UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

RESEARCH TRIANGLE PARK, NC 27711 

APR 16 2012 

OFFICE OF 

MEMORANDUM 

AIR QUALITY PlANNING 

AND STANDARDS 

SUBJECT: 

FROM: 

TO: 

Voluntary Consensus Standard Results for Standards of Performance for Crude Oil and 

Natural Gas Production, Transmission and Distribution ( 40 CFR part 60, subpart 0000) 

Conniesue B. Oldham, Group Leader~ [)~ Measurement Technology Group (El43-02) 

David Cozzie, Group Leader 

Fuels and Incineration Group (D243-05) 

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 MIG searches and reviews to determine if VCS are available and practical for use in lieu of stationary 

source methods cited in the Standards of Performance for Crude Oil and Natural Gas Production, 

Transmission and Distribution ( 40 CFR part 60, subpart 0000). 

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 MIG 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 Standards of Performance for Crude Oil and Natural Gas Production, 

Transmission and Distribution ( 40 CFR part 60, subpart 0000) 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 

Searches were conducted for EPA Methods 1, 1A, 2, 2A, 2C, 2D, 3A, 3B, 3C, 4, 10, 15, 16, 16A, 18, 21, 

22, 25A and 301of 40 CFR Part 60, Appendix A. No potential voluntary consensus standards were 

identified for EPA Methods 1A, 2A, 2D, 21 and 22. 

Three voluntary consensus standards were identified as applicable for the purpose of this rule. The 

voluntary consensus standard ASTM D6522-00 (2005), "Standard Test Method for the 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 

an acceptable alternative to EPA Method 3A and 10 for identifying nitrogen oxides, carbon monoxide, 

and oxygen concentrations when the fuel is natural gas. The voluntary consensus standard ASTM D6420-

99 (2004), "Test Method for Determination of Gaseous Organic Compounds by Direct Interface Gas 

Chromatography/Mass Spectrometry" is an acceptable alternative to EPA Method 18. The voluntary 

consensus standard ANSIIASME PTC 19-10-1981- Part 10 "Flue and Exhaust Gas Analyses" is an 

acceptable alternative for EPA Methods 3B and 16A manual portion only, not the instrumental part. 

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. 

The search identified 19 other VCS that were potentially applicable for this rule in lieu of EPA reference 

methods. After reviewing the available standards, EPA determined that 19 candidate VCS (ASTM 

D3154-00 (2006), ASTM D3464-96 (2007), ASTM D3796-90 (2004), ISO 10780:1994, ASME B133.9-

1994 (2001), ANSIIASME PTC 19-10-1981 Part 10, ASTM D5835-95 (2007), ISO 10396:1993, ISO 

12039:2001, ASTM D6522-00 (2005), CAN/CSA Z223.2-M86 (1999), CAN/CSA Z223.21-M1978, 

ASTM D3162-94 (2005), ASTM D4323-84 (2009), ANSIIASME PTC 19-10-1981 Part 10, ASTM 

D6060-96 (2001), ISO 14965:2000(E), EN 12619 (1999), ASTM D 4855-97 (2002)) 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 19 methods are listed in Attachment I, 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) 541-777 4 with any further questions in this matter. 

Attachments 

cc: Jodi Howard, EPA/SPPD (E143-01) 

Rima Howell, EPA/AQAD (E143-02) 

Greg Nizich, EPA/SPPD (E143-01) 

Hillary Ward, EPA/SPPD (E143-01) 

Bruce Moore, EPA/SPPD (E143-01) 

Michael Toney, EPA/AQAD (E143-02) 
Attachment 1. List of Voluntary Consensus Standards Not Applicable for Standards of Performance for Crude Oil and Natural 

Gas Production, Transmission and Distribution (40 CFR part 60, subpart 0000) 

SIMILAR EPA 

STANDARD EPA • S COMMENTS ON VOLUNTARY CONSENSUS 

REFERENCE VOLUNTARY CONSENSUS STANDARD STANDARD 

METHOD 

EPA Methods 1, 2, 2C, ASTM D3154-00 (2006) - Standard Method for This standard is impractical as an alternative to EPA 

3, 3B, and 4 Average V e1ocity in a Duct (Pitot Tube Method) Methods 1, 2, 2C, 3, 3B, and 4 for the purposes of this rule 

since the standard appears to lack in quality control and 

quality assurance requirements. Specifically, ASTM D3154 

does not include the following: (1) proof that openings of 

standard pitot tube have not plugged during the test; (2) if 

differential pressure gauges other than inclined manometers 

(e.g., magnehelic gauges) are used, their calibration must be 

checked after each test series; and (3) the frequency and 

validity range for calibration of the temperature sensors. 

