Three Decades of Condensable Particulate Matter (CPM) Regulation

2017-03-17 Three Decades of CPM Regulation


Condensable Particulate Matter (CPM) is material that is in a vapor state at stack conditions, but condenses and/or reacts upon cooling and dilution in the ambient air to become solid or liquid Particulate Matter (PM) immediately after discharging from the stack.  All CPM is assumed to be in the PM2.5 size fraction.


1987  After promulgating the PM10 National Ambient Air Quality Standards (NAAQS) the EPA began recommending that, in certain circumstances, states consider including the condensable portion of PM10 emissions in the determination of total and fine PM emissions from major stationary sources.

1991  EPA Promulgated Method 202.  The original Method used wet impingers – in which sulfur dioxide was captured and formed sulfur trioxide and sulfuric acid artifacts. This caused captures to be biased high by improperly quantifying the sulfuric artifacts as condensable PM.

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OSHA News: US Department of Labor Issues Final Rule to Lower Beryllium Levels

2017-01-06 New OSHA Rule for Beryllium Exposure

WASHINGTON – A new rule issued today by the U.S. Department of Labor’s Occupational Safety and Health Administration dramatically lowers workplace exposure to beryllium, a strategically important material that can cause devastating lung diseases. The new beryllium standards for general industry, construction and shipyards will require employers to take additional, practical measures to protect an estimated 62,000 workers from these serious risks.

Beryllium is a strong, lightweight metal used in the aerospace, electronics, energy, telecommunication, medical and defense industries. However, it is highly toxic when beryllium-containing materials are processed in a way that releases airborne beryllium dust, fume, or mist into the workplace air that can be then inhaled by workers, potentially damaging their lungs.

Recent scientific evidence shows that low-level exposures to beryllium can cause serious lung disease. The new rule revises previous beryllium permissible exposure limits, which were based on decades-old studies.

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The Benefits of Automated Particulate Analysis by SEM-EDS

Automated Particle Analysis by SEM/EDS

When encountering puzzling particulate results, questions arise such as:

What species of particulate are in this sample?

What is the chemical composition of these particles?

What is the particle size distribution of this sample?

Automated particle analysis by Scanning Electron Microscopy and Energy Dispersive X-ray Spectrometry (SEM-EDS) provides a method to answer questions about particle populations that arise in a very wide range of industries. Some examples of SEM-EDS application include: wear particle analysis, size distribution of pharmaceutical ingredients, source determination of airborne particulate, and nanoparticle characterization.  SEM-EDS can also determine whether non-process related particulate is biasing the catch through identification of particle species and chemical composition.

SEM-EDS is a powerful analytical tool for obtaining concise information about a particulate sample.

Figure 1: Representative Automated Particle Analysis High Contrast

Figure 1: Representative Automated Particle Analysis High Contrast

The first step in SEM/EDS automated particle analysis is to acquire a background image with sufficient contrast between the background and the particles so that image analysis can differentiate between them (Figure 1).  For automated image analysis systems, a “particle” is defined as a set of contiguous pixels all of which are brighter (or more rarely, darker) than the threshold brightness used to define the surrounding “background” pixels.

Next, particles are recognized by the image analysis system (which is a part of the SEM/EDS software).  Figure 2 shows the same field of view as Figure 1, except that there is indication of the particle count that the system has identified.  The analysis system saves the location of each particle and then two-dimensional size and shape parameters for each particle are determined. Typical parameters include maximum, minimum and average diameters, perimeter, and aspect ratio.

Figure 2: Representative Automated Particle Analysis

Figure 2: Representative Automated Particle Analysis

Once the particles in the field of view are recognized, the automation system of the microscope conducts a chemical analysis of each particle to acquire the signature on an EDS spectrum.  A typical example appears as Figure 3.  A peak in the EDS spectrum indicates the presence of the corresponding element in the particle which can then be classified based on its composition.  In Figure 3, the spectrum shows the particle to be composed of Iron (Fe) and Oxygen (O), indicating an Iron Oxide particle.

Once every particle in the field of view is recognized and its dimensions and composition saved, the microscope moves to a new field of view and the process is repeated until a set number of particles or a predetermined number of fields of view have been analyzed.  Using this systematic analysis sampling allows for the characterization (size, shape, composition) of hundreds and even thousands of particles in just a few hours without operator involvement beyond the initial setup.

