# UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

# RESEARCH TRIANGLE PARK, NC 27711 

# JUN 

# 3 0 2014 OFFICE OF 

# MEMORANDUM AIR QUALITY PLANNING AND STANDARDS 

# SUBJECT: FROM: TO: Voluntary Consensus StandardResults for 40 CPRPart 63, Subpart KKKKKNational Emission Standards for Hazardous AitPfl:Illuta fi.pr Clay Ceramics Manufacturing 

# I ,) !

/ 

# / 

# Jodi Howard, Acting Group Leade '( ' · MeasurementTechnology Group ( 3· -02) Keith Barnett, Group Leader Minerals and Manufacturing Group (D243-02) Atyourrequest, the MeasurementTechnology Group (MTG) ofthe Office ofAir Quality Planning and Standards (OAQPS) conducted searches and reviews to address the National Technology Transfer and AdvancementAct (NTTAA) requirements onthe use ofvoluntary consensus standards (VCS). The NTTAA directs EPAto use VCS in regulatory and procurement activities unless doing so would be inconsistentwith 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 ofstationary source methods cited inthe Results for 40 CPRPart 63, SubpartKKKKKNational Emission Standards for Hazardous AirPollutants for Clay CeramicsManufacturing. In 1998, OAQPS began implementing the requirements oftheNTTAA by conducting searches to identify VCS. Searches continue to be performed to meetthe requirements ofthe NTTAA. 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 activeVCS 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 expectthese additional efforts will help us to support a periodic review ofall EPA reference methods and performance standards for possible incorporation by reference (IBR) ofVCS in lieu ofor as alternatives toEPA procedures. We anticipate thatthese activities will provide an opportunity for further review, consideration and possible IBRofVCS overlooked in theNational Standards Service Network (NSSN) searches orfinalized after Federal agency review in the EPA rulemaking process. We conducted searches for the 40 CPRPart 63, SubpartKKKKKNational Emission Standards for Hazardous Air Pollutants for Clay Ceramics Manufacturingthrough theEnhanced NSSN Database managedby the AmericanNational Standards Institute (ANSI). We also contacted VCS organizations, and accessed and searchedtheir databases. Searches were conducted for EPA Methods 1, lA, 2, 2A, 2C, 2D, 2F, 2G, 3, 3A, 3B, 4, 5, 22, 23, 26, Internet Address (URL) • http://www.epa.gov Recycled/Recyclable • Printed

**w~h** 

# Vegetable Oil Based Inks on Recycled Paper (Minimum 25% Postconsumer)

# 2 26A, 29, and 320 of40 CFR Part 60, AppendixA. 

# No applicable voluntary consensus standards were identified for EPAMethods 1A, 2A, 2D, 2F, 2G, and 22. Fourvoluntary consensus standards were identified as acceptable alternatives to the EPA test methods for the purpose ofthis rule. The voluntary consensus standard ANSIIASME PTC 19-10-1981- Part 10 Flue and Exhaust Gas Analyses is acceptable as an alternative to Method 3Aand 3B for the manualprocedures only and notthe instrumental procedures. The voluntary consensus standard ASTMD6735-0I -Standard TestMethod for Measurement ofGaseous Chlorides and Fluorides from Mineral CalciningExhaust Sources Impinger Method is acceptable as an alternative to Methods 26 and 26A. The voluntary consensus standard ASTM D6784-02 - Standard TestMethod for Elemental, Oxidized, Particle-Bound and Total Mercury Gas Generated from Coal-Fired Stationary Sources (Ontario Hydro Method) is acceptable as an alternative to Method 29 (portion for mercury only). The voluntary consensus standard ASTM D6348-03(2010)- Determination ofGaseous Compounds by ExtractiveDirectInterfaceFourier Transform (FTIR) Spectroscopy is acceptable as an alternative to Method 320 with the following conditions: (1) The test plan preparation and implementation inthe Annexes to ASTM D 6348-03, Sections A1 through A8 are mandatory; and (2) In ASTM D6348-03 Annex AS (Analyte Spiking Technique), the percent (%) R mustbe determined for each target analyte (Equation A5.5). In order for the test datato be acceptable for a compound, %Rmust be 70%2:R:::; 130%. Ifthe %Rvalue does notmeetthis criterion for atarget compound, the test datais not acceptable for that compound and the test must be repeated for that analyte (i.e., the samplingand/or analytical procedure should be adjusted before a retest). The %Rvalue for each compoundmust be reported in the testreport, and all field measurements must be corrected with the calculated %Rvalue for that compound by using the following equation: 