EPAMethod2 ASTM D3464-96 (2007) - Standard Test Method The applicability specifications in this ASTM standard are 

Average Velocity in a Duct Using a Thermal not clearly defined, e.g., range of gas composition, 

Anemometer temperature limits. Also, the lack of supporting quality 

assurance data for the calibration procedures and 

specifications, and certain variability issues that are not 

adequately addressed by the standard, limit EPA's ability to 

make a definitive comparison of the method in these areas. 

EPA Method2 ASTM D3796-90 (2004)- Standard Practice for This ASTM standard is intended to be a calibration 

Calibration of Type S Pitot Tubes procedure for the S-type pitot tube and not a method by 

which stack gas velocity and/or volumetric flowrates can be 

measured as in EPA Method 2. In addition, the calibration 

procedure does not require an inclined manometer and does 

not specifY any additional accuracy verifications for the use 

of other types of differential pressure gauges. 

l 

' 

I 
SIMILAR EPA 

STANDARD VOLUNTARY CONSENSUS STANDARD 

EPA'S COMMENTS ON VOLUNTARY CONSENSUS 

REFERENCE STANDARD 

METHOD 

EPA Method2 ISO 107 80: 1994 - Stationary Source Emissions-- This standard recommends the use of an L-shaped pitot, 

Measurement of Velocity and Volume Flowrate of Gas which historically has not been recommended by EPA. The 

Streams in Ducts EPA specifies the S-type design which has large openings 

that are less likely to plug up with dust. 

EPA Methods 2, 3A, 4 ASME Bl33.9-1994 (2001)- Measurement of Exhaust Not a quantitative method, per se, although a good primer® 

Emissions from Stationary Gas Turbine Engines for this source category that includes technical descriptions 

of 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. 

EPA Methods 3A, 3B, ANSIIASME PTC 19-10-1981- Part 10-- Flue and This standard is not an acceptable alternative to EPA 

3C and 10 Exhaust Gas Analyses Methods 3A and 3B. This standard includes manual and 

instrumental methods of analyses for carbon dioxide (C02), 

carbon monoxide (CO), hydrogen sulfide (H2S), nitrogen 

oxides (NOx), oxygen (02), and sulfur dioxide (S02). The 

VCS method analytes that include one or more of the same 

techniques as the EPA methods are as follows: C02 

[manual (3B, 6A and 6B) and instrumental (3A and 3C)]; 

CO [manual (3B) and instrumental (10 and lOB)]; H2S 

[manual (15A and 16A) and instrumental (15, 16, and 16B) 

]; NOx [manual (7 and 7C) and instrumental (7A, 7B, 7E, 

20)]; 0 2 [manual (3B) and instrumental (3A, 3C, 20)]; and 

S02 [manual (6, 6A, 6B, 20) and instrumental (6C)]. The 

manual methods are all acceptable alternatives to the 

corresponding EPA test methods (3B, 6, 6A, 6B, 7, 7C, 

15A, 16A, 20 (S02 part of20 only)). [Note that one ofthe 

standard's manual S02 procedures incorporates EPA Method 

6 in its entirety.l For the standard's instrumental procedures, -

2 
SIMILAR EPA 

STANDARD EPA • S COMMENTS ON VOLUNTARY CONSENSUS 

REFERENCE VOLUNTARY CONSENSUS STANDARD 

STANDARD 

METHOD 

only general descriptions of the procedures are included 

which are not true methods. Therefore, the instrumental 

procedures (3A, 3C, 6C, 7A, 7B, 7E, 10, lOB, 15, 16, 16B, 

20 (NOx part of20 only)) are not acceptable alternatives to I 

the corresponding EPA methods. I 

EPA Methods 3A, 10 ASTM D5835-95 (2007)- Standard Practice for These standards are impractical alternatives to EPA Methods i 

Sampling Stationary Source Emissions for Automated 3A for the purposes of this rule because they lack in detail 

Determination of Gas Concentration and quality assurance/quality control requirements. 

Specifically, these two standards do not include the 

ISO 10396:1993- Stationary Source Emissions: following: (1) sensitivity ofthe method; (2) acceptable 

Sampling for the Automated Determination of Gas levels of analyzer calibration error; (3) acceptable levels of 

Concentrations sampling system bias; (4) zero drift and calibration drift 

limits, time span, and required testing frequency; (5) a 

method to test the interference response of the analyzer; (6) 

procedures to determine the minimum sampling time per run 

and minimum measurement time; and (7) specifications for 

data recorders, in terms of resolution (all types) and 

recording intervals (digital and analog recorders, only). 

EPA Methods 3A, 10 ISO 12039:2001 -Stationary Source Emissions-- This standard is not acceptable as an alternative to EPA 

Determination of Carbon Monoxide, Carbon Dioxide, Methods 3 A. This ISO standard is similar to EPA Method 

and Oxygen--Automated Methods 3A but is missing some key features. In terms of sampling, 

the hardware required by ISO 12039:2001 does not include 

a 3-way calibration valve assembly or equivalent to block 

the sample gas flow while calibration gases are introduced. 

