Environmental Protection Agency (EPA) Fiscal Year 2020 Agency Report

1. Please provide a summary of your agency’s activities undertaken to carry out the provisions of OMB 

Circular A-119, “Federal Participation in the Development and Use of Voluntary Consensus Standards 

and in Conformity Assessment Activities” and the National Technology Transfer and Advance Act 

(NTTAA). The summary should contain a link to the agency’s standards-specific website(s) where 

information about your agency’s standards and conformity assessment related activities are available.

In FY2020 the United States Environmental Protection Agency (EPA) continued to comprehensively carry 

out the provisions of OMB Circular A-119, “Federal Participation in the Development and Use of Voluntary 

Consensus Standards and in Conformity Assessment Activities” and the National Technology Transfer 

and Advance Act (NTTAA).

In FY2019 EPA reported on the development of an internal process to approve and manage staff 

participation in Voluntary Consensus Standards (VCS) and other private sector standards. Consistent with 

OMB Circular A-119, this internal process helps to ensure that EPA’s participation in private sector 

standards activities is aligned to our mission and strategic priorities, coordinated across the Agency, 

coordinated with other government agencies, and consistent with related laws and policies. This internal 

process additionally highlights the importance of Agency participation in standards development, as 

directed by the National Technology Transfer and Advancement Act (NTTAA) and OMB Circular A-119.

EPA continued implementation of this internal process in FY2020, including extensive outreach to 

managers and senior leadership responsible for EPA’s 100+ staff currently participating in standards 

development activities. In FY2020 EPA offices continued to prioritize participation in VCS and other 

private sector standards development activities as an important means to advance EPA’s mission.

We highlight the following as examples: 

A. American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE) Guidelines for 

Protecting Building Occupants from Smoke During Wildfire and Prescribed Burn Events Committee 

(GPC44).

Early in 2020, EPA’s Office of Air and Radiation (OAR) and Office of Research and Development (ORD) 

worked with the National Institute of Standards and Technology (NIST) to propose that ASHRAE develop 

a guideline for protecting building occupants from smoke during wildfire and prescribed burn events. 

ASHRAE approved the proposal and a Committee (GP44) was formed in mid-2020. EPA's objectives are 

to ensure that the developed guideline includes the best technology and science related to monitoring of 

wildfire smoke and mitigating its health impacts. EPA also wants to ensure that the guideline aligns with 

current interagency guidance on mitigating the impacts of wildfire smoke. Because of the urgent need to 

protect building occupants from infiltration of wildfire smoke, a subset of this committee developed interim 

guidance in the fall of 2020. EPA was an integral part of this group that identified technical information 

from a range of disciplines (Heating, ventilation, and air conditioning (HVAC) engineers, epidemiologists, 

public health officials, architects) and synthesized it into an easy to understand process for building 

managers. The interim guidance emphasizes the importance of a smoke readiness plan, and addresses 

issues such as upgrading air filters, use of portable air cleaners, and HVAC system management during 

the SARS-CoV-2 pandemic. This interim guidance was approved by the full ASHRAE committee ahead of 

the 2021 wildfire season.

B. ASTM International committee E35 (Pesticides, Antimicrobials, and Alternative Control Agents), 

subcommittee E35.15 (Antimicrobial Agents)

EPA’s Office of Pesticide Programs (OPP) within the Office of Chemical Safety and Pollution Prevention 

(OCSPP) actively participates with ASTM International Committee E35 and Subcommittee E35.15 to 

develop new and revise existing standard methods for disinfectant efficacy testing (e.g., towelette testing, 

laundry sanitizers, virology testing) and to advance relevant research in these areas. As of FY2020 there 

are twelve ASTM standards that pertain to OPP’s regulatory guidance, including to the Series 810 - 

Product Performance Test Guidelines, which are generally intended to meet testing requirements for the 
effectiveness of pesticide products under the Federal Insecticide, Fungicide, and Rodenticide Act 

(FIFRA). EPA staff serve as the technical contacts for five of these ASTM standards. Within the ASTM 

standards development process, technical contacts play an important role that may include serving as the 

primary author of a new or revised standard, addressing technical questions about the standard from the 

public, etc.

C. American National Standards Institute (ANSI) development of the Standardization Roadmap for 

Unmanned Aircraft Systems (Version 2.0)

EPA’s Office of Pesticide Programs (OPP) within the Office of Chemical Safety and Pollution Prevention 

(OCSPP)

provided guidance and comment on the American National Standards Institute (ANSI) development of the

Standardization Roadmap for Unmanned Aircraft Systems (Version 2.0). This roadmap was published by 

the ANSI Unmanned Aircraft System Standardization Collaborative (UASSC). The UASSC’s mission is to 

coordinate and accelerate the development of the standards and conformity assessment programs 

needed to facilitate the safe integration of unmanned aircraft systems (UAS) – commonly known as drones 

– into the national airspace system (NAS) of the United States. The UASSC is also focused on 

international coordination and adaptability. The Roadmap identifies existing standards and standards in 

development, defines where gaps exist, and makes recommendations for priority areas where there is a 

perceived need for additional standardization. EPA’s review and comment toward the roadmap provided 

related to the development of section 8.3.2 of the Roadmap, Pesticide Application.

D. NSF/ANSI/CAN 61: Drinking Water System Components

EPA’s Office of Research and Development (ORD) participates in the NSF International committees 

responsible for developing NSF/ANSI/CAN 61. In FY 2020, the Office of Ground Water and Drinking 

Water (OGWDW) within EPA’s Office of Water undertook rulemaking under the Reduction of Lead in 

Drinking Water Act (RLDWA). ORD and OGWDW worked closely to ensure that, as much as possible, 

modifications to NSF/ANSI/CAN 61 could be made to keep it consistent with RLDWA so that use of 

NSF/ANSI/CAN 61 could fulfil EPA’s needs specified in the final rule “Use of Lead Free Pipes, Fittings, 

Fixtures, Solder, and Flux for Drinking Water.” The revised NSF/ANSI/CAN 61 contains aspects that fulfill 

the RLDWA - as well as other aspects that go beyond the RLDWA – without imposing additional testing 

burden on the plumbing and plumbing products industry. This modification helped increase industry 

acceptance of the final rule since many plumbing manufacturers have a history of reliance on 

NSF/ANSI/CAN 61.

