The Source Sampling Section is responsible for auditing source (stack) tests and continuous emission monitors (CEMs) test data to ensure that the methods and procedures used comply with established federal and state standards. In addition, the section is involved with coordinating activities relating to source and CEMs tests. Typically, a request for a source test or the installation of a CEM is originated by one of the other programs (e.g. Permit Review Branch, Field Operations Branch or even the Division of Enforcement). For instance, a permit or a regulation may require that a CEM be installed on a particular process or that a source test be conducted after startup and/or periodically. No matter the reason, if the test is to be successful and if the data is to be useful, it is important that those required to conduct a stationary source test meet the federal and state stack testing regulations. The Source Sampling Section helps bridge the gap between a facility or Agency of Interest (AI) and the permitted or regulatory testing requirements through pre-test protocol reviews, on-site test observations, and post-test technical reviews of the test report data.
The Division for Air Quality (DAQ) divides the majority of the stationary source tests into two categories - compliance demonstration and Relative Accuracy Test Audits.
- A compliance test (performance test or stack test) measures the amount of a specific pollutant or pollutants being emitted through regulated stacks at an AI. It involves the use of standardized procedures and calibrated tools. Compliance tests generally serve two purposes: 1) initial determination that an AI has the ability to comply with requirements, and 2) ongoing compliance demonstration with the emissions limits established for the AI.
- A Relative Accuracy Test Audit (RATA, RAA, RA, RCA) measures the performance of a CEM operating at a source’s emission point. The audit test is a quality assurance performance test used to validate the data collected with a CEM. The audit testing may use United States Environmental Protection Agency (U.S. EPA) Federal Reference Method (FRM) test methods or U.S. EPA protocol gas to check the performance of the CEM. If the CEM reports a concentration within an allowable percentage of the concentration found using the FRM test or the known concentration of the protocol gas, then the CEM passes the audit.
401 KAR 50:045. Performance tests. Section 2. Pretest Requirements
- (1) A source required to conduct a performance test shall submit a completed Compliance Test Protocol form, DEP form 6028, or a test protocol a source has developed for submission to other regulatory agencies, in a format approved by the cabinet, to the cabinet's DAQ a minimum of 60 days prior to the scheduled test date.
- (2) The cabinet shall review the Compliance Test Protocol submittal for approvability and determine the need for a pretest meeting with the source.
- (3) If a pretest meeting is held:
- (a) The source shall resolve with the division all testing and process issues; and
- (b) The division's approval shall be in writing and sent to the source.
- (4) The source shall not deviate from the approved pretest protocol without the division's prior approval.
On Sept. 13, 2010, the U.S. Environmental Protection Agency (EPA) issued the final rule to restructure the stationary source audit program. Audit samples must be analyzed along with the samples collected while testing for regulatory compliance. The changes finalized in this rule allow accredited providers to supply the audit samples and require sources to obtain and use audit samples obtained from the accredited providers instead of EPA, as was the former practice. The list of required audit samples for testing methods can be found at: https://www.epa.gov/emc/emc-technical-support
It is important that an AI and/or the test firm conducting the test communicate with the division to schedule a test date. The Source Sampling Section coordinates with the division’s Field Operations Branch, Permit Review Branch, AI, and test firm to schedule a test date. This coordination provides the best opportunity for the division to have personnel on-site to observe the source test. Federal and state regulation requires a 30- to 60-day notification prior to the test, specifically, to afford the division an opportunity to observe the test. The majority of the test dates are scheduled with the submittal of the Test Protocol and confirmed with the test notification.
A final test report is required to be submitted to the division 45 days after the test has been completed. The 45-day requirement is listed in Section G – General Provisions of the AI’s current permit. Federal regulation may require a shorter or longer time period for the test report to be submitted. It is the AI’s responsibility to meet all federal and state regulations. The KYDAQ Source Test Report Format
guidance document provides a summary of how a test report should be organized and formatted before it is submitted to the division.
All test protocols, test notifications, test reports and any test-related documentation shall be submitted to the DAQ’s Source Sampling Section. Documents may be submitted in a hardcopy or electronic format. Hardcopy documents shall be delivered to the Division for Air Quality, Attn: Source Sampling Section (to the address below).
Electronic copies may be emailed to Jessica.Dixon@ky.gov
or submitted through the Sampling Protocol and Test Report Submittal
eForm website. Emailed documents are limited to ~9MB. Documents submitted through the eForm website are limited to 100MB.