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 ofPerformance for Crude Oil and Natural Gas Production, Transmission and Distribution (40 CFRpart 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 MeasurementTechnology Group (MTG), ofthe Office ofAir Quality Planning and Standards (OAQPS), conducted searches and reviews to address the National Technology Transfer and AdvancementAct (NTTAA) requirements onthe use ofvoluntary 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 ifVCS are available and practical for use in lieu ofstationary
source methods cited in the Standards ofPerformance for Crude Oil and Natural Gas Production, Transmission and Distribution (40 CFRpart 60, subpart 0000).

In 1998, OAQPS began implementingthe requirements ofthe NTTAA by conducting searches to identify VCS. Searches continue to be performed to meet the requirements ofthe NTTAA. While we have made a reasonable effort to identify and evaluate potentiallypractical VCS, our findings do not necessarily represent all potential alternative standards which may exist.

The MIG participates in the American Societyfor 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 expectthese additional efforts will help us to support a periodic review ofall EPA reference methods and performance standards for possible incorporation byreference (IBR) ofVCS in lieu ofor as alternatives to EPA procedures. We anticipate thatthese activities will provide an opportunity for further review, consideration and possible IBR ofVCS overlooked in the National Standards Service Network (NSSN) searches orfinalized after Federal agency review in the EPA rulemaking process.

We conducted searches for the Standards ofPerformance for Crude Oil and Natural Gas Production, Transmission and Distribution (40 CFRpart 60, subpart 0000)through the Enhanced NSSN Database managed by the American National Standards Institute (ANSI). We also contacted VCS organizations, and accessed and searchedtheir databases.

Internet Address (URL) • http://www

.epa.gov Recycled/Recyclable • Printed**w~h** Vegetable Oil Based Ink s on Recycled Paper (Minimum 25% Postconsumer)

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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 301of40 CFRPart 60, AppendixA. 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 ofthis rule. The voluntary consensus standard ASTMD6522-00 (2005), "Standard Test Method for the Determination of Nitrogen Oxides, Carbon Monoxide, and Oxygen Concentrations in Emissions from Natural Gas-Fired Reciprocating Engines, CombustionTurbines, 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), "TestMethod for Determination ofGaseous 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, notthe instrumental part.
Duringthe search, ifthe title or abstract (ifprovided) ofthe VCS describedtechnical sampling and analytical procedures that are similarto EPA's reference method, the MTG considered it as a potential equivalent method. All potential standards were reviewed to determine the practicality ofthe VCS for this rule. This review requires significant method validation data which meets the requirements ofEPA Method 301 for accepting alternative methods or scientific, engineering and policy equivalence to procedures in EPA reference methods. The MTG may reconsider determinations ofimpracticality when additional information is available for particularVCS.

The search identified 19 otherVCS thatwere potentially applicable for this rule in lieu ofEPA reference methods. Afterreviewingthe available standards, EPA determined that 19 candidate VCS (ASTM D3154-00 (2006), ASTMD3464-96 (2007), ASTMD3796-90 (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, ASTMD6522-00 (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), ASTMD 4855-97 (2002)) identified for measuring emissions ofpollutants ortheir surrogates subjectto emission standards in the rule would not be practical due to lack ofequivalency, documentation, validation data and other importanttechnical and policy considerations. These 19 methods are listed in Attachment I, along with the EPAreview comments.

I hope our research into this matter has been useful and timely to your Group's efforts inthis rulemaking. Please contact me at (919) 541-7774 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) HillaryWard, EPA/SPPD (E143-01) Bruce Moore, EPA/SPPD (E143-01) Michael Toney, EPA/AQAD (E143-02)Attachment 1. ListofVoluntary Consensus Standards NotApplicable for Standards ofPerformancefor Crude Oil and Natural Gas Production, Transmission and Distribution (40 CFRpart 60, subpart 0000)