EPA has also been working within NSF/ANSI/CAN 61 to get the acceptance criterion for lead release 

certification under NSF/ANSI/CAN 61 Section 9 lowered, to provide better health protection against lead 

contamination for products used in schools and day care centers, as well as residences and commercial 

buildings. This revision to the NSF/ANSI/CAN 61 standard was done through the NSF standard Task 

Group process. With the 2020 edition of NSF/ANSI/CAN 61 the lower lead acceptance criterion became a 

voluntary test with new product labeling requirements to help consumers identify the lowest lead-leaching 

products. There is also a multi-year phase in to make the lower lead acceptance criterion a mandatory 

component of NSF/ANSI/CAN 61 in the future.

In addition, we highlight additional examples from FY 2019 that were not included in EPA’s FY 2019 

reporting:

A. NSF/ANSI 426-2018: Environmental Leadership and Corporate Social Responsibility Assessment of 

Servers

Rare earths are a key material used in hard disk drives used in servers. Mining of rare earths has 

significant impacts on water and soil quality, generates waste, and requires energy use. Reusing rare 

earths can help reduce the impacts of mining as well as increase the resiliency and security of the United 

States by ensuring access to these materials for new products. The U.S. government has indicated its 

interest in increasing recycling of rare earths and other critical minerals in EO13817 – A Federal Strategy 
to Ensure Secure and Reliable Supplies of Critical Minerals.

EPA initiated development of criteria to include in NSF/ANSI 426 addressing these issues. EPA 

conducted outreach to and collaborated with the U.S. Department of Energy’s (DOE’s) Critical Materials 

Institute, Seagate (a major disk drive manufacturer), the Green Electronics Council (GEC), and other 

experts, encouraging them to participate in an NSF task group that would explore options and develop 

criterion for possible inclusion in NSF/ANSI 426. In FY2020 NSF/ANSI 426 incorporated criterion that:

• incentivize use of recycled rare earths in hard disk drives (criterion 7.1.4) and

• enable easier location of the hard disk drives for recyclers (criterion 9.2.4).

NSF/ANSI 426 is the first known standard built to help purchasers identify and procure more sustainable 

servers, and the first one in any sector known to incentivize use of recycled rare earths. At the time of the 

publication of this standard, there were no known instances of successful use of recycled rare earths in 

products. The criterion that incentivized use of recycled rare earths was included in the standard as an 

aspirational goal in the hopes of sparking some movement toward meeting this objective.

Spurred by the criterion in the NSF/ANSI 426, Dell decided to take on this challenge. Through the creation 

of innovative partnerships with suppliers, Dell was able to develop a new closed-loop process to recover 

the rare earth magnets from recovered enterprise equipment. The magnets are reformed for reuse in new 

hard-disk drives (HDDs) in Dell Latitude 5400 and 5500 notebooks.

During the pilot alone, Dell diverted 660 pounds of magnet material from landfills to create 25,000 HDDs. 

The process is scalable to use over 8,000 pounds of magnet material to create over 300,000 closed-loop 

HDDs annually. The same process can be adapted to build drives for other drive models by reshaping the 

magnets or even in other magnet industries such as magnetic resonance imaging (MRI) machines or 

electric vehicle motors. EPA awarded Dell a 2019 EPA Sustainable Materials Management Electronics 

Challenge Gold Award Winner for this work.

B. The NELAC (National Environmental Laboratory Accreditation Council) Institute (TNI)

Throughout FY2019, EPA’s Office of Water collaborated with The NELAC (National Environmental 

Laboratory Accreditation Council) Institute (TNI) on updating and implementing TNI standards that focus 

on laboratory accreditation as it relates to the Clean Water Act (CWA). This collaboration helps to improve 

consistency of the various state wastewater laboratory certification programs, as essential components of 

each state’s National Pollutant Discharge Elimination System (NPDES) permit program.

C. Standard Methods

EPA’s Office of Water completed a collaborative effort with the Standard Methods Committee (which is 

responsible for developing Standard Methods for the Examination of Water and Wastewater) that began 

in FY2018 to develop a method for the analysis of peracetic acid (PAA) in wastewater. EPA supported the 

design of the method and a unique interlaboratory method validation study that brought together multiple 

analysts in a single location in order to validate the method for an analyte with a very short holding time 

(e.g., minutes). A proposed version of Standard Method 4500-PAA PERACETIC ACID (RESIDUAL) was 

published in October of 2019. EPA expects to propose the method for inclusion at 40 CFR 136 in a future 

rulemaking effort.

D. Standard Methods and ASTM International D19 Committee on Water

EPA’s Office of Water is finalizing a Methods Update Rule (MUR) to allow the use of additional Voluntary 

Consensus Standards (VCSs) for determinations of microbial and chemical pollutants in wastewater. EPA 

proposed to revise 40 CFR 136 (October 22, 2019, 84 FR 56590), which lists analytical testing 

procedures (methods) required to be used by industries and municipalities when analyzing the chemical, 

physical, and biological properties of wastewater and other environmental samples for reporting under the 

EPA’s National Pollutant Discharge Elimination System (NPDES) permit program. 

(https://www.federalregister.gov/documents/2019/10/22/2019-22437/clean-water-act-methods-updaterule-for-the-analysis-of-effluent)
EPA worked directly with the Standard Methods Committee and the ASTM D19 Committee to include, 

enhance, or clarify the quality control requirements associated these methods, where feasible. EPA then 

requested that these organizations submit to EPA new VCSs and revised versions of older VCSs to be 

considered for inclusion in a proposed Methods Update Rule (MUR) related to the NPDES permit 

program. Standard Methods and ASTM International submitted these revised VCSs with changes clearly 

identified and new VCSs with supporting performance data. EPA reviewed all information to ensure the 

methods were appropriate for use as alternatives to the existing EPA-approved methods for NPDES 

compliance monitoring. EPA published the proposed rule on October 22, 2019 and took public comments 

on the incorporation of these VCSs into the regulations at 40 CFR 136.3. All of these VCSs were favorably 

received by the public. EPA plans to finalize these methods into the 40 CFR 136.3 regulations in Spring 

2021.

The MUR contained four revised microbiological and 27 revised chemical methods from Standard 

Methods, and 46 revised chemical methods and minor editorial changes from ASTM.

2. Please list the government-unique standards (GUS) your agency began using in lieu of voluntary 

consensus standards during FY 2020. Please note that GUS which are still in effect from previous years 

should continue to be listed, thus the total number in your agency's report will include all GUS currently in 

use (previous years and new as of this FY): 39

(1) Government Unique Standard

EPA Method 1 – Traverse Points, Stationary Sources [Incorporated: 2001]

Voluntary Standard

ASTM D3154-00, Standard Method for Average Velocity in a Duct (Pitot Tube Method)

Rationale

1. The standard appears to lack in quality control and quality assurance requirements. It 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. 2. They are too general, 

too broad, or not sufficiently detailed to assure compliance with EPA regulatory requirements.

