UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

... _ FEB 5. 2014 .. THE ADMINISTRATOR 

MEMORANDUM 

SUBJECT: 

FROM: 

TO: 

Voluntary Consensus Standard Results for Federal Plan Requirements for Sewage Sludge 

Incineration Units Constructed On or Before October 14, 2010; 40 CFR Part 62, Subpart 

LLL 

Robin 

Measurement 

Segall, 

Technology 

Acting Group 

Group 

Leader 

(E143-02) 

~51.....-... W ~~ () 

David Cozzie, Group Leader 

Fuels and Incineration 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 (NTT AA) 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 if VCS are available and practical for use in lieu of stationary 

source methods cited in the Results for Federal Plan Requirements for Sewage Sludge Incineration Units 

Constructed On or Before October 14, 2010; 40 CFR Part 62, Subpart LLL. 

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 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 of VCS overlooked in the National 

Standards Service Network (NSSN) searches or finalized after Federal agency review in the EPA 

rulemaking process. 

We conducted searches for Federal Plan Requirements for Sewage Sludge Incineration Units Constructed 

On or Before October 14, 2010; 40 CFR Part 62, Subpart LLL through the Enhanced NSSN Database 

managed by the American National Standards Institute (ANSI). We also contacted VCS organizations, 

and accessed and searched their databases. 

Recycled/Recyclable • Printed with Vegetable 011 Based Inks on 100% Recycled Paper (40% Postconsumer) 
2 

Searches were conducted for EPA Methods 5, 6, 6C, 7, 7E, 10, lOA, lOB, 22, 23, 26A, 29 and 30B of 40 

CFR Part 60, Appendix A. No applicable voluntary consensus standards were identified for EPA Method 

22. 

Two voluntary consensus standards were identified as acceptable alternatives to the EPA test methods for 

the purpose of this rule. The voluntary consensus standard ANS1JASME PTC 19-10-1981- Part 10 Flue 

and Exhaust Gas Analyses is acceptable as an alternative to Method 6 and 7 for the manual procedures 

only and not the instrumental procedures, and the voluntary consensus standard 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 alternative to Method 29 and 

Method 30B. 

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 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 validation data which meets the requirements of EPA 

Method 301 for accepting alternative 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 23 other VCS that were potentially applicable for this rule in lieu of EPA reference 

methods. After reviewing the available standards, EPA determined that 23 candidate VCS (ASME 

B 133.9-1994 (2001), ISO 9096:1992 (2003), ANS1! ASME PTC-38-1980 (1985), ASTM 

D3685/D3685M-13, CAN/CSA Z223.1-M1977, ANS1JASME PTC 19-10-1981 part 10, ISO 10396:1993 

(2007), ISO 12039:2001, ASTM D5835-95 (2013), ASTM D6522-11, CAN/CSA Z223.2-M86 (1999), 

ISO 7934:1998, ISO 11632:1998, ASTM D1608-98 (2009), ISO 11564:1998, CAN/CSA Z223.24-

M1983, CAN/CSA Z223 .21-M1978, ASTM D3162-12, EN 1948-3 (1996), EN 1911-1,2,3 (1998), 

ASTM D6735-01 (2009), 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 23 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 Groups efforts in this rulemaking. 

Please contact me at (919) 541-7774 with any further questions in this matter. 

Attachments 

cc: Amy Hambrick, EPNSPPD (E143-01) 

Rima Howell, EPNAQAD (E143-02) 

Michael Toney, EPNAQAD (E143-02) 
Attachment 1. List of Voluntary Consensus Standards Not Applicable for Federal Plan Requirements for Sewage S

Units Constructed On or Before October 14, 2010; 40 CFR Part 62, Subpart LLL 

SIMILAR EPA 

STANDARD 

REFERENCE 

METHOD 

EPA Method 5 

EPA Method 5 

VOLUNTARY CONSENSUS STANDARD 

ASME B133.9-1994 (2001)- Measurement of Exhaust 

Emissions from Stationary Gas Turbine Engines 

(Revision of ANSI Bl33.9-1979) 

