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OAR Box 1490 

Prepped by Charmelle Mathews 

Document Number: 

.20) IV-B-20 

Docket Number: 

A-94-52 

Printed 8/4/2008 11:51:46 AM Sheet 20 of 273 
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Q 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

| S8RZ. I RESEARCH TRIANGLE PARK, NC 27711 

V n 0 ^ 

NOV 2 0 2002 

OFFICE OF 

MEMORANDUM ^SSS^SST 

SUBJECT: Voluntary Consensus Standard Results for the Reinforced Plastic Composites 

Production NESHAP Rule 

FROM: Frederick J. Thompson, Group Leader 

Source Measurement Analysis Group (D243-02) 

TO: Penny Lassiter, Group Leader 

Organic Chemicals Group (C504-04) 

At 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 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 ofthe EMC 

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

source methods cited in the NESHAP Rule. 

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. 

Also, the EMC participates in the American Society for 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 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 anticipate 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 Reinforced Plastic Composites Production NESHAP Rule 

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 1,1 A, 2, 2A, 2C, 2D, 2F, 2G, 3, 3A, 3B, 4,18, 25, 

25A, 204, and 204B, C, D, E. No VCS were identified for EPA Methods 1 A, 2A, 2D, 2F, 2G, 

204, 204B-E. Please see the attached tables for a detailed summary ofour findings. 

The attached tables describe the VCS found, which EPA standard reference method(s) the 

VCS potentially affects, ifthe VCS is equivalent to the EPA standard reference method, and 

EPA's comments after review ofthe standard. During the search, ifthe title or abstract (if 

provided) ofthe VCS described technical sampling and analytical procedures that are similar to 

EPA's reference method, the EMC ordered a copy ofthe standard and reviewed 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 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. 

Three voluntary consensus standards were identified as acceptable alternatives to EPA 

test methods for the purposes ofthis rule. 

The voluntary consensus standard ASME PTC 19-10-1981-Part 10, "Flue and Exhaust 

Gas Analyses," is cited in this rule for its manual method for measuring the oxygen, carbon 

dioxide, and carbon monoxide content of exhaust gas. This part of ASME PTC 19-10-1981-Part 

10 is an acceptable alternative to Method 3B. 

The voluntary consensus standard, ASTM D6420-99, "Standard Test Method for 

Determination of Gaseous Organic Compounds by Direct Interface Gas Chromatography-Mass 

Spectrometry (GC/MS)," is appropriate in the cases described below for inclusion in this final 

rule, in addition to the currently available EPA Method 18, codified at 40 CFR part 60, 

appendix A. 

Similar to EPA's performance-based Method 18, ASTM D6420-99 is also a performancebased method for measurement of gaseous organic compounds. However, ASTM D6420-99 was 

written to support the specific use of highly portable and automated GC/MS. While offering 

advantages over the traditional Method 18, the ASTM method does allow some less stringent 

criteria for accepting GC/MS results than required by Method 18. Therefore, ASTM D6420-99 

is a suitable alternative to Method 18 only where: 
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(1) the target compound(s) are those listed in Section 1.1 of ASTM D6420-99, 

and 

(2) the target concentration is between 150 ppbv and 100 ppmv. 

For target compound(s) not listed in Section 1.1 of ASTM D6420-99, but potentially 

detected bv mass spectrometry, the regulation specifies that the additional system continuing 

calibration check after each run, as detailed in Section 10.5.3 ofthe ASTM method, must be 

followed, met, documented, and submitted with the data report even if there is no moisture 

condenser used or the compound is not considered water soluble. For target compound(s) not 

listed in Section 1.1 of ASTM D6420-99, and not amenable to detection by mass spectrometry, 

ASTM D6420-99 does not apply. 

As a result, EPA will cite ASTM D6420-99 in subpart WWWW of part 63. The EPA 

will also cite Method 18 as a gas chromatography (GC) option in addition to ASTM D6420-99. 

This will allow the continued use of GC configurations other than GC/MS. 

