# UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

# RESEARCH TRIANGLE PARK, NC 27711 

# SEP 022015 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 ReductionPlants 

# r4~ SteffanJohnson, Group Leader


# ~/,,£'. MeasurementTechnologyGroup(E143-02) 

# ~/"-£ **~** Chuck French, Group Leader Metals and InorganicChemicals Group (D243-02) Atyour request, the MeasurementTechnology Group (MTG) ofthe Office ofAir QualityPlanning and Standards (OAQPS) conducted searches and reviews to address theNational Technology Transfer and Advancement Act (NTTAA) requirements on the use ofvoluntary consensus standards (VCS). The NTT AA directs EPA to use VCS in regulatory and procurement activities unless doing so would be inconsistentwith applicable law or otherwise impracticable. This memorandum documents the results of theMTG searches and reviews to determine ifVCS are available and practical for use in lieu ofstationary source methods cited in the Results for National Emission Standards for Hazardous Air Pollutants for Primary Aluminum ReductionPlants. In 1998, OAQPS began implementing the requirements oftheNTTAA by conducting searchesto identify VCS. Searches continue to be performed to meetthe requirements ofthe NTT AA. While we have made a reasonable effortto identify and evaluate potentiallypractical VCS, ourfindings do not necessarily represent all potential alternative standards which may exist. The MTGparticipates in the American Societyfor Testing and Materials (ASTM), which is one ofthe most activeVCS organizations on emissions testing, and has been invited to participate in theUSA Technical Advisory Group for International Organization for Standardization (ISO) relating to emissions monitoring. We expectthese additional efforts will help us to support a periodicreview ofall EPA reference methods and performance standards for possible incorporation by reference (IBR) ofVCS in lieu ofor as alternatives to EPA procedures. We anticipate thatthese activities will provide an opportunity for further review, consideration and possibleIBRofVCS overlooked in theNational Standards ServiceNetwork (NSSN) searches orfinalized afterFederal agency review in the EPA rulemaking process. We conducted searches for National Emission Standards for Hazardous AirPollutants for Primary Aluminum Reduction Plants through the Enhanced NSSNDatabase managed by the AmericanNational 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 of40 CFR Part 60, AppendixA. 

# No applicable voluntary consensus standards were identified for EPAMethods 22 and 315. One voluntary consensus standards was identified as an acceptable alternativeto the EPAtestmethods for the purpose ofthis rule. The voluntary consensus standard ASTMD6748-02 "StandardTest 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, ifthe title or abstract (ifprovided) oftheVCS described technical sampling and analytical procedures that are similm· to EPA'sreference method, the MTG considered it as a potential equivalent method. All potential standards were reviewed to determinethe practicality ofthe VCS for this rule. This review requires significant method validation data whichmeetsthe requirements ofEPA Method 301 for accepting alternative methods or scientific, engineering and policy equivalenceto procedures in EPA reference methods. The MTG mayreconsider determinations ofimpracticality when additional information is available for particularVCS. The search identified 13 otherVCS that were potentially applicable forthis rule in lieu ofEPAreference methods. After reviewing the available standards, EPA determined that 13 candidateVCS (ASTM D3154-00 (2006), ASTMD3464-96 (2007), ASTM D3796-90 (2004), ISO 10780:1994, ASME B133.9- 1994 (2001), ISO 9096:1992 (2003), ANSI/ASME PTC-38-1980 (1985), ASTMD3685/D3685M-2013, CAN/CSAZ223.1-M1977, ASTM D3268-91 (2011), ASTMD3266-91 (2011), EN 13211:2001, CAN/CSAZ223.26-M1987) 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 13 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 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 Hazardous Air Pollutants for Primary Aluminum Reduction Plants. SIMILAR EPA STANDARD VOLUNTARYCONSENSUSSTANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS REFERENCE STANDARD METHOD EPA Methods 1, 2, 3 ASTM D3154-00 (2006)

- Standard Method for This method is impractical as an alternative to EPA Average Velocity in a Duct (Pitot Tube Method) Methods 1, 2, 2C, 3, 3B and 4 for the purposes of this rule since the standard appears to lack in quality control and quality assurance requirements. Specifically, ASTM D3154 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 of the temperature sensors.
EPA

