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 CFR Part 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) 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 of voluntary 

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 Standards of Performance 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 of the NTTAA by conducting 

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

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 of the most active ves 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 

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 of Mechanical 

Engineers (ASME), Three Park Avenue, New York, NY 10016-5990. 

Another VCS, ASTM D6735-01, "Standard Test Method for Measurement of Gaseous 

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, 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 ordered 

a copy of the standard and reviewed 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 301 for 

accepting altemative 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. 

The search identified 22 other VCS that were potentially applicable for this rule in lieu of 

EP A 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/ASME PTC38-1980 (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 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 

22 methods are listed in Attachment 1, along with the EPA review comments. 
3 

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 

22 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) 541-7774 with any further questions in this matter. 

Attachments 

cc: Bill Maxwell, EPAlSPPD (D243-01) 

Rima Howell, EPAlAQAD (E143-02) 

Michael Toney, EPAlAQAD (E143-02) 
Attachment 1. List of Voluntary Consensus Standards Not Applicable for the Standards of Performance for National 

Emission Standards for Hazardous Air Pollutants: Coal and Oil-fired Electric Utility Steam Generating Units, 

40 CFR Part 63, Subpart UUUUU. 

SIMILAR EPA 

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 (Pi tot Tube Method) 

EPA Methods 2, 3A, 4 ASME B133.9-1994 (2001) - Measurement of 

and 5 Exhaust Emissions from Stationary Gas Turbine 

Engines (Revision of ANSI 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 in quality control and 

quality assurance requirements. Specifically, ASTM 

D3154 does not include the following: (1) proofthat 

openings of standard pitot tube have not plugged during 

the test; (2) if differential pressure gauges other than 

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. 

This standard is not a quantitative method, per se, 

although a good primer for this source category that 

includes technical descriptions of manual and 

instrumental sampling procedures, as well as 

perfonnance specifications for instrumental methods. 

This standard has many good references, including the 

EPA Methods and Perfonnance Specifications. 
SIMILAR EPA 

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 of analyses 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 of the same techniques as the EPA methods 

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 EPA test methods (3B, 6, 6A, 6B, 7, 7C, 

l5A, 16A, 20 (S02 part of20 only)). [Note that one of 

the standard=s manual S02 procedures incorporates EPA 

Method 6 in its entirety]. For the standard=s 

instrumental procedures, only general descriptions of the 

procedures are included which are not true methods. 

Therefore, the instrumental procedures (3A, 3C, 6C, 7 A, 

7B,7E, 10, lOB, 15, 16, 16B, 20 (NOx part of20 only)) 

are not acceptable alternatives to the corresponding EPA 

methods. 

2 
SIMILAR EPA 

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 of this rule 

Automated Determination of Gas Concentration because they lack in detail and quality assurance/quality 

control requirements. 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 of analyzer calibration 

Determination of Gas Concentrations error; (3) acceptable levels of sampling system bias; (4) 

zero drift and calibration drift limits, time span, and 

required testing frequency; (5) a method to test the 

interference response of the analyzer; (6) procedures to 

determine the minimum sampling time per run and 

minimum measurement time; and (7) specifications for 

data recorders, in terms of resolution (all types) and 

recording intervals (digital and analog recorders, only). 

EPA Methods 3A and ISO 12039:2001 - Stationary Source Emissions-- This standard is not acceptable as an alternative to EPA 

10 Determination of Carbon Monoxide, Carbon Methods 3A and 10. This ISO standard is similar to EPA 

Dioxide, and Oxygen--Automated Methods Method 3A and 10 but is missing some key features. In 

terms of sampling, the hardware required by ISO 

12039:2001 does not include a 3-way calibration valve 

assembly or equivalent to block the sample gas flow 

while calibration gases are introduced. In its 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 criteria for calibration error, 

3 
SIMILAR EPA 

STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS 

REFERENCE STANDARD 

METHOD 

calibration drift, or sampling system bias tests as in the 

EP A method, although checks of these quality control 

features are required by the ISO standard. 

