UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

RESEARCH TRIANGLE PARK, NC 27711 

APR 1 Z015 

OFFICE OF 

MEMORANDUM 

AIR QUALITY PLANNING 

AND STANDARDS 

SUBJECT: 

FROM: 

TO: 

Voluntary Consensus Standard Results for Emission Guidelines and Compliance Times 

for Municipal Solid Waste Landfills 

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David Cozzie, Group Leader 

Fuels and Incineration Group (E l43-0l) 

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 Transfe r and 

Advancement Act (NTT AA) requirements on the use of voluntary consensus standards (VCS). The 

'ITAA 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 if VCS are ava ilable and practical for use in lieu of stationary 

source methods cited in the Emission Guidelines and Compliance Times for Municipa l Solid Waste 

Landfi lls. 

In 1998. OAQPS began implementing the requirements of the NTT AA by conducting searches to identify 

VCS. Searches continue to be performed to meet the requirements of the NTTAA. While we have made a 

reasonable effort to identi fy 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 fo r Testing and Materials (ASTM), which is one of the 

most acti ve VCS orga nizations on emissions testing, and has been invited to participate in the US/\ 

Technical Advisory Group for International Organization fo r Standardization (ISO) relating to em issions 

monitoring. We expect these additional efforts will help us to suppo1i a periodic review of all EPA 

reference methods and performance standards for possible incorporation by reference (IBR) of VCS in 

li eu of or as alternatives to EPA procedures. We anticipate that these activities will prov ide an 

opportunity for further review, consideration and possible I BR of VCS overlooked in the National 

Standards Service etwork (NSSN) sea rches or finalized after Federal agency review in the EPA 

rulemaking process. 

We conducted searches for Emission Guidelines and Compliance Times fo r Municipal Solid Waste 

Landfills through the Enhanced NSSN Database managed by the American National Standards Insti tute 

(ANSI). We also contacted VCS organizations and accessed and searched their databases. Searches were 

conducted for EPA Methods 2. 2E, 3. 3A. 3C 18, 2 1, 25, 25A, and 2SC of 40 CFR Part 60, Appendix A. 

No applicable voluntary consensus standards were identifi ed for EPA Methods 2E, 21. and 25C. 

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

Recycled/Recyclable • Printed wrth Vegetable Oil Based Inks on Recycled Paper (Minimum 25% Posfconsumer) 
2 

During the search, if the title or abstract (if provided) of the VCS described technica l sampling and 

analytical procedures that are similar to EPA's reference method, the MTG considered 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 va lidati on data wh ich meets the requirements 

of EPA Method 30 I for accepting alternati ve methods or scientific, engi neering and policy equiva lence to 

procedures in EPA reference methods. The MTG may reconsider determinations of impracticality when 

additional information is available for particular VCS. 

One voluntary consensus standard was identified as an acceptable alternative to EPA test methods for the 

purposes of this rule. The voluntary consensus standard ASTM 0 6420-99 (20 I 0), "Test Method fo r 

Determination of Gaseous Organic Compounds by Direct Interface Gas Chromatography/Mass 

Spectrometry" is an acceptable alternati ve to Method 18. 

The search identified 14 VCS that were potentially applicable for this rule in lieu of EPA reference 

methods. After reviewing the ava ilable standards, EPA determined that 14 candidate VCS (ASTM 

D3 l 54-00 (2006), ASTM 0 3464-96 (2007), ASTM 0 3796-90 (200 I), ISO I 0780: 1994, ASME B 133.9-

1994 (200 1), ANSl/ASME PTC 19- 10-1 98 1Part10, ISO 10396:1 993 (2007), ISO 12039: 2001 , ASTM 

0 5835-95 (2013), ASTM D6522-l l. CA /CSA Z223.2-M86 (1999), ASTM 06060-96 (2009), ISO 

l 4965:2000(E), EN 126 19 ( 1999)) identified fo r measuring emissions of pollutants or their surrogates 

subject to emission standards in the rule would not be practical due to lack of equivalency, 

documentation, va lidation data and other important technical and policy considerations. These 14 

methods are listed in Attachment I, along with the EPA review comments. 

I hope our research into this matter has been useful and timely to your Group's effo11s in this rulemaking. 

Please contact me at (9 I 9) 54 1- 9724 with any further questions in this matter. 

