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 of Performance for Phosphate Processing 

Jason Dewees, Acting Group Leader 

Measurement Technology Group (E143-02) 

Keith Barnett, Group Leader 

Minerals and Manufacturing Group (D243-6 

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 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 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 Phosphoric Acid Manufacturing and Phosphate Fertilizer Production RTR 

Standards of Performance for Phosphate Processing. 

In 1998, OAQPS began implementing the requirements ofthe 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 Phosphoric Acid Manufacturing and Phosphate Fertilizer Production RTR 

Standards of Performance for Phosphate Processing through the Enhanced NSSN Database managed by 

the American National Standards Institute (ANSI). We also contacted VCS organizations and accessed 

and searched their databases. Searches were conducted for EPA Methods 5, 13A, 13B, 30B, and 320 of 

40 CFR Part 60, Appendix A. 

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

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

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. 

One voluntary consensus standard was identified as an acceptable alternative to EPA test methods for the 

purposes ofthis rule. The voluntary consensus standard ASTM D6348-03(2010), "Determination of 

Gaseous Compounds by Extractive Direct Interface Fourier Transform (FTIR) Spectroscopy" is an 

acceptable alternative to Method 320. 

The search identified 8 VCS that were potentially applicable for this rule in lieu of EPA reference 

methods. After reviewing the available standards, EPA determined that 8 candidate VCS (ASME B133.9-

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), ASTM D3266-91 (2011), CAN/CSA 

Z223 .26-M 1987) 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 8 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 Group's efforts in this rulemaking. 

Please contact me at (919) 541- 9724 with any further questions in this matter. 

Attachments 

cc: Tina Ndoh, 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 

Production RTR Standards of Performance for Phosphate Processing 

SIMILAR EPA 

STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLU

REFERENCE STANDA

METHOD 

EPA Method 5 ASME B133.9-1994 (2001)- Measurement of Exhaust Not a quantitative method, per se, a

Emissions from Stationary Gas Turbine Engines this source category that includes te

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

performance specifications for inst

standard has many good references

Methods and Performance Specific

ENGINES AND TURBINES DO 

NOT A METHOD? 

EPA Method 5 ISO 9096:1992 (2003)- Determination of Although sections of ISO 9096 inc

Concentration and Mass Flow Rate of Particulate and 5 to some degree, this ISO stan

Matter in Gas Carrying Ducts Manual Gravimetric EPA Method 5 for collection of par

Method standard ISO 9096 does not provid

guidance for performing many of th

specified in Methods 1, 2, and 5. M

operational details are lacking or no

quality assurance/quality control gu

operations required to produce qual

particulate data (e.g., guidance for m

train operating temperatures, specif

and procedures, and sample prepara

procedures) are not provided by the 

Method 5. Also, details of equipme

requirements, such as those specifie

not included in the ISO standard, e.

measurements, data reduction guida

sample calculations. 
SIMILAR EPA 

STANDARD - EPA'S COMMENTS ON VOL

REFERENCE VOLUNTARY CONSENSUS STANDARD STANDA

METHOD 

EPA Method 5 ANSIIASME PTC-38-1980 (1985)- Determination of This standard also includes proce

· the Concentration of Particulate Matter in Gas Streams Methods 1 and 2. The difference 

EPA Methods 5 and 17 is, in gene

is not specific about equipment re

presents the options available and 

option. The key specific differenc

80 and the EPA methods are that 

allows in-stack filter placement as 

stack filter placement in EPA Met

many different types of nozzles, p

equipment; 3) does not specify a f

minimum allowable filter weight 

methods; and 4) allows filter pape

efficient, as compared to the 99.95 

by the EPA methods. 

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

Sampling and Determination of Particulate Matter in is lacking in the following areas th

Stack Gases quality, representative particulate 

filter holder temperature should b

and notjustabove the acid dew-p

specifications for measuring and m

temperature during sampling; 3) p

Methods 1, 2, 3, and 4, that are re

17; 4) technical guidance for perfo

sampling procedures, e.g., mainta

sampling train operating temperat

. guidelines and procedures (_delete

2 
SIMILAR EPA 

STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOL

REFERENCE STANDA

METHOD 

blanks for determining and subtrac

contamination; and 5) detailed equ

requirements, e.g., component exch

glass cyclones for heavy particulat

droplets, operating under a negativ

exchanging particulate loaded filte

implementation guidance, sample r

reduction guidance, and particulate 

EPA Method 5 CAN/CSA Z223.1-M1977- Method for the Detailed technical procedures and 

Determination ofParticulate Mass Flows in Enclosed that are required in EPA Methods 

Gas Streams included in CAN/CSA Z223.1. Se

does not include in its filter weighi

Method 5 requirement to repeat we

a constant weight is achieved. Thir

the weight to be reported to the nea

CAN/CSA Z223.1 requires only w

mg. Lastly, CAN/CSA Z223 .1 allo

pi tot for velocity measurement whe

opening is not expected to be a pro

Method 5 requires an S-shaped pito

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

13B Separation and Collection of Particulate and Gasous since flows are limited to 0.5 cfm a

Fluorides in the Atmosphere (Sodium Bicarbonate not done. Also, this standard is a s

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 f

13B Separation and Collection of Particulate and Acidic since flows are limited to 0.5 cfm a

-

3 
SIMILAR 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 VOLU

STANDA

not done. Also, this standard is a s

This standard is not acceptable as a

Methods 29 (mercury only), 101, a

atomic absorption spectrometry (C

procedures only, because of lack o

Specifically, CAN/CSA Z223.26 d

specifications for the number of ca

analyzed, procedures to prevent car

the next, and procedures for subtrac

response to calibration blank as in t

CAN/CSA Z223 .26 does not requir

be forced through or close to zero (

percent of the recorder full scale) a

Also, CAN/CSA Z223 .26 does not 

assure that two consecutive peak he

3 percent of their average value and 

greater than 10 percent of the recor

methods. CAN/CSA Z223.26 does 

a blank and a standard to be run at 

and specifications for the peak heig

standard as in the EPA methods.