# UNITED STATES ENVIRONMENTAL PROTECTION AGENCY RESEARCH TRIANGLE PARK, NC 27711 

# MAY 2 02015 OFFICE OF 

# MEMORANDUM AIR QUALITY PLANNING AND STANDARDS 

# SUBJECT: 

# FROM: TO: Voluntary Consensus StandardResults for Oil andNatural Gas Sector: Emission Standards for New and Modified Sources BarrettParker, Acting Group Leader MeasurementTechnology Group (E143-02) David Cozzie, Group Leader Fuels and Incineration Group (E143-05) Atyour 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 on the use ofvoluntary consensus standards (VCS). The NTTAA directs EPAto use VCS in regulatory and procurement activities unless doing so wouldbe inconsistentwith 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 ofstationary source methods cited in the Oil and Natural Gas Sector: Emission Standards for New andModified Sources. In 1998, OAQPS began implementing the requirements oftheNTTAA by conducting searchesto identify VCS. Searches continueto be performedto meetthe requirements ofthe NTTAA.While we have made a reasonable effortto 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 andMaterials (ASTM), which is one ofthe most activeVCS organizations on emissions testing, and has been invited to participate in the USA Technical Advisory Group for International Organization for Standardization (ISO) relatingto emissions monitoring. We expectthese additional efforts will help us to suppmt a periodic review ofall EPA reference methods and performance standards for possible incorporation by reference (IBR) ofVCS in lieu ofor as alternatives to EPA procedures. We anticipate that these activities will provide an opportunity for further review, consideration and possible IBRofVCS overlooked in the National Standards ServiceNetwork (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 StandardsInstitute (ANSI). We also contacted VCS organizations and accessed and searched their databases. Searches were conducted for EPAMethods 1, lA, 2, 2A, 2C, 20, 3A, 3B, 3C, 4, 6, 10, 15, 16, 16A, 21, 22 and 25A of 40 CFRPart 60, AppendixA. 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 Duringthe search, ifthe title or abstract (ifprovided) ofthe VCS describedtechnical sampling and analytical procedures that are similarto EPA'sreference 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 reviewrequires significantmethod validation datawhich meets the requirements ofEPA Method 301 for accepting alternative methods or scientific, engineering and policy equivalenceto procedures inEPAreference methods. The MTG may reconsider determinations ofimpracticality when additional information is available for particularVCS. One voluntary consensus standard was identified as an acceptable alternative to EPAtest methods for the purposes ofthisrule. The voluntary consensus standard ANSIIASME PTC 19-10-1981 Part 10 (2010), "Flue andExhaust Gas Analyses" is an acceptable alternative to EPAMethods 3B, 6, 6A, 6B, 15A, 16A manual portions only and notthe instrumental portion. The search identified 18 VCS thatwere potentially applicable for this rule in lieu ofEPA reference methods. Afterreviewing the available standards, EPA determinedthat 18 candidateVCS (ASTM D3154-00 (2006), ASTM D3464-96 (2007), ASTM D3796-90 (2004), ISO 10780:1994, ASME B133.9- 1994 (2001), ANSI/ASMEPTC 19-10-1981 Part 10, ISO 10396:1993 (2007), ISO 12039: 2001, ASTM D5835-95 (2013), ASTMD6522-11, CAN/CSA Z223.2-M86 (1999), ISO 7934:1998, ISO 11632:1998, CAN/CSAZ223.21-M1978, ASTM D3162-12, ASTM D4323-84(2009), ISO 14965:2000(E),EN 12619 (1999)) identified for measuring emissions ofpollutants ortheir surrogates subjectto emission standards in the rule wouldnotbe practical due to lack ofequivalency, documentation, validation data and other importanttechnical and policy considerations. These 18 methods are listed in Attachment 1, along with the EPA review comments. I hope ourresearch into this matter has been useful and timely to your Group's efforts in this rulemaking. Please contactme 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 Standards for New and Modified Sources. SIMILAR EPA STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS REFERENCE STANDARD METHOD EPA Method 1, 2 ASTM D3154-00 (2006)

- Standard Method for This standard appears to cover EPA's Part 60 Methods 1, 2, Average Velocity in a Duct (Pitot Tube Method) 2C, 3, 3B, 4, but lacks in quality control and quality assurance requirements.

