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 Standard Results for 40 CFR Part 63, Subpart JJJJJ National 

Emission Standards for Hazardous Air Pollutants for Brick and Structural Clay Products 

Manufacturing , , 

Jodi Howard, Acting Group Leader f{p\JJ,(~) MeasLtrement Technology Group (E ·-02) 

Keith Barnett, Group Leader 

Minerals and Manufacturing Group (D243-02) 

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 ofvoluntary consensus standards (VCS). The 

NTT AA 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 Results for 40 CFR Part 63, Subpart JJJJJ National Emission Standards for 

Hazardous Air Pollutants for Brick and Structural Clay Products Manufacturing. 

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 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) ofVCS 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. 

We conducted searches for the 40 CFR Part 63, Subpart JJJJJ National Emission Standards for Hazardous 

Air Pollutants for Brick and Structural Clay Products Manufacturing through the Enhanced NSSN 

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

organizations, and accessed and searched their databases. 

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

Recycled/Recyclable • Printed w~h Vegetable Oil Based Inks on Recycled Paper (Minimum 25% Postconsumer) 
2 

Searches were conducted for EPA Methods I, IA, 2, 2A, 2C, 2D, 2F, 2G, 3, 3A, 3B, 4, S, 22, 26, 26A, 

29, and 320 of 40 CFR Part 60, Appendix A. No applicable voluntary consensus st~ndards were identified 

for EPA Methods 1A, 2A, 2Q, 2F, 2G, and 22. 

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

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

and Exhaust Gas Analyses is acceptable as an alternative to Method 3A and 3B for the manual procedures 

only and not the instrumental procedures. The voluntary consensus standard ASTM D673S-01 -Standard 

Test Method for Measurement of Gaseous Chlorides and Fluorides from Mineral Calcining Exhaust 

Sources Impinger Method is acceptable as an alternative to Methods 26 and 26A. 

The voluntary consensus stand~rd ASTM D6784-02 - Standard Test Method 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 of Gaseous Compounds by 

Extractive Direct Interface Fourier Transform (FTIR) Spectroscopy is acceptable as an alternative to 

Method 320 with the following conditions: (1) The test plan preparation and implementation in the 

Annexes to ASTM D 6348-03, Sections A 1 through A8 are mandatory; and (2) In ASTM D6348-03 

Annex AS (Analyte Spiking Technique), the percent(%) R must be determined for each target analyte 

(Equation AS .S). In order for the test data to be acceptable for a compound, %R must be 70 % 2: R :S 

130%. If the %R value does not meet this criterion for a target compound, the test data is not acceptable 

for that compound and the test must be repeated for that analyte (i.e., the sampling and/or·analytical 

procedure should be adjusted before a retest). The %R value for each compound must be reported in the 

test report, and all field measurements must be corrected with the calculated %R value for that compound 

by using the following equation: Reported Result = (Measured Concentration in the Stack x 100) I% R. 

During the search, ifthe 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 19 other VCS that were potentially applicable for this rule in lieu of EPA reference 

methods. After reviewing the available standards, EPA determined that 19 candidate VCS (ASTM 

D31S4-00 (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 

DS83S-9S (20 13), ASTM D6S22-11, CAN/CSA Z223 .2-M86 (1999), ISO 9096:1992 (2003), 

ANSIIASME PTC-38-1980 (198S), ASTM D368S/D368SM-13, CAN/CSA Z223.1-M1977, EN 1911-

1,2,3 (1998), ASTM D43S8-94 (1999), 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 19 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) S41-4607 with any further questions in this matter. 
Attachments 

cc: Michael Toney, EPA/AQAD (El43-02) 

Rima Howell, EPA/AQAD (El43-02) 

JeffTelander, EPA/SPPD (D243-02) 

3 
Attachment 1. List of Voluntary Consensus Standards Not Applicable for 40 CFR, Part 63 Subpart JJJJJ National 

for Hazardous Air Pollutants for Brick and Structural Clay Products Manufacturing 

SIMILAR EPA 

STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLU

REFERENCE STANDAR

METHOD 

EPA Methods I, 2, 2C, ASTM D3I54-00 (2006) - Standard Method for This method is impractical as an al

3, 3B, 4 Average Velocity in a Duct (Pitot Tube Method) Methods I, 2, 3, and 3B for the pur

the standard appears to lack in qual

assurance requirements. Specifical

not include the following: (1) proo

standard pitot tube have not plugge

differential pressure gauges other t

(e.g., magnehelic gauges) are used, 

checked after each test series; and (

validity range for calibration of the 

EPAMethod2 ASTM D3464-96 (2007) - Standard Test Method This method is impractical as an al

Average Velocity in a Duct Using a Thermal 2 for the purposes of this rule prim

Anemometer applicability specifications are not 

range of gas composition, temperat

lack of supporting quality assuranc

, procedures and specifications, and 

that are not adequately addressed b

EPA's ability to make a definitive 

method in these areas. 