# ReportedResult = 

# (Measured Concentration in the Stackx 100)I%R. Duringthe search, ifthe title or abstract (ifprovided) ofthe VCS described technical sampling and analytical procedures that are similarto EPA's reference method, the MTG considered it as a potential equivalentmethod. All potential standards were reviewed to determine the practicality ofthe VCS for this rule. This reviewrequires significantmethod validation datawhich meets the requirements ofEPA Method 301 for accepting alternative methods or scientific, engineering and policy equivalence to procedures in EPAreference methods. The MTG may reconsider determinations ofimpracticality when additional information is available for particularVCS. The search identified 20 otherVCS thatwerepotentially applicable for this rule in lieu ofEPAreference methods. After reviewing the available standards, EPA determined that 20 candidateVCS (ASTM D3154-00 (2006), ASTM D3464-96 (2007), ASTM D3796-90 (2004), ISO 10780:1994, ASME B133.9- 1994 (2001), ANSI/ASME PTC 19-10-1981 Part 10, ISO 10396:1993(2007), ISO 12039:2001, ASTM D5835-95 (2013), ASTMD6522-11, CAN/CSA Z223.2-M86 (1999), ISO 9096:1992 (2003), ANSI/ASME PTC-38-1980 (1985), ASTM D3685/D3685M-13, CAN/CSA Z223.1-M1977, EN 1911- 1,2,3 (1998), ASTM D4358-94 (1999), EN 1948-3 (1996), EN 13211:2001, CAN/CSAZ223.26-M1987) identified for measuring emissions ofpollutants ortheir surrogates subjectto emission standards inthe rule would notbe practical due to lack ofequivalency, documentation, validation data and other important technical and policy considerations. These 20 methods are listed inAttachment 1, along withthe EPA review comments. I hope ourresearch into this matterhas been useful and timely to your Groups efforts in this rulemaking. Please contactme at (919) 541-4607 with any further questions inthis matter. ·

# Attachments cc: Michael Toney, EPA/AQAD (E143-02) Rima Howell, EPA/AQAD (E143-02) JeffTelander, EPA/SPPD (D243-02) 

# 3

## Attachment 1. 

## List of Voluntary Consensus Standards Not Applicable for 40 CFR Part 63, Subpart KKKKK National Emission Standards

for Hazardous Air Pollutants for Clay Ceramics Manufacturing SIMILAR EPA STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS REFERENCE STANDARD METHOD EPA Methods 1, 2, 2C, ASTM D3154-00

· (2006)

- Standard Method for This method is impractical as an alternative to EPA

3,

3B, 4 Average Velocity in a Duct (Pitot Tube Method) Methods 1, 2, 3, and 3B 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) proof that 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.

EPA

Method 2 ASTM D3464-96 (2007)

- Standard Test Method This method is impractical as an alternative to EPA Method 1



## Average Velocity in a Duct Using a Thermal 2 for the purposes of this rule primarily because

, Anemometer

applicability specifications are not clearly defined, e.g., range

of gas composition, 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. EPAMethod2

ISO 10780: 1994

- Stationary Source Emissions- This method is impractical as an alternative to EPA Method Measurement of Velocity and Volume Flowrate of Gas 2 in this rule. The standard recommends the use of anLStreams in Ducts shaped pitot, which historically has not been recommended



# 1SIMILAR EPA STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS REFERENCE STANDARD METHOD by EPA. The EPA specifies the S-type design, which has large openings that are less likely to plug up with dust.

EPA Method 2 ASTM D3796-90 (2004)- Standard Practice for This ASTM standard is intended to be a calibration Calibration of Type S Pi tot Tubes procedure 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 require an inclined manometer and does
not specify any additional accuracy verifications for the use

of

other types of differential pressure

_ gauges. EPA-Methods

2, 3A, 4, ASME Bl33.9-1994 (2001)- Measurement of Exhaust Not a quantitative method, per se, although a good primer

5 Emissions from Stationary Gas Turbine Engines for this source category that includes technical descriptions (Revision of ANSI Bl33.9-1979) of manual and instrumental sampling procedures, as well as performance

specifications for instrumental methods. This standard has many good references, including the EPA Methods and Performance Specifications. 