In its calibration procedures, ISO 12039:2001 only specifies 

a two-point calibration while EPA Method 3A and 10 

specifies a three-point calibration. Also, ISO 12039:2001 

does not specifY performance criteria for calibration error, 

3 
SIMILAR EPA 

STANDARD VOLUNTARY CONSENSUS STANDARD 

EPA'S COMMENTS ON VOLUNTARY CONSENSUS 

REFERENCE STANDARD 

METHOD 

calibration drift, or sampling system bias tests as in the EPA 

method, although checks ofthese quality control features are 

required by the ISO standard . 

EPA Methods 3A, 10 ASTM D6522-00 (2005)- Standard Test Method for This standard is not acceptable as a substitute for EPA I the Determination ofNitrogen Oxides, Carbon Method 3A when the fuel is not natural gas. ASTM D6522 

Monoxide, and Oxygen Concentrations in Emissions has been determined to be technically appropriate for 

from Natural Gas-Fired Reciprocating Engines, identifYing nitrogen oxides, carbon monoxide, and oxygen 

Combustion Turbines, Boilers and Process Heaters concentrations when the fuel is natural gas. 

Using Portable Analyzers 

EPA Methods 3A, 10 CAN/CSA Z223.2-M86 (1999)- Method for the This standard is unacceptable as a substitute for EPA 

Continuous Measurement of Oxygen, Carbon Dioxide, Methods 3A (nitrogen oxides and oxygen parts of20 only) 

Carbon Monoxide, Sulphur Dioxide, and Oxides of since it does not include quantitative specifications for 

Nitrogen in Enclosed Combustion Flue Gas Streams measurement system performance, most notably the 

calibration procedures and instrument performance 

characteristics. The instrument performance characteristics 

that are provided are non-mandatory and also do not provide 

the same level of quality assurance as the EPA methods. 

For example, the zero and span/calibration drift is only 

checked weekly, whereas the EPA methods requires drift 

checks after each run. 

4 
SIMILAR EPA 

STANDARD EPA • S COMMENTS ON VOLUNTARY CONSENSUS 

REFERENCE VOLUNTARY CONSENSUS STANDARD STANDARD 

METHOD 

EPA Method 10 CAN/CSA Z223.21-Ml978- Method for the This standard is not acceptable as an alternative to EPA 

Measurement of Carbon Monoxide: 3 Method of Methods 10 and 1 OA because it is lacking in the following 

Analysis by Non-Dispersive Infrared Spectrometry areas: 1) sampling procedures; 2) procedures to correct for 

the carbon dioxide concentration; 3) instructions to correct 

the gas volume if C02 traps are used; 4) specifications to 

certify the calibration gases are within 2 percent of the target 

concentration; 5) mandatory instrument performance 

characteristics (e.g., rise time, fall time, zero drift, span drift, 

precision); 6) quantitative specification of the span value 

maximum as compared to the measured value: the standard 

specifies that the instruments should be compatible with the 

concentration of gases to be measured, whereas EPA 

Method 10 and 1 OA specify that the instrument span value 

should be no more than 1.5 times the source performance 

standard. 

EPA Method 10 ASTM D3162-94 (2005) - Standard Test Method for This ASTM standard, which is stated to be applicable in the 

Carbon Monoxide in the Atmosphere (Continuous range of0.5- 100 ppm CO, does not cover the range of EPA 

Measurement by Nondispersive Infrared Spectrometry) Method 10 (20 - 1000 ppm CO) at the upper end but claims 

to have a lower limit of sensitivity. Also, ASTM D3162 I 

does not provide a procedure to remove carbon dioxide 

interference. Therefore, this ASTM standard is not 

appropriate for combustion source conditions. In terms of 

NDIR instrument performance specifications, ASTM D3162 

has much higher maximum allowable rise and fall times (5 

minutes) than EPA Method 10 (which has 30 seconds). 

5 
SIMILAR EPA 

STANDARD EPA Is COMMENTS ON VOLUNTARY CONSENSUS I 

VOLUNTARY CONSENSUS STANDARD REFERENCE STANDARD I 

METHOD 

EPA Method 15 ASTM 04323-84 (2009)- Standard Test Method for This standard is not acceptable as an alternative to EPA 

Hydrogen Sulfide in the Atmosphere by Rate of Method 15 since it only applies to concentrations of H2S 

Change of Reflectance from 1 ppb to 3 ppm without dilution, which is likely to be 

lower than the levels at source conditions. Also, many 

quality control items are missing in ASTM 04323, such as 

checks for calibration drift and sample line losses. The 

calibration curve is also determined with only one point, as 

opposed to a multi-point curve of EPA Method 15. 