Voluntary Standard

ASTM D3154-91 (1995), Standard Method for Average Velocity in a Duct (Pitot Tube Method)

Rationale

Is too general, too broad, or not sufficiently detailed to assure compliance with EPA regulatory 

requirements.

(2) Government Unique Standard

EPA Method 10 [Incorporated: 2015]

Voluntary Standard

ANSI/ASME PTC 19-10-1981-Part 10

ISO 10396:1993 (2007)

ISO 12039:2001

ASTM D5835-95 (2007)

ASTM D6522-00 (2005)
CAN/CSA Z223.2-M86 (1999)

CAN/CSA Z223.21-M1978

ASTM D3162-94 (2005)

Rationale

The use of these voluntary consensus standards would not be practical with applicable law due 

to a lack of equivalency, documentation, validation data and other important technical and 

policy considerations.

(3) Government Unique Standard

EPA Method 101 - Mercury Emissions, Chlor-Alkali Plants (Air) [Incorporated: 2001]

Voluntary Standard

ASTM D6216-98 - Standard Practice for Opacity Monitor Manufacturers to Certify 

Conformance with Design and Performance Specifications.

Rationale

The EPA is incorporating ASTM D6216 (manufacturers certification) by reference into EPA 

Performance Specification 1, Sect. 5 & 6 in another rulemaking. ASTM D6216 does not address 

all the requirements specified in PS-1.

(4) Government Unique Standard

EPA Method 101a - Mercury Emissions Sewer/Sludge Incinerator [Incorporated: 2001]

Voluntary Standard

ASTM D6216-98 - Standard Practice for Opacity Monitor Manufacturers to Certify 

Conformance with Design and Performance Specifications.

Rationale

The EPA is incorporating ASTM D6216 (manufacturers certification) by reference into EPA 

Performance Specification 1, Sect. 5 & 6 in another rulemaking. ASTM D6216 does not address 

all the requirements specified in PS-1.

(5) Government Unique Standard

EPA Method 10A – Carbon Monoxide for Certifying CEMS [Incorporated: 2001]

Voluntary Standard

CAN/CSA Z223.21-M1978, Method for the Measurement of Carbon Monoxide: 3—Method of 

Analysis by Non-Dispersive Infrared Spectrometry.

Rationale

1. It is lacking in the following areas: (1) Sampling procedures; (2) procedures to correct for the 

carbon dioxide concentration; (3) instructions to correct the gas volume if CO2 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 maximum as compared to the 

measured value: The standard specifies that the instruments should be compatible with the 

concentration of gases to be measured, whereas EPA Method 10 specifies that the instrument 
span value should be no more than 1.5 times the source performance standard. 2. Is too general, 

too broad, or not sufficiently detailed to assure compliance with EPA regulatory requirements.

(6) Government Unique Standard

EPA Method 12 – Inorganic Lead, Stationary Sources [Incorporated: 2000]

Voluntary Standard

ASTM D4358-94 (1999), Standard Test Method for Lead and Chromium in Air Particulate 

Filter Samples of Lead Chromate Type Pigment Dusts by Atomic Absorption Spectroscopy

Rationale

These ASTM standards do not require the use of glass fiber filters as in EPA Method 12 and 

require the use of significantly different digestion procedures that appear to be milder than the 

EPA Method 12 digestion procedure. For these reasons, these ASTM standards cannot be 

considered equivalent to EPA Method 12. Also, the subject ASTM standards do not require the 

use of hydrogen fluoride (HF) as in EPA Method 29 and, therefore, they cannot be used for the 

preparation, digestion, and analysis of Method 29 samples. Additionally, Method 29 requires 

the use of a glass fiber filter, whereas these three ASTM standards require cellulose filters and 

other probable nonglass fiber media, which cannot be considered equivalent to EPA Method 29.

Voluntary Standard

ASTM E1741-95 (1995), Standard Practice for Preparation of Airborne Particulate Lead 

Samples Collected During Abatement and Construction Activities for Subsequent Analysis by 

Atomic Spectrometry

Rationale

These ASTM standards do not require the use of glass fiber filters as in EPA Method 12 and 

require the use of significantly different digestion procedures that appear to be milder than the 

EPA Method 12 digestion procedure. For these reasons, these ASTM standards cannot be 

considered equivalent to EPA Method 12. Also, the subject ASTM standards do not require the 

use of hydrogen fluoride (HF) as in EPA Method 29 and, therefore, they cannot be used for the 

preparation, digestion, and analysis of Method 29 samples. Additionally, Method 29 requires 

the use of a glass fiber filter, whereas these three ASTM standards require cellulose filters and 

other probable nonglass fiber media, which cannot be considered equivalent to EPA Method 29.

Voluntary Standard

ASTM E1979-98 (1998), Standard Practice for Ultrasonic Extraction of Paint, Dust, Soil, and 

Air Samples for Subsequent Determination of Lead

Rationale

These ASTM standards do not require the use of glass fiber filters as in EPA Method 12 and 

require the use of significantly different digestion procedures that appear to be milder than the 

EPA Method 12 digestion procedure. For these reasons, these ASTM standards cannot be 

considered equivalent to EPA Method 12. Also, the subject ASTM standards do not require the 

use of hydrogen fluoride (HF) as in EPA Method 29 and, therefore, they cannot be used for the 

preparation, digestion, and analysis of Method 29 samples. Additionally, Method 29 requires 
the use of a glass fiber filter, whereas these three ASTM standards require cellulose filters and 

other probable nonglass fiber media, which cannot be considered equivalent to EPA Method 29.

(7) Government Unique Standard

EPA Method 15 – Determination of Hydrogen Sulfide, Carbonyl Sulfide, and Carbon Disulfide 

Emissions from Stationary Sources [Incorporated: 2018]

Voluntary Standard

ASTM D4323-84 (2009) - Standard Test Method for Hydrogen Sulfide in the Atmosphere by 

Rate of Change of Reflectance

Rationale

This standard is not acceptable as an alternative to EPA Method 15 since it only applies to 

concentrations of H2S from 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 a multi-point curve of EPA Method 15.

(8) Government Unique Standard

EPA Method 17 - Particle Matter (PM) In Stack Filtration [Incorporated: 2001]

Voluntary Standard

ASME C00049

Rationale

EPA looked at this standard for both Pulp and Paper Hazardous Air Pollutant rules and for the 

Small Municipal Waste Combustion rule. Contains sampling options beyond which would be 

considered acceptable for Method 5.

