UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

RESEARCH TRIANGLE PARK, NC 27711 

SEP 0 2 2015 

OFFICE OF 

MEMORANDUM 

AIR QUALITY PLANNING 

AND STANDARDS 

SUBJECT: 

FROM: 

TO: 

Voluntary Consensus Standard Results for National Emission Standards for Hazardous 

Air Pollutants for Primary Aluminum Reduction Plants r4~ 

Steffan Johnson, Group Leader ~/,,£'. 

Chuck 

MeasurementTechnologyGroup(E143-02) 

French, Group Leader 

~/"-£ ~ 

Metals and Inorganic Chemicals Group (D243-02) 

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 

NTT AA 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 Results for National Emission Standards for Hazardous Air Pollutants for 

Primary Aluminum Reduction Plants. 

In 1998, OAQPS began implementing the requirements ofthe NTTAA by conducting searches to identify 

VCS. Searches continue to be performed to meet the requirements of the NTT AA. 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 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 National Emission Standards for Hazardous Air Pollutants for Primary 

Aluminum Reduction Plants 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 wHh Vegetable Oil Based Inks on Recycled Paper (Minimum 25% Postconsumer) 
2 

Searches were conducted for EPA Methods 1, 2, 3, 5, 13A, 13B, 14, 14A, 17, 22, 29, and 315 of 40 CFR 

Part 60, Appendix A. No applicable voluntary consensus standards were identified for EPA Methods 22 

and 315. 

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

the purpose of this rule. The voluntary consensus standard ASTM D6748-02 "Standard Test Method for 

Elemental, Oxidized, Pmticle- Bound and Total Mercury Gas Generated from Coal Fired Stationary 

Sources (Ontario Hydro Method)" is acceptable as an alternative to EPA Method 29 for the mercury 

portion only. 

During the search, if the title or abstract (if provided) ofthe VCS described technical sampling and 

analytical procedures that are similm· 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 3 01 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 13 other VCS that were potentially applicable for this rule in lieu of EPA reference 

methods. After reviewing the available standards, EPA determined that 13 candidate VCS (ASTM 

D3154-00 (2006), ASTM D3464-96 (2007), ASTM D3796-90 (2004), ISO 10780:1994, ASME B 133.9-

1994 (2001), ISO 9096:1992 (2003), ANSI/ASME PTC-38-1980 (1985), ASTM D3685/D3685M-2013, 

CAN/CSA Z223.1-M1977, ASTM D3268-91 (2011), ASTM D3266-91 (2011), EN 13211:2001, 

CAN/CSA Z223 .26-M1987) 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 13 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 Groups efforts in this rulemaking. 

Please contact me at (919) 541-5459 with any fmther questions in this matter. 

Attachments 

cc: David Putney, EPA/SPPD (D243-02) 

Michael Toney, EPA/AQAD (E143-02) 
Attachment 1. List of Voluntary Consensus Standards Not Applicable for National Emission Standards for Hazard

Primary Aluminum Reduction Plants. 

SIMILAR EPA 

STANDARD VOLUNTARYCONSENSUSSTANDARD EPA'S COMMENTS ON VOLUN

REFERENCE STANDARD 

METHOD 

EPA Methods 1, 2, 3 ASTM D3154-00 (2006) - Standard Method for This method is impractical as an alt

Average Velocity in a Duct (Pitot Tube Method) Methods 1, 2, 2C, 3, 3B and 4 for th

since the standard appears to lack in 

quality assurance requirements. Sp

D3154 does not include the followin

openings of standard pitot tube have 

test; (2) if differential pressure gaug

manometers (e.g., magnehelic gaug

calibration must be checked after ea

the frequency and validity range for 

temperature sensors. 

EPA Method 2 ASTM D3464-96 (2007) - Standard Test Method This method is impractical as an alt

Average Velocity in a D_uct Using a Thermal 2 for the purposes of this rule prima

Anemometer applicability specifications are not c

range of gas composition, temperatu

lack of supporting quality assurance 

procedures and specifications, and c

that are not adequately addressed by 

EPA's ability to make a definitive c

method in these areas. 

EPA Method 2 ISO 10780:1994 - Stationary Source Emissions- This method is impractical as an alt

Measurement ofVelocity and Volume Flowrate of Gas 2 in this rule. The standard recomm
SIMILAR EPA 

EPA'S COMMENTS ON VOLUN

STANDARD VOLUNTARY CONSENSUS STANDARD REFERENCE STANDARD 

METHOD 

Streams in Ducts shaped pitot, which historically has 

by EPA. The EPA specifies the S-t

large openings that are less likely to 

EPAMethod2 ASTM D3796-90 (2004)- Standard Practice for This ASTM standard is intended to 

Calibration of TypeS Pitot Tubes procedure for the S-type pitot tube a

which stack gas velocity and/or volu

measured as in EPA Method 2. In a

procedure does not require an inclin

not specify any additional accuracy 

of other types of differential pressur

EPA Methods 2 ASME B 133.9-1994 (2001)- Measurement of Exhaust Not a quantitative method, per se, a

Emissions from Stationary Gas Turbine Engines for this source category that include

(Revision of ANSI Bl33.9-1979) of manual and instrumental samplin

performance specifications for instru

standard has many good references, 

Methods and Performance Specifica

FOR ENGINES AND TURBINES 

ALL? NOT A METHOD? 