EPA Method 15 and ANSIIASME PTC 19-10-1981- Part 10 Flue and This standard includes manual and instrumental methods of 

16 Exhaust Gas Analyses analyses for carbon dioxide (C02), carbon monoxide (CO), 

hydrogen sulfide (H2S), nitrogen oxides (NOx), oxygen 

(02), and sulfur dioxide (S02). The VCS method analytes 

that include one or more of the same techniques as the EPA 

methods are as follows: C02 [manual (3B, 6A and 6B) and 

instrumental (3A and 3C)]; CO [manual (3B) and 

instrumental (10 and lOB)], H2S [manual (15A and 16A) 

and instrumental (15, 16, and 16B) ], NOx [manual (7 and 

7C) and instrumental (7A, 7B, 7E, 20)], 0 2 [manual (3B) 

and instrumental (3A, 3C, 20)], and S02 [manual (6, 6A, 

6B, 20) and instrumental (6C)]. The manual methods are 

all acceptable alternatives to the corresponding EPA test 

methods (3B, 6, 6A, 6B, 7, 7C, 15A, 16A, 20 (S02 part of 

20 only)). [Note that one of the standards manual S02 

procedures incorporates EPA Method 6 in its entirety]. For 

the standards instrumental procedures, only general 

descriptions of the procedures are included which are not 

true methods. Therefore, the instrumental procedures (3A, 

6 
SIMILAR EPA 

STANDARD EPA • S COMMENTS ON VOLUNTARY CONSENSUS 

VOLUNTARY CONSENSUS STANDARD REFERENCE STANDARD 

METHOD 

3C, 6C, 7A, 7B, 7E, 10, lOB, 15, 16, 16B, 20 (NOx part of 

20 only)) are not acceptable alternatives to the 

corresponding EPA methods. 

EPA Method 18 ASTM D6060-96 (2001) Practice for Sampling of This voluntary consensus standard is not acceptable as an 

Process Vents with a Portable Gas Chromatography alternative for EPA Method 18 because it lacks key quality 

control and assurance requirements included in EPA Method 

18. For example, ASTM D6060: 1) lacks the requirement 

of three reference standards in triplicate; 2) lacks the 

calibration acceptan_ce criteria that the triplicate calibration 

standards agree within 5 percent of their average; 3) lacks a 

post-sampling volume flow rate check and requirement to I 

I 

repeat the test if the pre- and post-test flowrates differ by 

more than 20 percent; 4) lacks triplicate samples for 

recovery tests and allows a 15 percent difference between 

the pre-test and recovery test data vs. 10 percent for Method 

18; 5) lacks the accuracy performance criteria of 10 percent 

of the preparation value for audit samples; and 6) lacks 

reporting/documentation requirements. Also, ASTM D6060 

does not include procedures for sample collection using 

other media, such as bags and solid sorbents. 

EPA Method 25A ISO 14965:2000(E)- Air Quality--Determination of This standard is an impractical alternative to EPA Method 

Total Nonmethane Organic Compounds--Cryogenic 25 or 25A because it does not measure solvent process 

Pre-concentration and Direct Flame Ionization Method vapors in concentrations greater than 1 0 ppm carbon. A 

method whose upper limit is 1 0 ppm carbon has a 

measurement range too limited to be useful in measuring 

source emissions. 

7 
SIMILAR EPA 

STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS 

REFERENCE STANDARD 

METHOD 

EPA Method 25A EN 12619 (1999) - Stationary Source Emissions-- This standard is an impractical alternative to EPA Method 

Determination of the Mass Concentration of Total 25 or 25A because it does not measure solvent process 

Gaseous Organic Carbon at Low Concentrations in vapors in concentrations greater than 40 ppm carbon. A 

Flue GasesBContinuous Flame Ionization Detector method whose upper limit is 40 ppm carbon has a 

Method measurement range too limited to be useful in measuring 

source emissions. 

EPA Method 301 ASTM D4855-97 (2002)- Standard Practice for This ASTM standard appears to be equivalent to EPA 

Comparing Test Methods Method 301 in its statistical design and decision criteria, but 

is less prescriptive than Method 301 for many procedures. 

For example, the ASTM does not require the use of at-test 

explicitly to test the precision of the alternative method but 

instead states that at-test or F-test should be used , as ' 

appropriate. The primary difference between ASTM 

D4855-97 and EPA Method 301, that makes the ASTM 

standard not acceptable as a complete alternative to the EPA 

method, is that the ASTM standard addresses the testing of 

Amaterials® rather than environmental samples. Because of 

this difference, the ASTM standard does not prescribe the 

use of paired samples as in the EPA method. This feature of 

EPA Method 301 is critical to its success and the 

acceptability of an alternate standard. 

8