OAR Box 1394 

Prepped by Ollie Stewart 

Document Number: 

29) ll-B-25 

Docket Number: 

A-94-52 

Printed 7/3/2008 7:52:00 AM Sheet 29 of 56 

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

RESEARCH TRIANGLE PARK, NC 27711 

SEP 6 2000 

cur v ^— S 

MEMORANDUM 

/ 

'•• • 

m I 9200I 

EPA AIR DOCKET 

OFFICE OF 

AIR QUALITY PLANNING 

AND STANDARDS 

SUBJECT: 

FROM: 

Voluntary Consensus Standard Results for the Reinforced Plastic Composites 

NESHAP Proposed Rule 

TO: 

William H. Lamason, Group Lead 

Source Measurement Technology Group (MD-19) 

Penny Lassiter, Group Leader 

Organic Chemicals Group (MD-13) 

JAN I 92001 

EPA AIR DOCKET 

At your request, the Emission Measurement Center (EMC) conducted searches and 

reviews to address the National Technology Transfer and Advancement Act (NTTAA) 

requirements on the use of voluntary consensus standards (VCS). The NTTAA directs EPA to 

use VCS in regulatory and procurement activities unless to do so would be inconsistent with 

applicable law or otherwise impractical. This memorandum documents the results ofthe EMC 

searches and reviews to determine if VCS are available and practical for use in lieu of stationary 

source methods or performance specifications cited in the Reinforced Plastic Composites 

Proposed Rule. 

Starting in 1998, the EMC began implementing the requirements ofthe NTTAA by 

conducting searches to identify VCS. 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. 

To enhance our opportunities to identify and use VCS, the EMC has other activities in 

support of NTTAA implementation. The EMC has plans to conduct more thorough, periodic 

efforts to contact VCS organizations to identify potential alternative methods. We completed our 

periodic search for FY2000. We plan to update this search in early FY2001. 

Also, the EMC participates in the American Society for Testing and Materials (ASTM), 

which is one ofthe 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) of VCS in lieu of or as alternatives to EPA procedures. 

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

J 

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

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and possible IBR of VCS overlooked in the National Standards Service Network (NSSN) 

searches or finalized after work group closure in the EPA rulemaking process. 

We conducted searches for the Reinforced Plastic Composites Proposed Rule through the 

Enhanced NSSN Database managed by the American National Standards Institute (ANSI). 

Searches were conducted for EPA Methods 1, IA, 2, 2A, 2C, 2D, 2F, 2G, 3, 3A, 3B, 4,18, 25, 

25A, 204, and 204B through 204E. Please note the attached table for the EMC's findings. No 

VCS were identified for EPA Methods 1 A, 2A, 2D, 2F, 2G, 204B through 204E . 

The attached table describes the VCS found, which EPA standard reference 

method(s)/performance specification(s) the VCS potentially affects, if the VCS is equivalent to 

the EPA standard reference method/performance specification, and EPA's comments after 

review ofthe standard. During the search, if the title or abstract (if provided) ofthe VCS 

described techmcal sampling and analytical procedures that are similar to EPA's reference 

method/performance specification, the EMC ordered a copy ofthe standard and reviewed it as a 

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

ofthe VCS for this rule. This test requires significant method validation data which meets the 

requirements of EPA Method 301 for accepting altemative methods or scientific, engineering 

and policy equivalence to procedures in EPA reference methods and performance specifications. 

The EMC may reconsider determinations of impracticality when additional information is 

available for particular VCS. 

The search identified 18 VCS's that appeared to have possible use in lieu of EPA 

reference methods/performance specifications. One consensus standard has been determined 

appropriate and should be cited in the Reinforced Plastic Composites NESHAP Proposal. 

The consensus standard, ASTM D6420-99 - Standard Test Method for Determination of 

Gaseous Organic Compounds by Direct Interface Gas Chromatography-Mass Spectrometry 

(GC/MS), has been identified by EPA as an acceptable alternative test method for EPA Method 

18. This ASTM method is appropriate in the cases described below for inclusion in the 

Reinforced Plastic Composites proposed rule in addition to the currently available EPA Method 

18 codified at 40 CFR Part 60 Appendix A. Similar to EPA's performance based Method 18, 

ASTM D6420-99 is also a performance based method for measurement of gaseous organic 

compounds. However, ASTM D6420-99 was written to support the specific use of highly 

portable and automated GC/MS. While offering advantages over the traditional Method 18, the 

ASTM method does allow some less stringent criteria for accepting GC/MS results than required 

by Method 18. Therefore, ASTM D6420-99 is a suitable alternative to Method 18 where: 

(1) the target compound(s) are those listed in Section 1.1 of ASTM D6420-99 

(Docket citation of table),and 

(2) the target concentration is between 150 ppb(v) and 100 ppm(v). 

