How to Prepare for Comprehensive Performance Tests (CPTs)

March 9, 2023

By: Michael J. Krall

We all know that Comprehensive Performance Tests (CPTs) are required to measure emissions from your CFR 40 Part 63 Subpart EEE units that are released into the air and set operating parameter limits (OPLs) for daily operations.

However, since these tests can be expensive and time-consuming, here’s how you can make the most of your investment.

Plan Your EPA Submission 15 Months Early
You are required to submit test plans to the EPA at least one year in advance of the actual test, and factoring this into your planning phase is important.

You should contact your experts and begin planning at least three months prior to the submission, which means this process should happen at least 15 months before your test date.

And since CPTs are required every 5 years, you should start planning for your next CPT three years after your last test.

Schedule Confirmatory Dioxin Stack Tests (CfPTs)
Confirmatory Dioxin Stack Tests (CfPTS) are required halfway between two CPTs. Typically, this is 31 months after your previous CPTs.

This test is only for Polychlorinated dibenzo-p-dioxins (PCDDs) and polychlorinated dibenzofurans (PCDFs).

Remember, this requires 60 days notification to agencies and plans/QAPP.

Conduct Continuous Emission Systems (CEMS) Performance Specification Tests (PST)
With every CPT and CfPT you will also be required to have a PST that will include Relative Accuracy Test Audits (RATA). The tests are required to show your CEMS collect accurate data and therefore are valid to use to monitor emissions for on-going compliance in submissions to the EPA.

Conduct CPT Waste Spiking (also known as Chemical Spiking)
In some cases, chemical spiking may be required to increase certain compounds in the waste feed to raise input mass rates and provide operating flexibility with regard to OPLs.

Preparing for spiking means additional planning and additional considerations, including tests for compound compatibility, waste feed line pressures, and sufficient spiking chemical rates to achieve OPLs objectives.

First Timers, Plan a Destruction and Removal Efficiency Demonstration
If you’re testing for the first time, you must plan a Destruction and Removal Efficiency (DRE) demonstration for organic emissions control.

Thankfully, a DRE demo may not be required again unless you change your process or waste feed organic composition significantly.

But remember: you must notify the EPA one year prior to any changes.

Be Selective in Selecting Your Contractor(s)

  • Lowest Price is Not Always your Best Selection (You get what you pay for)
  • Select a Contractor Than Can Provide Comprehensive Services That will Translate into Cost Efficiencies (Plan/QAPP Development), Setting Test Conditions, Sampling of Stack and Processes, Management of Analysis and Spiking, Reporting and Notice of Compliance (NOC) Submittals)
  • CPT Experience
  • Experience with Regulatory Agencies
  • Responsiveness

Overall, Here’s Your Long Term CPT Plan

  • 15 months before CPT: Plan and submit Plans/QAPP to the EPA
  • Year 1: Perform CPT
  • Year 2: Plan for and submit CfPT Plan
  • Year 3: Perform CfPT
  • Year 4: Repeat the process

Need Some Help?
We’re ready to help!
Reach out and get expert guidance for your next CPT.

Michael J. Krall
Michael Krall brings almost 40 years of industry experience to the Montrose team where he currently works as Vice President, Technical. Michael is a member of the Coalition for Responsible Waste Incineration, Council of Industrial Boiler Owners, NPRA, AWMA, and the Source Evaluation Society. He is also an EPA-Certified Qualified Energy Assessor (Region 1) and has authored multiple industry related publications with colleagues. Michael holds a degree in Chemical Technology from Broome Community College and a Bachelor’s Degree in Chemistry from State University of New York at Oswego.

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