### ONLY USE FOR 

### ENGINES AND TURBINES DO NOT USE AT ALL? NOT A METHOD?

EPA Methods 3A ASTM D5835-95 (2013)- Standard Practice for These standards are impractical alternatives to EPA Sampling Stationary Source Emissions for Automated Methods 3A, 6C, 7E, and 10 for the purposes of this rule Determination of Gas Concentration because they lack in detail and quality assurance/quality control requirements. Specifically, these two standards do
not include the following: (1) sensitivity of the method; (2) acceptable levels of analyzer calibration error; (3) acceptable levels of sampling system bias; ( 4) zero drift and

ISO

10396:1993 (2007)- Stationary Source calibration drift limits, time span, and required testing Emissions:

Sampling for the Automated Determination frequency; (5) a method to test the interference response of

of

Gas Concentrations the analyzer; (6) procedures to determine the minimum sampling time per run and minimum measurement time;

-- - 

### 2SIMILAR EPA STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS REFERENCE STANDARD METHOD and (7) specifications for data recorders, in terms of resolution (all types) and recording intervals (digital and analog recorders, only).

EPA Methods 3A ISO 12039:2001 -Stationary Source Emissions- This standard is not acceptable as an alternative to EPA Determination of Carbon Monoxide, Carbon Dioxide, Methods 3A and 10. This ISO standard is similar to the

and Oxygen--Automated Methods EPA methods, 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 the EPA methods specify a three-point calibration. Also, ISO 12039:2001 does not specify performance criteria for calibration error, calibration drift, or sampling system bias tests as in the EPA methods, although checks of these quality control

. features are required by the ISO standard.

EPA Methods 3A ANSI/ASME PTC 19-10-1981-Part 10- Flue and This method is not acceptable as a substitute for EPA Exhaust Gas Analyses Methods 3A, 6C, 7A, 7E, 10, 15, and 16. This standard includes manual and instrumental methods of analyses for carbon monoxide, nitrogen oxides, oxygen, and sulfur dioxide. The instrument methods are only general descriptions of procedures and are not true methods. Therefore, while some of the manual methods are acceptable

alternatives to EPA methods, the instrumental procedures are not.



### 3SIMILAR EPA STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS REFERENCE STANDARD METHOD EPA Method 3A ASTM D6522-ll- Standard Test Method for the ASTM D6522-ll has been determined to be technically Determination ofNitrogen Oxides, Carbon Monoxide, appropriate for identifying nitrogen oxides, carbon

and Oxygen Concentrations in Emissions from Natural monoxide, and oxygen concentrations when the fuel is Gas-Fired Reciprocating Engines, Combustion natural gas. 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 for EPA Continuous Measurement of Oxygen, Carbon Dioxide, Methods 3A, 6C, 7E, 10, lOA, and 20 (nitrogen oxides and Carbon Monoxide, Sulphur Dioxide, and Oxides of oxygen parts of20 only), since it does not include Nitrogen in Enclosed Combustion Flue Gas Streams quantitative specifications for measurement system 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 EPA methods requires drift checks after each run.
EPA Method 5 ANSIIASME PTC-38-1980 (1985)- Determination of This standard is not specific about equipment requirements,

the Concentration of Particulate Matter in Gas Streams and instead presents the options available and the pros and cons of each option. The key specific differences between ANSIIASME PTC-38 and the EPA methods are that the ASME standard: (1) allows in-stack filter placement as compared to the out-of-stack filter placement in EPA Method 5; (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



### 4SIMILAR EPA STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS REFERENCE STANDARD METHOD 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 method.

EPA Method 5 ASTM D3685/D3685M-98-13- Test Methods for This method is similar to EPA Method 5, but is lacking in Sampling and Determination of Particulate Matter in the following areas that are needed to produce quality,
Stack Gases representative particulate data: ( 1) requirement that the filter holder temperature should be between l20°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 filters, sampling preparation and implementation guidance, sample recovery guidance, data reduction guidance, and particulate sample calculations input.

