MEMORANDUM
SUBJECT:
Voluntary
Consensus
Standard
Results
for
the
Site
Remediation
NESHAP
Final
Rule
FROM:
Frederick
J.
Thompson,
(
Acting)
Group
Leader
Source
Measurement
Analysis
Group
(
D243­
02)

TO:
K.
C.
Hustvedt,
Group
Leader
Waste
and
Chemical
Processes
Group
(
C439­
03)

At
your
request,
the
Emission
Measurement
Center
(
EMC)
conducted
searches
and
reviews
to
address
the
National
Technology
Transfer
and
Advancement
Act
(
NTTAA)
requirements
on
the
use
of
voluntary
consensus
standards
(
VCS).
The
NTTAA
directs
EPA
to
use
VCS
in
regulatory
and
procurement
activities
unless
doing
so
would
be
inconsistent
with
applicable
law
or
otherwise
impracticable.
This
memorandum
documents
the
results
of
the
EMC
searches
and
reviews
to
determine
if
VCS
are
available
and
practical
for
use
in
lieu
of
stationary
source
methods
cited
in
the
Site
Remediation
NESHAP
Final
Rule.

In
1998,
the
EMC
began
implementing
the
requirements
of
the
NTTAA
by
conducting
searches
to
identify
VCS.
Searches
continue
to
be
performed
to
meet
the
requirements
of
the
NTTAA.
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
EMC
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)
of
VCS
in
lieu
of
or
as
alternatives
to
EPA
procedures.
We
anticipate
that
these
activities
will
provide
an
opportunity
for
further
review,
consideration
and
possible
IBR
of
VCS
overlooked
in
the
National
Standards
Service
Network
(
NSSN)
searches
or
finalized
after
work
group
closure
in
the
EPA
rulemaking
process.

We
conducted
searches
for
the
Site
Remediation
NESHAP
Final
Rule
through
the
Enhanced
NSSN
Database
managed
by
the
American
National
Standards
Institute
(
ANSI).
We
also
contacted
VCS
organizations,
and
accessed
and
searched
their
databases.
Searches
were
2
conducted
for
EPA
Methods
1,
1A,
2,
2A,
2C,
2D,
3,
4,
9,
18
(
total
organic
HAP
or
total
organic
compounds),
21,
22,
25,
25A,
25D,
25E,
27,
305,
316
of
40
CFR
part
60
Appendix
A,
and
Method
9095A
in
SW
846,
"
Test
Methods
for
Evaluating
Solid
Waste,
Physical/
Chemical
Methods."
No
applicable
voluntary
consensus
standards
were
identified
for
EPA
Methods
1A,
2A,
2D,
9,
21,
22,
25D,
25E,
27,
305,
316,
and
SW
846
Method
9095A.
Please
see
the
attached
tables
for
a
detailed
summary
of
our
findings.

The
attached
tables
describe
the
VCS
found,
which
EPA
standard
reference
method(
s)
the
VCS
potentially
affects,
if
the
VCS
is
equivalent
to
the
EPA
standard
reference
method,
and
EPA's
comments
after
review
of
the
standard.
During
the
search,
if
the
title
or
abstract
(
if
provided)
of
the
VCS
described
technical
sampling
and
analytical
procedures
that
are
similar
to
EPA's
reference
method,
the
EMC
ordered
a
copy
of
the
standard
and
reviewed
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
301
for
accepting
alternative
methods
or
scientific,
engineering
and
policy
equivalence
to
procedures
in
EPA
reference
methods.
The
EMC
may
reconsider
determinations
of
impracticality
when
additional
information
is
available
for
particular
VCS.