Voluntary Standard

ASTM D3685/3685M-95 - Standard Test method for Sampling and Determination of Particle 

Matter in Stack Gases

Rationale

EPA looked at this standard for both Pulp and Paper Hazardous Air Pollutant rules and for the 

Small Municipal Waste Combustion rule. Contains sampling options beyond which would be 

considered acceptable for Method 5.

(9) Government Unique Standard

EPA Method 18 [Incorporated: 2016]

Voluntary Standard

ASTM D6420-99 (2010)

ASTM D6060-17

Rationale

ASTM D6420-99 (2010) “Test method for Determination of Gaseous Organic Compounds by 

Direct Interface Gas Chromatography/Mass Spectrometry”
The use of this voluntary consensus standard would not be practical due to a lack of 

equivalency, documentation, validation data and other important technical and policy 

considerations. The EPA did not receive comments during the notice and comment period that 

caused us to alter the standards and methods in the final permits.

ASTM D6060-17 - Practice for Sampling of Process Vents with a Portable Gas 

Chromatography

This ASTM standard lacks key quality control and assurance requirements included in EPA 

Method 18. For example, ASTM D6060: 1) lacks the requirement of three reference standards 

in triplicate; 2) lacks the calibration acceptance criteria that the triplicate calibration standards 

agree within 5 percent of their average; 3) lacks a post-sampling volume flow rate check and 

requirement to repeat the test if the pre- and post-test flowrates differ by more than 20 percent; 

4) lacks triplicate samples for recovery tests and allows a 15 percent difference between the pretest and recovery test data vs. 10 percent for Method 18; 4) lacks the accuracy performance 

criteria of 10 percent of the preparation value for audit samples; 5) lacks 

reporting/documentation requirements. Also, ASTM D6060 does not include procedures for 

sample collection using other media, such as bags and solid sorbents.

(10) Government Unique Standard

EPA Method 2 – Velocity and S-type Pitot [Incorporated: 1999]

Voluntary Standard

ASTM D3464-96 (2001)

ASTM D3154 – 00 (2014)

ASTM D3463-96 (2014)

ASTM D3796-90 (2016)

ASME B133.9-1994 (2001)

Rationale

ASTM D3464-96 (2001), Standard Test Method Average Velocity in a Duct Using a Thermal 

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.

ASTM D3154 – 00 (2014), Standard Method for Average Velocity in a Duct (Pitot Tube 

Method): (added to Annual Report in FY2018) 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, heir calibration must be checked after 

each test series; and 3) the frequency and validity range for calibration of the temperature 

sensors. (not for EPA Methods 1, 2, 2C, 3, 3B, 4).

ASTM D3463-96 (2014), Standard Test Method Average Velocity in a Duct Using a Thermal 

Anemometer: (added to Annual Report in FY2018) 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 of the method in these areas.

ASTM D3796-90 (2016), Standard Practice for Calibration of Type S Pitot Tubes: (added to 

Annual Report in FY2018) 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.

ASME B133.9-1994 (2001) - Measurement of Exhaust Emissions from Stationary Gas Turbine 

Engines (this is the latest version, method has been withdrawn with no future updates): (added 

to Annual Report in FY2018) Not a quantitative method, per se, although a good primer for this 

source category that includes technical descriptions 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. Not a method. (not for EPA Methods 2, 3A, 4, 5).

Voluntary Standard

ISO 10780:1994, Stationary Source Emissions-- Measurement of Velocity and Volume 

Flowrate of Gas Streams in Ducts

Rationale

The standard recommends the use of an L-shaped 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.

(11) Government Unique Standard

EPA Method 21 - Volatile Organic Compound (VOC) Leaks [Incorporated: 2003]

Voluntary Standard

ASTM E1211-97 - Standard Practice for Leak Detection and Location Using Surface-Mounted 

Acoustic Emission Sensors

Rationale

This standard will detect leaks but not classify the leak as VOC, as in EPA Method 21. In 

addition, in order to detect the VOC concentration of a known VOC leak, the acoustic signal 

would need to be calibrated against a primary instrument. Background noise interference in 

some source situations could also make this standard difficult to use effectively.

(12) Government Unique Standard

EPA Method 24 – Determination of Volatile Matter Content, Water Content, Density, Volume 

Solids, and Weight Solids of Surface Coating [Incorporated: 2018]

Voluntary Standard

ASTM D3960-05, ASTM D6053-14, ISO 11890-1 (2000), ISO 11890-2 (2000) Part 2, ISO 

3233:1998

Rationale

ASTM D3960-05 - Standard Practice for Determining Volatile Organic Compound (VOC) 

Content of Paints and Related Coating: This standard measures the VOC content whereas EPA 
Method 24 determines volatile matter content (and water content, density, volume solids, and 

weight solids). If the regulation allows for the use of VOC content as a surrogate for HAP, then 

this method is an acceptable alternative to Method 24. If the regulation requires the 

measurement of volatile matter content, as in Method 24, then this standard is not acceptable;

ASTM D6053-14 - Standard Test Method for Determination of Volatile Organic Compound 

(VOC) Content of Electrical Insulating Varnishes: Under a separate action, the EPA is 

incorporating ASTM D6053-96 by reference into EPA Method 24. This standard will only be 

applicable for a specific type of coating (electrical insulating varnishes). Specimen size for 

magnet wire coating must be 2.0 grams +/- 0.1 grams;

ISO 11890-1 (2000) Part 1: Paints and Varnishes Determination of Volatile Organic Compound 

(VOC) Content Difference Method: This standard has different test conditions than EPA 

Method 24 and therefore is unacceptable as an alternative to Method 24 because measured 

nonvolatile matter content can vary with experimental factors such as temperature, length of 

heating period, size of weighing dish, and size of sample. ISO 11890-1 allows for different dish 

weights and sample sizes than the one size (58 mm in diameter and sample size of 0.5 g) of 

EPA Method 24. ISO 11890-1 also allows for different oven temperatures and heating times 

depending on the type of coating, whereas EPA Method 24 requires 60 minutes heating at 

110oC at all times. Nonvolatile matter content is not an absolute quantity but is dependent on 

temperature and heating period. The size of the weighing dish and the size of the sample may 

also affect the nonvolatile matter measured. Because the EPA Method 24 test conditions and 

procedures define volatile matter, ISO 11890 1 is unacceptable as an alternative;

ISO 11890-2 (2000) Part 2: Paints and Varnishes-Determination of Volatile Organic Compound 

(VOC) Content Gas Chromatographic Method: This standard only measures the VOC added to 

the coating and would not measure any VOC generated from the curing of the coating. The EPA 

Method 24 does measure cure VOC, which can be significant in some cases, and, therefore, ISO 

11890-2 is not an acceptable alternative to EPA Method 24.

