testing program to the next
- Expert testimony
Why Use ALL4 to Support your Source Testing Program?
Source testing is foundational to developing and complying with many air quality regulations, so it is important to set yourself up for success when contemplating a source testing program – we can help. ALL4 has multiple staff with years of source testing experience who understand the components of a successful source testing program. Planning for and conducting source testing takes time and effort; ALL4 can work as an extension of your facility’s environmental staff and relieve some of the burdens in the test planning, execution, and review phases. ALL4 has supported clients in a variety of industries across the country with many facets of source testing programs, from the management of small, one-time testing events to large complex testing programs. We have worked with facilities and industry associations to negotiate the scope of testing programs required by agency information collection requests and other orders, to minimize facility burden while providing the agency with useful information. We can develop testing programs with site-specific operations, regulatory constraints, and long-term goals in mind.
Source Testing Basics Training >
To learn more about how ALL4 can help you with your source testing program, please contact ALL4’s Tech Team Leader – CMS, Meghan Barber, at mbarber@all4inc.com.
