What is Stack Testing?

A stack test is a technique used to sample the flue gas stream from an emission source, unit or piece of control equipment at a facility subject to the Clean Air Act (CAA).  A stack test may also be known as a(n) “Emission Test”,  “Source Sampling Test”,  “Performance Test”,  or “Compliance Test”.  It is used to determine the characteristics and composition of a flue gas stream in order to calculate pollution emission rates, pollutant concentrations, control efficiencies, destruction efficiencies or other parameters which might help determine a facility’s compliance with permitted emission limits or capture/control efficiencies. Specific stack test methods that must be followed are provided in the EPA Code of Federal Regulations, unless the state has promulgated its own accepted procedures that were reviewed and approved by the EPA. Any deviations from the recommended test methods must be approved by the state and/or EPA.

A stack test usually consists of three phases: Protocol preparation/review, test completion/observation and final report preparation/review. These phases are implemented to ensure that each test is appropriate, accurate and valid. Stack tests are usually conducted by an environmental testing or consulting agency who shares procedural information as well as final results with both the client and proper regulatory agencies. First, the consultant must prepare a written protocol describing the pollutants to be tested, the sampling methods they plan to use, the expected operating conditions at the facility and any other expected deviations from standard procedures. The protocol should be submitted to both the proper regulatory personnel (EPA, state or local officials) as well as the facility for review prior to the test. Protocol preparation and review should be completed at least 30 days in advance of the proposed test date to ensure regulatory agencies have adequate time to review important information and plan selected observation arrangements.  When possible, regulatory personnel may be present during a sufficient portion of the testing to confirm that the test is valid. Depending on the type of test, samples may be sent to a laboratory for analysis or analyzed on site.

After the test results/samples have been analyzed, the consultant or testing company issues a final report to both the client and applicable regulatory agencies. Regulatory personnel then review the final report to ensure that the test was accurate, thorough and valid. If the facility does not meet its limits, the regulatory agency may take appropriate enforcement action to ensure the facility is brought into compliance. Enforcement actions typically begin with a written Notice of Violation (NOV) and, depending on the severity of the violation, the regulatory agency may proceed with a number of other enforcement actions. For example, the regulatory agency often instructs the facility to take corrective action within a specified time frame and, if appropriate, may assess a monetary penalty.

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