MEMORANDUM 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

RESEARCH TRIANGLE PARK, NC 27711 

MAR 3 1 2011 

OFFICE OF 

AIR QUALITY PLANNING 

AND STANDARDS 

SUBJECT: Voluntary Consensus Standard Results for National Emission Standards for 

Hazardous Air Pollutants for Polyvinyl Chloride and Copolymers Production (40 

CFR 63, Subpart HHHHHHH (Addendum to original memo dated 12/20/2010) 

FROM: Connie sue B. Oldham, Group Leader � Q{� 

Measurement Technology Group (E143-02) 

TO: Penny Lassiter, Group Leader 

Refining and Chemicals Group (E143-01) 

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 National Emission Standards for Hazardous Air Pollutants for Polyvinyl Chloride and 

Copolymers Production (40 CFR 63, Subpart HHHHHHH). 

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 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 

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

searches or finalized after Federal agency review in the EPA rulemaking process. 

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

RecycledIRecyclable • Printed wnh Vegetable Oil Based Inks on Recycled Paper (Minimum 25% Postconsumer) 
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We conducted searches for the National Emission Standards for Hazardous Air Pollutants 

for Polyvinyl Chloride and Copolymers Production (40 CFR 63, Subpart HHHHHHH) through 

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

We also contacted VCS organizations, and accessed and searched their databases. 

This rulemaking involves technical standards. EPA has decided to use ANSII ASME PTC 

19.10-1981, "Flue and Exhaust Gas Analyses as an acceptable alternative to EPA Method 3B. 

This standard is available from the American Society of Mechanical Engineers (ASME), Three 

Park Avenue, New York, NY 10016-5990 and ASTM D6420-99 (2004) as an acceptable 

alternative to EPA Method 18. . 

No applicable voluntary consensus standards were identified for EPA Methods 305, 

8021B, and SW-846 Method 003l. 

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 EP A Method 301 for 

accepting alternative methods or scientific, engineering and policy equivalence to procedures in 

EP A reference methods. The MTG may reconsider determinations of impracticality when 

additional information is available for particular VCS. 

The search identified 2 other VCS that were potentially applicable for this rule in lieu of 

EPA reference methods. After reviewing the available standards, EPA determined that 2 

candidate VCS (EN 1911-1,2,3 (1998), ASTM D6735-01) 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 2 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: Jodi Howard, EPAlSPPD (E143-01) 

Rima Howell, EPA/AQAD (E143-02) 

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

Hazardous Air Pollutants for Polyvinyl Chloride and Copolymers Production (40 CFR 63, Subpart HHHHHHH). 

SIMILAR EPA 

STANDARD VOLUNTARY CONSENSUS STANDARD EPA I S COMMENTS ON VOLUNTARY 

REFERENCE CONSENSUS STANDARD 

METHOD 

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

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

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

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

Ratified European Text-Part 3: Adsorption distinguish between the two. The EPA Methods 26 

Solutions Analysis and Calculation Ratified and 26A use an acidified absorbing solution to first 

European Text separate HCI 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. 

EPA Method 26A ASTM D6735-01 - Standard Test Method for This impinger-based standard to measure HCI is an 

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

321 from mineral calcining exhaust sources. 

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