ISO 9096:1992 (2003)- Determination of 

Concentration and Mass Flow Rate of Particulate 

Matter in Gas Carrying Ducts Manual Gravimetric 

Method 

1 

EPA'S COMMENTS ON VOLUN

STANDARD 

Not a quantitative method, per se, al

for this source category that includes 

of manual and instrumental sampling 

performance specifications for instru

standard has many good references, 

Methods and Performance Specifica

ONLY USE FOR ENGINES AND 

NOT USE AT ALL? NOT A MET

Although sections of ISO 9096 incor

1, 2, and 5 to some degree, this ISO 

equivalent to EPA Method 5 for coll

matter. The standard ISO 9096 does 

technical guidance for performing m

procedures specified in Methods 1, 2

performance and operational details 

nonexistent, and detailed quality assu

guidance for the sampling operations 

quality, representative particulate da

maintaining and monitoring train ope

specific leak check guidelines and pr

preparation and recovery procedures

the standard, as in EPA Method 5. A
SIMll..AR EPA 

STANDARD VOLUNTARYCONSENSUSSTANDARD EPA'S COMMENTS ON VOLUN

REFERENCE STANDARD 

METHOD 

equipment and/or operational require

specified in EPA Method 5, are not i

standard, e.g., stack gas moisture me

reduction guidance, and particulate s

EPA Method 5 ANSIIASME PTC-38-1980 (1985)- Determination of This standard also includes procedur

the Concentration of Particulate Matter in Gas Streams Methods 1 and 2. The difference be

EPA Methods 5 and 17 is, in general

80 is not specific about equipment re

instead presents the options available 

con's of each option. The key specif

ASME PTC-38-80 and the EPA met

ASME standard: 1) allows in-stack f

compared to the out-of-stack filter pl

Methods 5 and 17; 2) allows many d

nozzles, pitots, and filtering equipme

a filter weighing protocol or a minim

weight fluctuation as in the EPA met

filter paper to be only 99 percent effi

the 99.95 percent efficiency required 

EPAMethod5 ASTM D3685/D3685M-13- Test Methods for This ASTM standard is similar to EP

Sampling and Determination of Particulate Matter in but is lacking in the following areas 

Stack Gases produce quality, representative partic

1) requirement that the filter holder t

between 120°C and 134°C, and not ju

point; 2) detailed specifications for m

monitoring the filter holder temperat

3) procedures similar to EPA Method

are required by EPA Method 5 and 1

2 
SIMILAR EPA 

STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUN

REFERENCE STANDARD 

METHOD 

guidance for performing the Method 

procedures, e.g., maintaining and mo

operating temperatures, specific leak 

procedures (delete n and use of reag

determining and subtracting backgro

and 5) detailed equipment and/or ope

e.g., component exchange leak check

cyclones lor heavy particulate loadin

droplets, operating under a negative 

exchanging particulate loaded filters

and implementation guidance, sampl

data reduction guidance, and particul

calculations input. 

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

Determination of Particulate Mass Flows in Enclosed that are required in EPA Methods 1, 

Gas Streams included in CAN/CSA Z223.1. Seco

Z223.1 does not include in its filter w

the EPA Method 5 requirement to re

six hours until a constant weight is a

Method 5 requires the weight to be r

0.1 mg, while CAN/CSA Z223.1 req

the nearest 0.5 mg. Lastly, CAN/CS

use of a standard pitot for velocity m

plugging of the tube opening is not e

problem, whereas EPA Method 5 req

pi tot. 

EPA Methods ANSI/ASME PTC 19-10-1981- Part 10 Flue and This standard includes manual and in

6C,7E,10,10B Exhaust Gas Analyses analyses for carbon dioxide (C02), c

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3 
SIMILAR EPA 

STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUN

REFERENCE STANDARD 

METHOD 

hydrogen sulfide (H2S), nitrogen oxi

(Oz), and sulfur dioxide (S02). The V

that include one or more of the same 

methods are as follows: C02 [manua

instrumental (3A and 3C)]; CO [man

instrumental (10 and lOB)], H2S [ma

and instrumental (15, 16, and 16B)], 

7C) and instrumental (7A, 7B, 7E, 20

and instrumental (3A, 3C, 20)], and S

6B, 20) and instrumental (6C)]. The 

all acceptable alternatives to the corr

methods (3B, 6, 6A, 6B, 7, 7C, 15A, 

20 only)). [Note that one of the stan

procedures incorporates EPA Method 

the standard's instrumental procedure

descriptions of the procedures are inc

true methods. Therefore, the instrum

3C, 6C, 7A, 7B, 7E, 10, lOB, 15, 16, 

20 only)) are not acceptable alternati

corresponding EPA methods. 