ISO 3233:1998 - Paints and Varnishes-Determination of Percentage Volume of Nonvolatile 

Matter by Measuring the Density of a Dried Coating: This ISO standard is more applicable as a 

manufacturing tool than an emissions standard, since it measures the amount of coverage of a 

coating using a dipping plate.

(13) Government Unique Standard

EPA Method 28 (Section 10.1) – Wood Heaters, Certificate and Auditing [Incorporated: 2003]

Voluntary Standard

ASME Power Test Codes, Supplement on Instruments and Apparatus, part 5, Measurement of 

Quantity of Materials, Chapter 1, Weighing Scales

Rationale

It does not specify the number of initial calibration weights to be used nor a specific pretest 

weight procedure.

Voluntary Standard

ASTM E319-85 (Reapproved 1997), Standard Practice for the Evaluation of Single-Pan 

Mechanical Balances
Rationale

This standard is not a complete weighing procedure because it does not include a pretest 

procedure.

(14) Government Unique Standard

EPA Method 29 – Metals Emissions from Stationary Sources [Incorporated: 2001]

Voluntary Standard

ASTM D4358-94 (1999), Standard Test Method for Lead and Chromium in Air Particulate 

Filter Samples of Lead Chromate Type Pigment Dusts by Atomic Absorption Spectroscopy

Rationale

These ASTM standards do not require the use of glass fiber filters as in EPA Method 12 and 

require the use of significantly different digestion procedures that appear to be milder than the 

EPA Method 12 digestion procedure. For these reasons, these ASTM standards cannot be 

considered equivalent to EPA Method 12. Also, the subject ASTM standards do not require the 

use of hydrogen fluoride (HF) as in EPA Method 29 and, therefore, they cannot be used for the 

preparation, digestion, and analysis of Method 29 samples. Additionally, Method 29 requires 

the use of a glass fiber filter, whereas these three ASTM standards require cellulose filters and 

other probable nonglass fiber media, which cannot be considered equivalent to EPA Method 29.

Voluntary Standard

ASTM E1741-95 (1995), Standard Practice for Preparation of Airborne Particulate Lead 

Samples Collected During Abatement and Construction Activities for Subsequent Analysis by 

Atomic Spectrometry

Rationale

These ASTM standards do not require the use of glass fiber filters as in EPA Method 12 and 

require the use of significantly different digestion procedures that appear to be milder than the 

EPA Method 12 digestion procedure. For these reasons, these ASTM standards cannot be 

considered equivalent to EPA Method 12. Also, the subject ASTM standards do not require the 

use of hydrogen fluoride (HF) as in EPA Method 29 and, therefore, they cannot be used for the 

preparation, digestion, and analysis of Method 29 samples. Additionally, Method 29 requires 

the use of a glass fiber filter, whereas these three ASTM standards require cellulose filters and 

other probable nonglass fiber media, which cannot be considered equivalent to EPA Method 29.

Voluntary Standard

ASTM E1979-98 (1998), Standard Practice for Ultrasonic Extraction of Paint, Dust, Soil, and 

Air Samples for Subsequent Determination of Lead

Rationale

These ASTM standards do not require the use of glass fiber filters as in EPA Method 12 and 

require the use of significantly different digestion procedures that appear to be milder than the 

EPA Method 12 digestion procedure. For these reasons, these ASTM standards cannot be 

considered equivalent to EPA Method 12. Also, the subject ASTM standards do not require the 

use of hydrogen fluoride (HF) as in EPA Method 29 and, therefore, they cannot be used for the 

preparation, digestion, and analysis of Method 29 samples. Additionally, Method 29 requires 
the use of a glass fiber filter, whereas these three ASTM standards require cellulose filters and 

other probable nonglass fiber media, which cannot be considered equivalent to EPA Method 29.

Voluntary Standard

CAN/CSA Z223.26-M1987, Measurement of Total Mercury in Air Cold Vapour Atomic 

Absorption Spectrophotometeric Method

Rationale

It lacks sufficient quality assurance and quality control requirements necessary for EPA 

compliance assurance requirements.

(15) Government Unique Standard

EPA Method 29 for the determination of the concentration of Hg [Incorporated: 2015]

Voluntary Standard

ASTM D6784-02 (2008), “Standard Test Method for Elemental, Oxidized, Particle-Bound and 

Total Mercury in Flue Gas Generated from Coal-Fired Stationary Sources (Ontario Hydro 

Method)”

Rationale

The use of this voluntary consensus standard would be more expensive and is inconsistent with 

the final Hg standard that was determined using EPA Method 29 data.

(16) Government Unique Standard

EPA Method 29, “Metals Emissions from Stationary Sources” [Incorporated: 2017]

Voluntary Standard

ASTM D6784–02 (Reapproved 2008), ‘‘Standard Test Method for Elemental, Oxidized, 

Particle-Bound and Total Mercury Gas Generated from Coal-Fired Stationary Sources (Ontario 

Hydro Method)’’

Rationale

The use of this voluntary consensus standard would be impractical because this standard is only 

acceptable as an alternative to the portion of EPA Method 29 for mercury, and emissions testing 

for mercury alone is not required under 40 CFR part 63, subpart MM.

(17) Government Unique Standard

EPA Method 2C - Determination of Stack Gas Velocity and Volumetric Flow Rate in Small 

Stacks or Ducts (Standard Pitot Tube) [Incorporated: 2018]

Voluntary Standard

ASTM D3154 – 00 (2014), Standard Method for Average Velocity in a Duct (Pitot Tube 

Method)

Rationale

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, 

heir calibration must be checked after each test series; and 3) the frequency and validity range 

for calibration of the temperature sensors. (not for EPA Methods 1, 2, 2C, 3, 3B, 4)

(18) Government Unique Standard

EPA Method 3 – Gas Analysis for The Determination of Dry Molecular Weight [Incorporated: 

2018]

Voluntary Standard

ASTM D3154 – 00 (2014), Standard Method for Average Velocity in a Duct (Pitot Tube 

Method)

Rationale

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, 

heir calibration must be checked after each test series; and 3) the frequency and validity range 

for calibration of the temperature sensors. (not for EPA Methods 1, 2, 2C, 3, 3B, 4)

(19) Government Unique Standard

EPA Method 301- Field Validation of Pollutant Measurement Methods from Various Waste 

Media [Incorporated: 2018]

Voluntary Standard

ASTM D4855-97 (2002) - Standard Practice for Comparing Test Methods

Rationale

This ASTM standard appears to be equivalent to EPA Method 301 in its statistical design and 

decision criteria but is less prescriptive than Method 301 for many procedures. For example, the 

ASTM does not require the use of a t-test explicitly to test the precision of the alternative 

method, but instead states that a t-test or F-test should be used, as appropriate. The primary 

difference between ASTM D4855-97 and EPA Method 301, that makes the ASTM standard not 

acceptable as a complete alternative to the EPA method, is that the ASTM standard addresses 

the testing of materials rather than environmental samples. Because of this difference, the 

ASTM standard does not prescribe the use of paired samples as in the EPA method. This feature 

of EPA Method 301 is critical to its success and the acceptability of an alternate standard.