Method 2 ASTM D3464-96 (2007)

- Standard Test Method This method is impractical as an alternative to EPA Method Average Velocity in a D_uct Using a Thermal 2 for the purposes of this rule primarily because Anemometer applicability specifications 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 of the method in these areas.
EPA

Method 2 ISO 10780:1994

- Stationary Source Emissions- This method is impractical as an alternative to EPA Method Measurement ofVelocity and Volume Flowrate of Gas 2 in this rule. The standard recommends the use of anLI

## SIMILAR EPA EPA'S COMMENTS ON VOLUNTARY CONSENSUS

I 

## STANDARD

VOLUNTARY CONSENSUS STANDARD

REFERENCE STANDARD METHOD I 

## Streams in Ducts shaped pitot, which historically has not been recommended

I



## by

EPA. The EPA specifies the S-type design, which has large openings that are less likely to plug up with dust. EPAMethod2

ASTM D3796-90 (2004)- Standard Practice for This ASTM standard is intended to be a calibration Calibration of TypeS Pitot Tubes procedure for the S-type pitot tube and not a method by

. which

stack gas velocity and/or volumetric flowrates can be

I 

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

Emissions from Stationary Gas Turbine Engines for this source category that includes technical descriptions

(Revision of ANSI Bl33.9-1979) of 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?



## 2

### SIMILAR EPA STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS REFERENCE STANDARD I



### METHOD EPA Method 5

ISO 9096:1992 (2003)- Determination of This method is not acceptable as an alternative for EPA Concentration and Mass Flow Rate of Particulate Method 5. Although sections of ISO 9096 incorporate EPA Matter in Gas Carrying Ducts-Manual Gravimetric Methods 1, 2, and 5 to some degree, this ISO standard is Method not equivalent to EPA Method 5 for collection of particulate matter. The standard ISO 9096 does not provide

I 

### applicable

technical guidance for performing many of the integral procedures specified in Method 5. Major performance and operational details are lacking or nonexistent,

and detailed quality assurance/quality control guidance for the sampling operations required to produce quality, representative particulate data (e.g., guidance for maintaining and monitoring train operating temperatures, specific leak check guidelines and procedures, and sample preparation and recovery procedures) are not provided by
the standard, as in EPA Method 5. Also, details of equipment and/or operational requirements, such as those specified in EPA Method 5, are not included in the ISO standard, e.g., stack gas moisture measurements, data reduction guidance, and particulate sample calculations.

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

the

Concentration of Particulate Matter in Gas Streams Methods 1 and 2. The difference between this standard and EPA Methods 5 and 1 7 is, in general, that ASME PTC- 3 8-

80 is not specific about equipment requirements, and instead presents the options available and the pro's and con's of each option. The key specific differences between ASME PTC-38-80 and the EPA methods are that the ASME standard: 1) allows in-stack filter placement as compared to the out-of-stack filter placement in EPA

.... .)SIMILAR EPA STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS REFERENCE STANDARD METHOD Methods 5 and 17; 2) allows many different types of nozzles, pitots, and filtering equipment; 3) does not specify

a filter weighing protocol or a minimum allowable filter weight fluctuation as in the EPA methods; and 4) allows filter paper to be only 99 percent efficient, as compared to
the 99.95 percent efficiency required by the EPA methods.

EPA Method 5, 17 ASTM D3685/D3685M-98-13- Test Methods for This method is similar to EPA Method 5 and 17, but is Sampling and Determination of Particulate Matter in lacking in the following areas that are needed to produce
Stack Gases quality, representative particulate data: (1) requirement that
the filter holder temperatUre should be between l20°C and 134°C, and not just "above the acid dew-point;" (2) detailed specifications for measuring and monitoring the filter holder temperature during sampling; (3) procedures similar

to EPA Methods 1, 2, 3, and 4, that are required by EPA Method 5; (4) technical guidance for performing the Method 5 sampling procedures, e.g., maintaining and monitoring sampling train operating temperatures, and use

of reagent blanks for determining and subtracting background contamination; and (5) detailed equipment and/or operational requirements, e.g., component exchange leak checks, use of glass cyclones for heavy particulate loading and/or water droplets, operating under a negative stack pressure, exchanging particulate loaded filters, sampling preparation and implementation guidance, sample recovery guidance, data reduction guidance, and particulate sample calculations input.

