1

MEMORANDUM

SUBJECT: Voluntary Consensus Standard Results for Subpart I – Electronics Manufacturing, 

of the Greenhouse Gas Reporting Rule

FROM: Alexis McKittrick, EPA/OAR/CCD

TO: EPA Docket No. EPA-HQ-OAR-2011-0028

DATE: August 27, 2012

The EPA conducted searches and reviews of methods to address the National Technology Transfer and 

Advancement Act (NTTAA) 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 impractical. This memorandum documents the results of the 

VCS searches and reviews to determine if VCS are available and practical for use in lieu of stationary 

source methods cited in the Proposed Amendments and Confidentiality Determinations for Subpart I –

Electronics Manufacturing, of the Greenhouse Gas Reporting Rule. The EPA is proposing to include a 

stack testing option that would involve using the following EPA reference methods: 

• Method 1 or 1A at 40 CFR part 60, appendix A-1, to select sampling port locations and the 

number of traverse points in the exhaust stacks. 

• Method 2, 2A, 2C, 2D, 2F, or 2G at 40 CFR part 60, appendix A-1 and A-2, to determine gas 

velocity and volumetric flow rate in the exhaust stacks.

• Method 3, 3A, or 3B at 40 CFR part 60, appendix A-2, to determine the gas molecular weight 

of the exhaust using the same sampling site and at the same time as the fluorinated 

greenhouse gas (F-GHG) sampling is performed.

• Method 4 at 40 CFR part 60, appendix A-3, to measure gas moisture content in the exhaust 

stacks.

• Method 301 at 40 CFR part 63, appendix A, to perform field validations of alternative 

methods of measuring F-GHG emissions and abatement system destruction or removal 

efficiency (DRE).

• Method 320 at 40 CFR part 63, appendix A, to measure the concentration of F-GHG in the 

stack exhaust.

In 1998, the EPA 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 
2

reasonable effort to identify and evaluate potentially practical VCS, our findings do not necessarily 

represent all potential alternative standards which may exist.

The EPA 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 the Proposed Amendments for Subpart I – Electronics Manufacturing, of the 

Greenhouse Gas Reporting Rule through the Enhanced NSSN Database managed by the American 

National Standards Institute (ANSI). We also contacted VCS organizations, including the International 

SEMATECH Manufacturing Initiative (ISMI), and accessed and searched their databases.

Searches were conducted for EPA Methods 1, 1A, 2, 2A, 2C, 2D, 2F, 2G, 3, 3A, 3B, and 4 of 40 CFR 

part 60, Appendix A, and EPA Methods 301 and 320 of 40 CFR part 63, Appendix A. No applicable VCS

were identified for EPA Methods 1A, 2A, 2D, 2F, 2G, or 3A. 

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 referenced method, the EPA considered it as a potential 

equivalent method. All potential standards were reviewed to determine the practicality of the VCS for the 

proposed rule. The review required significant method validation data which meet the requirements of 

EPA Method 301 for accepting alternative methods, or a scientific, engineering, and policy evaluation to 

determine if it is equivalent to procedures in EPA reference methods. The EPA may reconsider

determinations of impracticality if additional information becomes available for a particular VCS.

The search identified 12 VCS that were potentially applicable for use in the proposed rule in lieu of EPA 

reference methods. After reviewing the available standards, EPA determined that the 12 potential VSC 

identified for measuring emissions of pollutants subject to Subpart I would not be practical due to lack of 

equivalency, documentation, validation data, and other important technical and policy considerations. 

These 12 methods are listed in Table 1 of this memorandum, along with EPA review comments.

The EPA also examined the ISMI 2009 Guideline for Environmental Characterization of Semiconductor 

Process Equipment – Revision 2, as a replacement for the ISMI 2006 Guideline that is referenced in the 
3

EPA protocol for determining abatement system DRE1(the DRE protocol is incorporated by reference for 

use in subpart I). The EPA did not propose using of the entire ISMI 2009 Guideline as an alternative to 

the ISMI 2006 Guideline because only portions of the ISMI 2006 and 2009 Guidelines are relevant to 

determining abatement system DRE, and because industry members and the ISMI have identified 

additional changes that will be incorporated into a future version of the ISMI Guideline. However, EPA 

considered portions of the 2009 ISMI Guideline, with modifications, that may be used as an alternative to 

the ISMI 2006 Guideline procedures referenced in the EPA’s DRE Protocol to provide flexibility and 

reduce burden, and has incorporated these adapted portions into the proposed rule. The 2009 ISMI 

Guideline includes a method to measure abatement system flow and to account for dilution that may 

occur between the inlet and out of the abatement system by measuring the change in concentration of a 

non-reactive tracer gas introduced into to the abatement system flow. To ensure thorough mixing of the 

tracer, the 2009 ISMI Guideline requires sources to measure the concentration at least eight duct 

diameters downstream of the injection site. Because of the presence of short ducts in POU abatement 

systems, these specifications would not be appropriate for several sources. Therefore, the EPA is 

proposing that facilities use procedures adapted from Section 8.1 of EPA Method 7E, Determination of 

Nitrogen Oxides Emissions From Stationary Sources (Instrumental Analyzer Procedure), in 40 CFR part 

60, Appendix A-4, to establish that the injected tracer is well mixed in the duct system and is not stratified 

(i.e., poorly mixed). The relevant portions of the ISMI 2009 Guideline and the adaptation of the 

procedures from Section 8.1 of EPA Method 7E are incorporated into proposed Appendix A to subpart I. 