Specifically, ASTM D3154-00 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, heir 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 not Average

Velocity in a Duct Using a Thermal clearly defined, e.g., range of gas composition, temperature Anemometer 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 defmitive comparison
of the method in these areas.
EPA

Method 2 ASTM D3796-90 (2004)- Standard Practice for This ASTM standard is intended to be a calibration procedure Calibration of Type S Pitot Tubes 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.
EPA

Method 2 ISO i0780: 1994- Stationary Source Emissions ISO 10780:1994 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.

- -SIMILAR EPA STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS REFERENCE STANDARD METHOD EPA Method 2, 3A, 4 ASME Bl33.9-1994 (2001)- Measurement ofEx.9.aust Not a quantitative method, per se, although a good primer for Emissions from Stationary Gas Turbine Engines this source category that includes technical descriptions of (Revision of ANSI B133.9-1979) 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. ONLY USE FOR ENGINES AND TURBINES DO NOT USE AT ALL? NOT A METHOD?
EPA Methods 3A, 3C ANSIIASME PTC 19-10-1981- Part 10 Flue and This standard includes manual and instrumental methods of

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

16B 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)], 02 [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 of the standard's manual S02 procedures incorporates EPA Method

6 in its entirety]. For the standard's instrumental procedures, only general descriptions of the procedures are included which
are not true methods. Therefore, the instrumental procedures -- (3A, 3C, 6C, 7A, 7B, 7_E! 10, lOB, 15, 16, !6B,_20 {NOx part

2SIMILAR EPA STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS REFERENCE STANDARD METHOD of20 only)) are not acceptable alternatives to the corresponding EPA methods.
EPA Method 3A, 10 ISO 10396:1993 (2007)- Stationary Source Emissions: This standard is similar to EPA Methods 3A, 6C, 7E, 10,20 Sampling for the Automated Determination of Gas (nitrogen oxides and oxygen parts of20 only), ALT 004, CTM Concentrations 022, but lacks in detail and quality assurance/quality control requirements. Specifically, ISO 10396 does not include the following: 1) sensitivity ofthe method; 2) acceptable levels of analyzer calibration error; 3) acceptable levels of 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; 7) specifications for data recorders, in terms of resolution (all types) and recording intervals (digital and analog recorders, only). This standard is also very similar

to ASTM D5835.
EPA Method 3A, 10 ISO 12039:2001 -Stationary Source Emissions This method is similar to EPA Methods 3A, 10, and 20 Determination of Carbon Monoxide, Carbon Dioxide, (oxygen portion of20 only). However, ISO 12039 is missing

and Oxygen Automated Methods some key features. In terms of sampling, the hardware required by ISO 12039 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 only specifies a two-point calibration while the EPA methods specify a 3-point calibration. Also, ISO 12039 does not specify performance criteria for calibration error, calibration drift, or sampling system bias tests, although checks of these quality control features are

---- 

### 3SIMILAR EPA STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS REFERENCE STANDARD METHOD required by the ISO standard. In addition, ISO 12039 does not include procedures for removal of C02 when CO is being tested, as in EPA Method 10.
EPA Method 3A, 10 ASTM D5835-95 (2013)- Standard Practice for This standard is similar to EPA Methods 3A, 6C, 7E, 10, 20 Sampling