EPA Methods 3A and ASTM D6522-00 (2005)- Standard Test Method This standard is not acceptable as a substitute for EPA 

10 for the Determination of Nitrogen 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, Combustion Turbines, Boilers and when the fuel is natural gas. 

Process Heaters Using Portable Analyzers 

EPA Methods 3A, 6C, CAN/CSA Z223.2-M86 (1999) - Method for the This standard is unacceptable as a substitute for EPA 

10, and lOA Continuous Measurement of Oxygen, Carbon Methods 3A, 6C, 10, lOA, and 20 (nitrogen oxides and 

Dioxide, Carbon Monoxide, Sulphur Dioxide, and oxygen parts of 20 only), since it does not include 

Oxides of Nitrogen in Enclosed Combustion Flue quantitative specifications for measurement system 

Gas Streams performance, most notably the calibration procedures and 

instrument performance characteristics. The instrument 

performance characteristics that are provided are nonmandatory and also do not provide the same level of 

quality assurance as the EPA methods. For example, the 

zero and span/calibration drift is only checked weekly, 

whereas the EP A 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 Flow Rate of Particulate Method 5. Although sections of ISO 9096 incorporate 

4 
SIMILAR EPA 

STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS 

REFERENCE STANDARD 

METHOD 

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

Gravimetric Method standard is not 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 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. 

EPA Method 5 ANSUASME PTC-38-1980 (1985) - This voluntary consensus standard is not acceptable as 

Determination of the Concentration of Particulate an alternative for EPA Method 5 because ANSU ASME 

Matter in Gas Streams 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 ANSUASME PTC-38 and the EPA methods are 

that the ASME standard: (1) allows in-stack filter 

5 
SIMILAR EPA 

STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS 

REFERENCE STANDARD 

METHOD 

placement as compared to the out-of-stack filter 

placement in the EPA methods (2) allows many different 

types of nozzles, pitots, and filtering equipment; (3) does 

not specify a filter weighing protocol or a minimum 

allowable filter 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. 

EPA Method 5 ASTM D36851D3685M-98 (2005) - Test Methods This method is similar to EPA Method 5, but is lacking 

for Sampling and Determination of Particulate in the following areas that are needed to produce quality, 

Matter in Stack Gases representative particulate data: (1) requirement that the 

filter holder temperature should be between 120°C and 

134°C, and not just "above the acid dew-point;" (2) 

detailed specifications for measuring and monitoring the 

filter holder temperature during sampling; (3) procedures 

similar to EPA Methods 1,2,3, 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 

6 
SIMILAR EPA 

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 of the 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/Thorin Method 7934:1998 is not valid if more than a negligible amount 

of S03 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 EP A 

Determination of the 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 in this ASTM standard 

Average Velocity in a Duct Using a Thermal are not clearly defined, e.g., range of gas composition, 

Anemometer temperature 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 definitive comparison of the method in these 

areas. 

EP A Methods 2 ASTM D3796-90 (2004) - Standard Practice for This ASTM standard is intended to be a calibration 

Calibration of Type S Pitot Tubes procedure for the S-type pitot tube and not a method by 

which stack gas velocity and/or volumetric flowrates can 

7 
SIMILAR EPA 

STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS 

REFERENCE STANDARD 

METHOD 

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 

pressure gauges. 

EPA Method 2 ISO 10780:1994 - Stationary Source Emissions-- ISO 10780: 1994 recommends the use of an L-shaped 

Measurement of Velocity and Volume Flowrate of pitot, which historically has not been recommended by 

Gas Streams in Ducts EP A. The EPA specifies the S-type design which has 

large openings that are less likely to plug up with dust. 

EP A Methods 10 and CAN/CSA Z223.21-M1978 - Method for the This standard is not acceptable as an alternative to EPA 

lOA Measurement of Carbon Monoxide: 3--Method of Methods 10 and lOA because it is lacking in the 

Analysis by Non-Dispersive Infrared following areas: 1) sampling procedures; 2) procedures to 

Spectrometry correct for the carbon dioxide concentration; 3) 

instructions to correct the gas volume if CO2 traps are 

used; 4) specifications to certify the calibration gases are 

within 2 percent of the target concentration; 5) mandatory 

instrument performance characteristics (e.g., rise time, 

fall time, zero drift, span drift, precision); 6) quantitative 

specification of the span value maximum as compared to 

the measured value: the standard specifies that the 

instruments should be Acompatible with the 

concentration of gases to be measured, whereas EPA 

Method 10 and lOA specify that the instrument span 

value should be no more than 1.5 times the source 

performance standard. 