(20) Government Unique Standard

EPA Method 306 - Chromium Emissions, Electroplating and Anodizing [Incorporated: 2002]

Voluntary Standard

ASTM D4358-94 (1999) - Standard Test Method for Lead and Chromium in Air Particulate 

Filter Samples of Lead Chromate Type Pigment Dusts by Atomic Absorption Spectroscopy

Rationale

This MACT standard (Petroleum Refineries) only cites Method 29. Therefore, the following 

EPA comment is only applicable for Method 29 not Method 12 and 306: Method 29 requires the 
use of hydrofluoric acid (HF) in its process of digestion of the sample. ASTM D4358-94 (1999) 

does not require the use of HF; therefore, it cannot be used in the preparation, digestion, and 

analysis of Method 29 samples. Additionally, Method 29 requires the use of a glass fiber filter, 

whereas the subject ASTM standard requires cellulose filters and other probable non-glass fiber 

media, and this further negates their use as Method 29 equivalent methods. (Same comment as 

provided for ASTM E1741 and ASTM E1979).

(21) Government Unique Standard

EPA Method 306a - Chromium Emissions, Electroplating -- Mason Jar [Incorporated: 2002]

Voluntary Standard

ASTM D4358-94 (1999) - Standard Test Method for Lead and Chromium in Air Particulate 

Filter Samples of Lead Chromate Type Pigment Dusts by Atomic Absorption Spectroscopy

Rationale

This MACT standard (Petroleum Refineries) only cites Method 29. Therefore, the following 

EPA comment is only applicable for Method 29 not Method 12 and 306: Method 29 requires the 

use of hydrofluoric acid (HF) in its process of digestion of the sample. ASTM D4358-94 (1999) 

does not require the use of HF; therefore, it cannot be used in the preparation, digestion, and 

analysis of Method 29 samples. Additionally, Method 29 requires the use of a glass fiber filter, 

whereas the subject ASTM standard requires cellulose filters and other probable non-glass fiber 

media, and this further negates their use as Method 29 equivalent methods. (Same comment as 

provided for ASTM E1741 and ASTM E1979).

(22) Government Unique Standard

EPA Method 311 "Analysis of Hazardous Air Pollutant Compounds in Paints and Coatings by 

Direct Injection Into a Gas Chromatograph" [Incorporated: 2015]

Voluntary Standard

ASTM D6438 (1999)—Standard Test Method for Acetone, Methyl Acetate, and 

Parachlorobenzotrifluoride Content of Paints and Coatings by Solid Phase Microextraction-Gas 

Chromotography

Rationale

This methods is impractical as an alternative to EPA Method 311 because it targets chemicals 

that are VOC and are not HAP

(23) Government Unique Standard

EPA Method 3A – Carbon Dioxide and Oxygen Concentrations, IAP [Incorporated: 1999]

Voluntary Standard

ISO 12039:2001

ANSI/ASME PTC 19-10-1981(2010)

ISO 10396:(2007)

ASTM D5835-95 (2013)

ASTM D6522-11

ASTM D6522

CAN/CSA Z223.2-M86 (R1999)
Rationale

ISO 12039:2001, Stationary Source Emissions-- Determination of Carbon Monoxide, Carbon 

Dioxide, and Oxygen--Automated Methods: This ISO standard is similar to EPA Method 3A, 

but 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.

ANSI/ASME PTC 19-10-1981(2010) - Part 10 Flue and Exhaust Gas Analyses: (added to 

Annual Report in FY2018) This standard includes manual and instrumental methods of analyses 

for carbon dioxide (CO2), carbon monoxide (CO), hydrogen sulfide (H2S), nitrogen oxides 

(NOx), oxygen (O2), and sulfur dioxide (SO2). The VCS method analytes that include one or 

more of the same techniques as the EPA methods are as follows: CO2 [manual (3B, 6A and 6B) 

and instrumental (3A and 3C)]; CO [manual (3B) and instrumental (10 and 10B)], H2S [manual 

(15A and 16A) and instrumental (15, 16, and 16B) ], NOx [manual (7 and 7C) and instrumental 

(7A, 7B, 7E, 20)], O2 [manual (3B) and instrumental (3A, 3C, 20)], and SO2 [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 (SO2 part of 20 only)). 

[Note that one of the standard’s manual SO2 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, 7E, 10, 10B, 15, 16, 16B, 20 (NOx part of 20 only)) are not acceptable 

alternatives to the corresponding EPA methods.

ISO 10396:(2007) - Stationary Source Emissions: Sampling for the Automated Determination 

of Gas Concentrations: (added to Annual Report in FY2018) This standard is similar to EPA 

Methods 3A, 6C, 7E, 10, 20 (nitrogen oxides and oxygen parts of 20 only), 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 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.

ASTM D5835-95 (2013) - Standard Practice for Sampling Stationary Source Emissions for 

Automated Determination of Gas Concentration: (added to Annual Report in FY2018) This 

standard is similar to EPA Methods 3A, 6C, 7E, 10, 20 (nitrogen oxides and oxygen parts of 20 

only), 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 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 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.

ASTM D6522-11 - Standard Test Method for the Determination of Nitrogen Oxides, Carbon 

Monoxide, and Oxygen Concentrations in Emissions from Natural Gas-Fired Reciprocating 

Engines, Combustion Turbines, Boilers and Process Heaters Using Portable Analyzers: (added 

to Annual Report in FY2018) ASTM D6522 has been determined to be technically appropriate 

for identifying nitrogen oxides, carbon monoxide, and oxygen concentrations when the fuel is 

natural gas.

CAN/CSA Z223.2-M86 (R1999) - Method for the Continuous Measurement of Oxygen, Carbon 

Dioxide, Carbon Monoxide, Sulphur Dioxide, and Oxides of Nitrogen in Enclosed Combustion 

Flue Gas Streams: (added to Annual Report in FY2018) This standard is unacceptable as a 

substitute for EPA Methods 3A, 6C, 7E, 10, 10A, and 20 (nitrogen oxides and oxygen parts of 

20 only), since it does not include quantitative specifications for measurement system 

performance, most notably the calibration procedures and instrument performance 

characteristics. The instrument performance characteristics that are provided are non-mandatory 

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.

