UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

RESEARCH TRIANGLE PARK, NC 27711 

SEP 2 1 2015 

OFFICE OF 

MEMORANDUM 

AIR QUALITY PLANNING 

AND STANDARDS 

SUBJECT: 

FROM: 

TO: 

Voluntary Consensus Standard Results for 40 CFR Part 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) 

Steffan Johnson, Group Leader_-/ J. :~ };u_ ·+ ~tv-- Measurement Technology Gro~3-02) r;r - o- - Keith Barnett, Group Leader 

Minerals and Manufacturing Group (D243-04) 

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 if VCS are available and practical for use in lieu of stationary 

source methods cited in the Results for 40 CFR Part 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). 

In 1998, OAQPS 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 

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 

I ieu 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 40 CFR Part 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. 

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

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

The EPA cites technical standard Method 9 of 40 CFR part 60, appendix A in this rule. One voluntary 

consensus standard was identified as an acceptable alternative to Method 9 for the purpose of this rule. 

The voluntary consensus standard ASTM D7520-09 "Standard Test Method for Determining the Opacity 

of a Plume in the Outdoor Ambient Atmosphere" is acceptable to use but with the following conditions: 

1. During the digital camera opacity technique (DCOT) certification procedure outlined in Section 

9.2 of ASTM D7520-09, you or the DCOT vendor must present the plumes in front of various 

backgrounds of color 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 of ASTM D7520-09. 

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 or the DCOT vendor must have a minimum of four (4) independent technology users apply 

the software to determine the visible opacity of the 300 certification plumes. For each set of 25 

plumes, the user may not exceed 15% opacity of any one reading and the average error must not 

exceed 7.5% opacity. 

This approval does not provide or imply a certification or validation of any vendor's hardware or 

software. The onus to maintain and verify the certification and/or training of the DCOT camera, software 

and operator in accordance with ASTM D7520-09 and this letter is on the facility, DCOT operator, and 

DCOT vendor. 

I hope our research into this matter has been useful and timely to your Groups efforts in this rulemaking. 

Please contact me at (919) 541-4 790 with any further questions in this matter. 

cc: Michael Toney, EPA/AQAD (E143-02) 

Sharon Nizich, EPA/SPPD (D243-04) 

Theresa Lowe, EP A/SPPD (D243-04)