Why Are Sampling Ports Required to be 90 Degrees Apart?

Why Are Sampling Ports Required To Be 90 Degrees Apart?

This question often arises regarding the requirement to place sampling ports 90 degrees apart in order to be Method 1 compliant.  This article will explain why this requirement is important to keep in mind during stack construction or alteration.

Quick Overview of EPA Method 1

Diagram 1

  1. The flow through the stack at the port location must be minimally cyclonic.
  2. For Method 1, the stack diameter must be 12 inches or greater or 113 square inches in a cross-sectional area–Method 1A includes ducts that are between 6 and 12 inches.
  3. 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).
    1. A minimum of two (2) test ports 90° apart must be installed on the sampling plane
    2. Common sense dictates that four (4) ports are preferred to allow for multiple trains and train maneuverability.
    3. Platform width should be greater than 4 feet from the stack to the handrail.

 

(See the original blog post for more details on the above)  (See the full text of EPA Method 1)

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Proposed Changes to EPA Method 202 for Condensable Particulate Matter (CPM)

On August 23, 2017, the U.S. Environmental Protection Agency (EPA) proposed technical revisions and editorial changes to clarify and update the procedures specified in Method 202.

Method 202 describes the procedures that stack testers must follow to measure condensable particulate matter (CPM) emissions from stationary sources. It is known as the “dry impinger” method.  The proposal does not modify the method significantly. It is in line with steps EPA has taken since 2010 to improve the implementation of the method and promote consistency in the measurement of CPM.

EPA is proposing the following revisions to Method 202:

  • Revisions to the procedures for determining the systematic error of the method, which is used to correct the results of the measurements made using this method;
  • Removes some procedural options to the method to standardize the way method is performed while also eliminating the potential for additional blank contamination;
  • Revise overly prescriptive requirements for the method specific reagents and equipment with more flexible performance-based criteria; and
  • Revise the method to correct inconsistent terminology, improve the readability, and to simplify the text to aid in consistent implementation of the method.

BACKGROUND

In 2010, the EPA revised Method 202 for determining condensable particulate matter (PM) from stationary sources to improve the measurement of fine PM emissions. These revisions increased the precision of Method 202 and reduced potential bias. The revisions improved the consistency in the measurements obtained between source tests performed under different regulatory authorities.

In 2014, the EPA issued interim guidance on the treatment of CPM results in the Prevention of Significant Deterioration (PSD) and Nonattainment NSR Permitting Programs. The guidance addressed concerns that the use of source-specific CPM test results obtained with Method 202 could include a positive bias — resulting in the overestimation of emissions due to the potential for blank contamination associated with the implementation of Method 202. As part of this guidance, the EPA announced plans to issue guidance on best practices for Method 202 implementation and to revise Method 202 as necessary.

In 2016, EPA issued the Best Practices Handbook to mitigate the bias concern, which was developed with significant input from stakeholders and trade groups. The proposed technical revisions incorporate the findings from the handbook.

FOR MORE INFORMATON

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
(microns)

Distribution
(%)

Particle Emission Rate
(lb/hr)

0.5 – 1.0


53.05


5.305

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: http://mvascientificconsultants.com/

 

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 minimally 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 from the nearest upstream disturbance and more than half a stack diameter from the stack exit or next downstream disturbance.  (See Diagram 1).

    Diagram 1 Sample Port Placement

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.  The distance of 90 degrees apart is a requirement whether two (2) or four (4) ports are installed.

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.  All installed platforms should be a minimum of 48 inches wide from stack wall to handrail.  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 © 2018 by Environmental Source Samplers, Inc.  All rights reserved.

Overcoming the Stack Testing Challenges of PM and Method 201a

Stack Test MethodologiesParticulate Matter (PM) is the term for solid or liquid particles found in the air – more accurately referred to as aerosols. Worldwide, most atmospheric aerosol particles (approximately 90%) are produced by ‘natural’ processes such as grinding and erosion of land surfaces resulting in dust, salt-spray formation in oceanic regions, biological decay, forest fires, chemical reactions of atmospheric gases, and volcanic injection. The balance of the PM is anthropogenic in source – from industry, agriculture, transport and construction. Particulate size, elemental breakdown and color can vary significantly between the many sources.

