UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

RESEARCH TRIANGLE PARK, NC 27711 

MAY 2 0 2015 

OFFICE OF 

MEMORANDUM 

AIR QUALITY PLANNING 

AND STANDARDS 

SUBJECT: 

FROM: 

TO: 

Voluntary Consensus Standard Results for Oil and Natural Gas Sector: Emission 

Standards for New and Modified Sources 

Barrett Parker, Acting Group Leader 

Measurement Technology Group (E143-02) 

David Cozzie, Group Leader 

Fuels and Incineration Group (E143-05) 

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 MTG searches and reviews to determine ifVCS are available and practical for use in lieu of stationary 

source methods cited in the Oil and Natural Gas Sector: Emission Standards for New and Modified 

Sources. 

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 suppmt 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 Oil and Natural Gas Sector: Emission Standards for New and Modified 

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

(ANSI). We also contacted VCS organizations and accessed and searched their databases. Searches were 

conducted for EPA Methods 1, lA, 2, 2A, 2C, 20, 3A, 3B, 3C, 4, 6, 10, 15, 16, 16A, 21, 22 and 25A of 

40 CFR Part 60, Appendix A. No applicable voluntary consensus standards were identified for EPA 

Methods 1A, 2A, 2D, 21 and 22. 

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

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

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. 

One voluntary consensus standard was identified as an acceptable alternative to EPA test methods for the 

purposes ofthis rule. The voluntary consensus standard ANSIIASME PTC 19-10-1981 Part 10 (2010), 

"Flue and Exhaust Gas Analyses" is an acceptable alternative to EPA Methods 3B, 6, 6A, 6B, 15A, 16A 

manual portions only and not the instrumental portion. 

The search identified 18 VCS that were potentially applicable for this rule in lieu of EPA reference 

methods. After reviewing the available standards, EPA determined that 18 candidate VCS (ASTM 

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

1994 (2001), ANSI/ASME PTC 19-10-1981 Part 10, ISO 10396:1993 (2007), ISO 12039: 2001, ASTM 

D5835-95 (2013), ASTM D6522-11, CAN/CSA Z223.2-M86 (1999), ISO 7934:1998, ISO 11632:1998, 

CAN/CSA Z223.21-M1978, ASTM D3162-12, ASTM D4323-84(2009), ISO 14965:2000(E), EN 12619 

(1999)) 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 18 methods are listed in Attachment 1, 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- 9724 with any further questions in this matter. 

Attachments 

cc: Matt Witosky, EPA/SPPD (E143-05) 

Bruce Moore, EPA/SPPD (E143-05) 

Michael Toney, EPA/AQAD (E143-02) 
Attachment 1. List of Voluntary Consensus Standards Not Applicable for Oil and Natural Gas Sector: Emission S

Modified Sources. 

SIMILAR EPA 

STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLU

REFERENCE STANDA

METHOD 

EPA Method 1, 2 ASTM D3154-00 (2006) - Standard Method for This standard appears to cover EPA

Average Velocity in a Duct (Pitot Tube Method) 2C, 3, 3B, 4, but lacks in quality co

requirements. Specifically, ASTM 

the following: 1) proof that opening

have not plugged during the test; 2) 

gauges other than inclined manome

gauges) are used, heir calibration m

test series; and 3) the frequency an

calibration of the temperature senso

EPAMethod2 ASTM D3464-96 (2007) - Standard Test Method The applicability specifications in t

Average Velocity in a Duct Using a Thermal clearly defined, e.g., range of gas c

Anemometer limits. Also, the lack of supporting 

the calibration procedures and spec

variability issues that are not adequ

standard limit EPA's ability to mak

of the method in these areas. 

EPA Method 2 ASTM D3796-90 (2004)- Standard Practice for This ASTM standard is intended to 

Calibration of Type S Pitot Tubes for the S-type pitot tube and not a m

velocity and/or volumetric flowrate

EPA Method 2. In addition, the ca

require an inclined manometer and 

additional accuracy verifications fo

differential pressure gauges. 

