What to Expect During Your Compliance Emissions Testing
A Compliance Emissions Test is an emissions test performed under the supervision of the regulating agency (usually a state agency, but sometimes US EPA) for the purpose of determining compliance status with respect to permitted emissions limits.
A Pretest Protocol is submitted to your state regulatory agency (and sometimes US EPA) in advance of testing. State agencies require at least 30-60 days prior to performance of the test program. Testing under most Subparts that require involvement of US EPA require submittal at least 60 days prior. This Protocol defines the test methodologies to be utilized as well as process operations expected during the test program.
Test Crew Arrival
The test crew will usually arrive on-site the afternoon prior to the first day that testing is scheduled to set up the test equipment. Most analyzers perform much more consistently if allowed to warm up and stabilize overnight; so hooking up power to the Environmental Mobile Laboratory (EML), the day preceding testing is critical. Please plan to have an electrician standing by and ready to connect power to the EML as soon as the test crew arrives onsite. Delays here can incur additional costs. Your project proposal specifies rather testing requires a lab trailer or not.
In order for a compliance emissions test to be considered valid, the process under test must operate at a certain minimum load, usually 90% of rated maximum, as specified in the emissions license. It is essential to arrange process conditions to meet this requirement, as failure to do so may result in the test results being rejected by the reviewing agency. The test protocol prepared by your Air Measurement Project Engineer will specify the process conditions necessary for testing.
A normal compliance test consists of triplicate tests for each pollutant at each source. Tests are typically 1 hour in length but for certain pollutants such as dioxin and metals may be longer, up to 4 hours or more. Most pollutants can be tested for simultaneously, but some cannot be due to logistical complications. Some time is required between tests for calibrations and wet method train (if applicable) turn around. Details of the number of tests and time required are stated in the project proposal.
Process Data Recording
During testing, process data sufficient to define the operations of the emissions source must be collected at a minimum frequency of once every 15 minutes. The exact data to be collected will be defined in the Pretest Protocol, and may take the form of operator’s logs, electronically-recorded data, strip charts, or even hand-written observations. It is critical that you or someone you designate ensure that all necessary process data is collected and given to the test crew before they depart. Insufficient or incomplete process data is a common reason for a test report to be rejected by the reviewing agency.
A representative of your state’s Department of Environmental Protection (or equivalent) will likely elect to observe all or part of the test program. For some test programs falling under the direct jurisdiction of US EPA, a representative from the regional EPA office may attend as well. This test administrator may or may not be your regular department contact. While on-site, the administrator will likely be most interested in observing how the testing is conducted. Air Measurement personnel are highly experienced in dealing with state test administrators. He/she may also wish to examine the emissions source and/or other plant operations. It is incumbent upon your facility to provide the administrator with access to whatever information and records he/she deems necessary. Depending on your plant’s security policy, you may also need to provide the administrator with an escort while he/she is on-site.
Test Crew Departure
As soon as all parties involved are assured that the test program was a success, the test crew will begin demobilizing. Please have an electrician available to disconnect power to the EML within one half hour from the conclusion of testing (if applicable). Be sure to provide copies of all process data necessary to the test crew before the crew leaves your facility.
Shortly after testing is completed (generally within two weeks) you will receive a draft copy of Air Measurement’s test report to review. Please promptly communicate your feedback on the test report to the Air Measurement engineer responsible for your project, who will take it under advisement before submitting the final test report. Unless you desire otherwise, Air Measurement will submit the test report directly to the appropriate personnel at your state’s environmental department / US EPA. Reports are submitted in PDF format, with printed and bound copies available on request.
If you have any questions concerning your upcoming compliance emissions test, don’t hesitate to contact your Air Measurement Project Engineer by phone or e-mail. Air Measurement personnel have years of experience performing similar testing and will work diligently to ensure that you are satisfied with the results of your test program.
Pretest Preparation Checklist
In order for your compliance test to be completed as quickly and efficiently as possible, please:
☐ Arrange access to any required site-specific safety training for the test crew. If this can be performed online in advance of test crew arrival, send any required information to your Air Measurement Project Engineer.
☐ Inform plant security personnel of the test crew’s anticipated arrival, if necessary.
☐ Check all sampling ports for blockage and ensure all port covers can be removed by hand. Significant extra charges can be incurred if testing is delayed due to port blockage.
☐ Ensure that safe access to the test site is possible. Remove ice and snow from the work area, if applicable.
☐ If testing requires an aerial lift to access the sampling location, please ensure that it is available the day prior to testing for equipment setup and port inspection.
☐ Ensure that the process to be tested is operating normally and that there is sufficient production scheduled on the test date(s) to ensure adequate load.
If Testing Requires a Trailer:
☐ Ensure there is a level, secure location at least 10’x25’ within 50’ of the electrical power hookup and within 100’ of the test location for trailer parking.
☐ Have a qualified electrician ready upon test crew arrival to connect electrical power to the EML. Air Measurement’s EMLs require 220-volt, single phase power, on a 100-amp circuit (60-amp may be suitable under certain conditions). 208-volt power (2 hot legs from a 3-phase circuit) can suffice. The trailer power cord has 4 bare wire leads (4-gauge) that will need to be wired into a junction box.