NESHAP for Area Source Boilers (40 CFR 63, Subpart JJJJJJ)

2017-04-20 NESHAP for Area Source Boilers (40 CFR, Subpart JJJJJJ)

The national emission standards for hazardous air pollutants (NESHAP) for area source boilers (40 CFR part 63, Subpart JJJJJJ) was published in the Federal Register on March 21, 2011 and EPA finalized changes to the rule in the Federal Register on February 1, 2013 and on September 14, 2016. The September 14, 2016, action announced EPA’s final decisions on five issues regarding the February 1, 2013, amendments for which reconsideration was granted.

ESS provides comprehensive emissions testing services to meet the federal and state requirements for industrial boilers, including Subpart JJJJJJ, Subpart DDDDD, Title V, and more.  See our list of capabilities for more information or call 910.799.1055 for more information.

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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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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:


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.