8 
SIMILAR EPA 

STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS 

REFERENCE STANDARD 

METHOD 

EP A Method 10 ASTM D3162-94 (2005) - Standard Test Method This ASTM standard, which is stated to be applicable in 

for Carbon Monoxide in the Atmosphere the range of 0.5 - 100 ppm CO, does not cover the range 

(Continuous Measurement by Nondispersive of EPA Method 10 (20 - 1000 ppm CO) at the upper end 

Infrared Spectrometry) but claims to have a lower limit of sensitivity. Also, 

ASTM D3162 does not provide a procedure to remove 

carbon dioxide interference. Therefore, this ASTM 

standard is not appropriate for combustion source 

conditions. In terms ofNDIR instrument performance 

specifications, ASTM D3162 has much higher maximum 

allowable rise and fall times (5 minutes) than EPA 

Method 10 (which has 30 seconds). 

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

Determination of Particulate Mass Flows in Enclosed measures that are required in EP A 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 EP A Method 5 requirement to repeat 

weighing every six hours until a constant weight is 

achieved. Third, EP A 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. 

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

9 
SIMILAR EPA 

STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS 

REFERENCE STANDARD 

METHOD 

And26A Emissions-Manual Method of Determination of EPA Method 26 or 26A. The sample absorbing solution 

HCI-Part 1: Sampling of Gases Ratified European (water) would be expected to capture both HCl and 

Text-Part 2: Gaseous Compounds Absorption chlorine gas, if present, without the ability to distinguish 

Ratified European Text-Part 3: Adsorption between the two. The EPA Methods 26 and 26A use an 

Solutions Analysis and Calculation Ratified acidified absorbing solution to first separate HCl and 

European Text 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. 

EPA Method 29 EN 13211 :2001 - Air Quality--Stationary Source This standard is not acceptable as an alternative to the 

Emissions--Determination of the Concentration of mercury portion of EPA Method 29 primarily because it 

Total Mercury is not validated for use with impingers, as in the EPA 

method, although the method describes procedures for 

the use of impingers. This European standard is 

validated for the use of fritted bubblers only and requires 

the use of a side (split) stream arrangement for isokinetic 

sampling because of the low sampling rate of the 

bubblers (up to 3 liters per minute, maximum). Also, 

only two bubblers (or impingers) are required by EN 

13211, whereas EPA Method 29 require the use of six 

impingers. In addition, EN 13211 does not include many 

of the quality control procedures of EPA Method 29, 

especially for the use and calibration of temperature 

sensors and controllers, sampling train assembly and 

10 
SIMILAR EPA 

STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS 

REFERENCE STANDARD 

METHOD 

disassembly, and filter weighing. 

EPA Method 29 CAN/CSA Z223.26-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 (CV AAS) 

analytical procedures only, because of lack of detail in 

quality control. Specifically, CAN/CSA Z223.26 does not 

include specifications for the number of calibration 

samples to be analyzed, procedures to prevent carryover 

from one sample to the next, and procedures for 

subtraction of the instrument response to calibration 

blank as in the EPA methods. Also, CAN/CSA Z223.26 

does not require that the calibration curve be forced 

through or close to zero (or a point no further than \j 2 

percent of the recorder full scale) as in the EP A methods. 

Also, CAN/CSA Z223.26 does not include a procedure 

to assure that two consecutive peak heights agree within 

3 percent of their average value and that the peak 

maximum is greater than 10 percerit of the recorder full 

scale, as in the EPA methods. CAN/CSA Z223.26 does 

not include instructions for a blank and a standard to be 

run at least every 'five samples, and specifications for the 

peak height of the blank and the standard as in the EPA 

methods. 

11