# 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 Segall, Acting Group Leader



# ~51.....-... 

# W

**~~** Measurement Technology Group (E143-02) () 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 a nd 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 Sludge Incineration

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 VOLUNTARY CONSENSUS STANDARD 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 performance

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

. (ECR, >00) 

### ONLY USE FOR ENGINES AND TURBINES DO NOT USE AT ALL? NOT A METHOD. Although sections of ISO 9096 incorporate EPA Methods

1, 2, and 5 to some degree, this ISO 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 ofSIMll..AR EPA STANDARD VOLUNTARYCONSENSUSSTANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS REFERENCE STANDARD METHOD 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 ANSIIASME PTC-38-1980 (1985)- Determination of This standard also includes procedures similar to EPA

the Concentration of Particulate Matter in Gas Streams Methods 1 and 2. The difference between this standard and EPA Methods 5 and 17 is, in general, that ASME PTC-38-

80 is not specific about equipment requirements, and instead presents the options available and the pro's and con's of each option. The key specific differences between ASME PTC-38-80 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 Methods 5 and 17; 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. EPAMethod5 ASTM D3685/D3685M-13- Test Methods for This ASTM standard is similar to EPA Methods 5 and 17, Sampling and Determination of Particulate Matter in but is lacking in the following areas that are needed to

Stack Gases produce quality, representative particulate data:

1) requirement that the filter holder temperature should be between 120°C and 134°C, and not just above the aciddewpoint; 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 and 17; 4) technical

2SIMILAR EPA STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS REFERENCE STANDARD METHOD guidance for performing the Method 5 and 17 sampling procedures, e.g., maintaining and monitoring sampling train operating temperatures, specific leak check guidelines and procedures (delete n 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 lor 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.

I

EPA

Methods 5 CAN/CSA Z223.1-M1977- Method for the Detailed technical procedures and quality control measures I Determination of Particulate Mass Flows in Enclosed that are required in EPA Methods 1, 2, 3, and 4 are not I

Gas Streams included in CAN/CSA Z223.1. Secondly, CAN/CSA Z223.1 does not include in its filter weighing procedures

the EPA Method 5 requirement to repeat weighing every I

six

hours until a constant weight is achieved. Third, EPA 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

pi tot.

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

6C , 7E,10

, 10B Exhaust Gas Analyses analyses for carbon dioxide (C0

2 ), carbon monoxide (CO),

- 3

### SIMILAR EPA STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS REFERENCE STANDARD METHOD hydrogen sulfide (H

2 

### S), nitrogen oxides (NOx), oxygen (Oz),

and sulfur dioxide (S0

2 ). 

### The VCS method analytes
that include one or more of the same techniques as the EPA methods are as follows: C0

2 

### [manual (3B, 6A and 6B) and instrumental (3A and 3C)]; CO [manual (3B) and instrumental (10 and lOB)], H

2 

### S [manual (15A and 16A)
and instrumental (15, 16, and 16B)], NOx [manual (7 and
7C) and instrumental (7A, 7B, 7E, 20)], 0

2 

### [manual (3B)
and instrumental (3A, 3C, 20)], and S0

2 

### [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, 15A, 16A, 20 (S0

2 

### part of

20 only)). [Note that one of the standard's manual S0

2 

### 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, 7A, 7B, 7E, 10, lOB, 15, 16, 16B, 20 (NOx part of

20 only)) are not acceptable alternatives to the corresponding EPA methods

.

EPA

Methods 5 ISO 10396:1993 (2007)- Stationary Source This standard is similar to EPA Methods 3A, 6C, 7E, 10, 20 Emissions: Sampling for the Automated Determination (nitrogen oxides and oxygen parts of 20 only), ALT 004,

of Gas Concentrations CTM 022, but lacks in detail and quality assurance/quality control requirements. Specifically, ISO 10396 does not
ASTM D5835-95 (2013)

- Standard Practice for include the following: 1) sensitivity of the method; Sampling Stationary Source Emissions for Automated 2) acceptable levels of analyzer calibration error; Determination of Gas Concentration 3) acceptable levels of sampling system bias; 4) zero drift
and calibration drift limits, time span, and required testing



### 4SIMILAR EPA STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS REFERENCE STANDARD METHOD 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 D5835.

