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1. The Time Frame for Conducting Stack Tests
2. Stack Test Waivers
3. Stack Test Notifications
4. Observation of Stack Tests
5. Representative Testing Conditions
6. Stoppages
7. Postponements
8. Test Reports
2. Stack Test Waivers
3. Stack Test Notifications
4. Observation of Stack Tests
5. Representative Testing Conditions
6. Stoppages
7. Postponements
8. Test Reports
8. TEST REPORTS
• The primary issue is what information is needed to adequately document the results of a stack
test conducted to determine and demonstrate compliance.
• The written test report should be sufficient to assess compliance with the underlying regulatory
requirements, permit conditions, or enforcement order, and adherence to the test requirements.
When reviewing the site-specific test plan, the delegated agency should identify for the facility
any information that should be included in the test report. During the actual test program, there
are usually modifications to the procedures specified in the site-specific test plan, and these
modifications should be documented in the test report.
• Similar to the site-specific test plan, certain basic elements should be addressed in a test report
to document the testing conditions and results, and enable the delegated agency to determine
whether a complete and representative stack test was performed. For a prototype of a
sufficiently detailed test report, see Emission Measurement Center Guideline Document (GD043),
"Preparation and Review of Emission Test Reports," (December 1998)
(www.epa.gov/ttn/emc/guidlnd.html). If the test report does not contain sufficient information
with which to adequately review the testing process and data results, it is within the discretion of
Page 19
the delegated agency to request additional information, or require another test if appropriate.
• The test report should include chain-of-custody information from sample collection through
laboratory analysis including transport. It also should include sufficient raw data and cross
correlations in the appendices such that a new set of calculations including statistics could be
independently generated from the raw data if necessary (e.g., median versus geometric-mean).
• The test report should be submitted to the delegated agency as soon as possible after
completion of the stack test and, at a minimum, in compliance with any underlying regulatory
requirements. For stack tests being conducted pursuant to 40 CFR Part 60, the test report is to be
submitted within 180 days after the initial startup date or within 60 days after reaching maximum
production rate. § 60.8(a). For those tests being conducted pursuant to 40 CFR Part 61, the test
report is to be submitted within 31 days after completion of the test. § 61.13(f). If the test is
being conducted pursuant to 40 CFR Part 63, the test report must be submitted within 60 days
after the test is completed unless another time frame is specified in the applicable subpart.
§ 63.9(h)(2)(i)(G). In addition, all test reports should be maintained consistent with the
requirements of the CAA and its implementing regulations, and made available to EPA upon
request. To assist in the preparation and transcription of test plans, the ERT should be used
when possible.
Rounding of Significant Figures:
• For clarification on how the results of a stack test should be calculated and reported, this
guidance defers to the current Agency guidance. See Memorandum from William G. Laxton and
John S. Seitz to New Source Performance Standards/National Emission Standards for Hazardous
Pollutants Compliance Contacts "Performance Test Calculation Guidelines" (June 6, 1990).
After reiterating the established procedure concerning the use of the metric system in expressing
compliance standards, the guidance states that all emission standards should have at least two
significant figures and at least five significant digits are to be carried in intermediate
calculations.
• When rounding off the calculated emission numbers, the guidance affirms the practices of the
American Society for Testing and Materials:
-If the first digit to be discarded is less than five, the last digit retained should not be
changed. When the first digit discarded is greater than five, or if it is a five followed by
at least one digit other than 0, the last figure retained should be increased by one unit.
When the first digit discarded is exactly five, followed only by zeros, the last digit
retained should be rounded upward if it is an odd number, but no adjustment made if it is
an even number.
-For example, if the emission standard is 90, 90.357 would be rounded to 90, 90.639
would be rounded to 91, 90.500 would be rounded to 90, and 91.500 would be rounded to
Page 20
92. See Laxton and Seitz, pp. 3-4.
VIII EPA ROLE
• As part of EPA’s oversight responsibilities, EPA may observe stack tests whenever the
Agency deems appropriate. The Agency also will review test reports as needed to verify that the
tests are being conducted properly, and that the results are being accurately interpreted and
reported by state/local agencies.
