Strategy:  Combined Compliance Tests to Minimize Testing.

Candidates:  Boilers, Industrial Furnaces, Cement Kilns, Lightweight Aggregate Kilns, Incinerators, Flares, etc.

Potential Cost Savings:  $5,000 to Greater than $250,000 per Test.

Facilities operating combustion units are faced with increasing regulatory requirements for compliance testing that can result in significant costs and effort for demonstrating compliance.  The combustion unit operators are typically required to conduct a number of compliance tests having various deadlines and schedules to satisfy multiple permit and regulatory requirements.  One methodology to reduce the burden of compliance testing while satisfying the regulatory requirements is combining compliance tests.  Combining compliance tests yields significant cost savings for facilities and the EPA owing to the fact that both the facility and agency are able to minimize their efforts and resources.

Facilities have an option to combine compliance tests such that the testing occurs simultaneously. The combination of compliance tests involves compliance strategy, Agency negotiations, extension requests, test notifications, combined test plans, and coordination to simultaneously conduct testing at a facility. The return on investment for combined test plans is the significant cost savings associated with the elimination of duplicate efforts for the mobilization of test equipment and personnel and duplicate sampling and analysis efforts. In addition, significant cost savings are associated with the minimization of efforts to generate test plans and reports and the efforts of facility personnel and burden to operations during testing. Combined compliance tests are smart compliance strategies for facilities.