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  • Compliance Guidance for Stationary Sources

    Stationary sources with air quality operating permits typically have testing and reporting requirements written into their permits, or have these requirements as a result of an applicable industry-based standard contained in 40 CFR Part 60 (New Source Performance Standards - NSPS) or Part 63 (National Emissions Standards for Hazardous Air Pollutants - NESHAP).  This section provides general guidance for testing and reporting for stationary sources.

    Stack Testing (Performance Testing)

    What is stack testing?

    Stack testing refers to the performance testing of process equipment and/or air pollution control devices which control emissions from process equipment. The testing may be done for emissions from the stack of an air pollution control device, or in the case of opacity for example, may be done for fugitive emissions from a piece of equipment.

    When does testing need to be done?

    If your facility is subject to the federal requirements of New Source Performance Standards (NSPS, 40 CFR Part 60), you will be required to conduct initial performance testing of process equipment and/or air pollution control devices as specified by an industry-based standard contained in the subpart(s) of Part 60 pertaining to your facility. General Part 60 performance testing rules contained in 40 CFR §60.8 require initial performance testing and test report submittal for affected equipment within 60 days after achieving maximum sustained production rate, but no later than 180 days after initial startup.

    If your facility is subject to the federal requirements of the National Emissions Standards for Hazardous Air Pollutants (NESHAP, 40 CFR Part 63), you may be required to conduct performance testing, depending on the specific subpart(s) of Part 63 pertaining to your facility. General Part 63 performance testing rules contained in 40 CFR §63.7 contain information relating to this testing.

    Your stationary source air quality operating permit may also contain requirements for periodic performance testing for certain processes or equipment. Make sure that the periodic testing is conducted within the time frames specified within your permit.

    What notifications must I submit prior to initial performance testing?

    General NSPS notification rules contained in 40 CFR §60.7 require:
    • Notification of the date of construction or reconstruction of affected equipment, postmarked no later than 30 days after such date;
    • Notification of the actual date of initial startup of affected equipment, postmarked within 15 days after such date;
    • Notification of any physical or operational change to an existing facility which may increase the emission rate, postmarked 60 days or as soon as practicable before the change is commenced;
    • Notification of any performance testing at least 30 days prior to the scheduled test date.  If after 30 days notice for an initially scheduled performance test, there is a delay (due to operational problems, etc.) the owner or operator of an affected facility shall notify PDEQ, either providing at least 7 days prior notice of the rescheduled date of the performance test, or by arranging a rescheduled date with PDEQ by mutual agreement.

    General NESHAP performance testing rules contained in 40 CFR §63.7 require:
    • Notification of performance testing in writing at least 60 calendar days prior to the performance test.

    These notifications, in addition to all other documents submitted to PDEQ, should contain a Certification of Truth, Accuracy and Completeness (CTAC) signed by the Responsible Official (RO) for the air quality operating permit. The CTAC is required for Class I sources by PCC 17.12.160.I and for Class II and II sources by PCC 17.12.165.H.

    How do I submit these notifications?

    You may send notifications to the following address:
    Attn: Air Compliance Program
    Pima County Department of Environmental Quality
    33 N Stone Avenue, Suite 700
    Tucson, AZ 85701

     

    You may also submit Stack Testing notifications and results via email by contacting the PDEQ Air Compliance Section at (520) 724-7322 and requesting the exclusive email address for electronic submittals.  Once in possession of the email address, permitees may submit all future Stack Testing notifications and results electronically.      

    Please be sure to include a signed Certification of Truth, Accuracy and Completeness (CTAC) with each submittal. 

    When do I need to submit a test plan?

    At least 14 calendar days prior to performing a test, a test plan must be submitted to PDEQ in accordance with the Arizona Testing Manual, as required by PCC 17.12.050D. This test plan should be submitted along with a signed Certification of Truth, Accuracy and Completeness (CTAC) described above. The test plan may be submitted via email, provided the signed CTAC form is attached.

    What does the test plan need to contain?

    The test plan should contain the elements specified in the Arizona Testing Manual which include:
    • Source Information (name, address, phone number, serial number of equipment being tested)
    • Testing Firm Information (name, address and phone number)
    • Description of Sampling Equipment (including schematic of sampling train)
    • Test Procedures (including list of pollutants to be sampled)
    • Emission Point Information (diagram of stack showing dimensions and sampling location and ports)
    • Process Information (including all control devices, fans and bypasses)
    • Process Equipment (description of process equipment, including process flow diagram, maximum rated capacity and actual maximum operating rate, process data being monitored and recorded during the test, normal process operating schedule during a 24-hour period)
    • Control Equipment (description of emission control system, including type of control equipment, rated capacity, data to be monitored and recorded to ensure representative operation of the control equipment such as flow rates, pressure drops, temperature, and minimum acceptable values for these parameters)
    • Quality Assurance/Quality Control (procedures such as calibrations used to maintain QA/QC)

    Who does the testing?