EPA Methods 10 ASTM D6522-11

- 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

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 

### (previously ASTM Z7773Z EPA Method 10 ISO 12039:2001

- Stationary Source Emissions This method is similar to EPA Methods 3A, 10, and 20 Determination of Carbon Monoxide, Carbon Dioxide, (oxygen portion of 20 only). However, ISO 12039 is

and Oxygen Automated Methods missing some key features. 

### In terms of sampling, the hardware required by ISO 12039 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 only specifies atwopoint calibration while the EPA methods specify a 3-point calibration. Also, ISO 12039 does not specify performance criteria for calibration error, calibration drift, or sampling system bias 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 C0

2 when

CO is being tested, as in EPA Method 10.

-- - 

### 5SIMILAREPASTANDARDVOLUNTARYCONSENSUSSTANDARDEPA'SCOMMENTSONVOLUNTARYCONSENSUSREFERENCESTANDARDMETHODEPAMethod6C,7E,10CAN/CSAZ223.2-M86(1999)-MethodfortheThisstandardisunacceptableasasubstituteforEPAContinuousMeasurementofOxygen,CarbonDioxide,Methods3A,6C,7E,10,lOA,and20(nitrogenoxidesandCarbonMonoxide,SulphurDioxide,andOxidesofoxygenpartsof20only),sinceitdoesnotincludeNitrogeninEnclosedCombustionFlueGasStreamsquantitativespecificationsformeasurementsystemperformance,mostnotablythecalibrationproceduresandinstrumentperformancecharacteristics.TheinstrumentperformancecharacteristicsthatareprovidedarenonmandatoryandalsodonotprovidethesamelevelofqualityassuranceastheEPAmethods.Forexample,thezeroandspan/calibrationdriftisonlycheckedweekly,whereastheEPAmethodsrequiresdriftchecksaftereachrun.EPAMethod6ISO7934:1998-StationarySourceEmissionsThisstandardisonlyapplicabletosourceswith30mg/m3DeterminationoftheMassConcentrationofSulfurS02ormore.Also,thisstandarddoesnotseparateS03DioxideHydrogenPeroxide/BariumfromS02asdoestheEPAmethods;therefore,ISOPerchlorate/ThorinMethod7934:1998isnotvalidifmorethananegligibleamountofS03is-present.Also,itdoesnotaddressammoniainterferences.6SIMILAR EPA STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS REFERENCE STANDARD METHOD EPAMethod6 ISO 11632:1998- Stationary Source Emissions Sampling procedures are similar to EPA Method 6, but Determination of the Mass Concentration of Sulfur lacks in detail and quality control procedures, such as
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 Method 7, however Nitrogen in Gaseous Combustion Products (Pheno- there are some key differences. ASTM D1608 variations Disulfonic Acid Procedures) are as follows (corresponding EPA Method 7 procedures

are in parentheses and italics): 405 nm absorbance (410 nm

or

optimized); 3 mL of 3% hydrogen peroxide in the absorbing solution (6 mL 3% hydrogen peroxide); no shaking of reaction flask to mix before or after sitting (shake for at least 5 minutes before and 2 minutes after sitting); overnight sample sitting step (at least 16 hours sitting); no wavelength calibration of spectrophotometer (calibration every 6 months); prepare calibration curve at minimum every few days (prepare calibration curve each
day that samples are analyzed); add NaOH to sample uptil
just basic without any quantitative measurement of basicity (add NH

4 0H until pH= 10 as determined by pH paper).

