Strategy:  Demonstrate Similarity for Multiple Units to Eliminate Compliance Testing

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

Potential Cost Savings:  $5,000 to Greater than $500,000 per Test

Numerous facilities have multiple combustion units. These facilities are required to conduct costly testing on these units to demonstrate compliance with regulations and permit requirements. The costs associated with planning, conducting, and reporting compliance tests are significant to facilities. Demonstrating similarity for multiple combustion units, which may or may not be identical, eliminates compliance testing for the similar units.

The demonstration of similarity is a technical justification that documents the comparison of the feedstreams, design, operation, and maintenance of the similar units. For a successful demonstration, the units must be similar, not necessarily identical. Once approved by the Agency, the compliance test results from one combustion unit are applied to one or more similar units. Thus, a facility eliminates costly testing on the similar unit(s). In addition, the cost savings should perpetuate into future compliance testing for the similar units.

All combustion units are required to conduct compliance tests. The costs and effort associated with conducting compliance tests are significant to facilities. Demonstrations of similarity reduce the burden of testing, and thus, are smart compliance strategies.