UNITED STATES ENVIRONMENTAL PROTECTION AGENCY RESEARCH TRIANGLE PARK, NC 27711 

## SEP 212015

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 (Addendum to original memo datedJune 30, 2014) Steffan Johnson, Group Leader_-/ J.



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# o- - Keith Barnett, Group Leader Minerals and Manufacturing Group (D243-04) Atyour request, the MeasurementTechnology Group (MTG) ofthe Office ofAir Quality Planning and Standards (OAQPS) conducted searches and reviews to address theNational 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 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, SubpartJJJJJNational Emission Standards for Hazardous Air Pollutants for Brick and Structural Clay Products Manufacturing (Addendumto original memo dated June 30, 2014). In 1998, OAQPS began implementing the requirements ofthe NTTAA by conducting searches to identify VCS
. Searches continue to be performed to meetthe requirements ofthe NTTAA. While we have made a reasonable effort to identify and evaluate potentially practical VCS, our findings do notnecessarily represent all potential alternative standards which may exist. The MTG participates in the American Society for Testing and Materials (ASTM), which is one ofthe 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 ofall EPA reference methods and performance standards for possible incorporation by reference (IBR) ofVCS in 

### Iieu ofor as alternatives to EPA procedures. We anticipate that these activities will provide an opportunity for further review, consideration and possible IBRofVCS overlooked intheNational Standards Service Network (NSSN) searches orfinalized after Federal agency review in the EPA rulemaking process. We conducted searches for the 40 CFRPart 63, Subpart JJJJJ National Emission Standards for Hazardous Air Pollutants for Brick and Structural Clay Products Manufacturing (Addendum to original memo dated June 30, 2014) through the Enhanced NSSN Database managed by the American National Standards Institute (ANSI). We also contacted VCS organizations, and accessed and searched their databases.

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The EPA cites technical standard Method 9 of40 CFR part 60, appendix A in this rule. One voluntary consensus standard was identified as an acceptable alternative to Method 9 for the purpose ofthis rule. The voluntary consensus standard ASTM D7520-09 "Standard TestMethod for Determiningthe Opacity ofa Plume in the Outdoor Ambient Atmosphere" is acceptable to use butwith the following conditions: 1. During the digital camera opacity technique (DCOT) certification procedure outlined in Section 9.2 ofASTM D7520-09, you or the DCOTvendor mustpresentthe plumes in front ofvarious backgrounds ofcolor and contrast representing conditions anticipated during field use such as blue sky, trees, and mixed backgrounds (clouds and/or a sparse tree stand)
. 2. You must also have standard operating procedures in place including daily or other frequency quality checks to ensure the equipment is within manufacturing specifications as outlined in Section 8.1 ofASTMD7520-09. 3. You must follow the record keeping procedures outlined in §63.10(b)(l) for the DCOT certification, compliance repm1, data sheets, and all raw unaltered JPEGs used for opacity and certification determination. 4. You orthe DCOT vendor must have a minimum offour (4) independent technology users apply the software to determine the visible opacity ofthe 300 certification plumes. For each set of25 plumes, the user may not exceed 15% opacity ofany one reading and the average error must not exceed 7.5% opacity. This approval does not provide or imply a certification orvalidation ofany vendor's hardware or software. The onus to maintain and verify the certification and/or training ofthe DCOT camera, software and operator in accordance with ASTM D7520-09 and this letter is on the facility, DCOT operator, and DCOTvendor. I hope our research into this matter has been useful and timely to your Groups efforts in this rulemaking. Please contactme at (919) 541-4790 with any further questions in this matter.

cc: Michael Toney, EPA/AQAD (E143-02) SharonNizich, EPA/SPPD (D243-04) Theresa Lowe, EPA/SPPD (D243-04)