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OAR Box 1672 

Prepped by Charmelle Mathews 

Document Number: 

W2S) ll-B-22 

Docket Number: 

A-98-13 

Printed 9/30/2008 11:01:00 AM Sheet 28 of 132 
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

RESEARCH TRIANGLE PARK, NC 27711 

MAR 3 1 2000 

MEMORANDUM 

OFFICE OF 

AIR QUALITY PLANNING 

AND STANDARDS 

SUBJECT: 

FROM: 

Voluntary Consensus Standard Results for the Organic Liquid Distribution 

MACT Proposed Rule 

TO: 

William H. Lamason, Group Leader 

Source Measurement Technology GroHjT(MD-19) 

K.C. Hustvedt, Group Leader 

Waste and Chemical Processes Group (MD-13) 

Per your request, the Emission Measurement Center (EMC) 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 all 

Federal agencies to use VCS in regulatory and procurement activities unless to do so would be 

inconsistent with applicable law or otherwise impracticable. This memorandum documents the 

results ofthe EMC searches and reviews to determine if VCS are available and practical for use 

in lieu of stationary source methods or performance specifications cited in the Organic Liquid 

Distribution MACT Proposed Rule. 

Starting in 1998, the EMC began implementing the requirements ofthe NTTAA by 

conducting searches to identify VCS. 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. 

To enhance our opportunities to identify and use VCS, the EMC has other activities in 

support of NTTAA implementation. The EMC has plans to conduct more thorough, periodic 

efforts to contact VCS organizations to identify potential alternative methods. We are currently 

in the process of completing our periodic search for FY2000, and are expected to have it 

completed by early summer. This process will be repeated in early FY2001. 

Also, the EMC participates in the American Society for Testing and Materials (ASTM) 

which is one ofthe most active VCS organizations on emissions testing. 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 expect 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 work group closure in the EPA rulemaking 

process. 

/ 

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

Recycled/Recyclable • Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 25% Postconsumer) 
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We conducted searches for the Organic Liquid Distribution MACT Proposed Rule 

through the Enhanced NSSN Database managed by the American National Standards Institute 

(ANSI). Searches were conducted for EPA Methods 1, la, 2,3,3a, 3b, 4,18,25,25a, and 27. 

Please note the attached table for the EMC's findings. 

The attached table describes the VCS found, which EPA standard reference method or 

methods the VCS potentially affects, if the VCS is equivalent to the EPA standard reference 

method, and EPA's comments after review ofthe standard. During the search, if the title or 

abstract (if provided) ofthe VCS described technical sampling and analytical procedures that are 

similar to EPA's reference method, we ordered a copy ofthe standard and reviewed it as a 

potential equivalent method. All potential standards were reviewed with a high quality test for 

determining practicality ofthe VCS for this rule. This test 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 and 

performance specifications. The EMC may reconsider determinations of impracticality when 

additional information is available for particular VCS. 

The search identified 19 VCS's that appeared to have possible use in lieu of EPA 

reference methods. However, after reviewing the available standards, EPA determined that 9 of 

the candidate consensus standards (ASTM D3154-91 Reapproved 1995, ASTM E337-84 

Reapproved 1996, ASTM D3464-96, ASTM D3796-90, ASTM 5835-95, ASTM 6060-96, ISO 

10396:1993, ISO 9096:1992, PTC 19-10-1981 or ASME C00031 -Part 10) identified for 

measuring emissions ofthe HAPs or 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. Ten ofthe remaining candidate consensus standards 

(BSR/ASME MFC 13m, ASTM Z6871Z, ASTM Z7773Z, ASTM D6420-99, ISO/FDIS 14965, 

ISO 14164:1999, ISO 10780:1994, ISO/DIS 12039, CAN/CSA Z223.2-M86, EN 12619 ) are 

new standards under development or standards currently under EPA review that EPA plans to 

follow, review and consider adopting at a later date. 

Two voluntary consensus standards, ASTM D2879-83, Standard Test Method for Vapor 

Pressure-Temperature Relationship and initial Decomposition Temperature of Liquids by 

Isoteniscope and API Publication 2517, Evaporative Loss from External Floating-Roof Tanks, 

Third Edition, February 1989 were already incorporated by reference in 63.14 and are also being 

used in this regulation. 