    EPA test methods may require certifications and training and/or equipment and expertise which most permitted facilities do not have. Although the hiring of a stack testing company is not required, it may be advantageous to hire such a company to ensure that the testing is conducted properly, in accordance with the appropriate test methods.  PDEQ does not endorse any stack testing companies; however, a list of testing companies is provided on the EPA's Emission Measurement Center website.

    What tests should be conducted?

    The parameters selected for testing will be specified within your air quality permit and/or the subpart(s) of 40 CFR Part 60 (NSPS) or Part 63 (NESHAP) which is applicable to your facility. Performance tests shall be conducted and data reduced in accordance with the test methods and procedures contained in the Arizona Testing Manual; 40 CFR Part 52 Appendices D and E; 40 CFR Part 60 Appendices A through F; and 40 CFR Part 61 Appendices B and C. Three test runs are required for each performance test, in accordance with PCC 17.12.050.F. Testing should be conducted while process equipment is operating at the maximum anticipated representative process rate. Any stoppages during testing should be documented and the reasons for such stoppages reported to PDEQ. Per PCC 17.12.050.F, tests may only be stopped for good cause, which includes forced shutdown, failure of an irreplaceable portion of the sample train, extreme meteorological conditions, or other circumstances beyond the operator's control. Termination of testing without good cause after the first test run is commenced shall constitute a failure of the test.

    When does the test report need to be submitted?

    The final test report should be submitted to PDEQ within 30 days after the completion of the testing, in accordance with the Arizona Testing Manual.

    What does the test report need to contain?

    Per the Arizona Testing Manual, the test report should include the following:
    • General Information (facility name and location, equipment/source sampled, testing company name and address)
    • Certification (by the testing company)
    • Introduction (test purpose, dates, pollutants tested)
    • Summary of Results (emission results, process data, allowable emissions)
    • Source Operation (description of source and control devices, process and control equipment data, representativeness of materials and operation)
    • Sampling and Analysis Procedures (sampling port location and stack cross-section with dimensions, description of sampling procedures, description of analytical procedures)
    • Appendices (complete results with example calculations, copies of original field and laboratory data sheets, copies of original production data signed by plant official, test log, calibration procedures and results, project participants and titles)

    How can I obtain training for stack testing?

    The EPA has provided the Clean Air Act National Stack Testing Guidance for additional information on stack testing.

    Opacity of visible emission is a frequently tested parameter during stack testing, and is measured using EPA Method 9. Opacity Certification, also known as Smoke School, is the formal training required to determine opacity by this test method. For more information on opacity:

    Compliance Certifications

    Who needs to submit compliance certifications?

    Class I stationary sources are required to submit annual or semi-annual compliance certifications pursuant to PCC 17.12.220.  PDEQ no longer requires compliance certifications for Class II and III stationary sources.

    What do compliance certifications contain?

    PCC 17.12.220.A.2.c describes the requirements for compliance certifications, including:
    • The identification of each term or condition of the permit that is the basis of the certification;
    • The identification of the methods or other means used for determining the compliance status with each condition during the certification period;
    • The status of compliance during the certification period, including whether compliance was continuous or intermittent;
    • Identification of any deviation from permit conditions, including excess emissions.
    Please review additional requirements in your permit and PCC 17.12.220.A.2.c.

    Where do I send compliance certifications?

    Permitted Class I stationary sources must submit compliance certifications to both PDEQ and the EPA Administrator.

    Compliance certifications should be sent to PDEQ at the following address:

    Attn: Air Compliance Program
    Pima County Department of Environmental Quality
    33 N. Stone Avenue, Suite 700
    Tucson, AZ 85701

    You may also submit Compliance Certifications via email by contacting the PDEQ Air Compliance Section at (520) 724-7322 and requesting the exclusive email address for electronic submittals.  Once in possession of the email address, permitees may submit all future Compliance Certifications electronically.      

    Please be sure to include a signed Certification of Truth, Accuracy and Completeness (CTAC) with each submittal. 

    Compliance certifications must also be submitted to the EPA Administrator
    :
    EPA Region 9 Enforcement Office
    75 Hawthorne Street (Air-5)
    San Francisco, CA 94105

    Summary Monitoring Reports

    Who needs to submit summary monitoring reports?

    Class I stationary sources are required to submit semi-annual summary monitoring reports pursuant to PCC 17.12.180.A.5.a. PDEQ no longer requires summary monitoring reports for Class II and III stationary sources. Sources may also be required to submit summary monitoring reports if they are subject to specific portions of 40 CFR Part 60 (New Source Performance Standards - NSPS), Part 63 (National Emission Standards for Hazardous Air Pollutants - NESHAP), or Part 64 (Compliance Assurance Monitoring - CAM).

    What do summary monitoring reports contain?

