ADEM Air Division Adds New Reporting Provision To Emission Test Protocol Guidance

The Alabama Department of Environmental Management's Air Division recently issued a revised version of its long-standing guidance document "Emissions Test Protocol and Test Report Requirements." The revised 5-page document is available here. Much of the new document describes procedures for emissions test protocols and other requirements that have been in place for over thirty years. The recent change involves an added requirement that certain other test reports must now be submitted to the Department if those tests are preparatory to or linked to eventual emissions test activities.

The original guidance has implemented ADEM's long-standing requirement for the submission of emissions test protocols for review and approval by the Department prior to conducting emissions tests. As the guidance states: "All stack tests conducted to demonstrate compliance . . . must have a written protocol submitted to the Air Division's Chemical Branch or Energy Branch at least 15 business days before the start of the test unless specified otherwise in the applicable regulations." Those test methods that require audit samples from an EPA-certified provider must be submitted at least 30 days prior to the test date. This is to assure that emissions stack testing is done in a manner consistent with approved EPA methods, or otherwise that any proposed deviations from those methods are reviewed and approved by ADEM before the test is conducted.

What is new is the addition of a requirement that any test performed for engineering or compliance purposes must be reported to the Air Division. The scope of this new requirement appears limited to reporting about engineering testing involving either limited or partial emissions tests (i.e. pre-tests or practice tests) or tests that may be deemed necessary or appropriate by the source in preparation for emissions tests required by the source's air permit. Thus, the guidance is not intended to require that all engineering test results be submitted to the Department. Finally, as to those tests that are subject to the submission requirement, there is no requirement for pre-approval of the test protocols from the Air Division. The Division only wants the test results regardless of the protocols.

As might be expected, the requirement has generated some questions, and the Department has prepared responses.

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