2 
SIMILAR EPA 

STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUN

REFERENCE STANDARD 

METHOD 

EPA Method 5 ISO 9096:1992 (2003)- Determination of This method is not acceptable as an 

Concentration and Mass Flow Rate of Particulate Method 5. Although sections of IS

Matter in Gas Carrying Ducts-Manual Gravimetric Methods 1, 2, and 5 to some degree

Method not equivalent to EPA Method 5 for 

particulate matter. The standard IS

applicable technical guidance for pe

integral procedures specified in Me

performance and operational details 

nonexistent, and detailed quality as

guidance for the sampling operation

quality, representative particulate d

maintaining and monitoring train op

specific leak check guidelines and p

preparation and recovery procedure

the standard, as in EPA Method 5. 

equipment and/or operational requir

specified in EPA Method 5, are not 

standard, e.g., stack gas moisture m

reduction guidance, and particulate 

EPA Method 5, 17 ANSIIASME PTC-38-1980 (1985)- Determination of This standard also includes procedu

the Concentration of Particulate Matter in Gas Streams Methods 1 and 2. The difference be

EPA Methods 5 and 1 7 is, in genera

80 is not specific about equipment r

instead presents the options availabl

con's of each option. The key speci

ASME PTC-38-80 and the EPA me

ASME standard: 1) allows in-stack 

compared to the out-of-stack filter p

.... 

.) 
SIMILAR EPA 

STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUN

REFERENCE STANDARD 

METHOD 

Methods 5 and 17; 2) allows many 

nozzles, pitots, and filtering equipm

a filter weighing protocol or a minim

weight fluctuation as in the EPA me

filter paper to be only 99 percent ef

the 99.95 percent efficiency require

EPA Method 5, 17 ASTM D3685/D3685M-98-13- Test Methods for This method is similar to EPA Meth

Sampling and Determination of Particulate Matter in lacking in the following areas that a

Stack Gases quality, representative particulate da

the filter holder temperatUre should 

134°C, and not just "above the acid 

specifications for measuring and mo

holder temperature during sampling

to EPA Methods 1, 2, 3, and 4, that 

Method 5; (4) technical guidance fo

Method 5 sampling procedures, e.g.

monitoring sampling train operating 

of reagent blanks for determining an

background contamination; and (5) 

and/or operational requirements, e.g

leak checks, use of glass cyclones fo

loading and/or water droplets, opera

stack pressure, exchanging particula

sampling preparation and implemen

recovery guidance, data reduction g

sample calculations input. 

4 
SIMILAR EPA 

STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUN

REFERENCE STANDARD 

METHOD 

EPA Method 5 CAN/CSA Z223.1-M1977- Method for the This standard is not acceptable as an 

Determination of Particulate Mass Flows in Enclosed Method 5. Detailed technical proce

Gas Streams control measures that are required in 

and 4 are not included in CAN/CSA 

CAN/CSA Z223 .1 does not include 

filter weighing requirement to repea

hours until a constant weight is achi

Method 5 requires the filter weight t

nearest 0.1 mg, while CAN/CSA Z2

the nearest 0.5 mg. Also, CAN/CSA 

of a standard pitot for velocity meas

of the tube opening is not expected t

whereas, EPA Method 5 requires an 

Provides additional sampling option

acceptable in EPA Method 23. 

EPA Methods 13A,l3B, ASTM D3268-91 (2011)- Standard Test Method for This standard appears to be a test fo

14, and 14A Separation and Collection of Particulate and Gaseous emissions, since flows are limited to 

Fluorides in the Atmosphere (Sodium Bicarbonate sampling is not done. Also, this stan

Coated Glass Tube and Particulate Filter Method procedure only. 

EPA Methods 13A,l3B, ASTM D3266-91 (2011)- Standard Test Method for This standard appears to be a test fo

14, and 14A Separation and Collection of Particulate and Acidic emissions, since flows are limited to 

Gaseous Fluoride in the Atmosphere (Double Paper sampling is not done. Also, this stan

Tape Sampler Method) procedure only. 

5 
SIMILAR EPA 

STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUN

REFERENCE STANDARD 

METHOD 

EPA Method 29 EN 13211:2001 -Air Quality Stationary Source EN 13211 is not acceptable as an al

Emissions Determination of the Concentration of Total portion of EPA Method 29 primarily 

Mercury validated for use with impingers, as 

although the method describes proce

impingers. This European standard 

offritted bubblers only and requires 

. stream arrangement for isokinetic sa

low sampling rate of the bubblers (u

maximum). Also, only two bubbler

required by EN 13211, whereas EPA 

use of six impingers. In addition, E

include many of the quality control 

Method 29, especially for the use an

temperature sensors and controllers, 

assembly and disassembly, and filter 

standard is not acceptable as an alter

29 (mercury only), and Method 30B

atomic absorption spectrometry (CV 

procedures only, because of lack of 

EPA Method 29 CAN/CSA Z223.26-M1987- Measurement of Total This standard is not acceptable as an 

Mercury in Air Cold Vapour Atomic Absorption Methods 29 (mercury only), 101, an

Spectrophotometeric Method vapor atomic absorption spectromet

procedures only, because of lack of 

Specifically, CAN/CSA Z223.26 do

specifications for the number of cali

analyzed, procedures to prevent carr

to the next, and procedures for subtr

~-- response to calibration blank as in th

6 
SIMILAR EPA 

STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUN

REFERENCE STANDARD 

METHOD 

CAN/CSA Z223 .26 does not require 

curve be forced through or close to 

further than 2 percent of the recorde

EPA methods. Also, CAN/CSA Z2

a procedure to assure that two conse

agree within 3 percent of their avera

peak maximum is greater than 10 pe

full scale, as in the EPA methods. C

not include instructions for a blank a

at least every five samples, and spec

height of the blank and the standard 

7