Figure 3: Representative EDS Spectrum of Automated Particle Analysis

Figure 3: Representative EDS Spectrum of Automated Particle Analysis

Finally, the results are tabulated, giving a complete picture of the particle types, sizes, and shapes.  The tabulation is entirely customizable since all of the data (size, shape, composition) is stored for each individual particle.

Table A: Percent Distribution of Particles by Mass with Corresponding Emission Rate

Amount of Particulate Emitted in One (1) Hour = 10 lbs

Particle Size


Particle Emission Rate

0.5 – 1.0



1.0 – 2.5 37.25 3.725
2.5 – 5.0 7.57 0.757
5.0 – 7.5 1.44 0.144
7.5 – 10 .40 0.04
10 – 25 0.28 0.028
25 – 50 0.00 0
50– 100 0.01 0.001
>100 0.00 0
TOTALS 100 10

ESS provides emissions testing, air quality analysis, and consulting services for manufacturers, municipal water treatment plants, public utilities, paper mills, and other industrial facilities in the US and overseas.  Since its inception in 1979, ESS has conducted thousands of emissions tests and provided countless hours of environmental consulting services.  ESS specializes in conducting the EPA testing methods for all applicable EPA subparts, such as: NSPS (40 CFR 60), NESHAP (40 CFR 63), RATA (40 CFR 75), and various other federal and state regulations.

We are committed to the highest standards of integrity, excellence and customer service.  ESS continues to invest in facilities, equipment, education, and safety to provide a broad range of services to meet our clients’ varying needs.

Adapted from information available at:


Scientists Find Way to Convert CO2 Into Ethanol

CO2 to Ethanol

Scientists at the Oak Ridge National Laboratory in Tennessee have discovered a chemical reaction to turn CO2 into ethanol, potentially creating a new technology to help avert climate change. Their findings were published in the journal ChemistrySelect.

Researcher had hoped to convert carbon dioxide that had been dissolved in water to methanol, a chemical released naturally by volcanic gases and microbes, which can cause blindness in humans if ingested.

But instead of methanol, they discovered they had ethanol, a primary component of gin and also a potential fuel source. Surprised, the team realized that not only was their new material converting the carbon dioxide to ethanol, it needed very little outside support.

The material is a small chip–about a square centimeter in size–covered in spikes, each just a few atoms across. Each spike is constructed out of nitrogen with a carbon sheath and a small sphere of copper embedded in each tip. The chip is dipped into water and carbon dioxide is bubbled in. The copper acts as a small lightning rod, attracting electricity and driving the first steps of the conversion of the carbon dioxide and water into ethanol, before the molecules move to the carbon sheath to finish the process.

Read more about this exciting development in the full article from Popular Science.

ZZZZ Compliance Testing and Portable Analyzers

Reciprocating Internal Combustion EngineSeveral million stationary reciprocating engines are in use throughout the United States. These engines, in general industry use, provide shaft power to drive process equipment, compressors, pumps, standby generator sets and other machinery. The uses are similar in agriculture, with many engines serving the purpose of driving irrigation pumps. Reciprocating engines also find wide application in municipal water supply, wastewater treatment, and in commercial and institutional emergency power and load-managing stations.

Many of these engines are subject to the RICE NESHAP, promulgated  by the EPA under 40 CFR 63, Subpart ZZZZ. Under Subpart ZZZZ, an owner/operator must demonstrate compliance by stack testing at the outlet exhaust to demonstrate the concentration of Carbon Monoxide (CO) in the stack exhaust of < 23 ppmvd at 15% O2.

This testing is typically conducted using continuous emissions monitors (CEMS), under EPA Test Methods 3a and 10, which provide the most accurate data possible on gaseous emissions. This approach is the gold standard for Subpart ZZZZ compliance testing and, as such, it is the methodology ESS uses.

An alternative approach to 3a and 10 is using ASTM D6522-00.  Rather than using CEMS, ASTM D6522-00 utilizes portable monitors, such as Testo 320s or 350s, for the reading of gaseous emissions.  While this method is EPA-approved for the conduct of ZZZZ testing for all engine ratings, it has been our experience that it simply does not provide the high-level accuracy we demand of our equipment.