ASTM D6420-99 is currently under EPA review as an approved alternative to Method 

18. The EPA will also compare this final ASTM standard to methods previously approved as 

alternatives to EPA Method 18 with specific applicability limitations. These methods, 

designated as ALT-017 and CTM-028, are available through EPA's Emission Measurement 

Center Internet site at www.epa.gov/ttn/emc/tmethods.html. The final ASTM D6420-99 

standard is very similar to these approved alternative methods, which may be equally suitable for 

specific applications. EPA plans to continue their review ofthe final standard and will consider 

adopting the ASTM standard at a later date. 

X 
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Questions regarding the NTTAA representative and EMC representation in ASTM can be 

directed to John Bosch at (919) 541-5583. Inquiries regarding the searches for the VCS can be 

made to Mike Ciolek (919) 541-4921. Please feel free to contact me at (919) 541-5374 if you 

have any general questions regarding EMC implementation ofthe NTTAA or our support to you. 

Attachment 

cc: John Bosch, EMC (MD-19) 

Mike Ciolek, EMC (MD-19) 

Fred Dimmick, EMAD (MD-14) 

David Mobley, EMAD (MD-14) 

Martha Smith, ESD (MD-13 ) w/attachment 

Frederick J. Thompson, EMC (MD-19) 
RESULTS OF THE EPA'S SEARCH TO IDENTIFY VOLUNTARY CONSENSUS STANDARDS FOR 

THE ORGANIC LIQUID DISTRIBUTION MACT PROPOSED RULE 

* All searches were completed through the Enhanced National Standards Service Network (NSSN) maintained by the American 

National Standards Institute (ANSI). The voluntary consensus standards identified were reviewed to determine if they could be used 

in lieu of EPA's standard reference method. 

Search Completed 3/2000 

-fc 

SIMILAR EPA STANDARD 

REFERENCE METHOD 

EPA Method 2 (possibly 1) 

EPA Method 1,2, 2c 3, 3b, 4 

VOLUNTARY 

CONSENSUS STANDARD 

BSR/ASMEMFC13mFlow Measurement by 

Velocity Traverse 

ASTM D3154-91 

(Reapproved 95) - Standard 

Method for Average Velocity 

in a Duct (Pitot Tube 

Method) 

IS THE 

VOLUNTARY 

CONSENSUS 

STANDARD 

EQUIVALENT TO 

EPA'S METHOD? 

Potential 

No 

EPA'S COMMENTS ON 

VOLUNTARY CONSENSUS 

STANDARD 

Under development when search was 

completed. Possibly similar to EPA 

Method 1 and 2. 

Appears to cover EPA's Part 60 

Methods 1, 2, 2c, 3, 3b, 4, but lacks 

quality requirements. 

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SIMILAR EPA STANDARD 

REFERENCE METHOD 

EPA Method 1,2, 5 

EPA Methods la, 2a, 2d 

VOLUNTARY 

CONSENSUS STANDARD 

ISO 9096:1992-

Determination of 

concentration and mass flow 

rate of particulate matter in 

gas carrying ducts - Manual 

gravimetric method. 

No specific procedures were 

identified regarding 

traversing and sampling for 

flow rates on small ducts or 

pipes 

IS THE 

VOLUNTARY 

CONSENSUS 

STANDARD 

EQUIVALENT TO 

EPA'S METHOD? 

No 

EPA'S COMMENTS ON 

VOLUNTARY CONSENSUS 

STANDARD 

Some portions of this method relate to 

EPA Methods 1 & 2. This method will 

not produce particulate matter 

measurements like EPA Method 5 

(example: there is no temperature 

control on the filter which is exposed 

to ambient levels). There is no EPA 

Method to compare this to. EPA can 

not approve^ this method without 

supporting data. 