SIMILAREPA

STANDARD EPA•S COMMENTS ONVOLUNTARY CONSENSUS REFERENCE VOLUNTARY CONSENSUS STANDARD STANDARD

METHOD EPAMethods 1, 2, 2C, ASTM D3154-00 (2006)

- Standard Method for This standard is impractical as an alternative to EPA 3, 3B, and 4 Average Ve1ocity in a Duct (Pitot Tube Method) Methods 1, 2, 2C, 3, 3B, and 4 for the purposes ofthis rule since the standard appears to lack in quality control and quality assurance requirements. Specifically, ASTMD3154 does not include the following: (1) proofthat openings of standard pitottube have not plugged duringthe test; (2) if differential pressure gauges otherthan inclined manometers (e.g., magnehelic gauges) are used, their calibration mustbe checked after each test series; and (3) the frequency and validity range for calibration ofthe temperature sensors. EPAMethod2 ASTM D3464-96 (2007)

- Standard TestMethod The applicability specifications in this ASTM standard are Average Velocity in a DuctUsing a Thermal not clearly defined, e.g., range ofgas composition, Anemometer temperature limits. Also, the lack ofsupporting quality

assurance datafor the calibration procedures and specifications, and certain variability issues that are not adequately addressedbythe standard, limit EPA's ability to make a definitive comparison ofthe method in these areas. EPA Method2 ASTM D3796-90 (2004)- Standard Practice for This ASTM standard is intended to be a calibration Calibration ofType S PitotTubes procedure for the S-type pitottube and not a method by which stack gas velocity and/or volumetric flowrates canbe measured as in EPA Method 2. In addition, the calibration procedure does notrequire an inclined manometer and does not specifY any additional accuracy verifications for the use ofothertypes ofdifferential pressure gauges.



### l ' ISIMILAREPA STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ONVOLUNTARY CONSENSUS REFERENCE STANDARD

METHOD EPA Method2 ISO 10780: 1994

- Stationary Source Emissions-- This standard recommends the use ofan L-shaped pitot, MeasurementofVelocity and Volume Flowrate ofGas which historicallyhas notbeen 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 ofExhaust Not a quantitative method, per se, although a good primer® Emissions from Stationary Gas Turbine Engines for this source categorythat includes technical descriptions ofmanual 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 ofanalyses 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 ormore ofthe 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 manualmethods 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,

- 

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### SIMILAREPA STANDARD EPA•S COMMENTS ONVOLUNTARY CONSENSUS REFERENCE VOLUNTARY CONSENSUS STANDARD STANDARD

METHOD only general descriptions ofthe procedures are included which are nottrue 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 ofthis rule because they lack in detail Determination ofGas 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 Samplingfor the Automated Determination ofGas levels ofanalyzer 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 testthe interference response ofthe analyzer; (6) procedures to determine the minimum samplingtime perrun and minimum measurementtime; and (7) specifications for data recorders, in terms ofresolution (alltypes) and recording intervals (digital and analog recorders, only). EPAMethods 3A, 10 ISO 12039:2001 -Stationary Source Emissions-- This standard is not acceptable as an alternative to EPA Determination ofCarbon Monoxide, Carbon Dioxide, Methods 3A. This ISO standard is similarto EPA Method and Oxygen--AutomatedMethods 3Abut is missing some key features. Interms ofsampling, the hardware required by ISO 12039:2001 does not include

a 3-way calibration valve assembly orequivalentto 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 criteriafor calibration error,


### 3SIMILAREPA 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 bythe ISO standard

. EPA Methods 3A, 10 ASTM D6522-00 (2005)- Standard TestMethod for This standard is not acceptable as a substitute for EPA

I the Determination ofNitrogen Oxides, Carbon Method 3Awhen 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/CSAZ223.2-M86 (1999)- Method for the This standard is unacceptable as a substitute for EPA Continuous Measurement ofOxygen, Carbon Dioxide, Methods 3A (nitrogen oxides and oxygen parts of20 only) CarbonMonoxide, 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 instrumentperformance characteristics. The instrument performance characteristics thatare provided are non-mandatory and also do notprovide the same level ofquality 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.



