.tfEDs rAf.	19-P-0251
* — *	U.S. Environmental Protection Agency	July 30,2019
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	 \ Office of Inspector General
At a Glance
Why We Did This Project
We conducted this audit to
determine the effectiveness of
U.S. Environmental Protection
Agency (EPA) oversight in
assuring that emission stack
tests are conducted in
accordance with EPA
regulation, policy and guidance.
The EPA estimates that there
are approximately 14,700 major
stationary sources of air
emissions in the United States,
such as refineries and power
plants that typically release
emissions via tall chimneys
called smokestacks or stacks.
Most of these facilities are
subject to emission limits set by
state-issued construction or
operating permits. If there are
no other means to demonstrate
compliance with permit limits,
as is typically the case with
particulate matter emissions,
stack emissions must be
determined using EPA-
approved test methods. If stack
testers do not follow applicable
EPA methods, test results are
subject to greater variability
and uncertainty. Accurate stack
tests and reports are needed to
verify that excess emissions do
not negatively impact human
health and the environment.
This report addresses the
following:
• Improving air quality.
Address inquiries to our public
affairs office at (202) 566-2391 or
OIG WEBCOMMENTS@epa.oiq.
List of OIG reports.
More Effective EPA Oversight Is Needed for
Particulate Matter Emissions Compliance Testing
What We Found
Our audit of 30 stack test reports from state and local
agencies in Washington state found numerous examples
of nonadherence to EPA test methods and inadequate
supporting documentation to assess data quality. These
problems were not identified by state and local
regulatory agencies responsible for implementing Clean
Air Act permitting programs in Washington state.
Effective EPA
oversight of stack
testing improves
data quality for
compliance
determinations and
other uses.
We also found that some state and local agencies rarely observe stack tests to
verify that EPA methods are properly followed. Several agencies told us that they
needed additional training and tools from the EPA to help them conduct oversight
of stack testing and reporting.
Some stack testing problems that we identified could impact the reliability of
stack test results and the resulting determination of whether a facility complies
with its permit limits. Effective reviews of stack test reports to identify any errors
in the implementation of stack test methods are particularly important when a
facility's emissions are near or at the permit limit. Errors in such instances have a
higher likelihood of affecting the reliability of the final compliance determination.
While state and local agencies have been delegated responsibility for
implementing Clean Air Act programs in Washington state, EPA Region 10
maintains responsibility and accountability for program compliance with federal
statutes and regulations. Region 10 should improve its oversight activities to
provide reasonable assurance that stack testing programs conducted in
Washington state meet federal requirements. Although we only reviewed stack
test reports from Washington state in EPA Region 10, EPA managers and staff
responsible for overseeing the Clean Air Act program at the national level told us
that they had observed similar problems in other states and EPA regions.
Recommendations and Planned Agency Corrective Actions
We made four recommendations to the Assistant Administrator for Air and
Radiation and the Assistant Administrator for Enforcement and Compliance
Assurance, including to develop and implement a plan for improving the
consistency of stack test reviews across EPA regions and delegated agencies,
as well as to provide additional training and tools to improve stack test report
reviews. We made two recommendations to the Regional Administrator of
Region 10 to communicate the EPA's requirements and guidance for stack
testing oversight to delegated agencies and to develop internal controls to verify
that delegated agencies are performing effective oversight of stack testing and
reporting. The agency agreed with our recommendations and provided
acceptable corrective actions.

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