EPA Method 5

ISO 9096:1992 (2003)- Determination of This method is not acceptable as an alternative for EPA Concentration and Mass Flow Rate of Particulate Method 5. Although sections of ISO 9096 incorporate EPA
Matter in Gas Carrying Ducts-Manual Gravimetric Method 5 to some degree, this ISO standard is not Method equivalent to EPA Method 5 for collection of particulate matter. The standard ISO 9096 does not provide applicable

- - 

### 5SIMILAR EPA STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON

. VOLUNTARY CONSENSUS REFERENCE STANDARD METHOD technical guidance for performing many of the integral procedures specified in Method 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 CAN/CSA Z223.1-Ml977- Method for the This standard is not acceptable as an alternative for EPA Determination of Particulate Mass Flows in Enclosed Method 5. Detailed technical procedures and quality

Gas Streams control measures that are required in EPA Methods 1, 2, 3, and 4 are not included in CAN/CSA Z223 .1. Second, CAN/CSA Z223 .1 does not include the EPA Method 5 filter weighing requirement to repeat weighing every six hours until a constant weight is achieved. Third, EPA Method 5 requires the filter weight to be reported to the nearest 0.1 mg, while CAN/CSA Z223 .1 requires only to
the nearest 0.5 mg. Also, 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.



### 6SIMILAR EPA STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS REFERENCE STANDARD METHOD I

EPA Method 23 EN 1948-3 (1996) (European Committee for Provides additional sampling options other than what is I Standardization)--Determination

of the Mass acceptable in EPA Method 23. Concentration ofPCDD'S/PCDF'S Part 3: Identification and Quantification EPA Method 26, 26A EN 1911-1,2,3 (1998)- Stationary Source Emissions- Part 3 of this standard cannot be considered equivalent to Manual

Method of Determination ofHCl-Part 1: EPA Method 26 or 26A. The sample absorbing solution Sampling of Gases Ratified European Text-Part 2: (water) would be expected to capture both HCl and chlorine Gaseous Compounds Absorption Ratified European gas, if present, without the ability to distinguish between Text-Part 3: Adsorption Solutions Analysis and the two. The EPA Methods 26 and 26A use an acidified Calculation Ratified European Text absorbing solution to first separate HCl 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 29 ASTM D4358-94 (1999)- Standard Test Method for The EPA Method 29 requires the use of hydrofluoric acid

Lead and Chromium in Air Particulate Filter Samples (HF) in its process of digestion of the sample. Since ASTM

of Lead Chromate Type Pigment Dusts by Atomic D4358-94 (1999) does not require the use ofHF, it cannot Absorption Spectroscopy be used in the preparation, digestion, and analysis of Method 29 samples. Additionally, Method 29 requires the
use of a glass fiber filter, whereas the subject ASTM standard requires cellulose filters and other probablenonglass

fiber media, and this further negates their use as EPA Method 29 equivalent methods.



### 7SIMILAR EPA I STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS

I REFERENCE

STANDARD METHOD EPA Methods 29 EN 13211:2001 -Air Quality--Stationary Source EN 13211 is not acceptable as an alternative to the mercury
(portion for mercury Emissions- Determination of the Concentration of Total portion of EPA Method 29 primarily because it is not

only) 101, lOlA Mercury 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 offritted

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 ofthe quality control procedures of EPA Method 29, especially for the use and calibration of temperature sensors and controllers, sampling train assembly and disassembly

, and filter weighing.

EPA Method 29 CAN/CSA Z223.26-M1987- Measurement ofTotal EPA Methods 29 (mercury only), 101, and lOlA, for the
(portion for mercury Mercury in Air Cold Vapour Atomic Absorption cold vapor atomic absorption spectrometry (CV AAS)

only) 101, lOlA Spectrophotometeric Method 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 2 percent of the recorder full scale)

as in the EPA methods. Also, CAN/CSA Z223 .26 does not **includ~aprocedure** to assure that two consecutive peak



### 8

## SIMILAR EPA STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS REFERENCE STANDARD :METHOD heights agree within 3 percent of their average value and that the peak maximum is greater than 10 percent 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.



# 9