MEMORANDUM 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

RESEARCH TRIANGLE PARK, NC 27711 

JUL 15 2015 

OFFICE OF 

AIR QUALITY PLANNING 

AND STANDARDS 

SUBJECT: Voluntary Consensus Standard Results for Risk and Technology Review 

Amendments to the Secondary Aluminum Production NESHAP ( 40 CPR Part 63, 

Subpart RRR) 

FROM: 

TO: 

James Hemby Acting Group Lead 

Measurement Teclmology Group 

Chuck French Gr up Leader 

Metals and Inorganic Chemicals Group (D243-02) 

At your request, the Measurement Technology Group (MTG) of the Office of Air Quality 

Planning and Standards (OAQPS) conducted searches and reviews to address the National 

Technology Transfer and Advancement Act (NTTAA) requirements on the use ofvoluntary 

consensus standards (VCS). The NTTAA directs EPA to use VCS in regulatory and procurement 

activities unless doing so would be inconsistent with applicable law or otherwise impracticable. 

This memorandum documents the results of the MTG searches and reviews to determine ifVCS 

are available and practical for use in lieu of stationary source methods cited in the Results for 

Risk and Technology Review Amendments to the Secondary Aluminum Production NESHAP ( 40 CPR 

Part 63, Subpart RRR). 

In 1998, OAQPS began implementing the requirements of the NTTAA by conducting searches 

to identify VCS. Searches continue to be performed to meet the requirements of the NTTAA. 

While we have made a reasonable effort to identify and evaluate potentially practical VCS, our 

findings do not necessarily represent all potential alternative standards which may exist. 

The MTG pmticipates in the American Society for Testing and Materials (ASTM), which is one 

of the most active VCS organizations on emissions testing, and has been invited to participate in 

the USA Technical Advisory Group for International Organization for Standardization (ISO) 

relating to emissions monitoring. We expect these additional efforts will help us to support a 

periodic review of all EPA reference methods and performance standards for possible 

incorporation by reference (IBR) ofVCS in lieu of or as alternatives to EPA procedures. We 

anticipate that these activities will provide an opportunity for further review, consideration and 

possible IBR ofVCS overlooked in the National Standards Service Network (NSSN) searches or 

finalized after Federal agency review in the EPA rulemaking process. 

We conducted searches for the Risk and Technology Review Amendments to the Secondary 

Aluminum Production NESHAP ( 40 CPR Part 63, Subpart RRR) through the Enhanced NS SN 

lntemet Address (URL) • http://www.epa.gov 

Recycled/Recyclable • Printed wtth Vegetable Oil Based Inks on Recycled Paper (Minimum 25% Postconsumer) 
2 

Database managed by the American National Standards Institute (ANSI). We also contacted 

VCS organizations and accessed and searched their databases. 

Searches were conducted for EPA Methods 1, 2, 3, 4, 5, 9, 23, 25A, 26, 26A, and 204 of 40 CFR 

Part 60, Appendix A. 

During the search, if the title or abstract (if provided) of the VCS described technical sampling 

and analytical procedures that are similar to EPA's reference method, the MTG considered it as 

a potential equivalent method. All potential standards were reviewed to determine the 

practicality of the VCS for this rule. This review requires significant method validation data 

which meets the requirements of EPA Method 3 01 for accepting alternative methods or 

scientific, engineering and policy equivalence to procedures in EPA reference methods. The 

MTG may reconsider determinations of impracticality when additional information is available 

for particular VCS. 

One voluntary consensus standard was identified as acceptable alternatives to EPA test methods 

for the purposes of this rule. The voluntary consensus standard ASTM D7520-13, "Standard Test 

Method for Determining the Opacity of a Plume in the Outdoor Ambient Atmosphere" is an 

acceptable alternative to Method 9 with the following conditions: 

1. During the digital camera opacity technique (DCOT) certification procedure outlined in Section 

9.2 of ASTM D7520-13, you or the DCOT vendor must present the plumes in front ofvarious 

backgrounds of color and contrast representing conditions anticipated during field use such as 

blue sky, trees, and mixed backgrounds (clouds and/or a sparse tree stand). 

2. You must also have standard operating procedures in place including daily or other frequency 

quality checks to ensure the equipment is within manufacturing specifications as outlined in 

Section 8.1 of ASTM D7520-13. 

3. You must follow the record keeping procedures outlined in §63 .1 O(b) (1) for the DCOT 

certification, compliance report, data sheets, and all raw unaltered JPEGs used for opacity and 

certification determination. 

4. You or the DCOT vendor must have a minimum of four ( 4) independent technology users apply 

the software to determine the visible opacity of the 300 certification plumes. For each set of25 

plumes, the user may not exceed 15% opacity of any one reading and the average error must not 

exceed 7.5% opacity. 

