# 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 ProductionNESHAP ( 40 

# CPRPart 63, 

# Subpart RRR) 

# FROM: TO: James Hemby Acting Group Lead MeasurementTeclmology Group Chuck French Gr up Leader Metals and Inorganic Chemicals Group (D243-02) Atyour request, the Measurement Technology Group (MTG) ofthe Office ofAir 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 EPAto use VCS inregulatory and procurement activities unless doing so would be inconsistent with applicable law or otherwise impracticable. This memorandum documents the results ofthe MTG searches and reviews to determine ifVCS are available andpractical for use in lieu ofstationary source methods cited inthe Results for Risk and Technology Review Amendments to the Secondary Aluminum Production NESHAP ( 40 

# CPR Part 63, 

# Subpart RRR). 

# In 1998, OAQPS beganimplementing the requirements ofthe NTTAA by conducting searches to identify VCS. Searches continue to be performedto meetthe requirements ofthe NTTAA. While we have made a reasonable effort to identify and evaluatepotentially practical VCS, our findings do notnecessarily represent all potential alternative standards whichmay exist. The MTGpmticipates in the American Society for Testing and Materials (ASTM), which is one ofthe most active VCS organizations onemissions testing, and has beeninvited to participate in the USATechnical Advisory Group for International Organizationfor Standardization (ISO) relating to emissions monitoring. We expectthese additional efforts will help us to support a periodic review ofall EPA reference methods and performance standards for possible incorporationbyreference (IBR) ofVCS in lieu ofor as alternatives to EPA procedures. We anticipate that these activities will provide an opportunity for further review, consideration and possible IBR ofVCS overlooked in theNational Standards ServiceNetwork (NSSN) searches or finalized after Federal agency review in the EPArulemaking process. We conducted searches for the Risk and Technology Review Amendments to the Secondary Aluminum ProductionNESHAP ( 40 

# CPR Part 63, 

# SubpartRRR) 

# throughthe Enhanced NSSN

lntemet Address (URL) • http://www.epa.gov Recycled/Recyclable • Printed wtth Vegetable Oil Based Inks on Recycled Paper (Minimum 25% Postconsumer)

# 2 Database managedby the AmericanNational Standards Institute (ANSI). We also contacted VCS organizations and accessed and searched their databases. Searches were conducted for EPAMethods 1, 2, 3, 4, 5, 9, 23, 25A, 26, 26A, and 204 of40 CFR Part 60, Appendix A. 

# During the search, ifthe title or abstract (ifprovided) ofthe VCS describedtechnical sampling and analytical procedures that are similarto EPA's reference method, the MTG considered it as a potential equivalent method. All potential standards were reviewedto determine the practicality ofthe VCS for this rule. This review requires significantmethod validation data whichmeets the requirements ofEPA Method 301 for accepting alternative methods or scientific, engineering andpolicy equivalence to procedures inEPAreference methods. The MTGmayreconsider determinations ofimpracticality when additional information is available for particular VCS. One voluntary consensus standard was identified as acceptable alternatives to EPAtest methods for thepurposes ofthis rule. The voluntary consensus standard ASTMD7520-13, "Standard Test Methodfor Determining the Opacity ofa 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 ofASTM D7520-13, you or the DCOT vendor must present the plumes in front ofvarious backgrounds ofcolor 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 ofASTM D7520-13. 3. You mustfollow the record keeping procedures outlined in §63.1O(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 offour (4) independenttechnology users apply the software to determine the visible opacity ofthe 300 certificationplumes. For each set of25 plumes, the user may not exceed 15% opacity ofany one reading and the average error must not exceed 7.5% opacity. 

# This approval does not provide or imply a certification or validation ofany vendor's hardware or software. The onus to maintain and verify the certification and/or training ofthe DCOT camera, software and operator in accordance with ASTM D7520-13 andthis letter is onthe facility, DCOT operator, and DCOT vendor. The search identified 15 VCS that were potentially applicable for this rule in lieu ofEPA reference methods. Afterreviewing 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/CSAZ223.1-M1977, EN 1948-3 (1996), ISO 14965:2000(E), EN 12619 (1999), EN 1911-1,2,3 (1998), ASTM D6725-01) identifiedfor measuring emissions ofpollutants or their surrogates subjectto emission standards intherule would not bepractical due to lack ofequivalency, documentation, validation data and other importanttechnical andpolicy considerations. These 15 methods are listed inAttachment 1, along withthe EPAreview comments. I hope ourresearch into this matterhas been useful and timely to your Group's efforts inthis rulemaking. Please contact me at (919) 541-5459 with any further questions inthis matter. Attachments cc: Rochelle Boyd, EPA/SPPD (D243-02) Michael Toney, EPA/AQAD (E143-02)