However, with any methodology and any test series, an experienced partner is the most crucial component to conducting a successful test, properly compiling and submitting the data, and working with state and federal requirements.

Since 1979, ESS has had the personnel and equipment to help your facility demonstrate compliance with any state and federal air-quality and emission requirement. If a stack test is required for your facility, give ESS a call today at (910) 799-1055.

Learn more:
Your One Stop Shop for RICE NESHAP ZZZZ Compliance
A Guide To Subpart ZZZZ and JJJJ RICE Rules
New RICE Rules for MACT Standards and Compliance

ESS Offers Electronic Reporting Tool (ERT) Entry for Emissions Compliance Reports

In 2016, ESS is working hard to stay at the forefront of the EPA’s Electronic Reporting Tool (ERT) report submittal system.  ESS now has customized spreadsheets designed for compatibility with the ERT uploading tool, resulting in faster entry in to the ERT.

According to the EPA, the ERT is used to electronically create and submit stationary source sampling test plans to regulatory agencies and, after approval, to calculate and submit the test results as an electronic report to the regulatory agency.

The ERT replaces the time-intensive manual preparation and transcription of stationary source emissions test plans and reports currently performed by contractors for emissions sources and the time-intensive manual quality assurance evaluations and documentation performed by State agencies. The ERT provides a format that:

  • Highlights the need to document the key information and procedures required by the existing EPA Federal Test Methods;
  • Facilitates coordination among the source, the test contractor, and the regulatory agency in planning and preparing for the emissions test;
  • Provides for consistent criteria to quantitatively characterize the quality of the data collected during the emissions test;
  • Standardizes the reports; and
  • Provides for future capabilities to electronically exchange information in the reports with facility, State or Federal data systems.

Currently, the EPA requires ERT reporting for compliance tests falling under the following rules:

Promulgated Regulations with Electronic Data Reporting Requirements*

Source Category Code of Federal Regulations Reference
40 CFR Part 60 40 CFR Part 63
Chromium Electroplating (Hard and Decorative) and Chromium Anodizing Tanks   Subpart N
Coal Preparation and Processing Plants Subpart Y
Commercial Industrial Solid Waste Incinerators Subpart CCCC and DDDD
Electric Utility Steam Generating Units Subpart Da Subpart UUUUU
Flexible Polyurethane Foam Production Subpart III
Gold Mines Subpart EEEEEEE
Industrial, Commercial, and Institutional Boilers Area Source Subpart JJJJJJ
Industrial, Commercial, and Institutional Boilers Major Source Subpart DDDDD
Industrial-Commercial-Institutional Steam Generating Units Subpart Db Subpart UUUUU
Industrial-Commercial-Institutional Steam Generating Units, Small Subpart Dc Subpart UUUUU
Marine Tank Vessel Loading Operations Subpart Y
Nitric Acid Plants Subpart Ga
Oil and Natural Gas Production Subpart OOOO Subpart HH and HHH
Pesticide and Active Ingredient Production Subpart MMM
Pharmaceuticals Production Subpart GGG
Polyether Polyols Production Subpart PPP
Polymers and Resins Group I Subpart U
Polymers and Resins Group IV Subpart JJJ
Polyvinyl Chloride and Copolymers Production Subpart HHHHHHH
Portland Cement Subpart F Subpart LLL
Printing and Publishing Industry Subpart KK
Pulp and Paper Industry Subpart S
RICE Subpart IIII and JJJJ Subpart ZZZZ
Secondary Lead Smelting Subpart X
Sewage Sludge Incinerators Subpart LLLL and MMMM
Steel Pickling– HCl Process Facilities and Hydrochloric Acid Regeneration Plants Subpart CCC
*EPA requirements subject to change.  See for the most up-to-date list


Call ESS today for a quote on your next air emission compliance test and we’ll provide you with exemplary service throughout your project.  910-799-1055.

Sample Port Installation, EPA Method 1, and Successful Testing

Too often the installation of sampling/testing ports is an afterthought in the process of stack construction.  However, sampling ports are essential to the stack testing process which is a requirement for demonstrating compliance.  In fact, the EPA goes so far as to state outright that Method 1 should be taken into consideration before stack construction begins.

