Preparing for a performance test: a practitioner's checklist

Read three layers of requirements

Test requirements come from the subpart's testing section, the general provisions (40 CFR 60.8 for NSPS, 40 CFR 63.7 for Part 63), and the permit. The subpart usually controls methods, number of runs, and operating conditions; the general provisions control notifications, plans, and reports unless the subpart overrides them. Read all three before scheduling.

Notifications and test plans

Both sets of general provisions require advance notice of a performance test to the agency, and Part 63 also requires a site-specific test plan when requested (40 CFR 63.7(b) and (c)). The lead times are in those sections, the subpart, and the permit, and some states add their own. Put the notification due date on the calendar before you book the testing company.

Operating conditions

Tests must be run at the operating conditions the rule specifies, often representative or maximum operation (40 CFR 60.8(c) and 63.7(e)). Plan production so the unit can run there for the whole test, record the operating data during each run, and know that the conditions tested can become limits on future operation in some programs.

Access and facilities

The owner provides sampling ports, safe sampling platforms, access, and utilities for the test (40 CFR 60.8(e)). Check port location and condition early; a port that fails the method's location criteria can delay the test.

Before test day

A short checklist that prevents most failed or repeated tests:

• Methods, runs, and run length confirmed against the subpart
• Notification and test plan sent, and any agency observer scheduled
• Unit able to hold the required load; process data logging ready
• Control device inspected and operating within its parameter ranges
• Fuel or material sampling arranged if the method needs it
• Units and basis of each limit written out for the tester (dry, O2 reference, standard conditions)

If a run fails or the test is interrupted

Document what happened during the run. The general provisions and the subpart address when runs may be discarded or repeated and what must be reported. Do not drop a run from the average without a basis in the rule, and report results as the subpart requires, including any electronic reporting it specifies.