# UNITED STATES ENVIRONMENTAL PROTECTION AGENCY RESEARCH TRIANGLE PARK, NC 27711 

# OCT

**~0** 

# 2014 OFFICE OF AIR QUALITY PLANNING 

# MEMORANDUM AND STANDARDS 

# SUBJECT: FROM: TO: Voluntary Consensus Standard Results for Phosphoric Acid Manufacturing and Phosphate Fertilizer Production RTR Standards ofPerformance for Phosphate Processing Jason Dewees, Acting Group Leader MeasurementTechnology Group (E143-02) Keith Barnett, Group Leader Minerals and Manufacturing Group (D243-6 Atyourrequest, the MeasurementTechnology Group (MTG) ofthe Office ofAir Quality Planning and Standards (OAQPS) conducted searches and reviews to address the National Technology Transfer and AdvancementAct (NTTAA) requirements on the use ofvoluntary consensus standards (VCS). The NTTAA directs EPAto use VCS in regulatory and procurement activities unless doing so wouldbe inconsistentwith 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 Phosphoric Acid Manufacturing and PhosphateFertilizer Production RTR Standards ofPerformance for Phosphate Processing. In 1998, OAQPS began implementingthe requirements oftheNTTAA by conducting searchesto identify VCS. Searches continue to be performed to meetthe requirements oftheNTTAA. 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 MTGparticipates 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 Phosphoric Acid Manufacturing and Phosphate FertilizerProduction RTR Standards ofPerformance for Phosphate Processingthrough the EnhancedNSSNDatabase managed by the American National Standards Institute (ANSI). We also contacted VCS organizations and accessed and searchedtheir databases. Searches were conducted for EPA Methods 5, 13A, 13B, 30B, and 320 of 40 CFRPart 60, AppendixA. Internet Address (URL) • http://www.epa.gov Recycled/Recyclable • Printed

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# Vegetable Oit Based Inks on Recycled Paper (Minimum 25% Poslconsumer)

# 2 During the search, ifthe title 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 equivalentmethod. All potential standards were reviewedto determine the practicality ofthe VCS for this rule. This review requires significant method validation datawhich meets the requirements ofEPAMethod 301 for accepting alternative methods or scientific, engineering and policy equivalenceto procedures in EPAreference methods. The MTG may reconsider determinations ofimpracticality when additional information is available for particular VCS. One voluntary consensus standard was identified as an acceptable alternative to EPAtest methods for the purposes ofthisrule. The voluntary consensus standard ASTMD6348-03(2010), "Determination of Gaseous Compounds by Extractive DirectInterface FourierTransform (FTIR) Spectroscopy" is an acceptable alternative to Method 320. The search identified 8 VCS thatwere potentially applicable for this rule in lieu ofEPA reference methods. Afterreviewingthe available standards, EPA determinedthat 8 candidateVCS (ASMEB133.9- 1994 (2001), ISO 9096:1992 (2003), ANSIIASME PTC-38-1980 (1985), ASTM D3685/D3685M-98 (2013), CAN/CSA Z223 .1-Ml977, ASTM D3268-91 (2011), ASTMD3266-91 (2011), CAN/CSA Z223.26-M 1987) identified for measuring emissions ofpollutants ortheir surrogates subjectto emission standards in the rule would not be practical due to lack ofequivalency, documentation, validation data and other importanttechnical and policy considerations. These 8 methods are listed in Attachment 1, along withthe EPAreview comments. I hope our research into this matterhas been useful and timelyto your Group's efforts in this rulemaking. Please contact me at (919) 541- 9724 with any further questions in this matter. Attachments cc: TinaNdoh, EPA/SPPD (D243-04) Michael Toney, EPA/AQAD (E143-02)Attachment 1. List of Voluntary Consensus Standards Not Applicable for the Phosphoric Acid Manufacturing and Phosphate Fertilizer Production

RTR Standards of Performance for Phosphate Processing SIMILAR EPA STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS REFERENCE STANDARD METHOD EPA Method 5 ASME B133.9-1994 (2001)- Measurement of Exhaust Not a quantitative method, per se, although a good primer for Emissions

from Stationary Gas Turbine Engines this source category that includes technical descriptions of (Revision

of ANSI B133.9-1979) 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 Method 5 ISO 9096:1992 (2003)- Determination of Although sections of ISO 9096 incorporate EPA Methods 1, 2, Concentration

and Mass Flow Rate of Particulate and 5 to some degree, this ISO standard is not equivalent to
Matter

in Gas Carrying Ducts Manual Gravimetric EPA Method 5 for collection of particulate matter. The Method 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 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.

'SIMILAR EPA STANDARD 

# - EPA'S

COMMENTS ON VOLUNTARY CONSENSUS

REFERENCE VOLUNTARY CONSENSUS STANDARD STANDARD METHOD 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- 3 8-

80 and the EPA methods are that the ASME standard: 1) allows in-stack filter placement as compared to theout-ofstack 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.

EPA Method 5 ASTM D3685/D3685M- 98 (2013)- Test Methods for This ASTM standard is similar to EPA Methods 5 and 17, but Sampling

and Determination of Particulate Matter in is lacking in the following areas that are needed to produce

Stack Gases quality, representative particulate data: 1) requirement that the filter holder temperature should be between l20°C and 134°C,
and notjustabove 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 and

17; 4) technical 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? 

### l, and use of reagent



### 2SIMILAR EPA STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS REFERENCE STANDARD METHOD 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 CAN/CSA Z223.1-M1977- Method for the Detailed technical procedures and quality control measures Determination

ofParticulate Mass Flows in Enclosed that are required in EPA Methods 1, 2, 3, and 4 are not

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 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

pi tot 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.

EPA Methods 13A, ASTM D3268-91 (2011)- Standard Test Method for This standard appears to be a test for atmospheric emissions,

13B Separation and Collection of Particulate and Gasous since flows are limited to 0.5 cfm and isokinetic sampling is Fluorides in the Atmosphere (Sodium Bicarbonate not done. Also, this standard is a sampling procedure only.
Coated Glass Tube and Particulate Filter Method EPA Methods 13A, ASTM D3266-91 (2011)- Standard Test Method for This standard appears to be a test for atmospheric emissions,

13B Separation and Collection of Particulate and Acidic since flows are limited to 0.5 cfm and isokinetic sampling is

- 3SIMILAR EPA STANDARD REFERENCE METHOD EPA Method 30B VOLUNTARY CONSENSUS STANDARD Gaseous Fluoride in the Atmosphere (Double Paper Tape Sampler Method) CAN/CSA Z223.26-Ml987- Measurement of Total Mercury in Air Cold Vapour Atomic Absorption Spectrophotometeric Method 4 EPA'S COMMENTS ON VOLUNTARY CONSENSUS STANDARD not done. Also, this standard is a sampling procedure only

. This standard is not acceptable as an alternative to EPA Methods 29 (mercury only)

, 101, and lOlA, for the cold vapor atomic

absorption spectrometry (CV AAS) 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 in the EPA methods.