Preparing for Emission Source Testing
Source testing is a significant tool used to determine a facility’s compliance with emission limits, or to capture or control efficiencies set according to the Clean Air Act. Also known as performance or stack testing, these synonymous terms relate to measurement of the amount of specific regulated pollutant or pollutants emitted.
As an EHS professional, you may not think about the complexities of emission source testing too much. Often, you’ll contract out the expertise of a source test company to complete this work for you. Regardless, there are still preparations you can take to make the tests run smoothly.
A few simple best practices can help you gain:
- more confidence in the final product/report from the source test company
- improved compliance due to better results from the source test
- cost savings, from less time that the testing company is onsite, billing you
When preparing for emission source testing, consider the following best practices:
- Keep processes in good operating condition. Operating efficiency not only saves on cost, but it also results in lower emissions. Occasionally vacuum out your ductwork. Specifically, do this shortly before a test is performed if you have very dusty processes. Additional dust may yield higher results than your actual emissions, which can have a negative impact on your facility.
- Test the air flow efficiency from your process to your stack. Balance what comes in with what goes out. Companies have found ducts that were not going where they expected or flows that were greater coming in than going out through the stack. Issues with air flow exposed during the testing process can cause expensive delays or the need for costly retesting.
- Review the test plan, ask questions and understand what will be done. Often, this review is too hasty, which results in blind trust of the test company. Taking the time to perform a close review of what is being sent will ensure greater accuracy and will more likely meet the requirements set forth in your permit. Look for outdated points of contact within your company and at the agency. Also look for dated permit numbers and test methods—your test company may not be aware of changes within your facility or personnel.
- Coordinate access for the test company. Make sure they have access and can safely get to relevant locations. If they’ll be on the roof or a stack, is there fall protection in place? Will they face heat or cold stress? If so, make sure they have suitable personal protective equipment. Have they taken care of any necessary pre-work training, or is it identified in the work schedule? Often, source testing days need every minute possible to complete all the required tests. Can the test company (and you) save time by getting training done ahead of time?
- Have a dedicated point of contact. Instead of relying on yourself or the operator on shift, designate a responsible individual (someone seen as a problem-solver) to be the main contact for the test company on the day of testing. This allows those on their regular shift—including yourself—to continue getting the day-to-day activities done.
- Think through logistics and have a plan. Sometimes the simplest things are left out of the planning process but need to be thought through, such as power sources, parking and communication. Frequently, the trailers used in source testing need power—so you might need to know where to plug an extension cord. You’ll need to know the best parking place for the test trailer (and whether that needs to be an area open and free from other work). Do you have a plan for communicating with the test company, control rooms and designated point of contact? If you use radios, be sure they have a full battery charge and are on the same channel.
Unfortunately, these little details can often cause unnecessary stress on the day of testing. With some planning and preparation, you will ease the stress of source testing. After all, passing is crucial for success; you do not want to pay for testing issues, delays or retesting. Being confident and comfortable with the testing process goes a long way when it comes to air quality compliance.
About the Author:
Jessica Stengel joined J. J. Keller & Associates, Inc. in 2021. As an Associate Editor on the Environmental, Health & Safety (EHS) Publishing Team, Jessica’s expertise is in researching and conveying regulatory-based content in easily understandable formats, primarily in the environmental area. Jessica has over five years’ experience as a writer and editor in environmental publishing.
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