EPA Method 2 ISO i0780: 1994- Stationary Source Emissions ISO 10780:1994 recommends the u

Measurement of Velocity and Volume Flowrate of Gas which historically has not been reco

Streams in Ducts EPA specifies the S-type design wh

are less likely to plug up with dust. - -
SIMILAR EPA 

STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLU

REFERENCE STANDA

METHOD 

EPA Method 2, 3A, 4 ASME Bl33.9-1994 (2001)- Measurement ofEx.9.aust Not a quantitative method, per se, a

Emissions from Stationary Gas Turbine Engines this source category that includes te

(Revision of ANSI B133.9-1979) manual and instrumental sampling 

performance specifications for instr

standard has many good references

Methods and Performance Specific

ENGINES AND TURBINES DO 

NOT A METHOD? 

EPA Methods 3A, 3C ANSIIASME PTC 19-10-1981- Part 10 Flue and This standard includes manual and 

6C, 10, lOB, 15, 16 and Exhaust Gas Analyses analyses for carbon dioxide (C02), 

16B hydrogen sulfide (H2S), nitrogen o

and sulfur dioxide (S02). The VCS 

include one or more of the same tec

methods are as follows: C02 [manu

instrumental (3A and 3C)]; CO [ma

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

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

(7A, 7B, 7E, 20)], 02 [manual (3B

20)], and S02 [manual (6, 6A, 6B, 

The manual methods are all accepta

corresponding EPA test methods (3

16A, 20 (S02 part of20 only)). [N

standard's manual S02 procedures 

6 in its entirety]. For the standard's 

only general descriptions of the pro

are not true methods. Therefore, th

-- (3A, 3C, 6C, 7A, 7B, 7_E! 10, lOB, 

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SIMILAR EPA 

STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOL

REFERENCE STANDA

METHOD 

of20 only)) are not acceptable alte

corresponding EPA methods. 

EPA Method 3A, 10 ISO 10396:1993 (2007)- Stationary Source Emissions: This standard is similar to EPA Me

Sampling for the Automated Determination of Gas (nitrogen oxides and oxygen parts 

Concentrations 022, but lacks in detail and quality 

requirements. Specifically, ISO 10

following: 1) sensitivity ofthe met

analyzer calibration error; 3) accep

system bias; 4) zero drift and calibr

span, and required testing frequenc

interference response of the analyz

determine the minimum sampling t

measurement time; 7) specification

terms of resolution (all types) and r

and analog recorders, only). This s

to ASTM D5835. 

EPA Method 3A, 10 ISO 12039:2001 -Stationary Source Emissions This method is similar to EPA Met

Determination of Carbon Monoxide, Carbon Dioxide, (oxygen portion of20 only). Howe

and Oxygen Automated Methods some key features. In terms of sam

required by ISO 12039 does not inc

valve assembly or equivalent to blo

while calibration gases are introduc

procedures, ISO 12039 only specifi

while the EPA methods specify a 3

ISO 12039 does not specify perform

calibration error, calibration drift, o

---- tests, although checks of these qual

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SIMILAR EPA 

STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLU

REFERENCE STANDA

METHOD 

required by the ISO standard. In ad

include procedures for removal of 

tested, as in EPA Method 10. 

EPA Method 3A, 10 ASTM D5835-95 (2013)- Standard Practice for This standard is similar to EPA Me

Sampling Stationary Source Emissions for Automated (nitrogen oxides and oxygen parts o

Determination of Gas Concentration 022, but lacks in detail and quality 

requirements. Specifically, ASTM 

the following: 1) sensitivity ofthe m

levels of analyzer calibration error; 

sampling system bias; 4) zero drift 

time span, and required testing freq

the interference response of the ana

determine the minimum sampling t

measurement time; 7) specification

terms of resolution (all types) and r

and analog recorders, only). This s

to ISO 10396. 