### Attachment 

### 1. List of Voluntary Consensus Standards Not Applicable for the Risk and Technology Review Amendments to the Secondary Aluminum Production NESHAP (40 CFR Part 63, Subpart RRR)

S I MILAR EPA STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS REFERENCE STANDARD METHOD EPA Methods 1

, 2, 3B ASTM D3154-00 (2006)

- Standard Method for This standard is impractical as an alternative to EPA Methods

and 4 Average Velocity in a Duct (Pitot Tube Method) 1, 2, 3B, and 4 for the purposes of this rule since the standard appears to lack in quality control and quality assurance requirements. Specifically,

ASTM 03154 does not include the following: ( 1) proof that openings of standard pi tot tube have
not plugged during the test; (2) if differential pressure gauges other t h an inclined manometers (e

. g . , magnehelic gauges) are used,

their calibration must be checked after each test series;
and (3) the frequency and validity range for calibration of the temperature sensors.

EPA

Methods 2 ASTM 03464-96 (2007)- Standard Test Method T h e applic a bilit y specific a ti o n s in thi s A S T M standa r d a re not Average

Velocity in a Duct Using a Thermal clearly defined

, e.g., range of gas composition, temperature Anemometer limits. Also

, the lack of supporting quality assurance data for

the calibration procedures and specifications

, and certain variability issues that are not adequately addressed by the standard limit EPA's ability to make a defmitive comparison ofthe method 

### in these areas.

EPA

Methods 2 ASTM D3796-90 (2004)- Standard Practice for This ASTM standard is intended to be a calibration procedure Calibration of Type S Pi tot Tubes for the S-type pitot tube and not a method by which stack gas velocity

and/or volumetric flowrates can be measured as in EPA Method 2. In addition

, the calibration procedure does not require an inclined manometer and does not specify any additional accuracy verifications for the use of other types of differential **pressur~** gauges .SIMILAR EPA ! STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS REFERENCE STANDARD METHOD EPA Methods 2 ISO 10780:1994

- Stationary Source Emissions- ISO 10780:1994 recommends the use of an L-shaped pitot, Measurement ofVelocity and Volume Flowrate of which historically has not been recommended by EPA. The

1

Ga

s Streams in Ducts EPA specifies the S-type design which has large openings that

are less likely to plug up with dust.

EPA Method 2, 4, ASME Bl33.9-1994 (2001)- Measurement ofExhaust N o t a quantit a tiv e method

, p er se, althou g h a good primer for

and 5 Emissions from Stationary Gas Turbine Engines this source cate g ory that includes technic a l descriptions of (Revision of ANSI B133.9-1979) manual and instrumental sampling procedures

, as well as performance

specifications for instrumental methods

. This standard has many good references, including the EPA Methods and Performance Specifications. ONLY USE FOR I ENGINESAND TURBINES DONOTUSEAT ALL? NOT A METHOD?

EPA Method 5 ISO 9096:1992 (2003)- Determination of This standard is not accept a bl e as an alternative for E PA Concentration and Mass Flow Rate of Particulate Me thod 5. A lth o u g h s e c ti ons o f ISO 90 96 incorpor a t e EPA
Matter in Gas Carrying Ducts- Manual Gravimetric Methods 1, 2

, and 5 to some degree, this ISO standard is not Method equivalent to EPA Method 5 for collection of particulate matter. The standard ISO 9096 does not provide applicable technical guidance for performing many of the integral procedures specified in Methods 1, 2, and 5. Major performance and operational details are lacking or nonexistent,
and detailed quality assurance/quality control guidance for the sampling operations required to produce quality

, representative

particulate data (e.g.

, guidance for maintaining
and monitoring train operating temperatures, specific leak check guidelines and procedures

, and sample preparation and



### 2SIMILAR 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 VOLUNTARY CONSENSUS STANDARD recovery procedures) are not provided by the standard

, as in EPA Method 5. Also, details of equipment and / or operational requirements , such as those specified in EPA Method 5, are
not

included in the ISO standard

, e.g., stack gas moisture measurements , data reduction guidance

, and particulate sample calculations. • This voluntary consensus standard is not acceptable as an alternative

for EPA Method 5 because ANSIIASME PTC-38

is not specific about equipment requirements, and instead presents the options available and the pros and cons of each option. The key specific differences between ANSI / ASME PTC- 3 8 and the EPA methods are that the ASME standard: ( 1) allows in-stack filter placement as compared to theout-ofstack filter placement in the EPA methods (2) allows many different types of nozzles, pi tots

