Clean Air Act & Air Permitting
Under the Clean Air Act (CAA), facilities that emit air pollutants—including combustion units, turbines, oil & gas operations, cement manufacturing, biogas systems, and landfill gas systems—must obtain air permits. Permits specify emission limits, monitoring requirements, recordkeeping, reporting, and testing protocols.
Applicable Sources & Emissions
- Combustion units, such as industrial boilers or gas-fired turbines, emit NOₓ, CO, SO₂, O₂, VOCs and particulate matter.
- Oil & Gas operations (compressors, flaring) and turbines require permit conditions under New Source Performance Standards and state-specific rules.
- Cement factories generate NOₓ, SO₂, particulate matter, and CO₂ and often require continuous or periodic monitoring.
- Biogas facilities and landfills generate methane and VOCs; they may operate flares or energy recovery systems under Title V permits.
Gas Analysis & Testing Instruments
Testing methods often rely on portable and fixed gas analyzers by manufacturers like Testo, MRU, Horiba, and M&C Tech, which support measurement of CO, NOₓ, O₂, CH₄, and VOCs. These instruments must be calibrated with traceable standards prior to testing. Many state permits require data from certified analyzers during periodic stack testing or source sampling to confirm compliance.
EPA EMC: Test Methods & Guidelines
- The EPA Air Emission Measurement Center (EMC) publishes a comprehensive catalog of promulgated test methods (e.g. Method 7C for NOₓ, Method 10 for CO) and conditional test methods (CTMs) like CTM‑034 used for simultaneous gas measurements
- EMC also provides guideline documents clarifying specific technical issues, calibration practices, and equipment requirements US EPA.
CTM‑030 offers detailed calibration and concentration verification procedures: calibration gas verification using EPA Protocol G1/G2 is mandatory before emissions measurement
Compliance Testing Procedures
📊 Periodic Stack Testing
- Permittees must conduct stack testing at intervals defined in their permit (e.g., annually or every 3–5 years).
- Tests are performed using EPA‑approved methods, often with portable analyzers connected to the stack or sampling port.
- Measured pollutants typically include CO, NOₓ, O₂, CH₄, and VOCs.
- Calibration before each test is required: span gas verification, analyzer zero/span checks, and QA/QC logs.
🧪 Continuous Emission Monitoring Systems (CEMS)
- In many large facilities—especially combustion turbines and cement plants—continuous gas monitors (CEMS) are mandated under Performance Specifications
- CEMS must meet criteria for accuracy, precision, and drift correction, and periodic audits or calibrations are required at set intervals
📥 Analysis & Reporting
- Post-test, data is compiled and compared to permit limits.
- Facilities must file compliance certifications, submit raw data, QA/QC logs, and deviations via NJDEP or EPA systems.
Source-Specific Considerations
| Source Type | Key Pollutants | Common Testing Methods | Example Analytical Tools |
| Combustion/Turbines | NOₓ, CO, O₂, SO₂ | EPA Methods 7C/D/E, 10, CTM‑034 | MRU, Testo portable analyzers |
| Oil & Gas Units | CH₄, CO, VOCs | CTM‑034, OTM‑50 | Gas analyzers, canisters |
| Cement Factories | PM, NOₓ, CO | Continuous (CEMS) + periodic | Fixed monitors & hand tools |
| Biogas & Landfills | CH₄, VOCs | Biogas sampling, flare testing | Gas analyzers, canister methods |
CTM‑034
- CTM‑034 is a standardized conditional test method commonly used for simultaneous measurement of O₂, CO, NOₓ from combustion sources, using portable analyzers.
- It outlines procedures for calibration, sampling, data reduction, and quality assurance.
- Many state permits reference CTM‑034 for short-duration stack testing to verify compliance with emission limits.
At Highmark Analytics, we specialize in helping industrial and commercial facilities meet the stringent requirements of the EPA’s Clean Air Act through comprehensive air emissions testing and permitting support. Our services are designed to ensure your operation remains compliant, efficient, and audit-ready.
🔍 Emissions Testing & Reporting
We offer on-site stack testing, mobile gas analysis, and continuous emissions monitoring solutions using trusted equipment from leading manufacturers like Testo, MRU, Horiba, and Signal Group. Our experienced technicians follow EPA-approved test methods (such as CTM-034, Method 10, 7E, etc.) to deliver accurate, documented results for pollutants including NOₓ, CO, SO₂, O₂, VOCs, and particulates.
📑 Air Permitting Assistance
Highmark Analytics works closely with environmental consultants and regulatory agencies to support your Title V, minor source, or general permit needs. We help interpret permit conditions, determine applicable emissions limits, and develop a testing schedule to meet compliance deadlines.
🛠 Equipment Rentals & Training
We also offer short- and long-term rentals of gas analyzers and emissions testing equipment, along with setup guidance and user training, so your team can operate confidently and in full compliance with regulatory standards.
✅ Compliance You Can Count On
From initial permitting to ongoing testing and reporting, Highmark Analytics provides the tools, expertise, and support to help your facility meet federal, state, and local air quality regulations—accurately and efficiently.


Gas Analysis & Testing Instruments
🧪 Continuous Emission Monitoring Systems (CEMS)