    Summary monitoring reports do not need to contain actual monitoring data, unless specifically required by federal rule. Sufficient information should be submitted which allows PDEQ to determine that the required monitoring was complete, and was conducted as specified in permit conditions and/or federal rule. The following information will suffice as a minimum:
    • Provide an outline of the required monitoring, as described in permit conditions or the applicable federal rule;
    • Include the frequency of each type of monitoring;
    • Certify that the monitoring was conducted as specified and at the required frequency.
    • If deviations from permit conditions occurred during the period of time covered by the report, these should be identified in the report.

    Where do I send summary monitoring reports?

    Permitted Class I stationary sources must submit summary monitoring reports to PDEQ at the following address:
    Attn: Air Compliance Program
    Pima County Department of Environmental Quality
    33 N. Stone Avenue, Suite 700
    Tucson, AZ 85701
    You may also submit Monitoring Reports via email by contacting the PDEQ Air Compliance Section at (520) 724-7322 and requesting the exclusive email address for electronic submittals.  Once in possession of the email address, permitees may submit all future Monitoring Reports electronically.      

    Please be sure to include a signed Certification of Truth, Accuracy and Completeness (CTAC) with each submittal. 

    Excess Emissions/Permit Deviations

    Class I, II and III permitted stationary sources are required to report excess emissions pursuant to PCC 17.12.040 and report permit deviations pursuant to PCC 17.12.180.A.5.b. Each type of reporting is described below.

    Excess Emissions Reporting

    An excess emission results from the release of an air pollutant to the atmosphere at a level which exceeds an emission limitation specified in the air quality operating permit or applicable federal standard. Excess emissions may occur from failure of an air pollution control device, or may occur as fugitive emissions.

    What notifications are required for excess emissions?

    The notification of excess emissions consists of two parts:
    • Notification must be made by telephone, fax, or email within 24 hours of the time the owner or operator first learned of the occurrence of the excess emissions.
    • Detailed written notification by submission of an excess emissions report must be done within 72 hours of the initial telephone, fax, or email notification.

    How do I make the initial notification of excess emissions?

    To make the initial notification by telephone, please call the PDEQ main number at (520) 724-7400. To make the initial notification by fax, please fax to (520) 838-7432. If you prefer, you may send the initial notification via email by submitting an Air Permit Inquiry and specifying you would like to submit your document electronically. The initial notification should include all available information which is required for the written report.

    What is required in the written excess emissions report?

    The written excess emissions report should contain the following:
    • Identity of each stack or other emission point where the excess emissions occurred;
    • Magnitude of the excess emissions expressed in the units of the applicable emission limitation and the operating data and calculations used in determining the magnitude of the excess emissions;
    • The time and duration, or expected duration of the excess emissions;
    • Identity of the equipment from which the excess emissions emanated;
    • The nature and cause of the emissions;
    • Steps taken, if the excess emissions were the result of a malfunction, to remedy the malfunction and the steps taken or planned to prevent the recurrence of the malfunction;
    • The steps that were or are being taken to limit the excess emissions; and
    • If the air quality permit contains procedures governing source operation during periods of startup or malfunction and the excess emissions resulted from startup or malfunction, a list of the steps taken to comply with the permit procedures.

    Where do I send the written excess emissions report?

    Written excess emissions reports should be sent to PDEQ at the following address:
    Attn: Air Compliance Program
    Pima County Department of Environmental Quality
    33 N. Stone Avenue, Suite 700
    Tucson, AZ 85701
    You may also submit Excess Emissions reports via email by contacting the PDEQ Air Compliance Section at (520) 724-7322 and requesting the exclusive email address for electronic submittals.  Once in possession of the email address, permitees may submit all future Excess Emissions reports electronically.      

    Please be sure to include a signed Certification of Truth, Accuracy and Completeness (CTAC) with each submittal. 

    Permit Deviation Reporting

    A permit deviation is an event or circumstance which deviates from permit conditions.  Excess emissions constitute a permit deviation.  However, permit deviations can occur over a broad range of circumstances which may or may not result in excess emissions.

    What notifications are required for permit deviations and when must they be submitted?

    Prompt written notification of permit deviations is required by certified mail, hand delivery or email within two working days of the time when the permit deviation was discovered. Notification will consist of a written report which contains the following:
    • Identification of the permit condition(s) for which the deviation occurred;
    • Identification of the equipment involved in the deviation;
    • Explanation of the probable cause of the deviation; and
    • Description of any corrective actions or preventive measures taken.

    Written permit deviation reports may be sent or delivered to the same address shown above, or emailed as instructed above. Please be sure to include a Certification of Truth, Accuracy and Completeness (CTAC) signed by the Responsible Official for the air quality permit with each submittal.
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    Department of Environmental Quality

    33 N. Stone Ave., Suite 700
    Tucson, AZ 85701

    Phone: (520) 724-7400
    Fax: (520) 838-7432


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