The EPA requested comments on proposed compliance demonstration requirements in 

the proposed rule, and specifically invited the public to identify potentially applicable voluntary 

consensus standards. The only comment we received on voluntary consensus standards was that 

we should allow the use ofthe vapor suppressant effectiveness test protocol developed by the 

Composite Manufacturers Association (CFA) to determine vapor suppressant effectiveness. We 

have reviewed the information supplied by the commenter and have incorporated this test 

method, "Vapor Suppressant Effectiveness Test Protocol," into the final rule as Appendix A to 

subpart WWWW of 40 CFR part 63. 

The search identified 13 VCS that were potentially applicable for this rule in lieu of EPA 

reference methods. The EPA determined that 11 of these 13 VCS (ASTMD3154-00, 

ASTMD3464-96 (2001), ASTMD3796-90 (1998), ASTMD5835-95, ASTMD6060-96 (in review 

2000), CAN/CSA Z223.2-M86 (1986), EN12619 (1999), ISO10396:1993, ISO10780:1994, 

ISO12039:2001, ISO14965:2000(E)) identified for measuring emissions ofthe HAPs or 

surrogates subject to emission standards would not be practical due to lack of equivalency, 

documentation, validation data and other important technical and policy considerations. These 

11 methods are listed in Attachment 1, along with the EPA review comments. Two ofthe 13 

candidate VCS (ASME/BSR MFC 12M and ASME/BSR MFC 13M) are new standards under 

development. These two methods are listed in Attachment 2, along with the EPA review 

comments. 
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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) 541-2707 with any ftirther questions in this matter. 

Attachments 

cc: Keith Barnett, ESD((C504-04), w/ attachments 

John Bosch, EMC (D243-02) 

Mike Ciolek, EMC (D243-02), w/ attachments 

Bill Lamason, EMAD (C304-02) 

Conniesue Oldham, EMC (D205-02), w/ attachments 
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Attachment 1. List of Voluntary Consensus Standards Not Applicable to the 

Reinforced Plastic Composites Production NESHAP 

" \ 

SIMILAR EPA STANDARD 

REFERENCE METHOD 

EPA Methods 1, 2, 2C, 3, 3B, 4 

EPA Method 2 

VOLUNTARY CONSENSUS 

STANDARD 

ASTM D3154-00 - Standard Method for 

Average Velocity in a Duct (Pitot Tube 

Method) 

ASTM D3796-90 (1998) - Standard 

Practice for Calibration of Type S Pitot 

Tubes 

EPA REVIEW COMMENTS 

This standard appears to cover EPA's Part 60 

Methods 1, 2, 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, 

their calibration must be checked after each test 

series; and 3) the frequency and validity range 

for calibration ofthe temperature sensors. 

This ASTM standard is intended to be a 

calibration 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. 
^ 

SIMILAR EPA STANDARD 

REFERENCE METHOD 

EPA Method 2 

EPA Method 2 

VOLUNTARY CONSENSUS 

STANDARD 

ASTM D3464-96 (2001) - Standard Test 

Method Average Velocity in a Duct Using 

a Thermal Anemometer 

ISO 10780:1994 - Stationary Source 

Emissions-Measurement of Velocity and 

Volume Flowrate of Gas Streams in Ducts 

EPA REVIEW COMMENTS 

The applicability specifications in this ASTM 

standard are not clearly defined, e.g., range of 

gas composition, 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 ofthe method in 

these areas. 

ISO 10780:1994 recommends the use of an Lshaped pitot, which historically has not been 

recommended by EPA. The EPA specifies the 

S-type design which has large openings that are 

less likely to plug up with dust. 
SIMILAR EPA STANDARD 

REFERENCE METHOD 

EPA Method 3A 

VOLUNTARY CONSENSUS 

STANDARD 

ISO 10396:1993 - Stationary Source 

Emissions: Sampling for the Automated 

Determination of Gas Concentrations 

EPA REVIEW COMMENTS 

Similar to EPA Methods 3A, 6C, 7E, 10, ALT 

004, CTM 022, but lacks in detail and quality 

assurance/quality control requirements. 

