Randy: 

We received comments on the FR proposal from Weston Solutions and this comment was not in the comment 

(see attached). However, we have received similar comments from others and will consider the alternatives that 

were suggested in those comments. I will add your e-mail to the Docket as a late comment (the docket closed 

June 26, 2009). 

For your information, when we were assessing the revised test method, we used many of the traditional good lab 

practices for cleaning glassware and found that there were intermittent spikes in the test results when we should 

have been measuring essentially blank samples. By employing the glass cleaning techniques that are used for 

low level organics analysis (e.g Method 23 et.al.) we were able to achieve consistent low blank levels. In some 

ways it was surprising in that it was not the organic blanks that were the problem but the inorganic blanks. If you 

look at the April 14, 2009 update of information on the development of this method you will find a draft 

comprehensive method development support document that was prepared to provide detailed information on the 

laboratory studies and assessments that have been performed by US EPA, Environment Canada, and EPRI that 

provide technical support for the proposed revisions to EPA Method 202 (and OTM-28). The document, “Draft 

Project Report - Evaluation and Improvement of Condensable Particulate Measurement,” can be downloaded 

from http://www.epa.gov/ttn/emc/methods/method202.html . This is much like an earlier project that I had where 

we found intermittent high results due to the inability to remove all the contaminants from the glassware and the 

contaminants were released following one or two uses of the glassware. 

_________________________________

Ron Myers 

U.S. Environmental Protection Agency 

Office of Air Quality Planning and Standards 

Sector Policy and Programs Division 

Monitoring Policy Group, D243-05 

RTP NC 27711 

Tel. 919.541.5407 

Fax 919.541.1039 

E-mail myers.ron@epa.gov 

Any one have thoughts or wants to handle this? 

----- Forwarded by Candace Sorrell/RTP/USEPA/US on 07/08/2009 02:12 PM ----- 

From: Candace Sorrell/RTP/USEPA/US

To: Ron Myers/RTP/USEPA/US@EPA, Jason Dewees/RTP/USEPA/US@EPA

Date: 07/08/2009 02:13 PM

Subject: Fw: Request for consideration re OTM-28

From: "Young, Randolph" <Randy.Young@WestonSolutions.com>

To: Candace Sorrell/RTP/USEPA/US@EPA

Date: 07/08/2009 02:11 PM

Subject: Request for consideration re OTM-28

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Candace— 

 

Are you the correct person to whom we should address these comments? Thank you. 

 

Weston Solutions, Inc. is a significant player in the source (and ambient) testing arena, and would like to ask for 

your consideration of the following points in proposed OTM-28 for condensible particulate matter: 

 

 1) We would generally expect that the soap and water and two different polarity solvent rinses would 

effectively clean the glassware. There are a host of cleaning methods and solutions available in the literature to 

clean glassware for any conceivable purpose. Is there some technical basis for the 300C baking temperature, 

such as volatilizing vacuum greases or other common contaminants? Or was this simply what was used during 

method development? Has the 300 deg C step been shown in field work to be necessary? 

 2) In general, the method is quite proscriptive instead of being performance based. Are there blank 

considerations as cut-off levels, for instance (the 2 mg specified?), that might allow for streamlining certain steps? 

 Most notably, the high-temperature baking? 

3) What is the temperature tolerance on the 300 deg C? 

 

Thanks in advance for your consideration of these items. We look forward to your response. 

 

Randy Young 

Weston Solutions 

Phone: 513-492-7324 

Cell: 513-382-7549 

FAX: 937-531-4401

CONFIDENTIALITY: This email and attachments may contain information which is confidential and 

proprietary. Disclosure or use of any such confidential or proprietary information without the written 

permission of Weston Solutions, Inc. is strictly prohibited. If you received this email in error, please 

notify the sender by return e-mail and delete this email from your system. Thank you. 

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