MEMORANDUM UNITED STATES ENVIRONMENTAL PROTECTION AGENCY RESEARCH TRIANGLE PARK, NC 27711



### FEB 15 10ff OFFICE OF AIR QUALITY PLANNING AND STANDARDS

SUBJECT: Voluntary Consensus Standard Results for National Emission Standards for Hazardous Air Pollutants: Coal and Oil-fired Electric Utility Steam Generating Units, 40 CFRPart 63, Subpart UUUUU

FROM: (! rConniesue B. Oldham, Group Leader

# ~cj)

# ¥**~** Measurement Technology Group (EI43-02)

TO: Robert Wayland, Group Leader Energy Strategies Group (D243-01)

At your 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 onthe 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 and practical for use in lieu ofstationary source methods cited in the Standards ofPerformance for National Emission Standards for Hazardous Air Pollutants: Coal and Oil-fired Electric Utility Steam Generating Units, 40 CFR Part 63, Subpart UUUUu.

In 1998, OAQPS began implementing the requirements ofthe NTTAA by conducting searches to identify VCS. Searches continue to be performed to meetthe requirements ofthe NTT AA. 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 participates in the American Society for Testing and Materials (ASTM), which is one ofthe most active

## ves organizations on emissions testing, and has been invited to participate in the USA Technical Advisory Group for International Organizationfor Standardization (ISO) relating to emissions monitoring. We expect these additional efforts will help us to support a periodic review ofall EPAreference methods andperformance standards for possible incorporation byreference (IBR) ofVCS in lieu ofor as alternatives to EPAprocedures. We anticipate thatthese activities will provide an opportunity for further review, consideration

Internet Address (URL). http://www.epa.gov RecycledIRecyclable • Printed wHh Vegetable Oil Based Inks on Recycled Paper (Minimum 25% Postconsumer)2

We conducted searches for the National Emission Standards for Hazardous Air Pollutants for Coal and Oil-fired Electric Utility Steam Generating Units, 40 CFR Part 63, Subpart UUUUU through the Enhanced NSSN Database managed by the American National Standards Institute (ANSI). We also contacted VCS organizations, and accessed and searched their databases. No applicable voluntary standards were identified for EPA Methods 2F, 2G, 8, 19, 201A and 202.

This rule involves technical standards. EPA has decided to use ANSII ASME PTC 19-10- 1981 Part 10, "Flue and Exhaust Gas Analyses," acceptable as an altemative to Methods 3B (for carbon dioxide, carbon monoxide, and oxygen), 6 (for sulfur dioxide), 6A and 6B (for carbon dioxide and sulfur dioxide). This standard is available from the American Society ofMechanical Engineers (ASME), Three ParkAvenue, New York, NY 10016-5990.

Another VCS, ASTM D6735-01, "Standard Test Method for Measurement ofGaseous Chlorides and Fluorides from Mineral Calcining Exhaust Sources Impinger Method", is an acceptable altemative to EPA Methods 26 and 26A.

An additional VCS, ASTM D6784-02 (2008)

- Standard Test Method for Elemental, Oxidized, Particle-Bound and Total Mercury Gas Generated from Coal-Fired Stationary Sources (Ontario Hydro Method) is acceptable as an altemative to Method 29 for mercury, but only if the standard falls within the applicable concentration range of 0.5 to 100 I-lgINm3
During the search, ifthe title or abstract (ifprovided) ofthe VCS described technical sampling and analytical procedures that are similarto EPA's reference method, the MTG 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 review requires significant method validation data which meets the requirements ofEPA Method 301 for accepting altemative methods or scientific, engineering and policy equivalence to procedures in EPA reference methods. The MTG may reconsider determinations ofimpracticality when additional,information is available for particular VCS.

The search identified 22 other VCS that were potentially applicable for this rule in lieu of EPA reference methods. After reviewing the available standards, EPA detennined that 22 candidate VCS (ASTM D3154-00 (2006), ASME B133.9-1994 (2001), ANSIIASME PTC 19- 10-1981 Part 10, ASTM D5835-95 (2007), ISO 10396:1993 (2007), ISO 12039:2001, ASTM D6522-00 (2005), CAN/CSA Z223.2-M86 (1999), ISO 9096:1992 (2003), ANSI/ASMEPTC38-1980 (1985), ASTM

### D3685/D3685M-98 (2005), ISO 7934:1998, ISO 11632:1998, ASTM D3464-96 (2007), ASTM D3796-90 (2004), ISO 10780:1994, CAN/CSA Z223.21-MI978, ASTM D3162-94 (2005), CAN/CSA Z223.1-M1977, EN 1911-1,2,3 (1998), EN 13211 :2001, CAN/CSA Z223.26-M1987) identified for measuring emissions ofpollutants or their surrogates subject to emission standards in the rule would not be practical due to lack ofequivalency, documentation, validation data and other importanttechnical and policy considerations. These 22 methods are listed in Attachment 1, along with the EPAreview comments.

