National Stack Testing Guidance. STAPPA/ALAPCO Enforcement and Compliance Workshop St. Louis, Missouri June 25-26, 2003

Transcription

1 National Stack Testing Guidance STAPPA/ALAPCO Enforcement and Compliance Workshop St. Louis, Missouri June 25-26, 2003

2 Why national stack testing guidance? Stack testing is one of the primary methods for determining a facility s ability to comply with CAA Stack testing has not been consistently applied by EPA or S/L 2000 Inspector General Report criticized OECA for: Not issuing comprehensive national guidance Inadequate oversight of S/L stack testing programs

3 How has OECA addressed IG s concerns? Issuance of revised CMS in April 2001 Universe of sources subject to stack testing Frequency of stack tests Reporting of test results Emphasis of existing HPV Policy How violations must be resolved Issuance of National Stack Testing Guidance (Sept 2003)

4 Process for drafting guidance OECA formed workgroup consisting of HQ and Regional representatives Reviewed existing Agency policies Evaluated existing S/L regulations/guidance Solicited S/L input

5 Goals of the national guidance Expand upon CMS & HPV guidance to fully address IG s concerns Improve uniformity of how stack tests are conducted Improve coordination between EPA and S/L Provide framework for assessing the effectiveness of S/L stack testing programs

6 CMS guidance on stack testing S/L should conduct a stack test whenever they deem appropriate S/L should conduct a stack test when there are no other means for determining compliance In determining when a stack test is necessary, S/L should consider Size of emission unit Time elapsed since last stack test Results of that test and margin of compliance Condition of equipment Availability and results of associated monitoring data

7 CMS Guidance on Stack Testing (cont) S/L are responsible for: Reporting date & results of all stack tests Adjusting the HPV status as appropriate Stack test reporting by pollutant currently being discussed with ECOS Some S/L have begun voluntarily reporting stack tests by pollutant

8 HPV guidance on stack tests Facilities are expected to be in compliance with emission limits at all times Failing a stack test is a violation for which appropriate enforcement must be taken

9 Issues addressed by national stack testing guidance Time frames for conducting tests Waivers Notification of stack tests Observation of stack tests Representative Conditions Stoppages Postponements Test Reports Technical Issues

10 Can facilities be granted additional time to complete a stack test? Time frames for conducting initial stack tests are established by regulation (i.e. NSPS, NESHAPS, MACT) There are no regulatory provisions to extend the testing deadlines Failure to test w/in requisite time frame is a violation

11 Time frames for conducting tests (cont) The only way a delegated agency can grant additional time is through issuance of an enforcement action stemming from the failure to test The delegated agency maintains flexibility in determining the scope of the enforcement response, based on the circumstances surrounding the failure to test

12 Should stack tests be waived for identical units? Generally, no Control devices & process operations may alter performance and ability to comply Therefore, waivers should not be granted for identical units, unless The units are located at the same facility, and The source can demonstrate, on an ongoing based, emissions from units are < 50% applicable standard S/L authorized to issue waivers should still consult with Regional office to ensure national consistency

13 What should be considered sufficient notification? Sources are required to adhere to the regulatory time-frames NSPS & NESHAPS (30 days) MACT (60 days) Written notification should be sent to the delegated agency and concurrently to the Regional office The test date should be acceptable to both the regulatory agency and the facility If adequate notification is not provided, results may be rejected and source required to retest

14 What should be considered sufficient notification? (cont) Notification not necessary if test is performed for facility s own benefit, however If facility fails it must report failure & results to delegated agency immediately Testing protocols must be provided as part of notification. While protocols may vary, all should contain certain basic elements A sufficiently detailed protocol is available at: Preparation & Review of Site-Specific Emission Test Plans

15 How often should stack tests be observed? S/L should observe as many stack tests as resources allow If S/L chooses not to observe stack test, prior review of test protocol is critical If adequate notification & an opportunity to observe test is not provided, test data may be rejected and source required to retest

16 What is the appropriate role of the regions for tests conducted for S/L? Regions may observe stack tests whenever deemed appropriate Consistent with CMS, Regions will periodically conduct analysis to determine if: Tests are being conducted properly Results are being interpreted and reported accurately

17 What are representative conditions under which stack tests should be conducted? A facility should test under the most severe conditions that create the highest emissions If operating at maximum capacity would result in the highest emissions, the facility should Test at maximum allowable/permitted capacity Using the highest emitting fuel for the pollutant tested Process material that causes the highest emissions

18 What are representative conditions under which stack tests should be conducted? (cont) For certain facilities, maximum capacity may not represent conditions resulting in the highest emissions In such circumstances, the facility may test at a lesser capacity upon documenting that this level results in the highest emissions

19 Is it ever appropriate to stop a test once started? Failure to complete a stack test once it is initiated is a violation of the requirement to conduct a stack test An enforcement order should be issued to ensure that a stack test is ultimately conducted The delegated agency maintains flexibility in determining the scope of the enforcement response, based on the circumstances surrounding the stoppage

20 Is it ever allowable to postpone a stack test? Postponements should be treated similar to stoppages An enforcement order should be issued to ensure that a test is ultimately conducted The delegated agency maintains flexibility in determining the scope of the enforcement response

21 What information is needed to document stack test results? A written test report must include sufficiently detailed information to document compliance with the regulatory requirements & test procedures All test reports should include certain basic elements. A prototype of a sufficiently detailed test report is provided at: Preparation and Review of Emission Test Reports

22 Technical issues addressed within guidance Soot-blowing Regarded as routine maintenance, constituting representative conditions and should be included as an element of stack test Rounding of significant figures Guidance affirms the practices of the American Society for Testing and Materials

23 Next Steps / Timeline Release draft guidance for review & comment June 2003 Proposed deadline for submission of comments July 31, 2003 Issuance of final guidance Sept 2003

24 Contact Information Greg Gholson (617) Mailing Address: US EPA (Mailcode SEW) 1 Congress Street, Suite 1100 Boston, MA