A ttachrnents 

cc: Linda Chappell , EPA/SPPO (0 243-04) 

Hillary Ward, EPA/SPPO (13 143-0 1) 

Michael Toney, EPA/AQAO (E143-02) 
Attachment l . List of Voluntary Consensus Standards Not Applicable fo r Emission Guidelines a nd Compliance Times fo r Municipal 

Solid Waste Landfills 

SIMILAR EPA 

STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS 

REFERENCE STAN DARD 

METHOD 

EPA Method 2 ASTM DJ 154-00 (2006) - Standard Method for This standard appears to cover EPA ·s Part 60 Methods I. 2, 

Average Ve locity in a Duct (Pitot Tube Method) 2C, 3, 38, 4. but lacks in quali ty contro l and quality assurance 

requirements. Specifica lly. ASTM D3 I 54-00 does not include 

the following: I) proof that openings of standard pitot tube 

have not pl ugged during the test; 2) if differential pressure 

gauges other than inclined manometers (e.g., magneheli c 

gauges) are used, heir cali bration must be checked after each 

test series; and 3) the frequency and validity range for 

ca libration of the temperature sensors. 

EPA Method 2 ASTM D3464-96 (2007) - Standard Test Method The applicability specifications in this ASTM standard are 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 ca libration 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. 

EPA Method 2 ASTM D3796-90 (2004) - Standard Practice for This ASTM standard is intended to be a ca libration procedure 

Calibration of Type S Pitot 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 

req uire an inclined manometer and does not specify any 

additional accu racy verifications for the use of other types of 

differential pressure gauges. 

EPA Method 2 ISO I 0780: 1994 - Stationary Source Emissions ISO I 0780: 1994 recommends the use of an L-shaped pi tot, 

Measurement of Velocity and Volume Flowratc of Gas wh ich historicn lly has not been recommended by EPA. The 

Streams in Ducts EPA specifies the S-type design which has large openings that 
SlMIL/\R EPA 

STANDARD 

REFERENCE 

METHOD 

EPA Method 2, 3A 

EPA Methods 3A, 3C 

VOLUNTARY CONSENSUS STANDARD 

ASME 8133.9-1 994(200 1) - Measurement of Exhaust 

Emissions from Stationary Gas Turbine Engines 

(Revision of ANSI 8133 .9-1979) 

ANSl/ASME PTC 19-10-1981- Part 10 Flue and 

Exhaust Gas Analyses 

2 

EPA·s COMMENTS ON VOLUNTARY CONSENSUS 

STANDARD 

are less likely to plug up with dust. 

Not a quantitative method. per se, although a good primer fo r 

this source category that includes technical descriptions of 

manual and instrumental sampling procedures, as well as 

performance spec ifications for instrumental methods. This 

standard has many good references. including the EPA 

Methods and Performance Specificatio ns. ONL Y USE FOR 

ENGINES AND TURBINES DO NOT USE AT ALL'? 

NOT A METHOD? 

This sta ndard includes manual and instrumental methods o f 

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 (38) and instrumental 

(I 0 and l OB)], H2S [manual ( I SA and I 6A) and instrumental 

( 15, 16, and 168) ], NOx [manual (7 and 7C) and instrume ntal 

(7 A, 78 , 7E, 20)), 02 [manual (38) and instrumental (3A, 3C, 

20)), and S02 [manua l (6, 6A, 6B, 20) and instrumental (6C)]. 

The manual methods are all acceptable alternatives to the 

corresponding EPA test methods (38, 6, 6A, 68, 7, 7C, I SA, 

l 6A, 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 instrumenta l procedures. 

o nly general descriptions of the procedures are inc luded which 

are not true methods. Therefore, the instrumental procedures 
SIMJLAR EPA 

STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTA RY CONSENSUS 

REFERENCE STAN DARD 

METHOD 

(3A, 3C, 6C, 7 A, 7B, 7E, I 0, I OB, 15. 16, 168, 20 (NOx part 

of20 only)) are not acceptable alternatives to the 

corresponding EPA methods. 

EPA Method 3 A ISO I 0396: 1993 (2007) - Stationary Source Em issions: This standard is similar to EPA Methods 3A, 6C, 7E, I 0, 20 

Sampling for the Automated Determination of Gas (nitrogen oxides and oxygen parts of20 only). ALT 004. CTM 

Concentrations 022, but lacks in detail and quality assurance/quality control 

requirements. Specifica lly. ISO I 0396 does not include the 

fo llowing: I) sensiti vity of the method; 2) acceptable leve ls of 

analyzer calibration error; 3) acceptable leve ls of sampling 

system bias: 4) zero drift and ca libration 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; 7) specifications for data recorders, in 

terms of resolution (all types) and recording intervals (digital 

and analog recorders, only). This standard is also very similar 

to ASTM 0 5835. 