### 3 subject to emission standards inthe rule would notbepractical due to lack ofequivalency, documentation, validation data and other importanttechnical andpolicy considerations. These 22 methods are listed in Attachment 1, along withthe EPAreview comments.

Ihope ourresearch into this matterhas beenuseful andtimelyto your Group's efforts in this rulemaking. Please contactme at (919) 541-7774 with any further questions inthis matter.

Attachments

cc: Bill Maxwell, EPAlSPPD (D243-01) Rima Howell, 

### EPAlAQAD (E143-02) Michael Toney, 

### EPAlAQAD (E143-02)Attachment 1. List 

### ofVoluntary Consensus Standards NotApplicable for the Standards 

### ofPerformance for National Emission Standards for Hazardous AirPollutants: Coal and Oil-fired Electric Utility Steam Generating Units, 40 CFRPart 63, SubpartUUUUU.
SIMILAREPA

STANDARD REFERENCE

METHOD VOLUNTARY CONSENSUS STANDARD

EPA Methods 1,2, 3B ASTM D3154-00 (2006)

- Standard Method for and 4 Average Velocity in a Duct (Pitot Tube Method)

EPA Methods 2, 3A, 4 ASMEB133.9-1994 (2001)

- Measurement of and 5 ExhaustEmissions from Stationary Gas Turbine Engines (Revision ofANSI B133.9-1979)

1 EPA'S COMMENTS ON VOLUNTARY CONSENSUS STANDARD

This standard is impractical as an alternative to EPA Methods 1, 2, 3B, and 4 for the purposes ofthis rule since the standard appears to lack inquality control and quality assurance requirements. Specifically, ASTM D3154 does not include the following: (1) proofthat openings ofstandard pitottube have notplugged during the test; (2) ifdifferential pressure gauges otherthan inclined manometers (e.g., magnehelic gauges) are used, their calibration mustbe checked after eachtest series; and (3) the frequency and validity range for calibration of the temperature sensors. This standard is not a quantitative method, per se, although a good primer for this source category that includes technical descriptions ofmanual and instrumental samplingprocedures, as well as perfonnance specifications for instrumental methods. This standard has many good references, including the EPA Methods and Perfonnance Specifications.SIMILAREPA STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS REFERENCE STANDARD

METHOD EPA Methods 3A, 6C, ANSI! ASME PTC 19-10-1981- Part 10-- Flue and This standard is not an acceptable alternative to EPA 10, and lOB Exhaust Gas Analyses Methods 3A, 6C, 10, and 10B.This standard includes manual and instrumental methods ofanalyses for carbon dioxide (C02), carbon monoxide (CO), hydrogen sulfide (H2S), nitrogen oxides (NOx), oxygen (02), and sulfur dioxide (S02). The VCS method analytes that include
one or more ofthe same techniques as the EPAmethods
are as follows: C02 [manual (3B, 6A and 6B) and instrumental (3A and 3C)]; CO [manual (3B) and instrumental (10 and lOB)], H2S [manual (15A and 16A) and instrumental (15, 16, and 16B) ], NOx [manual (7 and 7C) and instrumental (7A, 7B, 7E, 20)], 02 [manual (3B) and instrumental (3A, 3C, 20)], and S02 [manual (6, 6A, 6B, 20) and instrumental (6C)]. The manual methods are all acceptable alternatives to the corresponding EPAtest methods (3B, 6, 6A, 6B, 7, 7C, l5A, 16A, 20 (S02 part of20 only)). [Note that one of the standard=s manual S02procedures incorporates EPA Method 6 in its entirety]. Forthe standard=s instrumental procedures, only general descriptions ofthe procedures are included which are nottrue methods. Therefore, the instrumentalprocedures (3A, 3C, 6C, 7A, 7B,7E, 10, lOB, 15, 16, 16B, 20 (NOx part of20 only))
are not acceptable alternatives to the corresponding EPA methods.