 

1

Protocol for Measuring Destruction or Removal Efficiency (DRE) of Fluorinated Greenhouse Gas Abatement 

Equipment in Electronics Manufacturing, Version 1, EPA–430–R–10–003, March 2010.
4

Table 1. List of Voluntary Consensus Standards Not Applicable to the Proposed Amendments to Subpart I – Electronics Manufacturing, 

of the Greenhouse Gas Reporting Rule

EPA Standard 

Reference 

Method(s)

Similar Voluntary Consensus Standard EPA’s Comments on VCS

EPA Methods 1, 

2, 2C, 3, 3B, 4

ASTM D3154-00 (2006) – Standard Method for Average 

Velocity in a Duct (Pitot Tube Method)

This method is impractical as an alternative to EPA Methods 1, 

2, 3, and 3B for the purposes of the proposed rule because 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 tubes 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 Average 

Velocity in a Duct Using a Thermal Anemometer

The applicability specifications in this ASTM standard 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.

EPA Method 2 ASTM D3796-90 (2004) – Standard Practice for 

Calibration of Type S Pitot Tubes

This ASTM method is intended to be a calibration 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. 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, ASME B133.9-1994 (2004) – Measurement of Exhaust This method is impractical as an alternative to EPA Methods 2, 
5

3A, 4 Emissions from Stationary Gas Turbine Engines (Revision 

of ANSI [American National Standards Institute] B122.9-

1979)

3A, and 4 in the proposed rule. This method applies to engines 

that operate on natural gas and liquid distillate fuels, and is not a 

quantitative method.

EPA Method 3A ASTM D5835-95 (2001) – Standard Practice for Sampling 

Stationary Source Emissions for Automated 

Determination of Gas Concentration

ISO 10396:1993 – Stationary Source Emissions: Sampling 

for the Automated Determination of Gas Concentrations

These standards are impractical alternatives to EPA Method 3A 

for the purposes of the proposed rule 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 

calibration drift limits, time span, and required testing 

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; and (7) 

specifications for data recorders, in terms of resolution and 

recording intervals.

EPA Method 3A ISO 12039:2001 – Stationary Source Emissions –

Determination of Carbon Monoxide, Carbon Dioxide, and 

Oxygen – Automated Methods

This method is not acceptable as an alternative to EPA Method 

3A. This ISO standard is similar to EPA Method 3A 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 EPA Method 3A specifies 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 method, although 

checks of these quality control features are required by the ISO 

standard.

EPA Methods 3A

and 3B

ANSI/ASME PTC 19.10-1981-Part 10 – Flue and Exhaust 

Gas Analyses

This method is not acceptable as a substitute for EPA Method 

3A and 3B for measuring the oxygen, carbon dioxide, and 

carbon monoxide content of the exhaust gas. This ANSI/ASME 
6

standard includes manual and instrumental methods. The 

instrument methods are only general descriptions of procedures 

and are not true methods. Therefore, while some of the manual 

methods in the ANSI/ASME standard are acceptable alternatives 

to EPA methods, the instrumental procedures are not.

EPA Method 3A ASTM D6522-00 (2005) – Standard Test Method for the 

Determination of Nitrogen Oxides, Carbon Monoxide, and 

Oxygen Concentrations in Emissions from Natural GasFired Reciprocating Engines, Combustion Turbines, 

Boilers and Process Heaters Using Portable Analyzers

This method is impractical as an alternative to Method 3A in the

proposed rule. This method applies to engines, turbines, and 

boilers and process heaters that operate on natural gas. 

EPA Method 3A CAN/CSA [Canadian Standards Association] Z223.2-M86 

(1999) – Method for the Continuous Measurement of 

Oxygen, Carbon Dioxide, Carbon Monoxide, Sulphur 

Dioxide, and Oxides of Nitrogen in Enclosed Combustion 

Flue Gas Streams

This standard is impractical as a substitute for EPA Method 3A, 

since it does not include quantitative specifications for 

measurement system performance, most notably the calibration 

procedures and instrument performance characteristics. The 

instrument performance characteristics that are provided are 

non-mandatory 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 301 ASTM D4855-97 (2002) – Standard Practice for 

Comparing Test Methods

This ASTM standard is equivalent to EPA Method 301 in its 

statistical design and decision criteria, but is less prescriptive 

than Method 301 for many procedures, and is not being 

proposed as an alternative to Method 301. For example, the 

ASTM standard does not require the use of a t-test explicitly to 

test the precision of the alternative method, but instead states 

that a t-test or F-test should be used, as appropriate. The primary 

difference between ASTM D4855-97 and EPA Method 301, that 

makes the ASTM standard not acceptable as a complete 

alternative to the EPA method, is that the ASTM method 

addresses the testing of materials rather than environmental 

samples. Because of this difference, the ASTM standard does 

not prescribe the use of paired samples as in the EPA method. 
7

This feature of EPA Method 301 is critical to its success and the 

acceptability of an alternative standard.

EPA Method 320 ASTM D6348–03 (2010), Determination of Gaseous 

Compounds by Extractive Direct Interface Fourier 

Transform (FTIR) Spectroscopy

This test method employs an extractive sampling system to 

direct stationary source exhaust to an FTIR spectrometer for the 

identification and quantification of gaseous compounds that (1) 

have sufficient vapor pressure to be transported to the FTIR 

spectrometer and (2) absorb a sufficient amount of infrared 

radiation to be detected. Because emissions from the electronics 

manufacturing industry contain F-GHG in relatively low 

concentrations, and because all data previously received in 

support of stack testing used EPA Method 320, the EPA would 

need to consider more supporting data before approving ASTM 

D6348 as an alternative to EPA Method 320.