Air Compliance Testing's approach to determining the Volatile Organic Compound (VOC) Capture Efficiency (CE) correlates with the testing protocols outlined within the January 9, 1995 EPA document, Guidelines for Determining Capture Efficiency (EPA Method 204 series). This is the document that is typically referenced in your EPA Air Permit "Terms and Conditions" Testing Requirements section as the guideline document for use in determining an acceptable CE Test Protocol.
Air Compliance Testing has extensive experience in developing and performing these CE Test Protocols on various types of VOC emitting devices. The Guidelines document contains multiple test protocol options (i.e., a mass balance approach, a Temporary Total Enclosure (TTE) construction approach, etc.) that are uniquely applied to specific types of processes that require a CE determination test. In order to appropriately select and use one of the EPA's Test Protocol Options contained in the Guidelines document, or to compile a custom test protocol that would meet the Data Quality Objective (DQO) required for acceptance by the EPA, a thorough scientific assessment of your specific process should be performed. In many cases, a preliminary stack test (an informational test conducted in advance of your formal compliance demonstration) may also be required in order to determine if the proposed test protocol is in-fact going to result in an acceptable CE result. This is especially important when using an Alternative CE Test Protocol.
We are often asked to just select one of the EPA's Standard Test Protocols and provide a price for performing it. Unfortunately, without the up front assessment of your specific process, the type of VOCs expected, and their expected stack gas concentrations, we have no valid criteria for making a sound test protocol selection. Our experience has taught us that the initially proposed protocol and its corresponding price is not usually the one that will ultimately be used to demonstrate compliance.
Our approach to a CE/DE test event includes all the steps required to successfully completing these complex projects:
Perform Process Walk Through and Assessment
We begin by reviewing your process, performing a walk though with you. We look at the emission units, control devices, enclosures, test locations and the facility layout.
We gather and review information on the types and quantities of VOCs present (reviewing Material Safety Data Sheets or formulation data, for example), and evaluating the expected stack gas concentrations.
Based on the results of Steps 1 and 2, the next step may be to perform an informational stack test in advance of your formal compliance test. This step may be required in order to determine values for spike and recovery studies. In any case, it is a good idea.
The final step is to perform the compliance test event. If all the other steps have been completed prior to reaching this point, you can be confident that the results will be as expected on test day, when your EPA representative is at your facility to witness you test event.