EPA Method 2 ISO 10780: 1994 - Stationary Source Emissions - This method is impractical as an al

Measurement ofVelocity and Volume Flowrate of Gas 2 in this rule. The standard recomm

Streams in Ducts shaped pitot, which historically has 

--

--

1 
SIMILAR EPA 

STANDARD VOLUNTARYCONSENSUSSTANDARD EPA'S COMMENTS ON VOLU

REFERENCE STANDAR

METHOD 

by EPA. The EPA specifies the S-

large openings that are less likely t

EPAMethod2 ASTM D3796-90 (2004)- Standard Practice for This ASTM standard is intended to 

Calibration of Type S Pitot Tubes procedure for the S-type pitot tube 

which stack gas velocity and/or vo

measured as in EPA Method 2. In 

procedure does not require an incli

not specifY any additional accuracy 

of other types of differential pressu

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

5 Emissions from Stationary Gas Turbine Engines for this source category that includ

(Revision of ANSI B133.9-1979) of manual and instrumental sampli

performance specifications for inst

standard has many good references

Methods and Performance Specific

FOR ENGINES AND TURBINE

ALL? NOT A METHOD? 

EPA Methods 3A ASTM D5835-95 (2013)- Standard Practice for These standards are impractical alt

Sampling Stationary Source Emissions for Automated Methods 3A, 6C, 7E, and 10 for th

Determination of Gas Concentration because they lack in detail and qua

control requirements. Specifically

not include the following: (1) sensi

acceptable levels of analyzer calibr

acceptable levels of sampling syste

ISO 10396: 1993 (2007) - Stationary Source calibration drift limits, time span, a

Emissions: Sampling for the Automated Determination frequency; (5) a method to test the 

of Gas Concentrations the analyzer; (6) procedures to dete

sampling time per run and minimu

2 
SIMILAR EPA 

STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLU

REFERENCE STANDAR

METHOD 

' and (7) specifications for data reco

resolution (all types) and recording 

analog recorders, only). 

EPA Methods 3A ISO 12039:2001 -Stationary Source Emissions- This standard is not acceptable as a

Determination of Carbon Monoxide, Carbon Dioxide, Methods 3A and 10. This ISO stan

and Oxygen--Automated Methods EPA methods, but is missing some 

of sampling, the hardware required 

does not include a 3-way calibratio

equivalent to block the sample gas 

gases are introduced. In its calibra

12039:2001 only specifies a two-p

EPA methods specify a three-point 

12039:2001 does not specify perfo

calibration error, calibration drift, o

tests as in the EPA methods, althou

quality control features are require

EPA Methods 3A ANSIIASME PTC 19-10-1981-Part 10- Flue and This method is not acceptable as a 

Exhaust Gas Analyses Methods 3A, 6C, 7A, 7E, 10, 15, a

includes manual and instrumental m

carbon monoxide, nitrogen oxides, 

dioxide. The instrument methods a

descriptions of procedures and are 

Therefore, while some of the manu

acceptable alternatives to EPA met

procedures are not. 

3 
SIMILAR EPA 

STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLU

REFERENCE STANDAR

METHOD 

EPA Method 3A ASTM D6522-11- Standard Test Method for the ASTM D6522-11 has been determ

Determination ofNitrogen Oxides, Carbon Monoxide, appropriate for identifYing nitrogen 

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

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 

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

Carbon Monoxide, Sulphur Dioxide, and Oxides of oxygen parts of20 only), since it d

Nitrogen in Enclosed Combustion Flue Gas Streams quantitative specifications for mea

performance, most notably the cali

instrument performance characteri

performance characteristics that are 

nonmandatory and also do not prov

quality assurance as the EPA meth

zero and span/calibration drift is on

whereas the EPA methods requires 

run. 

EPA Method 5 ANSIIASME PTC-38-1980 (1985)- Determination of This standard is not specific about 

the Concentration of Particulate Matter in Gas Streams and instead presents the options av

cons of each option. The key speci

ANSI/ ASME PTC-3 8 and the EPA 

ASME standard: (1) allows in-stac

compared to the out-of-stack filter 

Method 5; (2) allows many differen

pitots, and filtering equipment; (3) 

-- weighing_protocol or_ a minimum a

4 
SIMILAR EPA . 

STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLU

REFERENCE STANDAR

METHOD 

fluctuation as in the EPA methods; 

paper to be only 99 percent efficien

99.95 percent efficiency required b

EPA Method 5 ASTM D3685/D3685M-98-13- Test Methods for This method is similar to EPA Met