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SIMILAR EPA STANDARD 

REFERENCE METHOD 

EPA Method 2 -Velocity - S Type 

Pitot 

EPA Method 2 

EPA Method 2 

VOLUNTARY 

CONSENSUS STANDARD 

ASTM D3464-96 - Standard 

Test Method Average 

Velocity in a Duct Using a 

Thermal Anemometer 

• 

ASTM D3796 -90 

(Reapproved 1994) -Standard 

Practice for Calibration of 

Type S Pitot Tubes 

ASTM (Z6871Z) -Practice 

for Determination of the 

volume flow rate of gas 

streams in ducts (automated) 

IS THE 

VOLUNTARY 

CONSENSUS 

STANDARD 

EQUIVALENT TO 

EPA'S METHOD? 

No 

No 

Potential 

EPA'S COMMENTS ON 

VOLUNTARY CONSENSUS 

STANDARD 

There is no EPA Method to compare 

this to. Applicability specifications are 

not clearly defined (example: range of 

gas composition, T limits). It appears 

to have the correct calibration 

procedures and specifications, but 

without supporting data. Some ofthe 

variability issues were not adequately 

addressed. EPA cannot call this 

equivalent to EPA Method 2 without 

supporting data. 

This is a very good detailed procedure 

for calibrating Type S pitot tubes, but it 

is not a complete method alternative to 

EPA Method 2. 

Under development when search was 

completed 3/00. Possibly similar to 

EPA Method 2. Very similar to ISO 

14164. 
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SIMILAR EPA STANDARD 

REFERENCE METHOD 

EPA Method 2 

Possibly similar to portions of any 

ofthe following EPA Methods: 

2, 2a-2h 

EPA Method 3, 6, 7, 15 

EPA Method 3a, 6c, 7e, ALT 004, 

CTM 022 

II 

VOLUNTARY 

CONSENSUS STANDARD 

ISO 14164:1999- Stationary 

source emissionsDetermination of the volume 

flowrate of gas streams in 

ducts - Automated method. 

ISO 10780:1994^Stationary 

Source 

Emissions-Measurement of 

velocity and volume flowrate 

of gas streams in ducts 

PTC 19-10-1981 or 

ASMEC00031 -Part 10 

Flue and Exhaust Gas 

Analyses 

ISO 10396:1993 - Stationary 

Source Emissions: Sampling 

for the Automated 

Determination of Gas 

Concentrations 

IS THE 

VOLUNTARY 

CONSENSUS 

STANDARD 

EQUIVALENT TO 

EPA'S METHOD? 

Potential 

Potential 

No 

No 

EPA'S COMMENTS ON 

VOLUNTARY CONSENSUS 

STANDARD 

This standard has recently been 

finalized and is currently under EPA 

review as a potential alternative to EPA 

Method 2. 

Copy of standard was unavailable at 

the time of review. Possibly similar to 

portions of any of the following EPA 

methods: 2, 2a-h. EPA will review the 

standard when it is received. 

Too broad to be useful in regulatory 

sense. Covers Methods 3, 6, 7, and 15 

with variants. 

Duplicates Method 3a, 6c, 7e, ALT 

004, CTM 022. Similar to ASTM D 

5835. Lacks in detail and quality 

assurance and quality control 

requirements. 
00 

SIMILAR EPA STANDARD 

REFERENCE METHOD 

EPA Method 3a, 10 

EPA Method 3a, 6c, 7e, ALT 004, 

CTM 022 

EPA Method 3a, 7e, 10 

VOLUNTARY 

CONSENSUS STANDARD 

ISO/DIS 12039 - Stationary 

Source Emissions -

Determination of Carbon 

Monoxide, Carbon Dioxide, 

and Oxygen - Automated 

Methods 

ASTM D5835-95 -Standard 

Practice for Sampling 

Stationary Source Emissions 

for Automated Determination 

of Gas Concentration. 

ASTM Z7773Z -

Determination of Nitrogen 

Oxides, Carbon Monoxide, 

and Oxygen Concentrations 

in Emissions from Natural 

Gas-Fired Reciprocating 

Engines, Combustion 

Turbines, Boilers and Process 

Heaters Using Portable 

Analyzers 

IS THE 

VOLUNTARY 

CONSENSUS 

STANDARD 

EQUIVALENT TO 

EPA'S METHOD? 

Potential 

No 

Potential 

EPA'S COMMENTS ON 

VOLUNTARY CONSENSUS 

STANDARD 

Under development when search was 

completed (3/00). Possibly similar to 

EPA Methods 3a & 10. 

