As you may be aware, Stationary Source Audit Samples (hereafter referred to as “audits”) have not been available since May 2010, including those for Method 25.  An audit is a blind sample whose value is known only to the sample provider and is not revealed to the tested facility until after they report the measured value of the audit sample.  They are used as a quality assurance tool for compliance stack testing events.  In September 2010, EPA took final action to promulgate amendments to the General Provisions to allow accredited audit sample providers (AASPs) to supply stationary source audit samples and to require sources to obtain and use these samples from the accredited providers instead of from EPA (through NJDEP in NJ), as was the prior practice.

Method 25 is one method where the Department felt that testing could not be sufficiently quality assured without audits.  As such, tests where Method 25 was the indicated method have been on hold since that time.  Although we had felt that audits would become available within a reasonable timeframe after the EPA audit regulation update, that has not been the case and we cannot predict with any certainty when these audits will become available.  Therefore, unless specifically specified by regulation, BTS will accept proposals to test using the best alternative testing procedures, such as Methods 25A/18, until such time as Method 25 audits become available.  If such alternative procedures are not currently included in an approved protocol, an addendum must be submitted for approval.  Be advised that any approval to use alternative procedures will not be valid for future test programs after Method 25 audits become available.