EPA Method 7 ISO 11564: 1998

- Stationary Source Emissions

- This ISO standard lacks many quality assurance/quality Determination of the Mass Concentration of Nitrogen control items

, such as: use of recognized analytical grade
Oxides- NEDA (naphthylethylenediamine)/ reagents, vs. EPA Method 7 which specifies ACS analytical Photometric Method grade reagents; no specific leak checking procedures are in
ISO 11564; and no quality control procedures for spectrophotometer, spike sample analysis, or audit sample analysis are in ISO 11564. ISO 11564 also uses an alkaline hydrogen peroxide absorbent whereas EPA Method 7C

7I


### SIMILAR EPA STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS REFERENCE STANDARD :METHOD uses alkaline permanganate

. ISO 11564 has two methods

of introducing the absorbing solution into the sample flask after the gas is sampled, whereas EPA Method 7 

### introduces I



### the absorbing solution into the flask prior to sampling the I


### gas.

EPA Method 7 

### CAN/CSA Z223.24-M1983 -Method for the This standard does not cover the range of the EPA method Measurement of Nitric Oxide and Nitrogen Dioxide in or this regulation. CAN/CSA Z223.24 only applies up to

Air 20 mg/m 3 , 

### whereas the EPA Method 7 

### range is 400 mg/m 3 . 

### Also, there are no specific quality assurance/quality control requirements for the spectrophotometer in CAN/CSA 2223.24. Performance specifications for the spectrophotometer are not required but are listed for consideration only and are said to be dependent upon the application of the method. Spectrophotometer wavelength calibration procedures are not included in CAN/CSA Z223.24 and the frequency of other calibration procedures

is said to be a function of the instrument quality and required accuracy of measurement vs. the requiredsixmonth calibration period of EPA Method 7.



### EPA Method 10, lOA CAN/CSA Z223.21-M1978- Method for the This standard is not acceptable as an alternative to EPA Measurement of Carbon Monoxide: 3 Method of Methods 10 and lOA because it is lacking in the following

- 

### 8

### SIMILAR EPA STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS REFERENCE STANDARD METHOD Analysis by Non-Dispersive Infrared Spectrometry areas: 1) sampling procedures; 2) procedures to correct for

the carbon dioxide concentration; 3) instructions to correct

the gas volume if C0

2 

### 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.

EPA Method 10 ASTM D3162-94 (2005)- Standard Test Method for This ASTM standard, which is stated to be applicable in the
Carbon Monoxide in the Atmosphere (Continuous range of 0.5

- 100 ppm CO, does not cover the range of Measurement by Nondispersive Infrared EPA Method 10 (20

- 1000 ppm CO) at the upper end but Spectrometry) 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 of NDIR 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 23 EN 1948-3 (1996) (European Committee for Provides additional sampling options other than what is Standardization)--Deterrnination of the Mass acceptable in EPA Method 23. Concentration ofPCDD'S/PCDF'S Part 3: Identification and Quantification -----



### 9SIMILAR EPA

I STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS REFERENCE STANDARD METHOD EPA Method 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 26A ASTM D6735-01 (2009)- Standard Test Method for This impinger-based standard to measure HCl is an Measurement

of Gaseous Chlorides and Fluorides acceptable alternative to EPA Methods 26, 26A, and 321

from Mineral Calcining Exhaust Sources Impinger from mineral calcining exhaust sources. Method EPA Method 29 EN 13211:2001- Air Quality Stationary Source EN 13211 is not acceptable as an alternative to the mercury Emissions

Determination of the Concentration of Total portion of EPA Method 29 primarily because it is not 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

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

10SIMILAR EPA STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS REFERENCE STANDARD METHOD temperature sensors and controllers, sampling train

, assembly and disassembly, and filter weighing. This standard is not acceptable as an alternative to EPA Methods

29 (mercury only), and Method 30B, for the cold vapor atomic

absorption spectrometry (CV AAS) analytical procedures only, because of lack of detail in quality control.

EPA Methods 29, 30B CAN/CSA Z223.26-M1987- Measurement of Total EPA Methods 29 (mercury only), 101, and lOlA, for the Mercury in Air Cold Vapour Atomic Absorption cold vapor atomic absorption spectrometry (CVAAS) 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 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 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 iri the EPA methods

.

- 

### 11