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Observing Emission Tests SOP

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Observing Emission Tests SOP Division of Air Pollution Control March 1, 2019 Observing Emission Tests SOP This document contains the Standard Operating Procedures (SOP) for Ohio EPA, Division of Air Pollution Control (DAPC) staff who observe emission tests. Purpose This SOP is designed to do the following: • Inform staff of DAPC’s basic expectations for observing emission tests. • Inform staff of on-site procedures they should follow in order to adequately observe an emission test. ITT review and acceptance, report review, acceptance/rejection recommendation and the logging of results in Stars 2 is also required, but outside the scope of this guidance. • Remind staff of the key steps they must take, as required, to ensure Ohio EPA personal safety procedures and policies are followed during emission tests. Emission Test Observation Expectations Have a basic understanding of permit requirements, approved ITT, the type of process being tested, and a reasonable understanding of the test methods being employed during the emission tests. Be present where the emission test activities are being conducted (i.e., stack, duct work, scaffolding, platforms, etc.) unless precluded due to space considerations or by Ohio EPA safety policy. Evaluate the emission testing site to identify any personal safety concerns that would prevent the completion of the observation responsibilities. Staff are expected to follow Ohio EPA’s Safety Office policies and procedures regarding field safety and working at elevated heights. Staff are not expected to work in confined spaces or use a respirator while observing emissions test. If possible, be on site to review test equipment and its condition prior to the first sampling run and observe the first emission test run. Observe the number of emission test runs specified in Engineering Guide #51. Determine if the testing equipment meets Test Method requirements, and if the emission testing is being conducted in accordance with the methods specified in the agreed upon Intent-to-Test Notification. Work with the test team and facility representatives to address unanticipated problems that may arise during the emission tests (i.e., source malfunction, production stoppages, etc.). To the extent possible, assess the data being collected from the testing contractor and the facility to determine that test methods and permit requirements are being met in order to validate each test run, or request that further testing be conducted. Standard Operating Procedures for Observing Emission Tests Pre-Test Procedures: Become familiar with the applicable requirements in the installation or operating permit(s) for the emissions unit(s) to be tested and the information in the approved Intent-to-Test Notification prior to the scheduled emission tests. Conduct a pre-test site visit to the facility location(s) where the emission testing will occur, if necessary. Ensure that any ITT specified or facility-provided personal protective equipment is taken to the facility/location(s) where the emission tests will occur. Check-in at facility guard station or facility office where the facility representative is located and meet the facility representative(s) and show EPA credentials. epa.ohio.gov • 50 W. Town St., Ste. 700 • P.O. Box 1049 • Columbus, OH 43216-1049 • (614) 644-3020 • (614) 644-2737 (fax) Observing Emission Tests SOP Attend facility-specific safety training, where necessary. Obtain any specialized PPE from the facility. Accompany the facility representative(s) to the process operation being tested and/or testing location(s) and meet the process operators and/or emission test team members. Observe where the emission sampling equipment is set-up and determine where observations will have to be made to be able to confirm that the method(s) is/(are) being conducted properly. Evaluate the emission testing site(s) to identify any personal safety concerns that would prevent the completion of the observation responsibilities. [If safety-related concerns exist, relay the specific concerns to the test team and/or facility representatives, as appropriate. If the safety concerns are not or cannot be addressed by the test team and/or facility representative(s), the observers are not obligated to complete their observation responsibilities for that test, and the facility representative(s) should be notified that if the emission test(s) are still conducted they may not constitute a valid compliance demonstration.] Check all quality assurance/quality control documentation and pre-test preparation documents (i.e., gaseous method calibration sheets, nozzle specification sheets, etc.) available from the emission test team. Confer with the emission test team and the facility representatives to ensure that all sampling will be conducted at the appropriate times, that the process will be operated as specified in the agreed upon Intent-to-Test Notification, and that the appropriate process operating data will be collected and included in the final emission test report. Don facility required clothing and/or personal protection equipment for type of test being conducted and location of emission sampling equipment. Check with the facility representative (or co-worker watching over the process operations) to ensure that all personnel are in the appropriate observation positions and that the process being tested is in operation and operating at the appropriate capacity, condition, and/or fuel usage rate for the compliance demonstration. During-Test Procedures: Utilize knowledge of the process operation and the emission test methods being employed to record the appropriate process operation and emission test data. [Please note that some example method checklists and field documentation forms are linked to this document. These example checklists and documentation forms may be used as they exist or with modifications made by the field offices.] Obtain any necessary process and/or control equipment parametric data during the emission test runs as specified in the agreed upon Intent-to-Test Notification. Communicate with on-site process observer, if applicable, and with the facility representative to ensure that the process operation being tested is still operating at the appropriate capacity, condition, and/or fuel usage rate or to determine if and when it is necessary and appropriate to stop the sampling run(s) should there be problems with the testing equipment or process operation. Contact a DO/LAA supervisor or manager (or co-workers, if on site) to determine the best course of action to address any problems that arise during the emission tests, as appropriate. Post-Test Procedures: Observe all necessary quality assurance/quality control activities such as leak checks and calibration drift checks. Observe post-test sample collection and any subsequent recovery of the samples. Obtain copies or scans of the test team’s field data sheets prior to leaving the facility. Return any specialized PPE that had been provided by the facility. Page|2 Observing Emission Tests SOP Reporting of performance tests in STARS2: All completed performance tests shall be reviewed and entered (including submission) into STARS2 “emissions tests” section by the DO/LAA within 90 days of the test date. The STARS2 “emissions test” entry should specify if the test was “witnessed” (by adding the DO/LAA staff names in the “witness(es)” section) only if the observations comply with the guidelines written above. Reference Links: (\\s.socisi01.isi.oitfs.ohio.gov\EPAShares\DAPC)\Engineer\Stack Test\Method Checklists (\\s.socisi01.isi.oitfs.ohio.gov\EPAShares\DAPC)\Engineer\Stack Test\Emission Testing Reference Information (\\s.socisi01.isi.oitfs.ohio.gov\EPAShares\DAPC)\Engineer\Stack Test\Engineering Guides Related to Emission Testing https://www.epa.gov/emc/emc-methods-support-directory https://www.epa.gov/emc Contact For more information, contact [email protected] or (614) 644-3611. Document Information Division: DAPC PCN: multiple Section: Permitting Initial Prepared Date: 11/07/16 Position Description: DO/LAA Stack Test Inspectors SOP Name: SOP09Test Observation.docx Page|3 .
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