EPA Methods 5 ISO 10396:1993 (2007)- Stationary Source This standard is similar to EPA Meth

Emissions: Sampling for the Automated Determination (nitrogen oxides and oxygen parts of 

of Gas Concentrations CTM 022, but lacks in detail and qua

control requirements. Specifically, I

ASTM D5835-95 (2013) - Standard Practice for include the following: 1) sensitivity o

Sampling Stationary Source Emissions for Automated 2) acceptable levels of analyzer calib

Determination of Gas Concentration 3) acceptable levels of sampling syst

and calibration drift limits, time span

4 
SIMILAR EPA 

STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUN

REFERENCE STANDARD 

METHOD 

frequency; 5) a method to test the int

the analyzer; 6) procedures to determ

sampling time per run and minimum 

specifications for data recorders, in t

types) and recording intervals (digita

only). This standard is also very sim

EPA Methods 10 ASTM D6522-11 - Standard Test Method for the ASTM D6522 has been determined t

Determination of Nitrogen Oxides, Carbon Monoxide, appropriate for identifying nitrogen o

and Oxygen Concentrations in Emissions from Natural monoxide, and oxygen concentration

Gas-Fired Reciprocating Engines, Combustion natural gas 

Turbines, Boilers and Process Heaters Using Portable 

Analyzers (previously ASTM Z7773Z 

EPA Method 10 ISO 12039:2001 - Stationary Source Emissions This method is similar to EPA Metho

Determination of Carbon Monoxide, Carbon Dioxide, (oxygen portion of 20 only). Howev

and Oxygen Automated Methods missing some key features. In terms 

hardware required by ISO 12039 doe

calibration valve assembly or equiva

sample gas flow while calibration ga

its calibration procedures, ISO 12039 

point calibration while the EPA meth

calibration. Also, ISO 12039 does no

criteria for calibration error, calibrati

system bias tests, although checks of 

features are required by the ISO stan

12039 does not include procedures fo

--

when CO is being tested, as in EPA M

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5 
SIMILAR EPA 

STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUN

REFERENCE STANDARD 

METHOD 

EPA Method 6C, 7E, 10 CAN/CSA Z223.2-M86 (1999)- Method for the This standard is unacceptable as a su

Continuous Measurement of Oxygen, Carbon Dioxide, Methods 3A, 6C, 7E, 10, lOA, and 2

Carbon Monoxide, Sulphur Dioxide, and Oxides of oxygen parts of 20 only), since it doe

Nitrogen in Enclosed Combustion Flue Gas Streams quantitative specifications for measu

performance, most notably the calibr

instrument performance characteristi

performance characteristics that are p

nonmandatory and also do not provid

quality assurance as the EPA method

zero and span/calibration drift is only 

whereas the EPA methods requires d

run. 

EPAMethod6 ISO 7934:1998- Stationary Source Emissions This standard is only applicable to so

Determination of the Mass Concentration of Sulfur S02 or more. Also, this standard doe

Dioxide Hydrogen Peroxide/Barium from S02 as does the EPA methods; 

Perchlorate/Thorin Method 7934:1998 is not valid if more than a 

S03 is- present. Also, it does not add

interferences. 

6 
SIMILAR EPA 

STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUN

REFERENCE STANDARD 

METHOD 

EPAMethod6 ISO 11632:1998- Stationary Source Emissions Sampling procedures are similar to E

Determination of the Mass Concentration of Sulfur lacks in detail and quality control pro

Dioxide Ion Chromatography calibration checks and leaks tests. 

EPA Method 7 ASTM D1608-98 (2009)- Test Method for Oxides of This standard is very similar to EPA 

Nitrogen in Gaseous Combustion Products (Pheno- there are some key differences. AST

Disulfonic Acid Procedures) are as follows (corresponding EPA M

are in parentheses and italics): 405 n

or optimized); 3 mL of 3% hydrogen 

absorbing solution (6 mL 3% hydrog

shaking of reaction flask to mix befo

(shake for at least 5 minutes before a

sitting); overnight sample sitting step 

sitting); no wavelength calibration o

(calibration every 6 months); prepare 

minimum every few days (prepare c

day that samples are analyzed); add 

just basic without any quantitative m

(add NH40H until pH= 10 as determ

EPA Method 7 ISO 11564: 1998 - Stationary Source Emissions - This ISO standard lacks many qualit

Determination of the Mass Concentration of Nitrogen control items, such as: use of recogn

Oxides- NEDA (naphthylethylenediamine)/ reagents, vs. EPA Method 7 which s

Photometric Method grade reagents; no specific leak chec

ISO 11564; and no quality control pr

spectrophotometer, spike sample ana

analysis are in ISO 11564. ISO 1156

hydrogen peroxide absorbent wherea

7 
SIMILAR EPA 

STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUN

REFERENCE STANDARD 

:METHOD 

uses alkaline permanganate. ISO 11

of introducing the absorbing solution 

after the gas is sampled, whereas EP

the absorbing solution into the flask 

gas. 

