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Environmental Testing/Monitoring: Testing 101. Testing 101. KDHE – BAR – Compliance & Enforcement Section. Testing 101. Air quality concerns Health effects Environmental effects Clean Air Act (CAA) Permits. Why test?. Source: Environmental Protection Agency (EPA). Testing 101.
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Testing 101 • KDHE – BAR – Compliance & Enforcement Section
Testing 101 • Air quality concerns • Health effects • Environmental effects • Clean Air Act (CAA) • Permits • Why test? Source: Environmental Protection Agency (EPA)
Testing 101 • Air quality concerns • Health effects • Environmental effects • Clean Air Act (CAA) • Permits • Why test? Source: Environmental Protection Agency (EPA)
Testing 101 • Types of Tests Performance Test • Goal: Determine emissions • Analyzes stack gas directly • Does not compare data to facility continuous monitoring system (CEMS) • Results reported in concentration (ex: ppm) or as a rate (ex: lb/ton, lb/hr)
Testing 101 • Types of Tests Relative Accuracy Test Audit • Goal: Ensure CEMS accuracy • Compares facility CEMS to reference method CEMS • Similar to cylinder gas audit (CGA) • Results reported in relative accuracy percentage or difference
Testing 101 • What tests? • Permit • State Regulations • Kansas Administrative Regulations (K.A.R.) • Federal Regulations • Code of Federal Regulations (CFR) • Test methods • CFR Appendices • Alternative Test Methods
Testing 101 • The Process
Testing 101 • Help Yourself • Be Proactive not Reactive • Don’t procrastinate • Be aware of deadlines for submitting notifications, protocols, and test results • Schedule tests well in advance • Plan for complications - Problems often arise during testing! • Contingency Plans? • Equipment Failure? • Weather delays? • New contract with new testing company? • What if tests demonstrate non-compliance? • Retesting?
Testing 101 • Help the Testers • Its all about timing • Time of the year • Weather • Site conditions that might affect testing • Is the contractor busy with other facilities? • Be prepared • Have accommodations ready • Familiar with the site? • Access to sampling location – stack and ports • Parking? • Facility contacts • Lots of power available • Retrieve data promptly for quick results
Testing 101 • Help KDHE • Communicating • SID # • Construction and/or Operating Permit # • Reason for test, what regulation is(are) the unit(s) subject to? • Process information • Don’t blindly trust testing company • QA/QC • Always review notifications, protocols, and test results, being submitted • Additional consultant? • Communicate internally - test company selection matters
Testing 101 • Available Resources
Testing 101 • Available Resources Small Business Environmental Assistance Program (SBEAP) • Pollution Prevention Institute • Help small businesses (≤ 100 employees) • Assess environmental compliance responsibilities • Compliance gaps are not reported to regulatory agencies • Identify pollution prevention opportunities
Testing 101 • Looking Forward • Protocol / Report Submission • PTs – Charles Marx • RATAs – Chris Appier • Standardized Forms (to be submitted with reports and/or protocols) • Kansas Electronic Information Management System (KEIMS)
Testing 101 Thank you/Questions