Similar to Methods 3a, 6c, 7e, ALT 

004, CTM 022. Lacks in detail and 

quality assurance and quality control 

requirements. Very similar to ISO 

10396. 

Under development when search was 

completed (3/00). Possibly similar to 

EPA Methods 3a, 7e and 10. 

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SIMILAR EPA STANDARD 

REFERENCE METHOD 

EPA Method 3a, 6c, 7e, 10 

EPA Method 4 

EPA Method 18 

VOLUNTARY 

CONSENSUS STANDARD 

CAN/CSA Z223.2-M86 -

Method for the Continuous 

Measurement of Oxygen, 

Carbon Dioxide, Carbon 

Monoxide, Sulphur Dioxide, 

and Oxides of Nitrogen in 

Enclosed Combustion Flue 

Gas Streams 

ASTM E337-84 (Reapproved 

1996) -Standard Test Method 

for Measuring Humidity with 

a Psychrometer (the 

Measurement of Wet-and 

Dry-Bulb Temperatures) 

ASTM D6420-99 - Test 

Method for Determination of 

Gaseous Organic Compounds 

by Direct Interface Gas 

Chromatography/Mass 

Spectrometry 

IS THE 

VOLUNTARY 

CONSENSUS 

STANDARD 

EQUIVALENT TO 

EPA'S METHOD? 

Potential 

No 

Potential 

EPA'S COMMENTS ON 

VOLUNTARY CONSENSUS 

STANDARD 

Copy ofthe standard was unavailable 

at the time of review. EPA will review 

the standard when it is received. 

Possibly similar to EPA Methods 3a, 

6c, 7e, and 10. 

This will only cover a small portion of 

what is acceptable for EPA Method 4. 

This ASTM procedure was finalized 

and adopted by ASTM and is currently 

under EPA review as an approved 

alternative to EPA Method 18. Also 

similar to EPA's Alternative Method 

17 (ALT-17) and Conditional Test 

Method (CTM 28). | 

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SIMILAR EPA STANDARD 

REFERENCE METHOD 

EPA Method 18 

EPA Method 25, 25a 

EPA Method 25A 

VOLUNTARY 

CONSENSUS STANDARD 

ASTMD6060-96 -Practice 

for Sampling of Process 

Vents with a Portable Gas 

Chromatography 

ISO/FDIS 14965 - Air 

Quality - Determination of 

Total Nonmethane Organic 

Compounds ~ Cryogenic 

Preconcentration and Direct 

Flame Ionization Method 

EN 12619-Stationary 

Source Emissions -

Determination ofthe Mass 

Concentration of Total 

Gaseous Organic Carbon at 

Low Concentrations in Flue 

Gases - Continuous Flame 

Ionization Detector Method | 

IS THE 

VOLUNTARY 

CONSENSUS 

STANDARD 

EQUIVALENT TO 

EPA'S METHOD? 

No 

Potential 

Potential 

EPA'S COMMENTS ON 

VOLUNTARY CONSENSUS 

STANDARD 

This method lacks key quality control 

and assurance that is required for EPA 

Method 18 - example: lacks acceptance 

criteria for calibration, details on using 

other collection media (e.g. solid 

sorbents), and reporting/documentation 

requirements. 

Under development when search was 

completed 3/00. Possible improvement 

of EPA Method 25a, but will not cover 

all aspects of EPA Method 25. EPA 

will review the standard when it is 

final. 

This standard was recently finalized 

and is currently under EPA review as a 

potential alternative to EPA Method 

25A. 
SIMILAR EPA STANDARD 

REFERENCE METHOD 

EPA Method 27 - Determination 

of Vapor Tightness of Gasoline 

Delivery Tank Using Pressure 

Vacuum Test 

VOLUNTARY 

CONSENSUS STANDARD 

No applicable standards 

found at this time. 

IS THE 

VOLUNTARY 

CONSENSUS 

STANDARD 

EQUIVALENT TO 

EPA'S METHOD? 

EPA'S COMMENTS ON 

VOLUNTARY CONSENSUS 

STANDARD 

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