Specifically, ISO 10396 does not include the 

following: 1) sensitivity of the 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 ofthe 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. 
^ 

SIMILAR EPA STANDARD 

REFERENCE METHOD 

EPA Method 3A 

VOLUNTARY CONSENSUS 

STANDARD 

ASTM D5835-95 - Standard Practice for 

Sampling Stationary Source Emissions for 

Automated Determination of Gas 

Concentration 

EPA REVIEW COMMENTS 

Similar to EPA Methods 3A, 6C, 7E, 10, ALT 

004, CTM 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 ofthe 

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. 

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SIMILAR EPA STANDARD 

REFERENCE METHOD 

EPA Method 3A 

VOLUNTARY CONSENSUS 

STANDARD 

CAN/CSA Z223.2-M86 (1986) - Method 

for the Continuous Measurement of 

Oxygen, Carbon Dioxide, Carbon 

Monoxide, Sulphur Dioxide, and Oxides 

of Nitrogen in Enclosed Combustion Flue 

Gas Streams 

EPA REVIEW COMMENTS 

This standard is unacceptable as a substitute for 

EPA Methods 3A, 6C, 7E, 10, IOA since it does 

not include quantitative specifications for 

measurement system perfonnance, 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. 
SIMILAR EPA STANDARD 

REFERENCE METHOD 

EPA Method 3A 

EPA Method 18 

VOLUNTARY CONSENSUS 

STANDARD 

ISO 12039:2001 - Stationary Source 

Emissions-Determination of Carbon 

Monoxide, Carbon Dioxide, and Oxygen -

Automated Methods 

ASTM D6060-96 (in review 2000) -

Practice for Sampling of Process Vents 

with a Portable Gas Chromatography 

EPA REVIEW COMMENTS 

This ISO standard is unacceptable as substitute 

for EPA Method 3A because it 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 

specifies a three-point calibration. Also, 

ISO 12039:2001 does not specify performance 

criteria for calibration error, calibration drift, or 

sampling system bias tests, as in the EPA 

method, although checks of these quality control 

features are required by the ISO standard. 

This standard lacks key quality control and 

assurance that is required for EPA Method 18. 

For example: lacks acceptance criteria for 

calibration, details on using other collection 

media (e.g. solid sorbents), and reporting/ 

documentation requirements. 
SIMILAR EPA STANDARD 

REFERENCE METHOD 

EPA Methods 25, 25A 

EPA Method 25A 

VOLUNTARY CONSENSUS 

STANDARD 

ISO 14965:2000(E) - Air Quality -

Determination of Total Nonmethane 

Organic Compounds - Cryogenic 

Preconcentration and Direct Flame 

Ionization Method 

EN 12619 (1999) - Stationary Source 

Emissions-Determination ofthe Mass 

Concentration of Total Gaseous Organic 

Carbon at Low Concentrations in Flue 

Gases-Continuous Flame Ionization 

Detector Method 

EPA REVIEW COMMENTS 

This standard is an impractical alternative to 

EPA Method 25A because it does not measure 

solvent process vapors in concentrations greater 

than 10 ppm carbon. A method whose upper 

limit is 10 ppm carbon has a measurement range 

too limited to be useful in measuring source 

emissions. 

This standard is an impractical alternative to 

EPA Method 25A because it does not measure 

solvent process vapors in concentrations greater 

than 40 ppm carbon. A method whose upper 

limit is 40 ppm carbon has a measurement range 

too limited to be useful in measuring source 

emissions. 
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Attachment 2. List of Voluntary Consensus Standards Not Final 

for the Reinforced Plastic Composites Production NESHAP 

SIMILAR EPA STANDARD 

REFERENCE METHOD 

EPA Method 2 (possibly 1) 

EPA Method 2 

VOLUNTARY CONSENSUS 

STANDARD 

ASME/BSR MFC 13M - Flow 

Measurement by Velocity Traverse 

ASME/BSR MFC 12M - Flow in Closed 

Conduits Using Multiport Averaging Pitot 

Primary Flowmeters 

EPA REVIEW COMMENTS 

Under development when search was completed. 

Possibly similar to EPA Methods 1 and 2. 

Under development when search was completed. 

Possibly similar to EPA Method 2. 

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