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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?
"" Can EMS recommend a stack test consultant(s)?
"" What information is required in a stack testing protocol?
"" What are the common protocol deficiencies?
"" What type of lead time should I consider when contemplating a test date?
"" Does EMS schedule contingency days?
"" What information is required in a stack test report?
"" What fees are associated with stack tests?
"" How will I know if the test program has been accepted by EMS?
  1. 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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  2. 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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  3. What information is required in a stack testing protocol?
    Please see Technical Manual 1004, Section IV.

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  4. 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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  5. 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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  6. 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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  7. What information is required in a stack test report?
    Please see Technical Manual 1004, Section VI.

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  8. 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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  9. 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.

    1. The tests indicated compliance.
    2. The tests indicated non-compliance for one or more contaminants.
    3. The tests indicated compliance, but at production and/or control parameter levels inconsistent with the Permit.
    4. 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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Last Updated: November 28, 2011