This approval does not provide or imply a certification or validation of any vendor's hardware or 

software. The onus to maintain and verify the certification and/or training of the DCOT camera, 

software and operator in accordance with ASTM D7520-13 and this letter is on the facility, 

DCOT operator, and DCOT vendor. 

The search identified 15 VCS that were potentially applicable for this rule in lieu of EPA 

reference methods. After reviewing the available standards, EPA determined that 15 candidate 

VCS (ASTM D3154-00 (2006), ASTM D3464-96 (2007), ASTM D3796-90 (2004), ISO 
3 

10780:1994, ASME B133.9-1994 (2001), ISO 9096:1992 (2003), ANSIIASME PTC-38-1980 

(1985), ASTM D3685/D3685M-98 (2005), CAN/CSA Z223.1-M1977, EN 1948-3 (1996), ISO 

14965:2000(E), EN 12619 (1999), EN 1911-1,2,3 (1998), ASTM D6725-01) identified for 

measuring emissions of pollutants or their surrogates subject to emission standards in the rule 

would not be practical due to lack of equivalency, documentation, validation data and other 

important technical and policy considerations. These 15 methods are listed in Attachment 1, 

along with the EPA review comments. 

I hope our research into this matter has been useful and timely to your Group's efforts in this 

rulemaking. Please contact me at (919) 541-5459 with any further questions in this matter. 

Attachments 

cc: Rochelle Boyd, EP A/SPPD (D243-02) 

Michael Toney, EPA/AQAD (E143-02) 
Attachment 1. List of Voluntary Consensus Standards Not Applicable for the Risk and Technology Review Amendm

Secondary Aluminum Production NESHAP (40 CFR Part 63, Subpart RRR) 

SIMILAR EPA 

STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLU

REFERENCE STANDAR

METHOD 

EPA Methods 1, 2, 3B ASTM D3154-00 (2006) - Standard Method for This standard is impractical as an al

and 4 Average Velocity in a Duct (Pitot Tube Method) 1, 2, 3B, and 4 for the purposes of th

appears to lack in quality control and 

requirements. Specifically, ASTM 0

following: ( 1) proof that openings o

not plugged during the test; (2) if dif

other than inclined manometers (e.g

used, their calibration must be check

and (3) the frequency and validity ra

temperature sensors. 

EPA Methods 2 ASTM 03464-96 (2007)- Standard Test Method The applicability specifications in th

Average Velocity in a Duct Using a Thermal clearly defined, e.g., range of gas co

Anemometer limits. Also, the lack of supporting q

the calibration procedures and speci

variability issues that are not adequa

standard limit EPA's ability to make 

ofthe method in these areas. 

EPA Methods 2 ASTM D3796-90 (2004)- Standard Practice for This ASTM standard is intended to b

Calibration of Type S Pi tot Tubes for the S-type pitot tube and not a m

velocity and/or volumetric flowrates 

EPA Method 2. In addition, the cali

require an inclined manometer and d

additional accuracy verifications for 

differential pressur~ gauges. 
SIMILAR EPA 

STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLU

REFERENCE STANDAR

METHOD 

EPA Methods 2 ISO 10780:1994 - Stationary Source Emissions- ISO 10780:1994 recommends the us

Measurement ofVelocity and Volume Flowrate of which historically has not been reco

Gas Streams in Ducts EPA specifies the S-type design whi

are less likely to plug up with dust. 

EPA Method 2, 4, ASME Bl33.9-1994 (2001)- Measurement ofExhaust Not a quantitative method, per se, al

and 5 Emissions from Stationary Gas Turbine Engines this source category that includes tec

(Revision of ANSI B133.9-1979) manual and instrumental sampling p

performance specifications for instru

standard has many good references, 

Methods and Performance Specifica

ENGINESAND TURBINES DO

NOT A METHOD? 

EPA Method 5 ISO 9096:1992 (2003)- Determination of This standard is not acceptable as an 

Concentration and Mass Flow Rate of Particulate Method 5. Although secti ons of ISO 

Matter in Gas Carrying Ducts- Manual Gravimetric Methods 1, 2, and 5 to some degree, 

