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Performance Testing for Stationary Source Air Emissions

StacksPerformance testing for stationary source air emissions is also known as stack testing or source testing. Performance testing is the quantification, measurement or determination of the physical or chemical properties of a stationary source's emissions. Performance tests are conducted by independent testing companies contracted by the facility required to perform source testing.

State Continuous Emissions Monitor Systems (CEMS) and Performance Test Rules are located at Minn. Rule Chapter 7017.

Guidance

Types of Engineering Tests

  • True Engineering Tests — Are conducted voluntarily by an emission facility with no intention to use the results as a data submittal. The test need not conform to the notification, procedural, and submittal requirements of the performance test rule, as long as the emission facility is operated within the parameters allowed under its current permit and any applicable rules or compliance documents. If a true engineering test indicates noncompliance with an emission or other limit, the Company must inform the MPCA. The MPCA may request test results, if necessary.
  • Data Submittal Engineering Tests — Are conducted voluntarily by the emission facility for the purpose of submitting the results to the MPCA. Data Submittal Engineering Tests are typically used to support a permit application or an emission inventory. The performance test rules notification, procedural, and submittal requirements must be followed.
  • Compliance Engineering Test —  Are conducted voluntarily by an emission facility for the purpose of submitting the results to the MPCA to change an existing operating limit or to demonstrate compliance at an alternate operating scenario. The performance test rules notification, procedural, and submittal requirements must be followed.

Noncompliance Reporting

Please be aware that all periods of noncompliance with emission or other limits must be reported to the MPCA.  Engineering tests are not exempt from this reporting requirement. Operating at a rate other than that allowed by the current air permit must also be reported. Deviations must be reported on the facility’s semiannual deviation (DRF-2) and annual compliance certification (CR-04) reporting forms.

Performance Test Facts

Testing Frequency Planning

Please note MPCA compliance staff may not change a testing schedule already established in a permit which typically requires a major permit amendment. The following is only guidance which the MPCA reserves the right to deviate from based on the consideration of additional factors such as compliance history, previous test results, stringency of limit, use of emission factor, etc.

While some permits require initial performance testing only, others require performance testing on a set schedule determined by the initial performance test. If you are required to test on a set schedule after your initial test, you should have a permit requirement to submit a test frequency plan after conducting your initial performance tests. After a test frequency plan is submitted to the MPCA, Performance Testing staff review the proposed test frequency and issue a review letter. If it is evident that problems exist with the equipment a more stringent testing frequency may be required. The testing frequency defined in the MPCA review letter becomes effective when it is received by the facility and will be incorporated into the facility’s permit in the next permit amendment.

A facility may request to relax a testing frequency if there is adequate historical information suggesting that the testing frequency could be reduced. Typically, adequate historical information consists of data from three or more performance tests. Below is MPCA guidance for establishing a testing frequency for emission limit testing.

Test result minus permit limit expressed as percentage of limit:

Then:

Test Result ≥ 90% of limit

Performance Test due every 12 months

60% ≤ Test Result < 90% of limit

Performance Test due every 36 months

Test Result < 60% of limit

Performance Test due every 60 months

A permit may have an emission limit to avoid a specific permitting or applicability threshold (usually a 12-month rolling sum limit). Demonstration of compliance with the limit may be done by calculating emissions using an emission factor.

The permit may also require testing to verify and/or update the emission factor, as well as submittal of a test frequency plan for future testing to update the emission factor. Unlike emission limit and control efficiency testing where a large margin of compliance is desirable, the desirable outcome of emission factor testing is a test result that is close as possible to the current emission factor. Based on this concept, the following is proposed guidance for emission factor testing frequency:

Absolute value of test result minus permit emission factor expressed as percentage of emission factor (see equation below):

Then:

X ≥ 40% of permit emission factor

Performance Test due every 12 months

10% ≥ X ≤ 40% of permit emission factor

Performance Test due every 36 months

X ≤ 10% of permit emission factor

Performance Test due every 60 months

Note: Guidance not intended for use in revising emission factors assumed when doing ambient air analyses, risk analyses, or other pre-permit issuance analyses only for emission factor testing frequency for emission factors used to calculate emissions to avoid a permitting threshold.


X = | T-A |/ A x 100%
A = permit emission factor
T = emission factor measured during test

Presentations

Staff Contacts

Staff

Area and Counties Served

Specialty Areas

Jim Kolar
Phone: 651-757-2174
Fax: 651-296-8717

Southern Minnesota: Blue Earth, Brown, Caver, Chippewa, Cottonwood, Dakota, Dodge, Faribault, Fillmore, Freeborn, Goodhue, Houston, Jackson, Kandiyohi, Lac-Qui-Parle, Le Sueur, Lincoln, Lyon, Martin, McLeod, Meeker, Mower, Murray, Nicollet, Nobles, Olmstead, Pipestone, Redwood, Renville, Rice, Rock, Scott, Sibley, Steele, Swift, Wabasha, Waseca, Watonwan, Winona, and Yellow Medicine

Nonmetallic, Asphalt

Andrew Place
Phone: 651-757-2652
Fax: 651-296-8717

Northeast Minnesota: Aitkin, Carlton, Cass, Cook, Crow Wing, Itasca, Kanabec, Koochiching, Lake, Mille Lacs, Pine, and St. Louis

Mining, Electronic Submittal Policy

Curtis Stock
Phone: 651-757-2757
Fax: 651-296-8717

Metro Area: Anoka, Chisago, Hennepin, Isanti, Ramsey, Washington, and Wright

Ethanol Facilities and Refineries

Marc Severin
Phone: 651-757-2716
Fax: 651-296-8717

Metro Area: Anoka, Chisago, Hennepin, Isanti, Ramsey, Washington

Waste Combustors

Lad Strzok
Phone: 651-757-2295
Fax: 651-296-8717

West and Northwest Minnesota: Becker, Beltrami, Benton, Big Stone, Clay, Clearwater, Douglas, Grant, Hubbard, Kittson, Lake of the Woods, Mahnomen, Marshall, Morrison, Norman, Otter Tail, Pennington, Polk, Pope, Red Lake, Roseau, Sherburne, Stearns, Stevens, Todd, Traverse, Wadena, Wilkin and Wright

Wood, Pulp and Paper Sector

All mailed correspondence and submittals should be addressed to:

  • Air Quality Compliance Tracking Coordinator
    Minnesota Pollution Control Agency
    520 Lafayette Road North
    St. Paul, Minnesota 55155-4194

All correspondence mailed directly to Performance Testing staff should be addressed to:

  • Minnesota Pollution Control Agency
    520 Lafayette Road North
    St. Paul, Minnesota 55155-4194

Links

Last modified on April 15, 2013 14:30
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