For target compound(s) not listed in Table 1.1 of ASTM D6420-99, but potentially 

detected bv mass spectrometry, the regulation should specify that the additional system 
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continuing calibration check after each run, as detailed in Section 10.5.3 ofthe ASTM method, 

be followed, met, documented, and submitted with the data report even if there is no moisture 

condenser used or the compound is not considered water soluble. The rule should also specify 

that for target compound(s) not listed in Table 1.1 of ASTM D6420-99, and not amenable to 

detection by mass spectrometry, ASTM D6420-99 does not apply. 

We recommend you propose to incorporate by reference (IBR) ASTM 6420-99 into 40 

CFR 63.14 for application with the Reinforced Plastic Composites Rule. We also recommend 

you propose to cite Method 18 as a gas chromatography (GC) option in addition to ASTM 

D6420-99. This will allow the continued use of other GC configurations. 

After reviewing the available standards, we determined that 13 ofthe 18 candidate 

consensus standards (ASME C00031 or PTC 19-10-1981, ASTM D3154-91 (1995), ASTM 

D3464-96, ASTM D3796-90 (1998), ASTM D5835-95, ASTM D6060 (in review 2000), ASTM 

E337-84 (Reapproved 1996), CAN/CSA Z223.2-M86 (1986), EN 12619 (1999), EN 1093-4: 

1996, ISO 9096:1992 (in review 2000), ISO 10396:1993, ISO 10780:1994) identified for 

measuring emissions ofthe HAPs or 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. Four ofthe 18 candidate consensus standards (ASME/BSR 

MFC 12M, ASME/BSR MFC 13M, ISO/DIS 12039, ISO/FDIS 14965) are new standards under 

development or standards currently under EPA review that EPA plans to follow, review and 

consider adopting at a later date. 

Questions regarding the NTTAA representative and EMC representation in ASTM and 

ISO can be directed to John Bosch at (919) 541-5583. Inquiries regarding the searches for the 

VCS can be made to Mike Ciolek at (919) 541-4921. Please feel free to contact me at (919) 541-

5374 if you have any general questions regarding EMC implementation ofthe NTTAA or our 

support to you. 

Attachment 

cc: John Bosch, EMC (MD-19) 

Mike Ciolek, EMC (MD-19) w/attachment 

Fred Dimmick, EMAD (MD-14) 

David Mobley, EMAD (MD-14) 

Keith Barnett, ESD (MD-13) w/attachment 

Frederick J. Thompson, EMC (MD-19) 
RESULTS OF THE EPA'S SEARCH TO IDENTIFY VOLUNTARY CONSENSUS STANDARDS FOR 

REINFORCED PLASTICS COMPOSITES NESHAP 

*A11 searches were completed through the Enhanced National Standards Service Network (NSSN) maintained by the American 

National Standards Institute (ANSI). The voluntary consensus standards identified were reviewed to determine if they could be used 

in lieu of EPA's standard reference method. 

Search completed 2000 

SIMILAR EPA STANDARD 

REFERENCE METHOD 

EPA Methods 1, 2, 2C 3, 3B, 4 

VOLUNTARY 

CONSENSUS STANDARD 

ASTM D3154-91 (1995)-

Standard Method for Average 

Velocity in a Duct (Pitot Tube 

Method) 

IS THE 

VOLUNTARY 

CONSENSUS.. 

STANDARD 

EQUIVALENT TO 

EPA'S METHOD? 

No 

EPA'S COMMENTS ON 

VOLUNTARY CONSENSUS 

STANDARD 

Appears to cover EPA's Part 60 

Methods 1, 2, 2C, 3, 3B, and 4, but 

lacks in quality control and quality 

assurance requirements. 

in 
SIMILAR EPA STANDARD 

REFERENCE METHOD 

EPA Methods 1,2 

EPA Methods 1 A, 2A, 2D 

EPA Method 2 (possibly 1) 

VOLUNTARY 

CONSENSUS STANDARD 

ISO 9096:1992 (in review 

2000) - Determination of 

Concentration and Mass Flow 

Rate of Particulate Matter in 

Gas Carrying Ducts - Manual 

Gravimetric Method. 

No procedures were identified 

regarding traversing and 

sampling for flow rates on 

small ducts or pipes. 