, and filtering equipment; (3) does not specify a filter weighing protocol or a minimum allowable fi Iter weight fluctuation as in the EPA methods; and

( 4) allows filter paper to be only 99 percent efficient, as compared to the 99.95 percent efficiency required by the EPA methods. This method is similar to EPA Method 5

, but is lacking in the following areas that are needed to produce quality, representative particulate data: ( 1) requirement that the filter holder temperature should be between l20 ° C and 134°C

, and
not just " abo v e the acid dew-point ; " (2) detailed specifications

for measuring and monitoring the filter holder temperature during sampling; (3) procedures similar to EPA Methods 1, 2,SIMILAR EPA STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS REFERENCE STANDARD METHOD 3, and 4, that are required by EPA Method 5; (4) technical guidance for performing the Method 5 sampling procedures, e.g., maintaining and monitoring sampling train operating temperatures, and use of reagent blanks for determining and subtracting background contamination; and (5) detailed equipment and/or operational requirements, e.g., component exchange leak checks, use of glass cyclones for heavy particulate loading and/or water droplets, operating under a negative

stack pressure, exchanging particulate loaded filters, sampling preparation and implementation guidance, sample recovery guidance, data reduction guidance, and particulate sample calculations input.

EPA Method 5 CAN/CSA Z223.1-M1977- Method for the Detailed technical procedures and quality control measures Determination

of Particulate Mass Flows in Enclosed that are required in EPA Methods 1, 2, 3, and 4 are not

Gas Streams included in CAN/CSA Z223.1. Secondly, CAN/CSA Z223.1 does not include in its filter weighing procedures the EPA Method 5 requirement to repeat \Neighing every six hours until

a constant weight is achieved. Third, EPA Method 5 requires

the weight to be reported to the nearest 0.1 mg, while CAN/CSA Z223.1 requires only weighing to the nearest 0.5
mg. Lastly, CAN/CSA Z223 .1 allows the use of a standard pitot for velocity measurement when plugging of the tube opening is not expected to be a problem, whereas EPA Method 5 requires an S-shaped pitot.

4SIMILAR EPA STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS REFERENCE STANDARD METHOD EPA Method 23 EN 1948-3 (1996) (European Committee for Provides additional sampling options other than what is 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 alternative to EPA Method 25

Total Nonmetbane Organic Compounds--Cryogenic or 25A because it does not measure solvent process vapors in Preconcentration and Direct Flame Ionization Method concentrations greater than I 0 ppm carbon. A method whose upper limit is 10 ppm carbon has a measurement range too limited to be useful in measuring source emissions.

EPA Method 25A EN 12619 (1999)

- Stationary Source Emissions- This standard is an impractical alternative to EPA Method 25 Determination ofthe Mass Concentration of Total or 25A because it does not measure solvent process vapors in Gaseous Organic Carbon at Low Concentrations in concentrations greater than 40 ppm carbon. A method whose

Flue GasesBContinuous Flame Ionization Detector upper limit is 40 ppm carbon has a measurement range too Method limited to be useful in measuring source emissions.

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

26A Manual Method of Determination ofHCl-Pati 1: Method 26 or 26A. The sample absorbing solution (water) Sampling of Gases Ratified European Text-Part 2: would be expected to capture both HCl and chlorine gas, if Gaseous Compounds Absorption Ratified European present, without the ability to distinguish between the two. Text-Part

3: Adsorption Solutions Analysis and The EPA Methods 26 and 26A use an acidified absorbing Calculation Ratified European Text solution to first separate HCl and chlorine gas so that they can

be

selectively absorbed, analyzed, and reported separately. In addition in EN 1911-1,2,3 (1998), the absorption efficiency

for chlorine gas would be expected to vary as the pH of the water changed during sampling.



### 5SIMILAR EPA STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS REFERENCE STANDARD METHOD EPA Method 26 and ASTM D6735-01 -Standard Test Method for This impinger-based standard to measure HCl is an acceptable

26A Measurement of Gaseous Chlorides and Fluorides alternative to EPA Methods 26, 26A, and 321 from mineral

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 limited number of facilities

the Emission of Airborne Hazardous Substances: Part which are not coating related. This standard will give biased

4 Capture Efficiency of an Exhaust System- Tracer low results with respect to capture efficiency and biased high
Method results with respect to emissions. Most of the VOC's in coatings are captured in the oven and this technique cannot simulate or measure this.

6