EPA Guidance on Method 202 and Recovery Blanks for CPM

EPA Guidance on Method 202 and Recovery Blanks for CPMOn April 8th, 2014, in response to feedback from industry owners, operators, and the NCASI Institute, the US EPA released a memorandum providing interim guidance on the treatment of Condensable Particulate Matter (CPM) test results, and expressed the intention to review and potentially revise the EPA Method 202 used to obtain CPM during a stack test.

At issue is the fear of owners and operators of overestimate of CPM emissions, due to the stringent field train recovery blank correction requirements. The method has many chances for contamination, in the chemicals, equipment, and sample containers that are used to sample, collect, and transport the samples to laboratories for weighing and analysis. This contamination can lead to the overestimation of CPM emissions in the stack, which can result in more stringent permit and operating requirements for a facility, particular in regards to Prevention of Significant Deterioration (PSD) and Nonattainment New Source Review (NSR) permitting programs.

A Field Train Recovery Blank is a part of the sampling method that enables the stack testing firm to determine a base-line for contamination of the actual emissions from the stack. During a standard test series, typically consisting of three (3) 60-minute test runs, a sampling train is set up to perform the blank after either run one or run two. The train is set up in exactly the same manner and procedure as the actual test runs, and is run for the same period of time as the actual test runs, with the exception that the train is not placed into the stack, and so is not grabbing an actual emission sample. The collected sample is labeled as a blank, and analyzed along with the other collected samples. The analysis of the blank sample provides the level of contamination in the sampling train, and the stack testing firm corrects the numbers from the actual test runs to account for this contamination.

However, under the existing rules the Testing Firm was only able to correct up to 2.0mg, even if the blank showed level of contamination higher than that upper limit, and that upper limit was the point of contention that NCASI and Industry Representatives requested action on. Upon reviewing the data presented by all parties, the EPA has agreed that a higher upper limit for blank correction is warranted, and has expressed that, in the interim, Stack Testing firms may use values as high as 5.1mg to be used in the corrections for the calculation of CPM. This is, of course, only if the blank shows readings of up to this amount – if the blank readings are lower, then the actual value will be used.

This solution is only for the interim, while EPA researches the issue. Should EPA feel that the research warrants a revision of the entire Method, that will occur, but in the meantime this action will potentially have real impact on facilities controlled and permitted for particulate matter emissions. In order to achieve the best results for you and your facility, a knowledgeable and experienced stack testing partner, up to date on all news and requirements in the federal and state regulatory bodies, is invaluable.

If you require emissions testing for PM, CPM, or any other regulated pollutants, give ESS a call today at (910) 799-1055.

Related Posts:
Overcoming the Stack Testing Challenges of PM and Method 201a
Compliance Stack Testing and Audit Sample Requirements
EPA Proposal – Carbon Pollution Standards for New Power Plants

Brian Mellor About Brian Mellor

Brian Mellor works with Environmental Source Samplers, Inc. (ESS), an environmental consulting firm specializing in stack testing, CEMS Testing, and EPA air emissions compliance.

ESS has conducted international stack testing projects at Johnson Atoll, in the Philippines, the Dominican Republic, Hong Kong, and various parts of Europe. If you need a team that will do your international job with efficiency and effectiveness, call ESS at (910) 799-1055 or visit www.ESSKnowsAir.com.