The pulp and paper industry is facing increasing regulatory scrutiny, particularly with the EPA’s Information Collection Request (ICR) focusing on stack testing for 40 CFR Part 63 Subpart MM and the future ICR for 40 CFR Part 63 Subpart S. Navigating these complex regulatory landscapes requires strategic planning, accurate data collection, and expert insights. As a leading national consulting firm, we provide specialized guidance and support to ensure your facility remains compliant while optimizing operational performance and bringing a breadth of experience to support the more unique testing requirements being mandated as part of these industry specific ICRs.

As part of the Subpart MM ICR, EPA is requiring significant stack testing beyond the common filterable particulate matter (PM) test per EPA Method 5. Facilities may be required to conduct stack tests related to organic hazardous air pollutants (HAP), mercury (Hg), acid gases, dioxins/furans, and polycyclic aromatic hydrocarbons (PAH). As results from these stack tests will be relied upon by EPA to develop maximum achievable control technology (MACT) emission standards for the industry, it is critical that these stack test events are well managed to ensure the accuracy and representativeness of the data. Additionally, the time investment for managing development of the stack test plan, overseeing the stack testing firm during the actual testing, and reviewing the subsequent stack test reports prior to submittal will be substantial for mill employees that are also juggling their normal day-to-day responsibilities. Trinity’s stack testing experts are uniquely suited to help support the management of the required ICR testing.

Why Trinity

Trinity’s team of stack testing experts offers support for environmental compliance within the pulp and paper industry and are ready to work with your team to respond to your ICR. We work closely with your facility to develop strategic approaches for compliance, emissions measurements, and quality assurance of data. Our team has hands-on experience within the pulp and paper industry and has over 80 years of experience collectively. Our team consists of former stack testers and industry experts who understand the nuances of coordinating and executing effective stack test programs as well as the many common pitfalls. Our experts have engaged with multiple ICR stack testing events within this industry and others and have familiarity with the stack test methods required as part of the ICR.

Targeted Support for ICR Testing

• ICR Response Strategy & Data Compilation – We assist with data review, organization, and submission to ensure full compliance with EPA requirements.
• Third-Party Testing Coordination – While we do not conduct emissions testing, we can assist with vendor selection, oversight, and quality assurance to ensure reliable results.
• Regulatory Interpretation & Compliance Planning – Our team clarifies EPA’s request and compliance obligations, helping facilities prepare strategic responses.

Stack Testing Consultation & Support

• Emissions Testing Strategy Development – We help facilities determine optimal stack testing schedules, methodologies, and compliance strategies to meet regulatory requirements.
• Stack Testing Firm Selection & Oversight – We assist in selecting qualified third-party stack testing vendors and ensure testing procedures align with EPA standards.
• Data Interpretation & Compliance Assurance – Our team provides expert analysis of stack test results to confirm compliance and recommend corrective actions if needed.
• Regulatory Reporting & Documentation – We support facilities in compiling and submitting accurate stack testing reports in accordance with EPA and state regulations.

Why Working with Stack Testing Experts is Critical

Proper stack testing is essential for ensuring compliance with environmental regulations and optimizing operational efficiency and is even more critical when the test data will be relied upon to establish industry emission standards. Our team offers unbiased and experienced support to testing projects. Working with stack testing experts provides key benefits:

• Accurate & Reliable Data – Expert oversight improves data integrity, reducing the risk of errors that could lead to non-compliance.
• Efficient Testing Processes – Proper planning and execution streamline the stack testing process, minimizing downtime and operational disruptions.

The burden of responding to stack testing ICRs should not be underestimated given the importance of accurate data supporting development of MACT emission limitations. Let Trinity’s stack testing experts help you navigate the ICR testing challenges.

Please contact Robert Rusi, Scott Chesnut, or Justin Sullivan if you have any questions regarding stack testing consultation support.