Frequently Asked Questions About Performance Testing for Stationary Source Emissions

1. I know I need to conduct a performance test. Where do I start?

The first steps in the test planning process include acquiring a stack testing consultant to conduct your performance test and developing a test plan. Please see the following website for test plan examples: Performance Testing for Stationary Source Air Emissions — Test Planning and Reporting

2. Who should I send my test plan to?

Please submit all hard copy test plans and test reports to:

Compliance Tracking Coordinator
Compliance/Enforcement Unit
Industrial Division
Minnesota Pollution Control Agency
520 Lafayette Road
St. Paul , MN 55155-4194

3. May I send my test plan via email?

Yes. Test plans are accepted by e-mail and may be sent to the appropriate test coordinator. Please see Staff Contacts on the Performance Testing for Stationary Source Air Emissions website to determine who should receive your test plan by the county your facility is located in or by specialty area.

4. What happens after I submit my test plan?

Hard copies are routed to the appropriate Performance Test Coordinator upon receipt by the MPCA. The Performance Test Coordinator conducts a preliminary review of the test plan. If the submitted test plan is lacking necessary information, the MPCA may request a revised plan. Approximately seven days prior to the performance test, a pretest meeting should be held. Once internal review of the test plan is complete and the pretest meeting has been held, the Performance Test Coordinator issues a test plan approval letter (TPAL) to the company. 

5. Will the MPCA contact me for a pre-test meeting?

Minnesota rules require the company conducting the performance test to contact the Agency to organize a pre-test meeting. We recommend companies to contact their Performance Test Coordinator at least one week prior to the test date to schedule the pre-test meeting. (See Minn.R.7017.2030 Supb.4)

6. Who must attend the pretest meeting? Does it have to be in person?

Pretest meetings are typically conducted over the phone and include the Performance Test Coordinator, a company representative, and a stack test company representative. Upon request, the pretest meeting may be held in person.  

7. What do I need to do if I have to reschedule my test?

If a test plan has been approved, please contact the appropriate Performance Test Coordinator immediately. Formal documentation of the rescheduling should be submitted. Remember that all applicable timelines set by a permit federal rule, or SIP must be adhered to.

8. I cannot schedule a test before the due date in my permit. How do I request an extension?

Extensions of test dates up to 365 days may be granted through the administrative amendment process if the agency finds that the extension is needed to test at worst case conditions or there are other extenuating circumstances which prevent timely testing and if the agency has been delegated authority to make such extensions by the EPA. The MPCA cannot grant extensions for testing required by federal regulations unless the State of Minnesota has been given delegated authority.

9. May I conduct my own test?

The performance test must be conducted by an independent testing company unless you have a permit or enforcement document that allows you to conduct some or all of your testing. (See Minn. R. 7017. 2020 Supb.2)

10. What consultants are available for conducting my stack test?

The MPCA does not endorse any particular consultants or maintain a list. However, a list of testing consultants is available on EPA's "Emission Measurement Center" website.

11. How must my equipment be operated during the performance test?

Generally your equipment must operate at worst-case conditions for each pollutant during the performance test. If an emission unit did not operate at worse case conditions during the test, the unit may be limited to the rate during the test in accordance with Minn. R. 7017.2025. Please note that  pollution control limits are re-evaluated during each performance test.

12. When do I need to include condensible particulate matter in my test?

The answer varies with the standard that applies to your facility. As a general rule, any of the PM standards that refer back to the industrial process equipment rule should include organic condensibles. (Note - as a practical matter include organic + inorganic condensibles (using Method 202) if you want to use the result as a PM10 emission factor for emission inventory or permitting purposes)

13. My permit requires me to test once every twelve months. What is the window for testing in the next year?

Generally this means that you should test at any time in the same month the following year. So if you tested in September 2004 the next test should be conducted in September 2005. If instead you conduct the second test in July 2005, the next subsequent test would be due in July 2006 as annual tests cannot be more than 12 months apart.    

14. I am testing regarding NESHAP requirements, when is my test plan due?

A list of test plan deadlines for the most common Minnesota NESHAPS is available below:

15. What is my Air Quality File number?

Reporting Test Results

1. What must be included in my test report?

The test report should include a summary table of the results, production data, control equipment operating data, raw sampling data or analytical data, calibration certifications, required reporting forms, a copy of the test plan and test plan approval, and any additional information that is relevant to the testing or the results. For more information, see Minn. R. 7017.2025 or Performance Test Report Completeness Criteria form. The following presentation provides great tips and examples for developing a complete report. 

2. May I send my test report in via email?

Effective March 3, 2010, the MPCA has changed its test report submittal policy. The new policy provides three additional methods for submitting your test report. Please review the following guidance to learn more about the new policy, submittal methods, and their requirements.

 

3. Am I required to submit the results of an engineering performance test that I conduct for my own information?

If an engineering test indicates noncompliance with a limit, the company must inform the MPCA. Generally, the pollutant, emissions, and operating conditions can be summarized and reported in place of a complete report, unless a more detailed report is requested. Results of a compliant engineering test need not be provided, unless requested by the MPCA.

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.

4. If early results indicate a test failure, can I stop the test and try again later?

Minn. R. 7017.2020 subp.5 requires each performance test to consist of at least three separate test runs. If after conducting one or more test runs the company determines that an emission limit has been exceeded, the MPCA should be contacted for further guidance. A detailed description of sampling or other problems experienced during the test should be included in the executive summary of the test report. Regardless of the number or length of test runs, data from an aborted emissions test may be used to establish violations pursuant to Minn. R. 7017.2020 Subp.6.

5. What happens if I get my test results back and they indicate noncompliance?

The unit must be retested under the requirements of Minn. R. 7017.2025, subp. 4. This retest must be conducted within 30 days of the MPCA notice of noncompliance, unless a compliance plan is submitted and approved by the MPCA. The period of noncompliance begins at the date of the initial noncompliant test. Therefore, you should take immediate measures to minimize emissions without waiting for the formal notification from the MPCA.

6. Can I use the data from my test report for emission fee inventory purposes?

Yes. The Emission Inventory rule, Minn. R. 7019.3000-7019.3100, requires the calculation of emissions based on an established hierarchy. In the absence of Continuous Emission Monitor (CEM) data meeting the requirements of Minn. R. 7019.3040, the next method of calculation, a performance test, must be used. When a performance test for PM, PM10, PM2.5, CO, NOx, SOx, VOC or Pb is conducted and meets the requirements of Minn. R. 7017.2001-7017.2060, the results must be used to calculate emissions, unless specified otherwise by Minn. R. 7019.3000-7019.3100 . It is the company’s responsibility to ensure the results of performance tests are accounted for in their annual emission inventory submittal. The final decision to approve the emission factor for any given inventory year will be made by the Emission Inventory Coordinator.

7. What steps do I need to take to submit confidential information as part of a test report?

Claims of confidentiality for information included in a test report must be based upon valid statutory basis to be considered for confidentiality review. Please reference Minn. R. 7000.1300 and Minn. Stat. § 13.37 and 116.075, to determine whether company information meets criteria. Claims of confidentiality must be contained in a cover letter accompanying the test report. The letter must specifically identify the information to which the claim applies, explaining the statutory basis for the claim. When submitting the report you must provide both a public and a confidential copy.