2SIMILAREPA STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS REFERENCE STANDARD

METHOD EPA Methods 3A, 6C, ASTM D5835-95 (2007)

- Standard Practice for These standards are impractical alternatives to EPA and 10 Sampling Stationary Source Emissions for Methods 3A, 6C, and 10 for the purposes ofthis rule Automated Determination ofGas Concentration because they lack indetail and quality assurance/quality controlrequirements. Specifically, these two standards ISO 10396: 1993 (2007)

- Stationary Source do not include the following: (1) sensitivity ofthe Emissions: Sampling for the Automated method; (2) acceptable levels ofanalyzer calibration Determination ofGas Concentrations error; (3) acceptable levels ofsampling system bias; (4)
zero drift and calibration drift limits, time span, and requiredtesting frequency; (5) a methodto test the interference response ofthe analyzer; (6) procedures to determine the minimum sampling time perrun and minimum measurement time; and (7) specifications for datarecorders, in terms ofresolution (all types) and recording intervals (digital and analog recorders, only). EPAMethods 3A and ISO 12039:2001

- Stationary Source Emissions-- This standard is not acceptable as an alternative to EPA 10 Determination ofCarbonMonoxide, Carbon Methods 3A and 10. This ISO standard is similarto EPA Dioxide, and Oxygen--Automated Methods Method 3A and 10 but is missing some key features. In terms ofsampling, the hardware required by ISO 12039:2001 does notinclude a 3-waycalibrationvalve assembly orequivalent to blockthe sample gas flow while calibration gases are introduced. Inits calibration procedures, ISO 12039:2001 only specifies a two-point calibration while EPA Method 3A and 10 specifies a three-point**c~libration.** Also, ISO 12039:2001 does not specify performance criteriafor calibration error,



### 3SIMILAR EPA STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS REFERENCE STANDARD

METHOD calibration drift, or sampling system bias tests as inthe EPA method, although checks ofthese quality control features are requiredby the ISO standard. EPA Methods 3A and ASTM D6522-00 (2005)- Standard TestMethod This standard is not acceptable as a substitute for EPA 10 for the Determination ofNitrogen Oxides, Method 3A and 10. ASTM D6522 has been determined Carbon Monoxide, and Oxygen Concentrations in to be technically appropriate for identifying nitrogen Emissions from Natural Gas-Fired Reciprocating oxides, carbon monoxide, and oxygen concentrations Engines, CombustionTurbines, Boilers and whenthe fuel is natural gas. Process Heaters Using Portable Analyzers

EPA Methods 3A, 6C, CAN/CSAZ223.2-M86 (1999)

- Methodfor the This standard is unacceptable as a substitute for EPA

10, and lOA Continuous Measurement ofOxygen, Carbon Methods 3A, 6C, 10, lOA, and 20 (nitrogen oxides and Dioxide, Carbon Monoxide, Sulphur Dioxide, and oxygenparts of20 only), since it does not include Oxides ofNitrogen in Enclosed CombustionFlue quantitative specifications for measurement system Gas Streams performance, most notably the calibrationprocedures and instrumentperformance characteristics. The instrument performance characteristics that are provided are nonmandatory and also do not provide the same level of quality assurance as the EPAmethods. For example, the
zero and span/calibration drift is only checkedweekly, whereas the EPA methods requires drift checks after each
fUll. EPA Method 5 ISO 9096:1992 (2003)

- Determination of This standard is not acceptable as an alternative for EPA Concentration and Mass FlowRate ofParticulate Method 5. Although sections of ISO 9096 incorporate

4SIMILAR EPA STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS REFERENCE STANDARD

METHOD Matter in Gas Carrying Ducts-Manual EPAMethods 1, 2, and 5 to some degree, this ISO Gravimetric Method standard is not equivalentto EPAMethod 5 for collection ofparticulate matter. The standard ISO 9096 does not provide applicable technical guidance for performing many ofthe integral procedures specified in Methods 1, 2, and 5. Majorperformance 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 recoveryprocedures) are not providedby the standard, as inEPA Method 5. Also, details of equipment and/or operational requirements, such as those specified inEPAMethod 5, are not included inthe ISO standard, e.g., stack gas moisture measurements, data reduction guidance, and particulate sample calculations. EPAMethod 5 ANSUASME PTC-38-1980 (1985)

- This voluntary consensus standard is not acceptable as Determination ofthe ConcentrationofParticulate an alternative for EPAMethod 5 because ANSU ASME Matter in Gas Streams PTC-38 is not specific about equipmentrequirements, and instead presents the options available and the pros and cons ofeach option. The key specific differences between ANSUASME PTC-38 andthe EPA methods are that the ASME standard: (1) allows in-stack filter