• Consistent with CMS and the State Review Framework, EPA will periodically conduct
analyses to evaluate whether stack tests are being properly conducted and sufficiently and
effectively utilized to determine compliance; and whether the results are being accurately
reported in a timely manner.
• The primary issue is what information is needed to adequately document the results of a stack
test conducted to determine and demonstrate compliance.
• The written test report should be sufficient to assess compliance with the underlying regulatory
requirements, permit conditions, or enforcement order, and adherence to the test requirements.
When reviewing the site-specific test plan, the delegated agency should identify for the facility
any information that should be included in the test report. During the actual test program, there
are usually modifications to the procedures specified in the site-specific test plan, and these
modifications should be documented in the test report.
• Similar to the site-specific test plan, certain basic elements should be addressed in a test report
to document the testing conditions and results, and enable the delegated agency to determine
whether a complete and representative stack test was performed. For a prototype of a
sufficiently detailed test report, see Emission Measurement Center Guideline Document (GD043),
"Preparation and Review of Emission Test Reports," (December 1998)
(www.epa.gov/ttn/emc/guidlnd.html). If the test report does not contain sufficient information
with which to adequately review the testing process and data results, it is within the discretion of
Page 19
the delegated agency to request additional information, or require another test if appropriate.
• The test report should include chain-of-custody information from sample collection through
laboratory analysis including transport. It also should include sufficient raw data and cross
correlations in the appendices such that a new set of calculations including statistics could be
independently generated from the raw data if necessary (e.g., median versus geometric-mean).
• The test report should be submitted to the delegated agency as soon as possible after
completion of the stack test and, at a minimum, in compliance with any underlying regulatory
requirements. For stack tests being conducted pursuant to 40 CFR Part 60, the test report is to be
submitted within 180 days after the initial startup date or within 60 days after reaching maximum
production rate. § 60.8(a). For those tests being conducted pursuant to 40 CFR Part 61, the test
report is to be submitted within 31 days after completion of the test. § 61.13(f). If the test is
being conducted pursuant to 40 CFR Part 63, the test report must be submitted within 60 days
after the test is completed unless another time frame is specified in the applicable subpart.
§ 63.9(h)(2)(i)(G). In addition, all test reports should be maintained consistent with the
requirements of the CAA and its implementing regulations, and made available to EPA upon
request. To assist in the preparation and transcription of test plans, the ERT should be used
when possible.
Rounding of Significant Figures:
• For clarification on how the results of a stack test should be calculated and reported, this
guidance defers to the current Agency guidance. See Memorandum from William G. Laxton and
John S. Seitz to New Source Performance Standards/National Emission Standards for Hazardous
Pollutants Compliance Contacts "Performance Test Calculation Guidelines" (June 6, 1990).
After reiterating the established procedure concerning the use of the metric system in expressing
compliance standards, the guidance states that all emission standards should have at least two
significant figures and at least five significant digits are to be carried in intermediate
calculations.
• When rounding off the calculated emission numbers, the guidance affirms the practices of the
American Society for Testing and Materials:
-If the first digit to be discarded is less than five, the last digit retained should not be
changed. When the first digit discarded is greater than five, or if it is a five followed by
at least one digit other than 0, the last figure retained should be increased by one unit.
When the first digit discarded is exactly five, followed only by zeros, the last digit
retained should be rounded upward if it is an odd number, but no adjustment made if it is
an even number.
-For example, if the emission standard is 90, 90.357 would be rounded to 90, 90.639
would be rounded to 91, 90.500 would be rounded to 90, and 91.500 would be rounded to
Page 20
92. See Laxton and Seitz, pp. 3-4.
VIII EPA ROLE
• As part of EPA’s oversight responsibilities, EPA may observe stack tests whenever the
Agency deems appropriate. The Agency also will review test reports as needed to verify that the
tests are being conducted properly, and that the results are being accurately interpreted and
reported by state/local agencies.
• Consistent with CMS and the State Review Framework, EPA will periodically conduct
analyses to evaluate whether stack tests are being properly conducted and sufficiently and
effectively utilized to determine compliance; and whether the results are being accurately
reported in a timely manner.
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