(24) Government Unique Standard

EPA Method 3B – Gas Analysis for the determination of emission rate correction Factor for 

Excess Air [Incorporated: 2018]

Voluntary Standard

ASTM D3154 – 00 (2014), Standard Method for Average Velocity in a Duct (Pitot Tube 

Method)

Rationale

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, 

heir calibration must be checked after each test series; and 3) the frequency and validity range 

for calibration of the temperature sensors. (not for EPA Methods 1, 2, 2C, 3, 3B, 4)

(25) Government Unique Standard

EPA Method 4 – Determination of Moisture Content in Stack Gas [Incorporated: 2018]

Voluntary Standard

a. ASTM D3154-00 (2014) Standard Method for Average Velocity in a Duct (Pitot Tube

Method)

b. ASME B133.9-1994 (2001) - Measurement of Exhaust Emissions from Stationary Gas 

Turbine Engines

Rationale

a. 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, 

heir calibration must be checked after each test series; and 3) the frequency and validity range 

for calibration of the temperature sensors. (not for EPA Methods 1, 2, 2C, 3, 3B, 4)

b. Not a quantitative method, per se, although a good primer for this source category that 

includes technical descriptions 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. 

Not a method. (not for EPA Methods 2, 3A, 4, 5).

(26) Government Unique Standard

EPA Method 5 [Incorporated: 2015]

Voluntary Standard

ASME B133.9-1994 (2001)

ISO 9096:1992 (2003)

ANSI/ASME PTC-38-1980 (1985)

ASTM D3685/D3685M-98 (2005)

CAN/CSA Z223.1-M1977

Rationale

The use of these voluntary consensus standards would not be practical with applicable law due 

to a lack of equivalency, documentation, validation data and other important technical and 

policy considerations.

(27) Government Unique Standard

EPA Method 515.4 – Chlorinated Acids in DW by LL Fast CG/ECD [Incorporated: 2003]

Voluntary Standard

ASTM D5317-98 -- Standard Test Method For Determination of Chlorinated Organic Acid 

Compounds in Water by Gas Chromatography With an Electron Capture Detector

Rationale

ASTM D5317-98 specifies acceptance windows for the initial demonstration of proficiency for 

laboratory fortified blank samples that are as small as 0 percent to as large as 223 percent 

recovery for picloram, with tighter criteria for other regulated contaminants. Therefore, this 

method permits unacceptably large control limits, which include 0 percent recovery.

Voluntary Standard

Standard Method 6640 B for the chlorinated acids

Rationale

The use of this voluntary consensus standard would have been impractical due to significant 

shortcomings in the sample preparation and quality control sections of the method instructions. 

Section 1b of Method SM 6640 B states that the alkaline wash detailed in section 4b2 is 

optional. The hydrolysis that occurs during this step is essential to the analysis of the esters of 

many of the analytes. Therefore, this step is necessary and cannot be optional. In addition, the 

method specifies that the quality control limits for laboratory-fortified blanks are to be based 
upon plus or minus three times the standard deviation of the mean recovery of the analytes, as 

determined in each laboratory. Therefore, this method permits unacceptably large control limits, 

which may include 0 percent recovery.

(28) Government Unique Standard

EPA Method 531.2 – N-Methylcarbamoylozimes/ates, Aqueous In/HPLC [Incorporated: 2003]

Voluntary Standard

Standard Method 6610, 20th Edition

Rationale

Standard Method 6610, 20th Edition has recently been approved for compliance monitoring. 

Standard Method 6610, 20th Supplemental Edition permits the use of a strong acid, 

hydrochloric acid (HCL), as a preservative. The preservatives in all of the other approved EPA 

and Standard Methods procedures for these analytes are weak acids that adjust the pH to a 

specific value based upon the pKa of the preservative. The use of HCL would require accurate 

determinations of the pH of the sample in the field and could be subject to considerable error 

and possible changes in pH upon storage. Although not specifically observed for oxamyl or 

carbofuran during the development of similar methods, structurally similar pesticides have been 

shown to degrade over time when kept at pH 3. Therefore, approval of this method is 

impractical because it specifies the use of a strong acid (HCL) when positive control of the pH 

is critical.

Voluntary Standard

Standard Method 6610, 20th Supplemental Edition

Rationale

Standard Method 6610, 20th Edition has recently been approved for compliance monitoring. 

Standard Method 6610, 20th Supplemental Edition permits the use of a strong acid, 

hydrochloric acid (HCL), as a preservative. The preservatives in all of the other approved EPA 

and Standard Methods procedures for these analytes are weak acids that adjust the pH to a 

specific value based upon the pKa of the preservative. The use of HCL would require accurate 

determinations of the pH of the sample in the field and could be subject to considerable error 

and possible changes in pH upon storage. Although not specifically observed for oxamyl or 

carbofuran during the development of similar methods, structurally similar pesticides have been 

shown to degrade over time when kept at pH 3. Therefore, approval of this method is 

impractical because it specifies the use of a strong acid (HCL) when positive control of the pH 

is critical.

(29) Government Unique Standard

EPA Method 5i - Low Level Particulate Matter, Stationary Sources [Incorporated: 2001]

Voluntary Standard

ASTM D6331-98

Rationale

This standard does not have paired trains as specified in method 5 and does not include some 
quality control procedures specified in the EPA method and which are appropriate to use in this 

rule.

(30) Government Unique Standard

EPA Method 6 - Determination of Sulfur Dioxide Emissions from Stationary Sources 

[Incorporated: 2018]

Voluntary Standard

a. ISO 7934:1998 (2016) - Stationary Source Emissions Determination of the Mass 

Concentration of Sulfur Dioxide Hydrogen Peroxide/Barium Perchlorate/Thorin Method

b. ISO 11632:1998 (2016) - Stationary Source Emissions Determination of the Mass 

Concentration of Sulfur Dioxide Ion Chromatography

Rationale

a. This standard is only applicable to sources with 30 mg/m3 SO2 or more. Also, this standard 

does not separate SO3 from SO2 as does the EPA methods; therefore, ISO 7934:1998 is not 

valid if more than a negligible amount of SO3 is present. Also, it does not address ammonia 

interferences.

b. Sampling procedures are similar to EPA Method 6, but lacks in detail and quality control 

procedures, such as calibration checks and leaks tests.

(31) Government Unique Standard

EPA Method 7E [Incorporated: 2015]

Voluntary Standard

ANSI/ASME PTC 19-10-1981-Part 10

ISO 10396:1993 (2007)

ASTM D5835-95 (2007)

CAN/CSA Z223.2-M86 (1999)

Rationale

The use of these voluntary consensus standards would not be practical with applicable law due 

to a lack of equivalency, documentation, validation data and other important technical and 

policy considerations.