EPA Method 3A, 10 ASTM D6522-11 -Standard Test Method for the ASTM D6522 has been determined 

Determination ofNitrogen Oxides, Carbon Monoxide, appropriate for identifying nitrogen 

and Oxygen Concentrations in Emissions from Natural and oxygen concentrations when th

Gas-Fired Reciprocating Engines, Combustion 

Turbines, Boilers and Process Heaters Using Portable 

Analyzers 

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

Continuous Measurement of Oxygen, Carbon Dioxide, 3A, 6C, 7E, 10, lOA, and 20 (nitrog

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SIMILAR EPA 

STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLU

REFERENCE STANDA

METHOD 

Carbon Monoxide, Sulphur Dioxide, and Oxides of parts of20 only), since it does not 

Nitrogen in Enclosed Combustion Flue Gas Streams specifications for measurement sys

notably the calibration procedures 

characteristics. The instrument per

that are provided are nonmandatory 

the same level of quality assurance 

example, the zero and span/calibrat

weekly, whereas the EPA methods 

each run. 

EPA Method 6 ISO 7934:1998 - Stationary Source Emissions This standard is only applicable to 

Determination of the Mass Concentration of Sulfur or more. Also, this standard does n

Dioxide Hydrogen Peroxide/Barium as does the EPA methods; therefore

Perchlorate/Thorin Method valid if more than a negligible amo

it does not address ammonia interfe

EPA Method 6 ISO 11632: 1998 - Stationary Source Emissions Sampling procedures are similar to 

Determination of the Mass Concentration of Sulfur in detail and quality control proced

Dioxide Ion Chromatography checks and leaks tests. 

EPA Method 10 CAN/CSA Z223.21-M1978- Method for the This standard is not acceptable as a

Measurement of Carbon Monoxide: 3 Method of Methods 10 and 1 OA because it is l

Analysis by Non-Dispersive Infrared Spectrometry areas: 1) sampling procedures; 2) p

carbon dioxide concentration; 3) in

volume ifC~ traps are used; 4) sp

calibration gases are within 2 perce

concentration; 5) mandatory instrum

characteristics (e.g., rise time, fall t

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-- precision); 6) quantitative specifica

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SIMILAR EPA 

STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLU

REFERENCE STANDA

METHOD 

maximum as ~ompared to the meas

specifies that the instruments shoul

concentration of gases to be measu

10 and 1 OA specify that the instrum

no more than 1.5 times the source p

EPA Method 10 ASTM D3162-12 - Standard Test Method for Carbon This ASTM standard, which is stat

Monoxide in the Atmosphere (Continuous range of0.5- 100 ppm CO, does n

Measurement by Nondispersive Infrared Spectrometry) Method 10 (20- 1000 ppm CO) at 

have a lower limit of sensitivity. A

provide a procedure to remove carb

Therefore, this ASTM standard is n

combustion source conditions. In t

performance specifications, ASTM 

maximum allowable rise and fall ti

Method 10 (which has 30 seconds)

EPA Method 15 ASTM D4323-84 (2009)- Standard Test Method for This standard is not acceptable as a

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

Change of Reflectance 1 ppb to 3 ppm without dilution, w

than the levels at source conditions

control items are missing in ASTM 

calibration drift and sample line los

is also determined with only one po

point curve ofEPA Method 15. 

EPA Methods 25, 25A ISO 14965:2000(E)- Air Quality Determination of This standard is an impractical alte

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

Preconcentration and Direct Flame Ionization Method concentrations greater than 10 ppm 

upper limit is 10 ppm carbon has a 

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SIMILAR EPA 

STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOL

REFERENCE STANDA

METHOD 

limited to be useful in measuring s

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

Detennination of the Mass Concentration of Total or 25A because it does not measur

Gaseous Organic Carbon at Low Concentrations in concentrations greater than 40 ppm 

Flue Gases Continuous Flame Ionization Detector upper limit is 40 ppm carbon has a 

Method limited to be useful in measuring s

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