Having a better understanding of EPA Method 1 can reduce or eliminate the need for excess modifications on an existing source.  That means knowing the optimum location for sampling ports can save money in your compliance testing budget.

So what is EPA Method 1 exactly and how can it be helpful to the pre-construction design and post-construction installation of sampling ports?

Simply stated, EPA Method 1 is a way to determine sampling port locations that are free from swirling air, or cyclonic flow.

What causes Cyclonic Flow?

Cyclonic Flow occurs when the sampling plane is too close to a disturbance (vane straighteners, fans, control equipment, etc.) or any duct configuration that causes a disturbance in the air flow causing the air to swirl rather than travel on a linear path.

Determining Placement of Sampling Ports

EPA Method 1 provides two options for sample port installation, as follows:

Simplified – Used most often and applies to most stacks

Alternative – Used for smaller stacks with a diameter less than 12 inches

The majority of our clients have larger stacks, so we’ll overview the Simplified Port Installation guidelines, but don’t hesitate to call us at 1-888-363-0039 if you need assistance understanding Alternative Port Installation.

Three Conditions for Simplified Port Installation

  1. The flow through the stack at the port location must be non-cyclonic.

Following Method 1 procedures as detailed by the EPA prevents issues with cyclonic flow for most stationary sources.  Cyclonic flow at a sampling plane will skew results which becomes an expensive issue if it causes compliance failure, that’s why ESS conducts EPA Method 1 with all stack testing.

  1. The stack diameter must be 12 inches or greater or 113 square inches in a cross-sectional area.

When the stack diameter is less than 12 inches, Alternative Port Installation must be used.

  1. The sampling plane must be located more than two stack diameters downstream from the nearest upstream disturbance  and more than half a stack diameter upstream from the stack exit or next downstream disturbance.  (See Diagram 1).
Diagram 1 Determining Sampling Plane

Diagram 1 Determining Sampling Plane

A disturbance is anything that interrupts or alters the flow of air and gas through the stack.  Examples of disturbances include: fans, duct bends, stack exits and vane straighteners.

Upstream measurement is the distance between the test ports and the nearest upstream disturbance.

Conversely, downstream measurement is the distance between the test ports and the stack exit.

To calculate the equivalent diameter of a rectangular duct use the equation:
De= 2(LxW) / (L+W)

While those three items cover the requirements for Method 1 Simplified Port Installation, there are still other sampling port factors to consider for a smooth test day.

Port Size and Pollutants Tested

Particulate, metals, dioxin/furans, flowrate or other manual method tests require a minimum of two (2) 4”-diameter ports located 90 degrees from each other.  PM10 and PM2.5 require at least two (2) 6”-inch ports.  It is common to install four (4) of these test ports 90 degrees apart from each other so that more testing can be conducted simultaneously.

Sampling ports for gases should be greater than one-quarter-inches in diameter and installed directly above one of the manual method ports.

Port Access

OSHA-compliant platforms are required for the testing team to access the sampling plane safely and effectively.  If a temporary platform must be erected, then OSHA-compliant scaffolding is preferred, but man lifts are also acceptable.  Scaffolding should be constructed directly in front of each sample port with enough room for the sampling equipment to access the ports (see diagram 2).

Diagram 2 Scaffolding Placement

Diagram 2 Scaffolding Placement

The safety of our crew is of utmost concern, so OSHA-compliant structures are mandatory for testing.

When test day arrives, be sure that sample ports are clean and free from debris.  Sample port condition is regularly monitored by state regulators.

Stack pressure and stack temperature can also affect sampling plane design—call us if you have questions on this point.

There are many issues to consider for an emissions test.  Being prepared with the knowledge to properly construct sample ports will save money by preventing excessive stack modification.  Furthermore, understanding and adhering to the guidelines of EPA Method 1 will ensure that sample port, size, placement, and access are not an issue on test day.

For assistance in determining your specific sampling port needs, questions about EPA Method 1, or any other stack testing issues feel free to call Environmental Source Samplers at 1-888-363-0039.  It would be our pleasure to assist you.

Download a PDF version of this article.

Copyright © 2015 by Environmental Source Samplers, Inc.  All rights reserved.

Understanding Upstream and Downstream

The terms “upstream” and “downstream” are frequently used in the stack testing industry to describe direction within a stack.  However, these terms are often confused and used opposite of their intended meaning.

