Trial Burns, Compliance Tests, and Other Emissions Testing
Focus’ objective is to assist clients in planning and conducting performance test programs that not only meet regulatory requirements, but also result in permit operating conditions that allow maximum operational flexibility. To accomplish these objectives, we work closely with the client’s operations, regulatory, and management personnel to:
- Develop a comprehensive test plan that includes effective test operating protocols; sampling, analysis, and monitoring methods; and appropriate quality assurance and quality control procedures (QA/QC).
- Assist in permit negotiations and in preparing responses to questions from the regulatory agencies.
- Provide complete services to manage the successful implementation of the test program and prepare complete and accurate test reports covering the sampling, analysis, QA/QC, and process operations.
Test Strategy
Focus’ goal is to execute any test program properly and completely the first time. To this end, test strategy is key so the compliance testing is conducted in concert with the facilities’ overall operational and compliance objectives. This strategy includes selecting the unit operational targets and test conditions with the correct overlay of sampling and analysis so the regulatory compliance objectives are achieved and the resulting test-determined limits will not inhibit future unit operations. Focus leads clients through the process of developing the compliance test strategy that integrates best with the compliance objectives and the plant operational philosophy.
Test Planning
The test plan is the direct communication with the regulatory agency. Once approved by the agency, the test plan serves largely as a contract between the client and the agency. Therefore, this communication needs to leave nothing to doubt. With the test strategy as a governing principle, Focus starts the test planning process by incorporating the regulatory requirements. Building on this foundation, Focus then incorporates the client’s safety, operations, and compliance objectives obtained from the directed discussions while developing the test strategy. The final test plan clearly delineates the operational targets and associated sampling and analysis for each test condition, and how the test results will be translated to final operating limits. The final document provides a basis for any post-test or future negotiations with the regulatory agency in determining the acceptability of the test data and establishment of the final operational limits.
Pretesting
In many cases, pretesting is highly recommended. Pretesting serves as a dress rehearsal for all aspects of the formal test and provides data on exactly where the system stands with regard to compliance. Going through the steps of testing exposes and identifies operational, logistical, sampling, or analysis issues. The pretest data may be used to make any necessary fine-tuning of test plan or strategy with regard to the operational targets, sampling and analysis protocols, spiking, etc. Pretesting minimizes the potential for problems or difficulties occurring during the formal test, failure to complete the formal test, and surprises in the test results.
Surrogate Spiking
When native waste has characteristics that can achieve the test objectives, this is the ideal and simplest approach. However, when this is not achievable, Focus develops a spiking strategy and plan to enhance the waste material to achieve the characteristics that will best demonstrate compliance. This must be done while achieving the final operational parameter limits necessary for the long-term safe, effective, efficient, and compliant operation of the system with sufficient operational flexibility such that production is not adversely impacted. Focus’ particular approach to selecting appropriate surrogates and spiking logistics, and the associated overlay of sampling and analysis, is based on many years of testing experience, and revolves around the overall testing strategy. Representativeness, compatibility, logistics, cost, performance targets, and detection limits are all considered in developing the surrogate spiking plan.
Test Management
When considering testing approaches, Focus is flexible and adaptable to the client’s particular situation. Focus can provide test management services ranging from turnkey to integration with the client’s existing contractor relationships. Focus, through a network of associates developed over many years of testing, can assemble a test team encompassing emissions testing firms, spiking contractors, and analytical laboratories to professionally execute the test to meet the requirements specified by the plan. In situations where a facility has existing and developed working relationships with particular service providers, e.g., a particular emissions testing firm, Focus will serve as the client’s test manager and assist the client in communications, organization, scheduling, and management of the test team. As necessary, Focus can access the network of providers to augment the existing service providers. These services can be provided contractually through Focus, or contracted directly by the client and under the technical direction of Focus during testing. Regardless of how the test team is assembled, Focus delivers successful test outcomes.
Test Execution
At the time of testing, Focus’ hands-on participation assures that the system is operated at the appropriate conditions and that all test preparations of the system have been made. The testing will be managed on-site by an experienced Focus testing engineer who is present during the entire testing process. The Focus engineer coordinates between the plant management and supervision, system operators, regulatory observers, spiking suppliers, and emissions testing personnel to achieve a smooth and seamless test execution. Focus oversees the testing activities to assure the target operating parameters are demonstrated and that all the samples specified by the test plan are appropriately captured, labeled, preserved, stored, and transported for analysis. Focus works to identify and resolve any test plan deviations in a way that will be mutually acceptable to the regulatory and facility personnel, and in order to preserve the integrity of the test data.
Test Reporting
In order to demonstrate that the control system is operating in compliance with the regulations and that the test objectives were met, the information and data collected during test execution must be reduced, summarized, and effectively communicated in the final report. Focus’ team verifies the calculations, validates that the data meets quality objectives, reviews the information to assure that the test meets the objectives and strategy set out at the start, and translates the test results into operational limits. Testing is documented in a manner that allows one to reproduce and understand exactly how every result presented in the final report was determined. The properly planned and executed test should result in minimal deviations. As needed, the final test report will identify and discuss any significant deviations in the sampling, analysis, QA/QC, or operational targets. Focus believes this approach is imperative so that the issues are identified and their impacts on the test results or determinations are evaluated, understood, explained, and resolved with the client and the regulatory agency.