### 5SIMILAREPA STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS REFERENCE STANDARD

METHOD placement as comparedto the out-of-stack filter placement in the EPAmethods (2) allows many different types ofnozzles, pitots, and filtering equipment; (3) does not specify a filter weighing protocol or a minimum allowable filter weight fluctuation as inthe EPA methods; and (4) allows filter paper to be only 99 percent efficient, as comparedto the 99.95 percent efficiency required by the EPAmethods. EPA Method 5 ASTM

### D36851D3685M-98 (2005)

- TestMethods This method is similarto EPA Method 5, but is lacking for Sampling and Determination ofParticulate inthe following areas that are neededto produce quality, Matter in Stack Gases representative particulate data: (1) requirementthatthe filter holdertemperature shouldbe between 120°C and 134°C, and notjust "abovethe acid dew-point;" (2) detailed specifications for measuring and monitoring the filter holdertemperature during sampling; (3) procedures similarto EPA Methods 1,2,3, 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 ofreagent blanks for determining and subtracting background contamination; and (5) detailed equipment and/or operational requirements, e.g., component exchange leak checks, use ofglass cyclones for heavy particulate loading and/or water droplets, operating under
a negative stack pressure, exchanging particulate loaded

6SIMILAREPA STANDARD VOLUNTARY CONSENSUS STANDARD .EPA'S COMMENTS ON VOLUNTARY CONSENSUS REFERENCE STANDARD

.

METHOD filters, sampling preparation and implementation guidance, sample recovery guidance, data reduction guidance, and particulate sample calculations input. EPA Method 6 ISO 7934: 1998

- Stationary Source Emissions-- This standard is only applicable to sources with 30 mg/m3 Determination ofthe Mass Concentration of S02 or more

. Also, this standard does not separate S03 Sulfur Dioxide--Hydrogen Peroxide/Barium from S02 as does the EPA methods; therefore, ISO Perchlorate/ThorinMethod 7934:1998 is not valid ifmore than a negligible amount ofS03 is present. Also, it does not address ammonia interferences. EPA Method 6 ISO 11632: 1998

- Stationary Source Emissions-- This standard sampling procedures is similar to EPA Determination ofthe Mass Concentration of Method 6, but lacks in detail and quality control Sulfur Dioxide--Ion Chromatography procedures, such as calibration checks and leaks tests

.

EPA Method 2 ASTM D3464-96 (2007)

- Standard Test Method The applicability specifications inthis ASTM standard Average Velocity in a DuctUsing a Thermal are not clearly defined, e.g., range ofgas composition, Anemometer temperature limits. Also, the lack ofsupporting quality
assurance data for the calibration procedures and specifications, and certain variability issues that are not adequately addressed bythe standard limit EPA's ability to make a definitive comparison ofthe method inthese
areas. EPA Methods 2 ASTM D3796-90 (2004)

- Standard Practice for This ASTM standard is intended to be a calibration Calibration ofType S Pitot Tubes procedure for the S-type pitottube and not a method by which stack gas velocity and/or volumetric flowrates can

7SIMILAR EPA STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS REFERENCE STANDARD

METHOD be measured as inEPA Method 2. In addition, the calibrationprocedure does not require an inclined manometer and does not specify any additional accuracy verifications for the use ofothertypes ofdifferential pressure gauges. EPA Method 2 ISO 10780:1994

- Stationary Source Emissions-- ISO 10780:1994recommends the use ofan L-shaped Measurement ofVelocity and Volume Flowrate of pitot, which historically has notbeenrecommended by Gas Streams in Ducts EPA. The EPA specifies the S-type design whichhas large openings that are less likely to plug up with dust. EPA Methods 10 and CAN/CSA Z223.21-M1978

- Method for the This standard is not acceptable as an alternative to EPA lOA Measurement ofCarbonMonoxide: 3--Method of Methods 10 and lOA because it is lacking inthe Analysis byNon-Dispersive Infrared following areas: 1) sampling procedures; 2) procedures to Spectrometry correct for the carbon dioxide concentration; 3) instructions to correctthe gas volume ifCO2 traps are used; 4) specifications to certify the calibration gases are within 2 percent ofthe target concentration; 5) mandatory instrumentperformance characteristics (e.g., rise time, fall time, zero drift, span drift, precision); 6) quantitative specification ofthe spanvalue maximum as comparedto the measured value: the standard specifies that the instruments shouldbe Acompatible with the concentration ofgases to be measured, whereas EPA Method 10 and lOA specify thatthe instrument span value should be no more than 1.5 times the source performance standard.



