Stack Tests, Notifications and Protocol Submittals FAQs

Questions regarding stack testing should be directed to (225) 219-3412

The test notification/test plan should include:

• Company name, agency interest number, permit number
• ID number of unit being tested
• Test date and company performing the testing
• Reason for conducting the test
• Pollutants being tested and the methods that will be used
• Operating parameters that will be recorded during the test

During performance testing, equipment should be operated, to the degree possible, at conditions most likely to challenge the emissions control measures of the facility (worst case emission conditions) with regard to meeting the applicable emission standard without creating an unsafe condition. When operating conditions are specified in the applicable emission standard, these should be followed. If operating conditions are not indicated in an individual standard, operating conditions should be developed as part of a site-specific test plan. The owner or operator is responsible for demonstrating that the facility is able to continuously comply with the applicable emission limits

Vennetta T. Hayes, P.E. – Engineer 6
Office of Environmental Assessment 
Air Planning & Assessment 
225-219-3412
P.O. Box 4314, Baton Rouge, LA 70821-4314

Also, a copy of test notifications should be sent to the regional office where your facility is located.  Notifications sent via the online stack test scheduler are automatically sent to both the Engineering Support Group AND the appropriate regional office.  A separate paper notification is not necessary.

Performance testing, such as engineering studies conducted for the facility’s own purposes, does not need to be submitted to the department. However, if the facility wishes to use the results for future compliance or permitting purposes, the test must be performed using approved methods, an accredited tester, and the results approved by the Engineering Support Group in the same manner as any required test.

An initial test is required after a major engine overhaul. "Major engine overhaul" means that the entire engine combustion section is dismantled, parts are replaced/reconditioned as needed, and the engine restarted. Any of the following may also constitute a major engine overhaul: the disassembly of cylinder heads; removal of intake and exhaust valve assemblies; removal of power piston bodies, pins, and connecting rods; disconnecting intake and exhaust manifolds; and disassembly of the fuel aspiration system such as carburetors and/or turbo chargers.

Results from testing performed in the last three years may be accepted by the department on a case by case basis to show compliance with new regulations or testing requirements. The test must be performed using approved methods, an accredited tester, and the results approved by the Engineering Support Group in the same manner as any required test. Performance tests more than three years old may not be accepted.

Any questions concerning the accreditation of a tester should be directed to Laboratory Services at (225) 219-3181. Test results will not be accepted by the LDEQ if the test is not performed by an LDEQ accredited tester or laboratory. However, facility personnel may conduct their own performance testing or laboratory analysis without LDEQ accreditation.

LAC 33:I.4501.A.2 states, in pertinent part, “Laboratory data generated by commercial environmental laboratories that are not accredited under these regulations will not be accepted by the department.” 

If all of the data that is submitted was generated by the accredited laboratory, rather than by the third-party sampler, then the data are acceptable.  Stated another way, if all the sampler did was take the sample, then whether he has some sort of accreditation is irrelevant. 

Only if some of the data submitted to the Department was also generated by the third-party sampler does an issue arise.  If the sampler generated the data by engaging in an activity meeting the definition of field test in LAC 33:I.4503.  If so, then those data are acceptable.  If the activity is not a field test, then the data generated by the unaccredited sampler will not be acceptable.  However, the data generated by the accredited lab will still be acceptable.  In this case, the Department would have to determine whether the lab data is adequate for the purpose submitted without the sampler’s data.

Yes.  The party taking the samples in this situation is analyzing the samples and sending the data directly to DEQ.  Thus, this party is not simply a sample collector, but is functioning as a laboratory, as defined in LAC 33:I.4503.A.   If this party is performing the analysis for a third party for a fee or other compensation, this party is a commercial laboratory as defined in LAC 33:I.4503.A.     In this situation, it does not qualify as a field test because:

The analyses produce data on multiple parameters.  The definition of field test states that it results in “the measurement of a specific parameter” (emphasis supplied).

The analyses provide data on the constituents of the samples, which is unlike the examples given in the definition of field test, all of which relate to other characteristics of the sample or of the ambient conditions surrounding the sampling (soil classification, pH, temperature, flow rate).

Therefore, the data described is not acceptable to DEQ unless the party is accredited under LELAP.

Yes.  The analysis of this question is the same as that for the previous question.  The certification procedure described in Performance Specification 1 in Appendix B of 40 CFR 60 is far too complex to be considered a field test as defined in LAC 33:I.4503.A, since it requires evaluation of multiple specifications for design, performance, and installation of the Continuous Opacity Monitoring System. 

Yes.  The analysis of this issue is the same as that for the previous 2 questions. The certification procedure described in the performance specifications for CEMS certifications in Appendix B of 40 CFR 60 is far too complex to be considered a field test as defined in LAC 33:I.4503.A, since it requires evaluation of multiple specifications for design, performance, and installation of the Continuous Emissions Monitoring System.

Portable emission analyzers that have received approval from the Department for internal combustion engine testing include:

Industrial-commercial-institutional steam-generating units which are subject to NSPS Subpart Db, are required by 40CFR 60.48b(b) to continuously monitor NOx emissions. As provided in 40CFR 60.48b(g)(2) units with a capacity between 100 MM BTU/hr and 250 MM BTU/hr may use an alternate to an in-stack NOx CEMS.

Described below is one option for alternate monitoring, which is commonly referred to as a "BACT box". It involves doing a test to establish an operating range, and then monitoring key parameters.

On May 20, 2007, LDEQ promulgated new regulations for abrasive blasting operations that fall under certain SIC (source industrial classification) codes.  These regulations are codified at LAC 33:III.Chapter 13, Subchapter F.  New facilities must comply with these regulations upon startup of the facility.  Existing facilities have one year to come into compliance.  The compliance date for existing facilities was May 20, 2008.

LAC 33:III.1327.A.2 requires abrasives to contain less than 10% (by weight) of fines that would pass through a No. 80 sieve.  This size requirement is waived for certain types of blasting and blasting media under LAC 33:III.1327.B.  LAC 33:III.1327.B.5 also allows the Department to approve exemptions for other abrasive media on a case-by-case basis.

On April 15, 2008, the Department approved an exemption for Dupont’s Starblast XL blasting medium.  However, any blasting conducted with this medium shall continue to be subject to all of the requirements of Chapter 13, Subchapter F, except for the size requirement of LAC 33:III.1327.A.2.

If you are required to perform triennial testing in accordance with LAC 33:III.2201.H.3 or 4, subsequent testing shall be performed between 35 and 37 months (3 years ±1 month) after the initial or previous Chapter 22 compliance test.

Turbines required to perform triennial testing in accordance with LAC 33:III.2201.H.3 must comply with the methods specified in LAC 33:III.2201.G.5.  However, the test runs are only required to last twenty minutes.  While LAC 33:III.2201.G.5 specifies that three minimum one-hour tests shall be performed, it also specifies that stack tests shall be performed according to the emissions testing guidelines on the department’s website.  The department’s emissions testing guidelines specifies that runs for turbine testing need only last at least twenty minutes.  Therefore, testing for turbines under LAC 33:III.2201 shall consist of three runs, each at least 20 minutes in length.

If the test results are at or below the manufacturer’s documentation at the tested load then the manufacturer’s documentation is acceptable to support compliance at 100% of the permitted maximum capacity.  If the test results are not at or below the manufacturer’s documentation at the tested load, other documentation will be accepted on a case-by-case basis.

This requirement is referring to the maximum permitted capacity, not the name plate capacity.  If the unit has operational limitations that prevent its capability to operate at 80% of the maximum permitted capacity then the permit should be modified to reflect the actual maximum operating capacity.