Clearing the Air on VOC Emissions/New test method used by EPA to estimate total mass

摘要

If EPA intends to use a new test method to estimate "total mass of the VOC," such a fundamental change must be undertaken through rulemaking. Not only is case law clear on this point, but also rulemaking will lead to more accurate and consistent accounting of VOC emissions. It offers an opportunity to work though technical problems, such as those in the midwest scaling method, and provide consistency and certainty regarding measurement of VOC emissions. Upon adoption of such a new method, a reasoned transition policy also would be needed to allow for the conversion from the many permits that were based on emissions as measured by the exiting reference test methods. Until EPA undertakes the required rulemaking, however, sources should be aware of the issues associated with VOC measurement and consider permitting and testing approaches that may avoid this issue in further permitting and compliance demonstrations.