PM can have high levels of toxicity and is considered by the Clean Air Act as one of the Criteria Pollutants. Originally, the focus has been on Total Suspended Particulates (TSP), but over the past decade the EPA has put a greater emphasis on the measurement of smaller particles, those less than 10 and 2.5 microns in diameter (PM10 and PM2.5). This is due to the greater health risk associated with the smaller particles, which are capable of reaching into the lower regions of the respiratory system.

From an emissions sampling standpoint, this has increased the importance of quantifying emissions in specific size ranges, rather than the analysis of total filterable particulate (by EPA Method 5). The most widely accepted methodology for determination of PM10 and PM2.5 from stationary sources is Method 201a. This isokinetic method requires some of the same sampling equipment as Method 5, but includes the addition of sizing cyclone(s) upstream of the PM filter. What is not as well-known are the multiple challenges and limitations with Method 201a that can hamper testing or even make it unfeasible. Many of these challenges can be mitigated but require knowledge of the stack condition prior to the sampling date. Some of these major challenges are summarized below.

Test Port Size – As mentioned, the method requires a particular set of equipment: a probe (equipped with special pitot tube extensions and temperature sensor), in-stack PM sizing cyclone(s) and a nozzle. The cyclone and nozzle combination required for the method are typically stainless steel, inflexible, and have a wide circumference, often wider than the test ports installed in some of the older stacks. Method 5, typically, only requires 4″ test ports, but the 201a equipment requires a test port of 6″ minimum to fit the sampling probe inside, so a facility that is not prepared for 201a testing may find that its test ports are too small and testing cannot take place. Further, if the test port is long, an 8″ (minimum) test port may be required to prevent the nozzle from scraping the inside of the port wall. We urge our clients to properly verify test port configuration prior to our arrival on-site.

Moisture Level of the Stack (Saturated Stacks) – If water droplets are present in the stack, it is not possible to utilize the Method 201a cyclone. The spherical nature of PM is assumed when utilizing the Method 201a cyclone. If moisture is present, this can cause conglomerations of the PM and also cause the PM to stick to the cyclone walls. Additionally, the moisture-laden aerosol mists do not act spherically – thus biasing the results. The EPA-accepted measurement of fine particulates in saturated stacks is Method 5/202, which adds the total filterable PM and the condensable particulate matter (CPM). Although the US EPA has defined PM10 (or 2.5) in a saturated stack as the sum of the PM + CPM, it is clearly an overestimation of the stack emissions.

Temperature of the Stack – Another challenge with the method is dealing with the heat of the gas stream inside of the stack. If the stack gas temperature is over 30 degrees C (85 F), then the Facility must account for the measurement of CPM by Method 202. Therefore, PM10 (or 2.5) is measured as the sum of the filterable fine fraction plus the CPM.

Some of the equipment used in typical 201a trains has a temperature limit of approximately 260 degrees C (500 F) before problems occur with seizing, galling, or thermal breakdown. The method can be used at temperatures of up to 1,371 degrees C (2,500 F) but, in order to do this, it requires the usage of specialty high-temperature resistant material, which generally must be procured or prepared beforehand, and which can drastically influence the price of the testing.

Other Sampling Options/Purpose of Sampling – ESS frequently conducts engineering testing for clients evaluating flue gas streams for particulate matter. The analysis of such streams can provide useful information to control device manufacturers, efficiency experts, and boiler engineers. Although EPA Methodology is required for demonstration of compliance, ESS typically recommends other sampling methodologies for engineering testing.

Such methodologies can include isokinetic sampling on specialty media and analysis utilizing x-ray diffraction, computer-controlled scanning, electron microscopy, or GC/MS scanning. ESS frequently provides in-depth particulate analyses including particulate sizing and elemental composition. Depending on the goals of the sampling, ESS will propose the best methodology to meet your required outcome.  Read more about Stack Test Methodologies ESS is qualified to conduct.

Summary – These factors – port size, stack moisture level, flue gas temperature, and the purpose of the sampling – are all important considerations for your PM test series. The Method 201a/202 test takes more preparation than many other emissions test and requires more communication between the facility and the professional stack testing company being used for the conduct of the test.

As in all things, experience is the key to success. ESS has conducted hundreds of tests for PM, CPM, PM10 and PM2.5 since 1979 and has the knowledge and experience to provide reliable and acceptable results for your engineering or compliance test program. If you require PM/PM10/PM2.5 testing – or other air emissions sampling services – give ESS a call today: 888-363-0039

Stack Testing Methods

Stack Testing Methods

Stack Testing Methods

Whether for engineering purposes or for compliance with EPA regulations, source emissions testing — or stack testing — is an important part of a facility’s operations.