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### SIMILAREPA 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 ofCarbon Monoxide: 3 Method of Methods 10 and 1 OA because it is lacking in the following Analysis byNon-Dispersive Infrared Spectrometry areas: 1) sampling procedures; 2) procedures to correct for the carbon dioxide concentration; 3) instructions to correct the gas volume ifC02 traps are used; 4) specifications to certifythe calibration gases are within 2 percent ofthe target concentration; 5) mandatory instrumentperformance characteristics (e.g., rise time, fall time, zero drift, span drift, precision); 6) quantitative specification ofthe span value maximum as comparedto the measured value: the standard specifies thatthe instruments should be compatible withthe concentration ofgases to be measured, whereas EPA Method 10 and 1 OA specifythatthe instrument span value shouldbe no more than 1.5 times the source performance standard. EPA Method 10 ASTMD3162-94 (2005)

- Standard Test Method for This ASTM standard, which is statedto be applicable in the Carbon Monoxide inthe Atmosphere (Continuous range of0.5- 100 ppm CO, does not coverthe range ofEPA MeasurementbyNondispersive Infrared Spectrometry) Method 10 (20

- 1000 ppm CO) at the upper endbutclaims to have a lower limit ofsensitivity. Also, ASTMD3162 I does notprovide a procedure to remove carbon dioxide interference. Therefore, this ASTM standard is not appropriate for combustion source conditions. Interms of NDIR instrument performance specifications, ASTMD3162 has much higher maximum allowable rise and fall times (5 minutes) than EPA Method 10 (which has 30 seconds).



### 5SIMILAREPA EPA

### Is COMMENTS ONVOLUNTARY CONSENSUS I STANDARD 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 ofH2S Change ofReflectance from 1ppb 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 ofEPAMethod 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 ofthe 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 manualmethods are all acceptable alternatives to the corresponding EPA test methods (3B, 6, 6A, 6B, 7, 7C, 15A, 16A, 20 (S02 part of 20 only)). [Notethat one ofthe standards manual S02 procedures incorporates EPA Method 6 in its entirety]. For the standards instrumental procedures, only general descriptions ofthe procedures are included which are not true methods. Therefore, the 

### instrumentalprocedures (3A,



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### SIMILAREPA STANDARD EPA•S COMMENTS ONVOLUNTARY 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, ASTMD6060: 1) lacks the requirement ofthree reference standards in triplicate; 2) lacks the calibration acceptan

_ ce criteriathatthe triplicate calibration standards agree within 5 percent oftheir average; 3) lacks a post-samplingvolume flow rate check and requirementto I I repeatthe test ifthe 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 datavs. 10 percent for Method 18; 5) lacks the accuracy performance criteriaof 10 percent ofthe preparation value for audit samples; and 6) lacks reporting/documentation requirements. Also, ASTMD6060 does not include procedures for sample collection using othermedia, 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 or25Abecause it does not measure solvent process Pre-concentration and Direct Flame Ionization Method vapors in concentrations greaterthan 1 0 ppm carbon. A method whose upper limit is 10 ppm carbon has a measurement range too limited to be useful in measuring

source emissions.



### 7SIMILAREPA STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ONVOLUNTARY CONSENSUS REFERENCE STANDARD

METHOD EPA Method 25A EN 12619 (1999)

- Stationary Source Emissions-- This standard is an impractical alternative to EPA Method Determination ofthe Mass Concentration ofTotal 25 or 25A because it does not measure solvent process Gaseous Organic Carbon atLow Concentrations in vapors in concentrations greaterthan 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 equivalentto 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 ofat-test explicitlyto test the precision ofthe 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 thatthe ASTM standard addresses the testing of Amaterials® ratherthan environmental samples. Because of this difference, the ASTM standard does not prescribe the

use ofpaired samples as in the EPA method. This feature of EPA Method 301 is criticalto its success and the acceptability ofan alternate standard.



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