Method equivalent to EPA Method 5 for coll

matter. The standard ISO 9096 does 

technical guidance for performing m

procedures specified in Methods 1, 2

performance and operational details 

and detailed quality assurance/qualit

sampling operations required to prod

representative particulate data (e.g., 

and monitoring train operating temp

check guidelines and procedures, an

2 
SIMILAR EPA 

STANDARD 

REFERENCE 

METHOD 

EPA Method 5 

EPA Method 5 

VOLUNTARY CONSENSUS STANDARD 

ANSIIASME PTC-38-1980 (1985)- Determination of 

the Concentration ofPa1iiculate Matter in Gas Streams 

ASTM D3685/D3685M-98 (2005) -Test Methods for 

Sampling and Determination of Particulate Matter in 

Stack Gases 

3 

EPA'S COMMENTS ON VOLU

STANDAR

recovery procedures) are not provid

EPA Method 5. Also, details of equ

requirements, such as those specifie

not included in the ISO standard, e.g

measurements, data reduction guida

sample calculations. • 

This voluntary consensus standard i

alternative for EPA Method 5 becau

is not specific about equipment requ

presents the options available and th

option. The key specific differences 

PTC-3 8 and the EPA methods are th

allows in-stack filter placement as c

stack filter placement in the EPA me

different types of nozzles, pi tots, and 

does not specify a filter weighing pr

allowable fi Iter weight fluctuation as 

( 4) allows filter paper to be only 99 

compared to the 99.95 percent effici

methods. 

This method is similar to EPA Meth

following areas that are needed to pr

representative particulate data: ( 1) r

holder temperature should be betwee

not just "above the acid dew-point;" 

for measuring and monitoring the fil

during sampling; (3) procedures sim
SIMILAR EPA 

STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLU

REFERENCE STANDAR

METHOD 

3, and 4, that are required by EPA M

guidance for performing the Method 

e.g., maintaining and monitoring sam

temperatures, and use of reagent bla

subtracting background contaminati

equipment and/or operational requir

exchange leak checks, use of glass c

particulate loading and/or water dro

negative stack pressure, exchanging 

sampling preparation and implemen

recovery guidance, data reduction g

sample calculations input. 

EPA Method 5 CAN/CSA Z223.1-M1977- Method for the Detailed technical procedures and q

Determination of Particulate Mass Flows in Enclosed that are required in EPA Methods 1, 

Gas Streams included in CAN/CSA Z223.1. Sec

does not include in its filter weighin

Method 5 requirement to repeat \Ne

a constant weight is achieved. Third

the weight to be reported to the near

CAN/CSA Z223.1 requires only we

mg. Lastly, CAN/CSA Z223 .1 allow

pitot for velocity measurement when 

opening is not expected to be a prob

Method 5 requires an S-shaped pitot

4 
SIMILAR EPA 

STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLU

REFERENCE STANDAR

METHOD 

EPA Method 23 EN 1948-3 (1996) (European Committee for Provides additional sampling option

Standardization)- Determination of the Mass acceptable in EPA Method 23. 

Concentration ofPCDD'S/PCDF'S- Part 3: 

Identification and Quantification 

EPA Method 25A ISO 14965:2000(E)- Air Quality- Determination of This standard is an impractical alter

Total Nonmetbane Organic Compounds--Cryogenic or 25A because it does not measure 

Preconcentration and Direct Flame Ionization Method concentrations greater than I 0 ppm 

upper limit is 10 ppm carbon has a m

limited to be useful in measuring so

EPA Method 25A EN 12619 (1999) - Stationary Source Emissions- This standard is an impractical alter

Determination ofthe Mass Concentration of Total or 25A because it does not measure 

Gaseous Organic Carbon at Low Concentrations in concentrations greater than 40 ppm 

Flue GasesBContinuous Flame Ionization Detector upper limit is 40 ppm carbon has a m

Method limited to be useful in measuring so

EPA Method 26 and EN 1911-1,2,3 (1998)- Stationary Source Emissions- Part 3 of this standard cannot be con

26A Manual Method of Determination ofHCl-Pati 1: Method 26 or 26A. The sample abso

Sampling of Gases Ratified European Text-Part 2: would be expected to capture both H

Gaseous Compounds Absorption Ratified European present, without the ability to disting

Text-Part 3: Adsorption Solutions Analysis and The EPA Methods 26 and 26A use a

Calculation Ratified European Text solution to first separate HCl and ch

be selectively absorbed, analyzed, a

addition in EN 1911-1,2,3 (1998), th

for chlorine gas would be expected t

water changed during sampling. 

5 
SIMILAR EPA 

STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLU

REFERENCE STANDAR

METHOD 

EPA Method 26 and ASTM D6735-01 -Standard Test Method for This impinger-based standard to me

26A Measurement of Gaseous Chlorides and Fluorides alternative to EPA Methods 26, 26A

from Mineral Calcining Exhaust SourcesCimpinger calcining exhaust sources. 

Method 

EPA Method 204 EN 1093-4:2008- Safety ofMachinery-Evaluation of This standard might work in a limite

the Emission of Airborne Hazardous Substances: Part which are not coating related. This 

4 Capture Efficiency of an Exhaust System-Tracer low results with respect to capture e

Method results with respect to emissions. M

coatings are captured in the oven an

simulate or measure this. 

6