ASME/BSR MFC 13MFlow Measurement by 

Velocity Traverse 

IS THE 

VOLUNTARY 

CONSENSUS 

STANDARD 

EQUIVALENT TO 

EPA'S METHOD? 

No 

Potential 

EPA'S COMMENTS ON 

VOLUNTARY CONSENSUS 

STANDARD 

Some portions of this standard relate to 

EPA Methods 1 & 2. This standard 

will not produce particulate matter 

measurements like EPA Method 5 

(example: there is no temperature 

control on the filter which is exposed to 

ambient levels). There is no EPA 

Method to compare this to. EPA 

cannot approved this standard without 

supporting data. 

Under development when search was 

completed. Possibly similar to EPA 

Methods 1 and 2. 

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SIMILAR EPA STANDARD 

REFERENCE METHOD 

EPA Method 2 

EPA Method 2 

VOLUNTARY 

CONSENSUS STANDARD 

ASTM D3464-96 - Standard 

Test Method Average 

Velocity in a Duct Using a 

Thermal Anemometer 

ASTM D3796-90 (1998) -

Standard Practice for 

Calibration of Type S Pitot 

Tubes 

IS THE 

VOLUNTARY 

CONSENSUS 

STANDARD 

EQUIVALENT TO 

EPA'S METHOD? 

No 

No 

EPA'S COMMENTS ON 

VOLUNTARY CONSENSUS 

STANDARD 

There is no EPA Method to compare 

this to. Applicability specifications are 

not clearly defined (example: range of 

gas composition, T limits). It appears 

to have the correct calibration 

procedures and specifications, but 

without supporting data. Some ofthe 

variability issues were not adequately 

addressed. EPA cannot call this 

equivalent to EPA Method 2 without 

supporting data. 

This is a very good detailed procedure 

for calibrating Type S pitot tubes, but it 

is not a complete method alternative to 

EPA Method 2. 
SIMILAR EPA STANDARD 

REFERENCE METHOD 

EPA Method 2 

EPA Method 2 

EPA Methods 2F, 2G 

EPA Method 3 

VOLUNTARY 

CONSENSUS STANDARD 

ISO 10780:1994 - Stationary 

Source Emissions -

Measurement of Velocity and 

Volume Flowrate of Gas 

Streams in Ducts 

ASME/BSR MFC 12MFlow in Closed Conduits 

Using Multiport Averaging 

Pitot Primary Flowmeters 

No applicable standards found 

at this time. 

ASMEC00031orPTC19-

10-1981- Part 10 Flue and 

Exhaust Gas Analyses 

IS THE 

VOLUNTARY 

CONSENSUS 

STANDARD 

EQUIVALENT TO 

EPA'S METHOD? 

No 

Potential 

No 

EPA'S COMMENTS ON 

VOLUNTARY CONSENSUS 

STANDARD 

This standard recommends the use of 

L-shaped pitots, although it contains 

procedures for the use of S-shaped 

pitots, as in EPA Method 2. ISO 10780 

has good detail, but has significant 

deficiencies, e.g., 1) the distance 

between each leg ofthe pitot to its faceopening plane can be up to 10 times the 

external tubing diameter vs. 1.5 times 

as specified in EPA Method 2; and 2) 

no direct calibration procedures are 

provided for an S-shaped pitot. 

Standard in development at the time the 

search was completed and not available 

for review. 

Too broad to be useful in regulatory 

sense. Covers EPA Methods 3, 6, 7, 

and 15 with variants. 
SIMILAR EPA STANDARD 

REFERENCE METHOD 

EPA Method 3A 

EPA Method 3A 

EPA Method 3A 

VOLUNTARY 

CONSENSUS STANDARD 

ISO 10396:1993-Stationary 

Source Emissions: Sampling 

for the Automated 

Determination of Gas 

Concentrations 

ISO/DIS 12039 - Stationary 

Source Emissions -

Determination of Carbon 

Monoxide, Carbon Dioxide, 

and Oxygen - Automated 

Methods 

ASTM D5835-95 - Standard 

Practice for Sampling 

Stationary Source Emissions 

for Automated Determination 

of Gas Concentration. 

IS THE 

VOLUNTARY 

CONSENSUS 

STANDARD 

EQUIVALENT TO 

EPA'S METHOD? 

No 

Potential 

No 

EPA'S COMMENTS ON 

VOLUNTARY CONSENSUS 

STANDARD 

Similar to EPA Methods 3 A 6C, 7E, 

10, ALT 004, CTM 022. Similar to 

ASTMD5835. Lacks in detail and 

quality assurance and quality control 

requirements. 