### 8SIMILAR EPA STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS REFERENCE STANDARD

METHOD EPA Method 10 ASTM D3162-94 (2005)

- Standard Test Method This ASTM standard, which is stated to be applicable in for Carbon Monoxide inthe Atmosphere the range of0.5

- 100 ppm CO, does not coverthe range (Continuous Measurementby Nondispersive ofEPA Method 10 (20

- 1000 ppm CO) atthe upper end Infrared Spectrometry) but claims to have a lower limit ofsensitivity. Also, ASTM D3162 does not provide a procedure to remove carbon dioxide interference. Therefore, this ASTM standard is not appropriate for combustion source conditions. Interms ofNDIRinstrument performance specifications, ASTM D3162 has much higher maximum allowable rise and fall times (5 minutes) than EPA Method 10 (which has 30 seconds). EPAMethod 5 CAN/CSA Z223.1-M1977

- Method for the Detailed technical procedures and quality control Determination ofParticulate Mass Flows in Enclosed measures that are required inEPA Methods 1, 2, 3, and 4 Gas Streams are not 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 weighing every six hours until a constant weight is achieved. Third, EPA Method 5 requires the weightto be reported to the nearest 0.1 mg, while CAN/CSAZ223.1 requires only weighing to the nearest 0.5 mg. Lastly, CAN/CSA Z223.1 allows the use ofa standard pitotfor velocity measurement whenplugging ofthe tube opening is not expectedto be a problem, whereas EPA Method 5 requires an S-shapedpitot. EPA Method 26 EN 1911-1,2,3 (1998)

- Stationary Source Part 3 ofthis standard cannotbe considered equivalentto

9SIMILAREPA STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS REFERENCE STANDARD

METHOD And26A Emissions-Manual Method ofDetermination of EPAMethod 26 or 26A. The sample absorbing solution HCI-Part 1: Sampling ofGases Ratified European (water) wouldbe expected to capture both HCl and Text-Part 2: Gaseous Compounds Absorption chlorine gas, ifpresent, without the ability to distinguish Ratified European Text-Part 3: Adsorption betweenthe two. The EPA Methods 26 and 26A use an Solutions Analysis and CalculationRatified acidified absorbing solutionto first separate HCl and European Text chlorine gas so that they can be selectively absorbed, analyzed, and reported separately. In addition inEN 1911-1,2,3 (1998), the absorption efficiency for chlorine gas would be expected to vary as the pH ofthe water changed during sampling. EPA Method 29 EN 13211 :2001

- Air Quality--Stationary Source This standard is not acceptable as an alternative to the Emissions--Determination ofthe Concentration of mercury portion ofEPA Method 29 primarilybecause it Total Mercury is not validated for use with impingers, as inthe EPA method, althoughthe method describes procedures for the use ofimpingers. This European standard is validated for the use offritted bubblers only and requires the use ofa side (split) stream arrangement for isokinetic samplingbecause ofthe low samplingrate ofthe bubblers (up to 3 liters perminute, maximum). Also, onlytwo bubblers (or impingers) are required byEN 13211, whereas EPA Method 29 require the use ofsix impingers. In addition, EN 13211 does not include many ofthe quality control procedures ofEPA Method 29, especially for the use and calibration oftemperature
sensors and controllers, sampling train assembly and

10SIMILAR EPA STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS REFERENCE STANDARD

METHOD disassembly, and filter weighing. EPA Method 29 CAN/CSAZ223.26-M1987

- Measurement of This standard is not acceptable as an alternative to EPA Total Mercury in Air Cold Vapour Atomic Methods 29 (mercury only), 101, and lOlA, for the cold Absorption Spectrophotometeric Method vapor atomic absorption spectrometry (CVAAS) analytical procedures only, because oflack ofdetail in quality control. Specifically, CAN/CSAZ223.26 does not include specifications for the number ofcalibration samples to be analyzed, procedures to prevent carryover from one sample to the next, and procedures for subtraction ofthe instrumentresponse to calibration blank as inthe EPAmethods. Also, CAN/CSAZ223.26 does notrequire thatthe calibration curve be forced through or close to zero (or a point no further than \j2 percent ofthe recorder full scale) as inthe EPA methods. Also, CAN/CSAZ223.26 does not include a procedure to assure thattwo consecutive peakheights agree within 3 percent oftheir average value and thatthe peak maximum is greaterthan 10 percerit ofthe recorder full scale, as inthe EPAmethods. CAN/CSAZ223.26 does not include instructions for a blank and a standard to be
run at least every'five samples, and specifications for the peakheight ofthe blank and the standard as inthe EPA methods.



### 11