EPA Method 3A ISO 12039:200 I - Stationary Source Emissions This method is similar to EPA Methods 3A, 10, and 20 

Determination of Carbon Monoxide, Carbon Dioxide, (oxygen portion of20 only). However, ISO 12039 is missing 

and Oxygen Automated Methods some key features. In terms of sampl ing. the hardware 

required by ISO 12039 does not include a 3-way ca libration 

va lve assembly or equivalent lo block the sample gas flow 

wh ile calibration gases are introduced. In its calibration 

procedures, I SO 12039 only specifies a two-point calibration 

while the EPA methods specify a 3-point ca libration. Also, 

ISO 12039 does not specify performance criteria for 

calibration error, ca libration drift, or sampling system bias 

3 
SIMILAR EPA 

STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS 

REFERENCE STANDARD 

METHOD 

tests, although checks of these quality control features are 

required by the ISO standard. In addition, ISO 12039 does not 

include procedures for removal of C02 when CO is being 

tested, as in EPA Method I 0. 

EPA Method 3A ASTM 05835-95 (201 3) - Standard Practice for This standard is similar to EPA Methods 3A. 6C, 7E. JO, 20 

Sampling Stationary Source Emissions for Automated (nitrogen oxides and oxygen parts of 20 only), ALT 004, CTM 

Determination of Gas Concentration 022, but lacks in detail and quality assurance/quality control 

requirements. Specifically. ASTM 0 5835-95 does not include 

the following: I) sensitivity of the method; 2) acceptable 

levels of analyzer calibration error; 3) acceptable leve ls of 

sampling system bias; 4) zero drift and ca libration 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; 7) specifications for data recorders, in 

terms of resolution (all types) and recording intervals (digital 

and analog recorders, only). This standard is also very similar 

to ISO I 0396. 

EPA Method 3A ASTM 06522-11 - Standard Test Method for the ASTM D6522 has been determined to be technically 

Determination of Nitrogen Oxides, Carbon Monoxide, appropriate for identifying nitrogen oxides, carbon monoxide, 

and Oxygen Concentrations in Emissions from Natural and oxygen concentrations when the fuel is natural gas. 

Gas-Fired Reciprocating Engines, Combustion 

Turbines, Boilers and Process Heaters Using Portable 

Analyzers 

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

Continuous Measurement of Oxygen, Carbon Dioxide, 3A, 6C, 7E, 10, 1 OA, and 20 (nitrogen ox ides and oxygen 

.+ 
SIMILAR EPA 

STANDARD 

REFERENCE 

METHOD 

EPA Method 18 

EPA Methods 25, 25A 

VOLUNTARY CONSENSUS STANDARD 

Carbon Monoxide, Sulphur Dioxide, and Oxides of 

Nitrogen in Enclosed Combustion Flue Gas Streams 

ASTM D6060-96 (2009) - Practice for Sampling of 

Process Vents with a Portable Gas Chromatography 

ISO 14965 :2000(E) - Air Quality Determination of 

Total Nonmethane Organic Compounds Cryogenic 

Preconcentration and Direct Flame Ionization Method 

5 

EPA'S COMMENTS ON VOLUNTARY CONSENSUS 

STANDARD 

parts of 20 only), since it does not include quantitative 

specifications for measurement system performance, most 

notably the calibration procedures and instrument performance 

characteristics. The instrument performance characteristics 

that are provided are nonrnandatory and also do not provide 

the same level of quality assurance as the EPA methods. For 

example, the zero and span/ca libration clri ft is only checked 

weekly, whereas the EPA methods requires drift checks after 

each run. 

Th is ASTM standard lacks key quality control and assurance 

requirements included in EPA Method 18. For example. 

ASTM D6060: I) lacks the requirement of three reference 

standards in triplicate; 2) lacks the calibration acceptance 

criteria that the triplicate calibration standards agree within 5 

percent of their average: 3) lacks a post-sampling volume now 

rate check and requirement to repeat the test if the pre- and 

post-test tlowrates differ by more than 20 percent; 4) lacks 

tri plicate samples for recovery tests and allows a 15 percent 

difference between the pre-test and recovery test data vs. I 0 

percent for Method 18; 4) lacks the accuracy performance 

criteria of I 0 percent of the preparation value for audit 

samples; 5) lacks reporting/documentation requirements. 

Also, ASTM 06060 does not include procedures for sample 

collection using other media, such as bags and solid sorbents. 

This standard is an impractical alternative to EPA Method 25 

or 25A because it does not measure solvent process vapors in 

concentrations greater than I 0 ppm carbon. A method whose 
SIMILAR EPA 

STANDARD VO LUNT ARY CONSENSUS STANDARD EPA ·s COMMENTS ON VOLUNTARY CONSENSUS 

REFERENCE STANDARD 

METHOD 

upper I im it is I 0 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 of the 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 Gases Continuous Flame Ionization Detector upper limit is 40 ppm carbon has a measurement range too 

Method limited to be use rul in measuring source emissions. 

6