The
search
identified
ten
VCS
that
were
potentially
applicable
for
this
rule
in
lieu
of
EPA
reference
methods.
After
reviewing
the
available
standards,
EPA
determined
that
eight
of
the
ten
candidate
VCS
(
ASME
PTC
19­
10­
1981­
Part
10,
ASTM
D3154­
00,
ASTM
D3464­
96
(
2001),
ASTM
D6060­
96
(
2001),
ASTM
D6420­
99,
EN
12619
(
1999),
ISO
10780:
1994,
ISO
14965:
2000(
E))
identified
for
measuring
emissions
of
the
HAP
or
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
eight
methods
are
listed
in
Attachment
1,
along
with
the
EPA
review
comments.
Two
of
the
ten
candidate
VCS
(
ASME/
BSR
MFC
12M,
ASME/
BSR
MFC
13M,)
are
new
standards
under
development.
These
two
methods
are
listed
in
Attachment
2,
along
with
the
EPA
review
comments.

I
hope
our
research
into
this
matter
has
been
useful
and
timely
to
your
Group's
efforts
in
this
rulemaking.
Please
contact
me
at
(
919)
541­
2707
with
any
further
questions
in
this
matter.

Attachments
cc:
John
Bosch,
EMC
(
D243­
02)
Mike
Ciolek,
EMC
(
D243­
02),
w/
attachments
Greg
Nizich
(
C439­
03),
w/
attachments
Conniesue
Oldham,
EMC
(
D205­
02),
w/
attachments
Peter
Tsirigotis,
EMAD
(
C304­
02)
1
Attachment
1.
List
of
Voluntary
Consensus
Standards
Not
Applicable
to
the
Site
Remediation
NESHAP
Rule
SIMILAR
EPA
STANDARD
REFERENCE
METHOD
VOLUNTARY
CONSENSUS
STANDARD
EPA'S
COMMENTS
ON
VOLUNTARY
CONSENSUS
STANDARD
EPA
Methods
1,
2,
2C,
3,
4
ASTM
D3154­
00
­
Standard
Method
for
Average
Velocity
in
a
Duct
(
Pitot
Tube
Method)
This
standard
appears
to
cover
EPA's
Part
60
Methods
1,
2,
2C,
3,
3B,
4,
but
lacks
in
quality
control
and
quality
assurance
requirements.

Specifically,
ASTM
D3154­
00
does
not
include
the
following:
1)
proof
that
openings
of
standard
pitot
tube
have
not
plugged
during
the
test;
2)
if
differential
pressure
gauges
other
than
inclined
manometers
(
e.
g.,
magnehelic
gauges)
are
used,

their
calibration
must
be
checked
after
each
test
series;
and
3)
the
frequency
and
validity
range
for
calibration
of
the
temperature
sensors.

EPA
Method
2
ASTM
D3464­
96
(
2001)
­
Standard
Test
Method
Average
Velocity
in
a
Duct
Using
a
Thermal
Anemometer
Applicability
specifications
are
not
clearly
defined
(
example:
range
of
gas
composition,
T
limits).
It
appears
to
have
the
correct
calibration
procedures
and
specifications,
but
without
supporting
data.

Some
of
the
variability
issues
were
not
adequately
addressed.
The
EPA
cannot
call
this
equivalent
to
EPA
Method
2
without
supporting
data.

EPA
Method
2
ISO
10780:
1994
­
Stationary
Source
Emissions
­
Measurement
of
Velocity
and
Volume
Flowrate
of
Gas
Streams
in
Ducts
ISO
10780:
1994
recommends
the
use
of
an
Lshaped
pitot,
which
historically
has
not
been
recommended
by
EPA.
The
EPA
specifies
the
Stype
design
which
has
large
openings
that
are
less
likely
to
plug
up
with
dust.
SIMILAR
EPA
STANDARD
REFERENCE
METHOD
VOLUNTARY
CONSENSUS
STANDARD
EPA'S
COMMENTS
ON
VOLUNTARY
CONSENSUS
STANDARD
2
EPA
Method
3
ASME
PTC
19­
10­
1981­
Part
10
­
Flue
and
Exhaust
Gas
Analyses
The
instrumental
procedures
in
this
standard
only
include
general
descriptions
of
the
procedures
and
are
not
true
methods.

