Mitchell, Williams, Selig, Gates & Woodyard, P.L.L.C.

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The United States Environmental Protection Agency (“EPA”) Office of Inspector General (“OIG”) issued an April 10th Project Notification that it plans to:

. . . begin preliminary research for an audit of the EPA’s oversight of smokestack emissions testing and reporting, with an initial emphasis on EPA Region 10.

OIG states its objective is to determine the effectiveness of EPA oversight in assuring emission stack tests are conducted in accordance with EPA regulation, policy and guidance.

Assorted equipment, devices, methods, and tests are utilized by various stationary sources to verify the initial and/or continued proper operation of the required air pollution control equipment. This determination is typically based on a comparison of the amount of pollutant the stationary source is permitted and/or projected to emit with the amount actually emitted.

Periodic measurement of emissions from stationary sources are often accomplished with stack sampling. This direct measurement involves obtaining a representative sample form the specific facility emission point. In order to ensure results are representative of actual facility operating conditions, multiple samplings of each stack may be necessary.

OIG has asked that EPA provide the following before or at the project kickoff meeting:

  • Access to any EPA databases that Region 10 facilities use to report required stack testing data (including quality assurance data) to the EPA
  • Policies, procedures and guidance related to stack testing; EPA Methods 1, 2 and 5; and the EPA’s oversight of stack testing and reporting.

A copy of the April 10th OIG Project Notification can be downloaded here.