4SIMILAR EPA STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS REFERENCE STANDARD METHOD EPA Method 5

CAN/CSA Z223.1-M1977- Method for the This standard is not acceptable as an alternative for EPA Determination of Particulate Mass Flows in Enclosed Method 5. Detailed technical procedures and quality

Gas Streams control measures that are required in EPA Methods 1 2 3 and 4 are not included in CAN/CSA Z223 .1. Second: ' ' CAN/CSA Z223 .1 does not include the EPA Method 5 filter weighing requirement to repeat weighing every six hours until a constant weight is achieved. Third, EPA Method 5 requires the filter weight to be reported to the nearest 0.1 mg, while CAN/CSA Z223.1 requires only to the nearest 0.5 mg. Also, CAN/CSA Z223 .1 allows the use

of a standard pitot for velocity measurement when plugging

of the tube opening is not expected to be a problem, whereas, EPA Method 5 requires an S-shaped pitot. Provides additional sampling options other than what is acceptable in EPA Method 23.

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

14, and 14A

Separation and Collection of Particulate and Gaseous emissions, since flows are limited to 0.5 cfm and isokinetic Fluorides in the Atmosphere (Sodium Bicarbonate sampling is not done. Also, this standard is a sampling 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 for atmospheric

14, and 14A

Separation and Collection of Particulate and Acidic emissions, since flows are limited to 0.5 cfm and isokinetic Gaseous Fluoride in the Atmosphere (Double Paper sampling is not done. Also, this standard is a sampling
Tape Sampler Method) procedure only.
5SIMILAR EPA STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS REFERENCE STANDARD METHOD EPA Method 29

EN 13211:2001 -Air Quality Stationary Source EN 13211 is not acceptable as an alternative to the mercury Emissions Determination of the Concentration of Total portion of EPA Method 29 primarily because it is not Mercury validated for use with impingers

, as in the EPA method, although the method describes procedures for the use of impingers. This European standard is validated for the use offritted

bubblers only and requires the use of a side (split)



# . stream arrangement for isokinetic sampling because of the low sampling rate of the bubblers (up to 3 liters per minute, maximum). Also

, only two bubblers (or impingers) are required

by EN 13211, whereas EPA Method 29 require the use of six impingers. In addition, EN 13211 does not include many of the quality control procedures of EPA Method 29

, especially for the use and calibration of temperature sensors and controllers, sampling train assembly and disassembly, and filter weighing. This standard is not acceptable as an alternative to EPA Methods

29 (mercury only), and Method 30B, for the cold vapor atomic

absorption spectrometry (CV AAS) analytical procedures only, because of lack of detail in quality control.

EPA Method 29

CAN/CSA Z223.26-M1987- Measurement of Total This standard is not acceptable as an alternative to EPA Mercury in Air Cold Vapour Atomic Absorption Methods 29 (mercury only), 101, and 10 1A, for the cold Spectrophotometeric Method vapor atomic absorption spectrometry (CVAAS) analytical procedures only, because of lack of detail in quality control. Specifically, CAN/CSA Z223.26 does not include specifications for the number of calibration samples to be analyzed, procedures to prevent carryover from one sample

to the next, and procedures for subtraction of the instrument response to calibration blank as in the EPA methods. Also,

**~--** 

### 6SIMILAR EPA STANDARD VOLUNTARY CONSENSUS STANDARD EPA'S COMMENTS ON VOLUNTARY CONSENSUS REFERENCE STANDARD METHOD CAN/CSA Z223 .26 does not require that the calibration curve be forced through or close to zero (or a point no further

than 2 percent of the recorder full scale) as in the EPA methods. Also, CAN/CSA Z223 .26 does not include

a procedure to assure that two consecutive peak heights agree within 3 percent of their average value and that the peak maximum is greater than 10 percent of the recorder full scale, as in the EPA methods. CAN/CSA Z223 .26 does not include instructions for a blank and a standard to be run

at

least every five samples, and specifications for the peak height of the blank and the standard as in the EPA methods.



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