# 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 CFRPart 63, SubpartJJJJJNational Emission Standards for Hazardous Air Pollutants for Brick and Structural Clay Products Manufacturing , , Jodi Howard, Acting Group Leader



# f{p **\JJ,(~)** MeasLtrementTechnology Group



# (E **·-02)** Keith Barnett, Group Leader Minerals and Manufacturing Group (D243-02) At your request, the MeasurementTechnology Group (MTG) ofthe Office ofAir Quality Planning and Standards (OAQPS) conducted searches and reviews to address theNational Technology Transfer and Advancement Act (NTTAA) requirements onthe use ofvoluntary consensus standards (VCS). The NTT AA directs EPAto 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 ofstationary source methods cited in the Results for 40 CFRPart 63, Subpart JJJJJNational Emission Standards for Hazardous Air Pollutants for Brick and Structural Clay Products Manufacturing. In 1998, OAQPS began implementingthe requirements ofthe NTTAA by conducting searches to identify VCS. Searches continue to be performedto meet the 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 mayexist. 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 to EPA procedures. We anticipate thatthese activities will provide an opportunity for further review, consideration and possible IBRofVCS overlooked in the National Standards ServiceNetwork (NSSN) searches or finalized after Federal agency review in the EPA rulemaking process. We conducted searches for the 40 CFRPart 63, SubpartJJJJJNational Emission Standards for Hazardous Air Pollutants for Brick and Structural Clay Products Manufacturingthrough 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 of40 CFRPart 60, Appendix A. 

# No applicable voluntary consensus

**st~ndards** 

# were identified for EPAMethods 1A, 2A, 2Q, 2F, 2G, and 22. Four voluntary consensus standards were identified as acceptable alternatives to the EPAtest 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 ASTM D673S-01 -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

**stand~rd** 

# ASTM D6784-02 - StandardTestMethod for Elemental, Oxidized, Particle-Bound and Total Mercury Gas Generated from Coal-Fired Stationary Sources (Ontario Hydro Method) is acceptable as analternative to Method 29 (portion for mercury only). The voluntary consensus standard ASTMD6348-03(2010)- Determination ofGaseous Compounds by Extractive DirectInterface Fourier Transform (FTIR) Spectroscopy is acceptable as an alternative to Method 320 with the following conditions: (1) The testplan preparation and implementation in the Annexes to ASTMD 6348-03, Sections A1through A8 are mandatory; and (2)InASTMD6348-03 Annex AS (Analyte SpikingTechnique), the percent(%)R must be determined for eachtarget analyte (EquationAS .S). In order for the test datato be acceptable for a compound, %Rmustbe 70 % 2: R 

# :S 130%. Ifthe %Rvalue does notmeetthis 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%Rvaluefor each compoundmust be reported in the test report, and all field measurements must be corrected withthe calculated %Rvalue for that compound by using the following equation: 

# ReportedResult = 

# (Measured Concentration in the Stackx 100)I%R. Duringthe search, ifthetitle 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 equivalent method. All potential standards were reviewed to determine the practicality ofthe VCS for this rule.This review requires significant method validation data which meets the requirements ofEPA Method 301 for accepting alternative methods or scientific, engineering and policy equivalenceto procedures in EPA reference methods. The MTG may reconsider determinations ofimpracticality when additional information is available for particularVCS. The search identified 19 otherVCS that were potentially applicable for this rule in lieu ofEPAreference methods. Afterreviewing the available standards, EPA determinedthat 19 candidateVCS (ASTM D31S4-00 (2006), ASTMD3464-96 (2007), ASTMD3796-90 (2004), ISO 10780:1994, ASME B133 .9- 1994 (2001), ANSI/ASMEPTC 19-10-1981 Part 10, ISO 10396:1993(2007), ISO 12039:2001, ASTM DS83S-9S (2013), ASTMD6S22-11, CAN/CSA Z223.2-M86 (1999), ISO 9096:1992 (2003), ANSIIASMEPTC-38-1980 (198S), ASTM D368S/D368SM-13, CAN/CSAZ223.1-M1977, EN 1911- 1,2,3 (1998), ASTM D43S8-94 (1999), EN 13211:2001, CAN/CSA Z223.26-M1987) identified for measuring emissions ofpollutants ortheir surrogates subjectto emission standards in the rule would not be practical dueto lack ofequivalency, documentation, validation data and other importanttechnical and policy considerations. These 19 methods are listed in Attachment 1, along withthe EPA review comments. I hope our research into this matter has been useful and timely to your Groups efforts in this rulemaking. Please contactme 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) 

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

for Hazardous Air Pollutants for Brick and Structural Clay Products Manufacturing SIMILAR EPA STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS REFERENCE STANDARD METHOD EPA Methods I, 2, 2C, ASTM D3I54-00 (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 I, 2, 3, and 3B for the purposes of this rule since
the standard appears to lack in quality control and quality assurance requirements. Specifically, ASTM D3I54 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. EPAMethod2

ASTM D3464-96 (2007)

- Standard Test Method This method is impractical as an alternative to EPA Method 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 ofthe method in these areas.

EPA

Method 2 ISO 10780: 1994

- Stationary Source Emissions

- This method is impractical as an alternative to EPA Method Measurement ofVelocity 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

-- -- 1 I I ISIMILAR EPA STANDARD VOLUNTARYCONSENSUSSTANDARD 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. EPAMethod2 ASTM D3796-90 (2004)- Standard Practice for This ASTM standard is intended to be a calibration Calibration of Type S Pitot 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 B133.9-1979) 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;

2' SIMILAR 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 12039:200 I 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 ANSIIASME 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 D6522-11- Standard Test Method for the ASTM D6522-11 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 ANSI/ ASME PTC- 3 8 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 I

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 ofiSO 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-M1977 -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 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 probable non-· glass

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



### 7SIMILAR EPA STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS REFERENCE STANDARD METHOD EPA Methods 29 EN 13211:2001 -Air Quality--Stationary Source EN 13211 is not acceptable as an alternative to the mercury 

### f:Jfi~~qro 

## fmi**ffi.~cury** Emissions-Determination ofthe Concentration of Total portion of EPA Method 29 primarily because it is not
y '

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 ofEPA



# . 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-Ml987- Measurement of Total 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 9r 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

**~--** 

### 8SIMILAR 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 maximmn 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