(32) Government Unique Standard

EPA Method 9 [Incorporated: 2016]

Voluntary Standard

ASTM D7520-09 “Standard Test Method for Determining Opacity of a Plume in the Outdoor 

Ambient Atmosphere”

Rationale

The use of this voluntary consensus standard would not be practical due to a lack of 

equivalency, documentation, validation data and other important technical and policy 
considerations. The EPA did not receive comments during the notice and comment period that 

caused us to alter the standards and methods in the final permits.

(33) Government Unique Standard

EPA Method ALT 004 [Incorporated: 2002]

Voluntary Standard

ASTM D5835-95 - Standard Practice for Sampling Stationary Source Emissions for Automated 

Determination of Gas Concentration

Rationale

Similar to Methods 3a, 6c, 7e, 10, ALT 004, CTM 022. Lacks in detail and quality assurance 

and quality control requirements. Very similar to ISO 10396.

Voluntary Standard

ISO 10396:1993 - Stationary Source Emissions: Sampling for the Automated Determination of 

Gas Concentrations

Rationale

Duplicates Method 3a, 6c, 7e, 10, ALT 004, CTM 022. Lacks in detail and quality assurance 

plus quality control requirements. Similar to ASTM D5835.

(34) Government Unique Standard

EPA Method CTM 022 [Incorporated: 2002]

Voluntary Standard

ASTM D5835-95 - Standard Practice for Sampling Stationary Source Emissions for Automated 

Determination of Gas Concentration

Rationale

Similar to Methods 3a, 6c, 7e, 10, ALT 004, CTM 022. Lacks in detail and quality assurance 

and quality control requirements. Very similar to ISO 10396.

Voluntary Standard

ISO 10396:1993 - Stationary Source Emissions: Sampling for the Automated Determination of 

Gas Concentrations

Rationale

Duplicates Method 3a, 6c, 7e, 10, ALT 004, CTM 022. Lacks in detail and quality assurance 

plus quality control requirements. Similar to ASTM D5835.

(35) Government Unique Standard

EPA Performance Specification 2 (nitrogen oxide portion only) [Incorporated: 2001]

Voluntary Standard

ISO 10849:1996, Determination of the Mass Concentration of Nitrogen Oxides--Performance
Rationale

Is too general, too broad, or not sufficiently detailed to assure compliance with EPA regulatory 

requirements.

(36) Government Unique Standard

EPA Performance Specification 2 (sulfur dioxide portion only) [Incorporated: 2001]

Voluntary Standard

ISO 7935:1992, Stationary Source Emissions--Determination of the Mass Concentration of 

Sulfur Dioxide--Performance Characteristics of Automated Measuring Methods"

Rationale

Is too general, too broad, or not sufficiently detailed to assure compliance with EPA regulatory 

requirements.

(37) Government Unique Standard

SW846-6010b [Incorporated: 2002]

Voluntary Standard

ASTM C1111-98 (1998) - Standard Test Method for Determining Elements in Waste Streams 

by Inductively Coupled Plasma-Atomic Emission Spectrometers

Rationale

This standard lacks details for instrument operation QA/QC, such as optimizing plasma 

operating conditions; upper limit of linear dynamic range; spectral interference correction; and 

calibration procedures, which include initial and continuous calibration verifications. Also lacks 

internal standard and method of standard addition options for samples with interferences.

Voluntary Standard

ASTM D6349-99 (1999) - Standard Test Method for Determining Major and Minor Elements in 

Coal, Coke, and Solid Residues from Combustion of Coal and Coke by Inductively Coupled 

Plasma-Atomic Emission Spectrometers

Rationale

This standard lacks details for instrument operation QA/QC, such as optimizing plasma 

operating conditions, upper limit of linear dynamic range, spectral interference correction, and 

calibration procedures, that include initial and continuous calibration verifications. Also lacks 

details for standard preparation, and internal standard and method of standard addition options 

for samples with interferences.

(38) Government Unique Standard

Validated Method 8327: Per-and Polyfluoroalkyl Substances (PFAS) Using External Standard 

Calibration and Multiple Reaction Monitoring (MRM) Liquid Chromatography/Tandem Mass 

Spectrometry (LC/MS/MS) [Incorporated: 2019]

Voluntary Standard

ASTM D7979-19: Standard Test Method for Determination of Perfluorinated Compounds in 
Water, Sludge, Influent, Effluent and Wastewater by Liquid Chromatography Tandem Mass 

Spectrometry (LC/MS/MS)

Rationale

For the reasons set forth below, EPA determined that PFAS analytical methods should be 

validated by multiple laboratories, rather than by a single lab, for use under the Resource 

Conservation and Recovery Act (RCRA) and other EPA programs, e.g., the Comprehensive 

Environmental Response, Compensation, and Liability Act (CERCLA). The ASTM D7979 

standard is not multi-lab validated for the matrices of concern for RCRA and CERCLA.

Multi-lab validation accomplishes several purposes: First, it is a means to assess accuracy and 

reproducibility of data independent of the organization that developed the method. Second, it 

reduces uncertainty regarding the method used to produce the data to support decision making. 

By assuring accuracy and reproducibility of the data and confidence in the method, methods 

that are multi-lab validated provide additional assurance to EPA decision-makers and the public 

that resulting data used to protect human health and the environment are robust, reliable and of 

known quality.

EPA test methods that support RCRA and are used by other Federal programs can be found in 

the EPA publication, Test Methods for Evaluating Solid Waste: Physical/Chemical Methods, 

also known as SW-846. Under RCRA’s SW-846 methods program, the methods development 

and validation process for Validated Method 8327 and other methods contained in SW-846 

includes posting a method on EPA’s public website for public comment, comment adjudication 

and relevant method revisions

(39) Government Unique Standard

WaterSense Specification for Spray Sprinkler Bodies Appendix B: Spray Sprinkler Body 

Performance test method [Incorporated: 2017]

Voluntary Standard

ASABE/ICC 802-2014, “Landscape Irrigation Sprinkler and Emitter Standard”

Rationale

WaterSense used ASABE/ICC 802-2014 (section 303.5.2) as the basis for its sprinkler 

performance test. However, no product testing was done by the ASABE/ICC standard 

development committee prior to publishing the standard. When WaterSense did this testing 

many changes had to be made to eliminate redundant steps, correct deficiencies in the method 

and provide sufficient detail to run the test consistently at any laboratory. WaterSense has 

submitted the revised method to the ASABE/ICC 802 committee for consideration in the 

revision of the standard