Frequently Asked Questions |
- I need to do a stack test. Can I do the test or do I need to hire
a testing consultant? How do I find a testing consultant?
Most facilities (but not all) do not have the in-house expertise to
perform their own test and will need to hire a stack test firm. An
informational list of consultants who claim to do testing in NJ is available as well as a national
informational database. You are by no means limited to selecting
test consultants from either of these lists. These lists are informational
only.
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- Can EMS recommend a stack test consultant(s)?
EMS can not recommend a consultant. EMS does not approve or disapprove
consultants.
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- What information is required in a stack testing protocol?
Please see Technical Manual
1004, Section IV.
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- What
are the common protocol deficiencies?
Not specifying how the permitted equipment will be operated
during the test. In general, operation at maximum permitted capacity
(±5%) is required. Not specifying that the process will be
monitored and that this data will be included in the test report.
Not specifying that the report will be certified with the language
in NJAC 7:27-1.39(a) 1 and 2, and be certified by a Professional Engineer
or Certified Industrial Hygienist.
Not including a stack diagram, including distances from upstream/downstream
disturbances and the number and location of traverse points.
Not including a cyclonic flow check.
Not providing analyzer operating ranges and calibration gas
concentrations.
Not providing an adequate description of the sampling train,
including materials of construction and reagents used, and/or an adequate
description of the sampling train operation.
Not specifying what will be included in the final report or
not including all elements that are required.
Not specifying in-stack detection limits or their basis.
Proposing an inappropriate test method.
Proposing sample train operation that will not provide an adequate
in-stack detection limit to determine compliance.
Not providing an adequate description of the analytical procedures,
including calibration and quality assurance/quality control procedures.
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- What
type of lead time should I consider when contemplating a test date?
In general, you should plan for a 30-45 day lead time in getting on
the schedule, depending on the number of days required for testing.
An approved protocol is required to get on the schedule.
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- Does EMS schedule contingency days?
EMS does not schedule contingency days. Problems are dealt with on
a case-by-case basis. Testing is expected to start within a reasonable
time from the scheduled start time. Failure to do so will result in
cancellation of the test program and a requirement to reschedule.
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- What information is required in a stack test report?
Please see Technical Manual
1004, Section VI.
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- What fees are associated with stack tests?
Service fees for protocol review, test observation and report review
will be invoiced to the facility at the conclusion of the test program,
consistent with NJAC 7:27-8.6 (Preconstruction Permits) or 7:27-22.31
(Operating Permits).
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- How will I know if the test program has been accepted by EMS?
At the completion of our review, you will receive a letter from EMS
detailing our findings. In general, the results will fall into one
of four categories.
- The tests indicated compliance.
- The tests indicated non-compliance for one or more contaminants.
- The tests indicated compliance, but at production and/or control
parameter levels inconsistent with the Permit.
- Retests are recommended for one or more contaminants with an explanation
of why we are recommending retests.
In all
cases, our findings are sent to the appropriate regional Air Compliance
and Enforcement office for final disposition.
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