Stationary Source Emissions for Automated (nitrogen oxides and oxygen parts of20 only), ALT 004, CTM Determination of Gas Concentration 022, but lacks in detail and quality assurance/quality control requirements. Specifically, ASTM D5835-95 does not include
the following: 1) sensitivity ofthe method; 2) acceptable levels of analyzer calibration error; 3) acceptable levels of 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; 7) specifications for data recorders, in terms of resolution (all types) and recording intervals (digital and analog recorders, only). This standard is also very similar

to ISO 10396.
EPA Method 3A, 10 ASTM D6522-11 -Standard Test Method for the ASTM D6522 has been determined to be technically Determination ofNitrogen Oxides, Carbon Monoxide, appropriate for identifying nitrogen oxides, carbon monoxide,

and Oxygen Concentrations in Emissions from Natural and oxygen concentrations when the fuel is natural gas. 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 substitute for EPA Methods Continuous Measurement of Oxygen, Carbon Dioxide, 3A, 6C, 7E, 10, lOA, and 20 (nitrogen oxides and oxygen

-- ---


### 4SIMILAR EPA STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS REFERENCE STANDARD METHOD Carbon Monoxide, Sulphur Dioxide, and Oxides of parts of20 only), since it does not include quantitative Nitrogen in Enclosed Combustion Flue Gas Streams specifications for measurement system performance, most notably the calibration procedures and instrument performance characteristics. The instrument performance characteristics that are provided are nonmandatory 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.
EPA Method 6 ISO 7934:1998

- Stationary Source Emissions This standard is only applicable to sources with 30 mg/m 3 S02 Determination of the Mass Concentration of Sulfur or more. Also, this standard does not separate S03 from S02 Dioxide

Hydrogen Peroxide/Barium as does the EPA methods; therefore, ISO 7934:1998 is not Perchlorate/Thorin

Method valid if more than a negligible amount of S03 is present. Also,

it does not address ammonia interferences.

EPA Method 6

ISO 11632: 1998

- Stationary Source Emissions Sampling procedures are similar to EPA Method 6, but lacks Determination of the Mass Concentration of Sulfur in detail and quality control procedures, such as calibration Dioxide Ion Chromatography checks and leaks tests.
EPA Method 10 CAN/CSA Z223.21-M1978- 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 **ifC~** 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

-- - -- 

### 5SIMILAR EPA STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS REFERENCE STANDARD METHOD maximum as

**~ompared** to the measured value: the standard specifies that the instruments should be Acompatible 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 D3162-12

- Standard Test Method for Carbon This ASTM standard, which is stated to be applicable in the 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 does not provide a procedure to remove carbon dioxide interference. Therefore, this ASTM standard is not appropriate for combustion source conditions. In terms ofNDIR instrument performance specifications, ASTM D3162 has much higher maximum allowable rise and fall times ( 5 minutes) than EPA Method 10 (which has 30 seconds).
EPA Method 15 ASTM D4323-84 (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 from Change of Reflectance 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 D4323, such as checks for calibration drift and sample line losses. The calibration curve

is

also determined with only one point, as opposed to amultipoint curve ofEPA Method 15.
EPA Methods 25, 25A ISO 14965:2000(E)- Air Quality Determination of This standard is an impractical alternative to EPA Method 25
Total Nonmethane Organic Compounds Cryogenic or 25A because it does not measure solvent process vapors in Preconcentration and Direct Flame Ionization Method concentrations greater than 10 ppm carbon. A method whose upper limit is 10 ppm carbon has a measurement range too

6

## SIMILAR EPA I 

## STANDARD

VOLUNTARY CONSENSUS STANDARD EPA ' S COMMENTS ON VOLUNTARY CONSENSUS REFERENCE STANDARD METHOD limited to be useful in measuring source emissions.

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

of the Mass Concentration of Total or 25A because it does not measure solvent process vapors in Gaseous

Organic Carbon at Low Concentrations in concentrations greater than 40 ppm carbon. A method whose

Flue

Gases Continuous Flame Ionization Detector upper limit is 40 ppm carbon has a measurement range too Method

limited to be useful in measuring source emissions

.

- --- - - --- --- -- - -



## 7