When conducting your stack test the methods used to conduct the testing must be understood and followed carefully, in order to obtain reliably accurate data that will be accepted by the EPA to show compliance.  These methods have been set by the EPA, and are available for public review on the EPA website, which has been linked at the bottom of this article.

A full understanding of each and every method is a long and difficult process that will often require the assistance of specifically trained engineers such as can be found in an experienced stack testing organization.

However, it is helpful to have a basic understanding of some of the more common types of stack testing methods, and for that purpose we have compiled a short list of commonly analyzed pollutants, and the EPA-approved methods used to test for them.

Particulate Matter (PM): EPA Methods 5, 201a, 202 – Particulate matter, also known as particle pollution or PM, is a complex mixture of extremely small particles and liquid droplets. PM is made up of a number of components, including acids (such as nitrates and sulfates), organic chemicals, metals, and soil or dust particles.  Particulates are categorized by size.  “Inhalable coarse particles,” such as those found near roadways and dusty industries, are larger than 2.5 micrometers and smaller than 10 micrometers in diameter. “Fine particles,” such as those found in smoke and haze, are 2.5 micrometers in diameter and smaller.  The smaller the particles the more hazardous they are, as they are more easily absorbed.

  • Method 5 is used to determine filterable particulate matter. The PM mass, which includes any material that condenses at or above the filtration temperature (248 +25oF) is determined gravimetrically.
  • Method 201a is used to measure filterable particulate matter (PM) emissions equal to or less than a nominal aerodynamic diameter of 10 micrometers (PM10) and 2.5 micrometers (PM2.5). You cannot use this method on a wet source.
  • Method 202 is used to measure condensable particulate matter. Method 5 and 201a only measure particulate matter that condenses at or above 248oF. Method 202 is used in conjunction with the above methods to account for PM emissions that condense below 248oF.

Gaseous Emissions (SO2, NOx, CO): EPA methods 3a, 6c, 7e and 10 – This is a catch-all term for a variety of air pollutants that are emitted in gaseous form.  The most common, according to the EPA, are:

  • Carbon monoxide (CO): EPA method 10 — A colorless, odorless gas emitted from combustion processes.  Particularly in urban areas, the majority of CO emissions to ambient air come from mobile sources.
  • Nitrogen dioxide (NO2): EPA method 7e — One of a group of highly reactive gasses known as nitrogen oxides (NOx), also including nitrous acid and nitric acid. NO2 forms quickly from emissions from vehicles, power plants, and off-road equipment. It contributes to ground-level ozone, and fine particle pollution.
  • Sulfur dioxide (SO2): EPA method 6c — One of a group of highly reactive gasses known as “oxides of sulfur.”  The largest sources of SO2 emissions are from fossil fuel combustion at power plants (73%) and other industrial facilities (20%).  Smaller sources of SO2 emissions include industrial processes such as extracting metal from ore, and the burning of high sulfur containing fuels by locomotives, large ships, and non-road equipment.

Each of these methods uses a continuous instrumental analyzer to determine emissions, and requires mobile laboratories or access to climate controlled shelters. Real time results using these methods are available on a ppmvd basis.

Multiple Metals (As, Be, Cd, Cr, Pb, Hg, Ni): EPA Method 29 – This method can be used to determine emissions of 17 different metals, including mercury. Method 5 can be run in the same train to determine filterable particulate emission at the same time. Metals are found naturally in the environment, but also in manufactured products.  The most commonly tested metals include Lead, Mercury, and Arsenic.

Special Note on CEMS RATA: Many facilities use a system know as a CEMS, or Continuous Emissions Monitoring System, that provides continuous feedback on emission levels and act as a substitute for regular stack testing.  These CEMS units are subject to a 3rd party check known as a Relative Accuracy Test Audit, or RATA, to guarantee that it is reading emission levels accurately.   (See info on CEMS Testing)

For how to conduct the methods themselves, there is information available on the EPA website, in an index format, at the following webpage: http://www.epa.gov/region1/info/testmethods/

We invite you to contact Environmental Source Samplers (ESS) to learn more about our stack testing services.  Visit www.ESSKnowsAir.com or call 888-363-0039.

EPA Method 1 – Options for Sample Port Installation

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

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.

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