EPA
Method
18
ASTM
D6060­
96
(
2001)
­
Practice
for
Sampling
of
Process
Vents
with
a
Portable
Gas
Chromatography
This
standard
lacks
key
quality
control
and
assurance
that
is
required
for
EPA
Method
18.
For
example:
lacks
acceptance
criteria
for
calibration,

details
on
using
other
collection
media
(
e.
g.
solid
sorbents),
and
reporting/
documentation
requirements.

EPA
Method
18
ASTM
D6420­
99
­
Standard
Testing
Method
for
Determination
of
Gaseous
Organic
Compounds
by
Direct
Interface
Gas
Chromatography­
Mass
Spectrometry
(
GC/
MS)
This
standard
only
detects
25
of
the
98
specific
organic
HAP
constituents
subject
to
regulation
by
this
rule.
The
specific
organic
HAP
composition
of
the
remediation
material
to
be
cleaned
up
is
often
unknown
and
using
a
method
to
determine
compliance
with
total
organic
HAP
emissions
limitations
that
only
detects
a
narrow
subset
of
the
entire
group
of
98
organic
HAP
compounds
subject
to
the
rule
is
not
appropriate.
Method
18
is
the
only
method
currently
available
to
ensure
that
all
98
HAP
compounds
regulated
by
this
rule
are
accounted
for
in
the
computation
of
the
total
organic
HAP
emissions
from
an
affected
source.
SIMILAR
EPA
STANDARD
REFERENCE
METHOD
VOLUNTARY
CONSENSUS
STANDARD
EPA'S
COMMENTS
ON
VOLUNTARY
CONSENSUS
STANDARD
3
EPA
Methods
25
and
25A
ISO
14965:
2000(
E)
­
Air
Quality
­

Determination
of
Total
Nonmethane
Organic
Compounds
­
Cryogenic
Preconcentration
and
Direct
Flame
Ionization
Method
This
standard
is
an
impractical
alternative
to
EPA
Method
25A
because
it
does
not
measure
solvent
process
vapors
in
concentrations
greater
than
10
ppm
carbon.
A
method
whose
upper
limit
is
10
ppm
carbon
has
a
measurement
range
too
limited
to
be
useful
in
measuring
source
emissions.

EPA
Method
25A
EN
12619
(
1999)
­
Stationary
Source
Emissions­
Determination
of
the
Mass
Concentration
of
Total
Gaseous
Organic
Carbon
at
Low
Concentrations
in
Flue
Gases­
Continuous
Flame
Ionization
Detector
Method
This
standard
is
an
impractical
alternative
to
EPA
Method
25A
because
it
does
not
measure
solvent
process
vapors
in
concentrations
greater
than
40
ppm
carbon.
A
method
whose
upper
limit
is
40
ppm
carbon
has
a
measurement
range
too
limited
to
be
useful
in
measuring
source
emissions.
1
Attachment
2.
List
of
Voluntary
Consensus
Standards
Not
Final
for
the
Site
Remediation
NESHAP
Rule
SIMILAR
EPA
STANDARD
REFERENCE
METHOD
VOLUNTARY
CONSENSUS
STANDARD
EPA'S
COMMENTS
ON
VOLUNTARY
CONSENSUS
STANDARD
EPA
Method
2
(
possibly
1)
ASME/
BSR
MFC
13M
­
Flow
Measurement
by
Velocity
Traverse
Under
development
when
search
was
completed.

Possibly
similar
to
EPA
Methods
1
and
2.

EPA
Method
2
ASME/
BSR
MFC
12M
­
Flow
in
Closed
Conduits
Using
Multiport
Averaging
Pitot
Primary
Flowmeters
Under
development
when
search
was
completed.

Possibly
similar
to
EPA
Method
2.