EPA Method 7 CAN/CSA Z223.24-M1983 -Method for the This standard does not cover the rang

Measurement of Nitric Oxide and Nitrogen Dioxide in or this regulation. CAN/CSA Z223.2

Air 20 mg/m3, whereas the EPA Method 

Also, there are no specific quality as

requirements for the spectrophotome

CAN/CSA 2223.24. Performance sp

spectrophotometer are not required b

consideration only and are said to be 

application of the method. Spectroph

calibration procedures are not includ

Z223.24 and the frequency of other c

is said to be a function of the instrum

required accuracy of measurement vs

month calibration period of EPA Me

EPA Method 10, lOA CAN/CSA Z223.21-M1978- Method for the This standard is not acceptable as an 

Measurement of Carbon Monoxide: 3 Method of Methods 10 and lOA because it is lac

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8 
SIMILAR EPA 

STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUN

REFERENCE STANDARD 

METHOD 

Analysis by Non-Dispersive Infrared Spectrometry areas: 1) sampling procedures; 2) pro

the carbon dioxide concentration; 3) 

the gas volume if C02 traps are used

certify the calibration gases are withi

target concentration; 5) mandatory in

characteristics (e.g., rise time, fall tim

drift, precision); 6) quantitative speci

value maximum as compared to the m

standard specifies that the instrument

Acompatible with the concentration 

measured, whereas EPA Method 10 

the instrument span value should be n

the source performance standard. 

EPA Method 10 ASTM D3162-94 (2005)- Standard Test Method for This ASTM standard, which is stated 

Carbon Monoxide in the Atmosphere (Continuous range of 0.5 - 100 ppm CO, does not 

Measurement by Nondispersive Infrared EPA Method 10 (20 - 1000 ppm CO) 

Spectrometry) claims to have a lower limit of sensit

D3162 does not provide a procedure 

dioxide interference. Therefore, this 

appropriate for combustion source co

NDIR instrument performance specif

D3162 has much higher maximum al

times (5 minutes) than EPA Method 

seconds). 

EPA Method 23 EN 1948-3 (1996) (European Committee for Provides additional sampling options 

Standardization)--Deterrnination of the Mass acceptable in EPA Method 23. 

Concentration ofPCDD'S/PCDF'S Part 3: 

Identification and Quantification 

-----

9 
SIMILAR EPA 

STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUN

REFERENCE STANDARD 

METHOD 

EPA Method 26A EN 1911-1,2,3 (1998)- Stationary Source Emissions- Part 3 of this standard cannot be con

Manual Method of Determination ofHCl-Part 1: EPA Method 26 or 26A. The sample 

Sampling of Gases Ratified European Text-Part 2: (water) would be expected to capture 

Gaseous Compounds Absorption Ratified European gas, if present, without the ability to 

Text-Part 3: Adsorption Solutions Analysis and the two. The EPA Methods 26 and 2

Calculation Ratified European Text absorbing solution to first separate H

that they can be selectively absorbed

reported separately. In addition in E

the absorption efficiency for chlorine 

expected to vary as the pH of the wa

sampling. 

EPA Method 26A ASTM D6735-01 (2009)- Standard Test Method for This impinger-based standard to mea

Measurement of Gaseous Chlorides and Fluorides acceptable alternative to EPA Metho

from Mineral Calcining Exhaust Sources Impinger from mineral calcining exhaust sourc

Method 

EPA Method 29 EN 13211:2001- Air Quality Stationary Source EN 13211 is not acceptable as an alt

Emissions Determination of the Concentration of Total portion of EPA Method 29 primarily 

Mercury validated for use with impingers, as 

although the method describes proce

impingers. This European standard 

of fritted bubblers only and requires 

stream arrangement for isokinetic sa

low sampling rate of the bubblers (u

maximum). Also, only two bubblers 

required by EN 13211, whereas EPA 

use of six impingers. In addition, EN 

include many of the quality control p

Method 29, especially for the use an

10 
SIMILAR EPA 

STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUN

REFERENCE STANDARD 

METHOD 

temperature sensors and controllers, 

, assembly and disassembly, and filter 

standard is not acceptable as an alter

29 (mercury only), and Method 30B

atomic absorption spectrometry (CV 

procedures only, because of lack of d

EPA Methods 29, 30B CAN/CSA Z223.26-M1987- Measurement of Total EPA Methods 29 (mercury only), 10

Mercury in Air Cold Vapour Atomic Absorption cold vapor atomic absorption spectro

Spectrophotometeric Method analytical procedures only, because 

quality control. Specifically, CAN/C

include specifications for the numbe

to be analyzed, procedures to preven

sample to the next, and procedures f

instrument response to calibration bl

methods. Also, CAN/CSA Z223.26 

the calibration curve be forced throu

a point no further than 2 percent of t

as in the EPA methods. Also, CAN/

include a procedure to assure that tw

heights agree within 3 percent of the

that the peak maximum is greater tha

recorder full scale, as in the EPA me

Z223.26 does not include instruction

standard to be run at least every five 

specifications for the peak height of 

. standard as iri the EPA methods . 

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