The key to remembering upstream and downstream when talking about flow is to think about another flowing object—a river!

Rivers generally flow from a source, like a mountain lake, to an outlet, like the ocean where the freshwater disperses into the saltwater.  In terms of stack air flow, the air emissions originate from an emissions source and travel through the stack to the stack exit where they disperse into the atmosphere.

The direction of travel from a source to an outlet is with the current, or downstream.  Conversely, the direction of travel from an outlet to a source is against the current, or upstream.

There are two simple mnemonic devices which can help you to remember the difference between upstream and downstream.

“Up the Creek Without a Paddle”

Imagine you are in a canoe enjoying a peaceful trip down the river when you hear the sound of a waterfall ahead.  You look around for your oars, but there are none in sight.  Frantically, you use your arms to try to paddle further upstream to safety, but it is very difficult because you are fighting the current.  This is a situation of being up the creek without a paddle.

Upstream is the direction toward the source and also against the current.

Upstream Downstream Diagram

Diagram Showing Upstream and Downstream in Relation to Current


“Gently Down the Stream”

Now imagine that you made it safely to the river bank and carried your canoe to bypass the waterfall on foot.  You put the canoe back into the river where you can lay back and relax because the current is carrying you gently down the stream to your destination.

Downstream is the direction away from the source and also with the current.

The diagram above is a visual aid demonstrating the relationship between current and upstream/downstream direction.

If you have questions about this topic, or any other emissions testing question, please call Environmental Source Samplers at 1-888-363-0039 and we will be happy to help you.

Download a PDF version of this article.

Copyright © 2015 by Environmental Source Samplers, Inc.  All rights reserved.

Preparing Your Hot Mix Asphalt Plant for Air Permit Compliance Testing

The saying “Time flies” never seems more appropriate than when air permits need to be renewed for Hot Mix Asphalt (HMA) plants.

If your plant’s permit is expiring soon (or even if it’s a bit down the road), it may benefit you to review the EPA-mandated testing required under your state-issued air permit.  With this in mind, allow us to provide a brief overview about air emissions testing for Hot Mix Asphalt plants.

Mobile Asphalt Plant by Wikisay (Own work) [CC BY-SA 3.0 ( or GFDL (], via Wikimedia Commons

Mobile Asphalt Plant by Wikisay

Why are Hot Mix Asphalt plants required to test air emissions?

In the past, HMA plants were notorious for generating noticeable levels of dust, smoke, odors, and noise.   In 1973, the EPA enacted New Source Performance Standards (NSPS), which required HMA producers to pass strict emission standards and install control systems to prevent the release of dust and smoke into the air. A facility must also meet stringent visible emissions tests in order to comply with regulations.  These NSPS rules have had a dramatic effect on the decreased levels of pollution emitted by HMA plants, and thus the testing continues to be a part of the regulations with which HMA plants must comply.

When do Hot Mix Asphalt plants need to test for air emissions?

The date by which an HMA plant must conduct compliance testing and submit a report to the state EPA office is outlined in each plant’s individual air permit.  In some cases, the air emissions test report may be due 12 months or more before the current permit expires.

It is important to note that new HMA plants are required to conduct performance testing within 60 days after achieving maximum production rate, but no later than 180 days after initial startup of the facility. (See 40 CFR 60 Subpart A §60.8)

Nearly all HMA plants operate on a limited calendar, with summer being the busiest season.  As a result, there are a limited number of days available to perform emissions testing.  It is best to plan testing so that it occurs earlier than the permit requires in case the weather causes a delay or cancellation of the intended testing.

How far in advance must Hot Mix Asphalt plants provide notice of testing to the state authorities?

NSPS rule 40 CFR 60 Subpart A §60.8 specifically requires owners to notify the state regulatory agency 30 days in advance of the anticipated test date.

The state authority may also require submission of protocols in advance of testing.  Check your individual air permit for your state’s test protocol submission rules.

What tests are required under NSPS 40 CFR 60 Subpart I – Standards of Performance for Hot Mix Asphalt Facilities?