Under development when search was 

completed. Standard not available for 

review. Possibly similar to EPA 

Methods 3 A and 10. 

Similar to EPA Methods 3A, 6C, 7E, 

10, ALT 004, CTM 022. Lacks in 

detail and quality assurance and quality 

control requirements. Very similar to 

ISO 10396. 

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SIMILAR EPA STANDARD 

REFERENCE METHOD 

EPA Method 3 A 

EPA Method 4 

EPA Method 18 

VOLUNTARY 

CONSENSUS STANDARD 

CAN/CSA Z223.2-M86 

(1986)-Method for the 

Continuous Measurement of 

Oxygen, Carbon Dioxide, 

Carbon Monoxide, Sulphur 

Dioxide, and Oxides of 

Nitrogen in Enclosed 

Combustion Flue Gas Streams 

ASTM E337-84 (Reapproved 

1996) - Standard Test Method 

for Measuring Humidity with 

a Psychrometer (the 

Measurement of Wet- and 

Dry-Bulb Temperatures) 

ASTM D6420-99 - Test 

Method for Determination of 

Gaseous Organic Compounds 

by Direct Interface Gas 

Chromatography/Mass 

Spectrometry 

IS THE 

VOLUNTARY 

CONSENSUS 

STANDARD 

EQUIVALENT TO 

EPA'S METHOD? 

No 

No 

Yes 

EPA'S COMMENTS ON 

VOLUNTARY CONSENSUS 

STANDARD 

Too general. This standard lacks in 

detail and quality assurance/quality 

control requirements. Appendices with 

valid quality control information are 

not a required part ofthe standard. 

This will only cover a small portion of 

what is acceptable for EPA Method 4. 

This ASTM procedure was recently 

finalized and adopted by ASTM and 

has been approved by EPA as an 

alternative to EPA Method 18 in 

circumstances as described in the 

NTTAA portion ofthe Reinforced 

Plastic Composites preamble. 

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SIMILAR EPA STANDARD 

REFERENCE METHOD 

EPA Method 18 

EPA Methods 25, 25A 

EPA Method 25A 

VOLUNTARY 

CONSENSUS STANDARD 

ASTM D6060 (in review 

2000) - Practice for Sampling 

of Process Vents with a 

Portable Gas Chromatography 

ISO/FDIS 14965 - Air 

Quality-Determination of 

Total Nonmethane Organic 

Compounds—Cryogenic 

Preconcentration and Direct 

Flame Ionization Method 

EN 12619 (1999) - Stationary 

Source EmissionsDetermination ofthe Mass 

Concentration of Total 

Gaseous Organic Carbon at 

Low Concentrations in Flue 

Gases—Continuous Flame 

Ionization Detector Method 

IS THE 

VOLUNTARY 

CONSENSUS 

STANDARD 

EQUIVALENT TO 

EPA'S METHOD? 

No 

Potential 

No 

EPA'S COMMENTS ON 

VOLUNTARY CONSENSUS 

STANDARD 

This standard lacks key quality control 

and assurance that is required for EPA 

Method 18. For example: lacks 

acceptance criteria for calibration, 

details on using other collection media 

(e.g. solid sorbents), and reporting/ 

documentation requirements. 

Under development when search was 

completed. Possible improvement of 

EPA Method 25A, but will not cover 

all aspects of EPA Method 25. EPA 

will review the standard when it is 

final. 

This standard is limited because it 

doesn't apply to solvent-using 

processes vapors or concentrations >40 

ppm carbon. Specifications for probe 

temperature are only 20°C above flue 

gas as compared to EPA Method 25A 

which specifies greater than or equal to 

110°C. 
SIMILAR EPA STANDARD 

REFERENCE METHOD 

EPA Method 204 

EPA Methods 204B through 204E 

VOLUNTARY 

CONSENSUS STANDARD 

EN 1093-4: 1996 - Safety of 

Machinery-Evaluation ofthe 

Emission of Airborne 

Hazardous Substances: Part 4 

Capture Efficiency of an 

Exhaust System—Tracer 

Method 

No applicable standards found 

at this time. 

IS THE 

VOLUNTARY 

CONSENSUS 

STANDARD 

EQUIVALENT TO 

EPA'S METHOD? 

No 

EPA'S COMMENTS ON 

VOLUNTARY CONSENSUS 

STANDARD 

This standard might work in a limited 

number of facilities which are not 

coating related. This standard will give 

biased low results with respect to 

capture efficiency and biased high 

results with respect to emissions. Most 

ofthe VOC's in coatings are captured 

in the oven and this technique cannot 

simulate or measure this.