Overview
Emissions testing is often required of facilities in West Virginia. The requirement can arise from a condition of a Division of Air Quality (DAQ) rule, a DAQ permit, or by order of the DAQ Director. Two common types of emission tests are the measurement of a pollutant discharged from a process stack or an observation of opacity.
To ensure that valid and appropriate data is obtained from the test, a protocol describing how the test will be conducted and how the source will be operated must be submitted to the DAQ at least 30 days (or more) prior to the anticipated test date. Notice of the actual test date must be submitted at least 15 days (or more) prior to that date. Most DAQ issued permits describe these notification requirements in the General Conditions section.
The protocol and notice must be submitted in writing to:
Director
West Virginia Department of Environmental Protection
Attn: Performance Testing
601 57th St. SE
Charleston, WV 25304
To facilitate this process, the DAQ has developed guidance and forms for submission of protocols. These documents are available for download or from the contacts listed below.
For most tests, the DAQ does not specify the manner in which a report must be presented. This has led to the submission of incomplete reports and failure of the report to address all compliance terms or conditions, thereby increasing the time necessary for regulatory review.
To address these issues, the DAQ is now requiring the information listed below to be included with the report. This requirement is made under the authority of WV Code §22-5-4. A performance/stack test report shall include the following:
- A certification of data accuracy, signed by a responsible official.
- A certification of compliance status, signed by a responsible official.
- A summary of conditions which form the basis for the compliance evaluation. The summary shall include the following:
- The permit or rule condition(s) evaluated, with citation number and language
e.g. Emission limit, operational scenario, monitoring parameter(s) - The result of the test for each permit or rule condition.
- a statement of compliance or noncompliance for each permit or rule condition.
Examples of a Certification of Data Accuracy, a Certification of Compliance Status, and a summary page are available for download or from the contact listed below. An instruction sheet for completing the summary page is also available.
Note that U.S. EPA has developed the
Electronic Reporting Tool (ERT) for submission of protocols and test results. The ERT can be used with a number of USEPA test methods. The ERT is available from the
USEPA. At this time the DAQ cannot accept the ERT via electronic mail. To submit a protocol and subsequent test report using the ERT, provide the information on a compact disk. A signed cover letter must accompany the compact disk.