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Reliance on nonbinding agency interpretations, especially from low- or mid-level staff, unless thoroughly analyzed and confirmed.
Failure to understand federal-state delegation status before testing NSPS and NESHAP regulated emissions.
No assurances that stack tester has the right equipment and the personnel to use that equipment, especially when the job presents atypical conditions (cyclonic flow, large stacks, hot stacks)
Deviation from the specified method unless addressed in the source test plan (e.g., use of snow instead of ice to cool impingers).
Lack of careful attention to what constitutes “representative conditions” or “maximum capacity” or whatever terms the regulation or permit condition use.
Failure to understand whether standards apply during startup, shutdown or malfunctions and need for testing during such conditions.
Lack of careful monitoring of operations during stack test.
Use of stack test to determine compliance (test is to measure and report emissions rates only—compliance determination should be left to management and legal).
Falsification of data!
Do not engage the low bid stack tester—your compliance status is too valuable to risk with low quality data.