Sampling and Determination of Particulate Matter in the following areas that are needed 

Stack Gases representative particulate data: (1) 

filter holder temperature should be 

134°C, and not just "above the acid 

specifications for measuring and m

holder temperature during samplin

to EPA Methods 1, 2, 3, and 4, tha

Method 5; (4) technical guidance f

Method 5 sampling procedures, e.g

monitoring sampling train operatin

of reagent blanks for determining a

background contamination; and ( 5) 

and/or operational requirements, e.

leak checks, use of glass cyclones.f

loading and/or water droplets, oper

stack pressure, exchanging particul

sampling preparation and impleme

recovery guidance, data reduction g

sample calculations input. 

EPA Method 5 ISO 9096:1992 (2003)- Determination of This method is not acceptable as an 

Concentration and Mass Flow Rate of Particulate Method 5. Although sections ofiS

Matter in Gas Carrying Ducts-Manual Gravimetric Method 5 to some degree, this ISO 

Method equivalent to EPA Method 5 for co

matter. The standard ISO 9096 doe

5 
SIMILAR EPA 

STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLU

REFERENCE STANDAR

METHOD 

technical guidance for performing 

procedures specified in Method 5. 

operational details are lacking or n

quality assurance/quality control g

operations required to produce qua

particulate data (e.g., guidance for 

monitoring train operating tempera

check guidelines and procedures, a

and recovery procedures) are not p

as in EPA Method 5. Also, details 

operational requirements, such as t

Method 5, are not included in the I

gas moisture measurements, data r

particulate sample calculations. 

EPA Method 5 CAN/CSA Z223 .1-M1977 -Method for the This standard is not acceptable as a

Determination of Particulate Mass Flows in Enclosed Method 5. Detailed technical proc

Gas Streams control measures that are required 

and 4 are not included in CAN/CS

CAN/CSA Z223 .1 does not includ

filter weighing requirement to repe

hours until a constant weight is ach

Method 5 requires the filter weight 

nearest 0.1 mg, while CAN/CSA Z

the nearest 0.5 mg. Also, CAN/CS

of a standard pitot for velocity mea

of the tube opening is not expected 

whereas, EPA Method 5 requires a

6 
SIMILAR EPA 

STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLU

REFERENCE STANDAR

METHOD 

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

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

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

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

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

Calculation Ratified European Text absorbing solution to first separate 

that they can be selectively absorb

reported separately. In addition in 

the absorption efficiency for chlori

expected to vary as the pH of the w

sampling. 

EPA Method 29 ASTM D4358-94 (1999)- Standard Test Method for The EPA Method 29 requires the u

Lead and Chromium in Air Particulate Filter Samples (HF) in its process of digestion of t

of Lead Chromate Type Pigment Dusts by Atomic D4358-94 (1999) does not require 

Absorption Spectroscopy be used in the preparation, digestio

Method 29 samples. Additionally, 

use of a glass fiber filter, whereas t

standard requires cellulose filters a

glass fiber media, and this further n

Method 29 equivalent methods. 

7 
SIMILAR EPA 

STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLU

REFERENCE STANDAR

METHOD 

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

f:Jfi~~qro fmi 

ffi.~cury 

Emissions-Determination ofthe Concentration of Total portion of EPA Method 29 primari

y ' Mercury validated for use with impingers, a

although the method describes pro

impingers. This European standar

offritted bubblers only and require

stream arrangement for isokinetic 

low sampling rate of the bubblers (

maximum). Also, only two bubble

required by EN 13211, whereas EP

use of six impingers. In addition, E

include many ofthe quality contro

. Method 29, especially for the use a

temperature .sensors and controller

assembly and disassembly, and filt

EPA Method 29 CAN/CSA Z223.26-Ml987- Measurement of Total EPA Methods 29 (mercury only), 

(portion for mercury Mercury in Air Cold Vapour Atomic Absorption cold vapor atomic absorption spect

only) 101, lOlA Spectrophotometeric Method analytical procedures only, because 

quality control. Specifically, CAN/

include specifications for the numb

to be analyzed, procedures to preve

sample to the next, and procedures 

instrument response to calibration 

methods. Also, CAN/CSA Z223 .2

the calibration curve be forced thro

a point no further than 2 percent of 

as in the EPA methods. Also, CAN

~-- include a procedure to assure that t

8 
SIMILAR EPA 

STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLU

REFERENCE STANDAR

METHOD 

heights agree within 3 percent of t

that the peak maximmn is greater 

recorder full scale, as in the EPA m

Z223 .26 does not include instructi

standard to be run at least every fiv

specifications for the peak height o

standard as in the EPA methods. 

9