 According to 40 CFR 60 Subpart I, the following EPA Methods are required for air compliance testing at Hot Mix Asphalt plants:

  • EPA Method 5 – Measures Filterable Particulate Matter (FPM)
  • EPA Method 9 – Measures Visible Emissions (VE)

Some states require additional particulate testing via EPA Method 202, although the NSPS does not require it.  Please check with your state regulatory agency for the requirements concerning your facility.

When are air emissions test reports due to the state regulatory office?

It depends.  For instance, South Carolina requires a hard copy in office (not just postmarked) by the 30th calendar day post-test, but North Carolina allows 60 days to submit the report.

However, we recommend that you consult your air permit for a specific answer.  Your state-issued air permit will outline all the specifics for your emissions compliance requirements.

Does ESS test air emissions at Hot Mix Asphalt plants?

Yes.  ESS currently conducts air emissions testing for Hot Mix Asphalt plants in North Carolina, South Carolina, and Virginia.

With some of the most experienced testing staff in the industry, ESS can meet all of your testing needs for a competitive price.  Our staff of professionals strives to provide courteous, timely service that exceeds client expectations.

Call us at 1-888-363-0039 or send an e-mail to to discuss your specific air testing needs.  We will be happy to assist you.

ESS Asia Conducts Isokinetic Training for EATC Students

Hanoi, Vietnam – Environmental Source Samplers, Inc. (ESS) continues its growth in the air-testing and environmental air-consulting markets of Southeast Asia. Continuing its multi-year expansion into the networks of the environmental sector of Vietnam, ESS was awarded a contract to provide training in the conduct of isokinetic emissions sampling for employees of the Vietnamese company Environment Analyze and Technique (EATC). EATC selected four of their most-experience and qualified technicians to attend the ESS training seminar, in order to further expand their skills with Apex Instruments isokinetic sampling equipment.

EATC students in Vietnam 2The objective of the three-day seminar was to introduce the EATC technicians to the basic principles of isokinetic testing and develop their sampling skills. The course was designed to train the students to develop the ability to plan, guide, evaluate, and personally conduct the source-sampling techniques and measurements in order to determine certain pollutant’s emission rates from stationary sources. The course provided a detailed review of EPA Methods 1 through 5, used to measure emission rates of Filterable Particulate Matter (FPM) from emissions sources.

Chief among the skills, methods, and techniques provided by the course was an overview of the basic operations of the sampling equipment, including the nomenclature and terminologies associated with its usage. Also covered were the purpose of the relevant testing methods, and an introduction to the field and lab calibrations and calculations that are a part of the methodology. Finally, ESS hosted a field sampling exercise to demonstrate the conduct of a Method 5 test, utilizing the Apex Instruments Source Sampling Train.

Emissions sampling is an increasingly important aspect of environmental protection in the Asian market, as the environmental impact of increasingly-rapid growth and industrialization are felt in the quality of air and water. As ESS’s work has grown in the Southeast Asian region, it has been increasingly important to maintain a staff and local presence in these growing markets. In January of 2013 ESS opened its first Asian office in Hanoi, Vietnam. In early February, ESS signed an agreement with Berkman Systems, allowing ESS to combine its expertise in US EPA sampling methodologies with the Berkman network of operations in Metro Manila, Cebu, and Davao, Philippines. ESS has leveraged its connections to grow rapidly in the region’s environmental sector, and continues to provide cost-effective solutions, and superior technical support for our client’s consulting and air-testing needs.

ESS is proud of our growing list of clients and network with key Vietnamese environmental firms such as EATC. ESS will continue to maintain its competitive advantage by building on its international experience; developing offices in strategic markets and assuring client satisfaction on every project.

Founded in 1979, ESS has been conducting point source, ambient and industrial hygiene air quality testing and consulting. ESS utilizes modern and consistently maintained equipment to conduct its testing services world-wide. They are qualified to conduct a wide range of air testing methodologies in almost any environment – and for almost any industry. ESS clients have easy access to the reliable and accurate reporting of test results through a secure online client portal, accessible through the main website, The ESS network of reputable vendors and service providers enables us to drive all our projects to on-time and on-budget completion. To learn more about ESS and their air quality testing services in Asia, the U.S. and beyond, please call (910) 799-1055 or visit

Here are a few more photos from the training exercises…

EATC students in Vietnam 3 EATC students in Vietnam 4 EATC students in Vietnam