MEMORANDUM
SUBJECT:
Voluntary
Consensus
Standard
Results
for
the
Supplemental
Notice
for
the
Proposed
National
Emission
Standards
for
Hazardous
Air
Pollutants;
and,
in
the
Alternative,
Proposed
Standards
of
Performance
for
New
and
Existing
Stationary
Sources
Electric
Utility
Steam
Generating
Units
FROM:
Frederick
J.
Thompson,
Group
Leader
Source
Measurement
Analysis
Group
(
D243­
02)

TO:
Robert
Wayland,
(
Acting)
Group
Leader
Combustion
Group
(
C439­
01)

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
Supplemental
Notice
for
the
Proposed
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
SNP­
NESHAP;
and,
in
the
Alternative,
Proposed
Standards
of
Performance
for
New
and
Existing
Stationary
Sources
(
NSPS)
Electric
Utility
Steam
Generating
Units.

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.
2
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
SNP­
NESHAP
and,
in
the
Alternative,
Proposed
NSPS
for
Electric
Utility
Steam
Generating
Units
through
the
Enhanced
NSSN
Database
managed
by
the
American
National
Standards
Institute
(
ANSI).
We
also
contacted
VCS
organizations,
and
accessed
and
searched
their
databases.
Searches
were
conducted
for
EPA
Methods
1,
1A,
2,
2A,
2C,
2D,
2F,
2G,
3,
3A,
3B,
4,
6,
6A,
6C,
7,
7A,
7C,
7D,
7E,
19,
20,
324;
ASTM
D6784­
02,
"
Standard
Test
Method
for
Elemental,
Oxidized,
Particle­
Bound
and
Total
Mercury
Gas
Generated
from
Coal­
Fired
Stationary
Sources
(
Ontario
Hydro
Method);"
and
EPA
Performance
Specifications
2
and
12A.
No
VCS
were
identified
for
EPA
Methods
1A,
2A,
2D,
2F,
2G,
7D,
19,
324,
and
ASTM
D6784­
02.
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.

One
voluntary
consensus
standard
was
identified
as
an
acceptable
alternative
for
EPA
methods
cited
in
this
proposed
rule.
The
voluntary
consensus
standard
ASME
PTC
19­
10­
1981­
Part
10,
"
Flue
and
Exhaust
Gas
Analyses,"
is
cited
in
this
rule
for
its
manual
method
for
measuring
the
oxygen,
carbon
dioxide,
sulfur
dioxide,
and
nitrogen
oxide
content
of
exhaust
gas.
These
parts
of
ASME
PTC
19­
10­
1981­
Part
10
are
acceptable
alternatives
to
EPA
Methods
3B,
6,
6A,
7,
7C,
and
20
(
sulfur
dioxide
only).

In
addition,
ASTM
D6784­
02,
"
Standard
Test
Method
for
Elemental,
Oxidized,
Particle­
Bound
and
Total
Mercury
Gas
Generated
from
Coal­
Fired
Stationary
Sources
(
Ontario
Hydro
Method),
is
cited
in
this
rule
as
an
alternative
analytical
technique
for
mercury
for
samples
taken
using
EPA
Method
324.

The
search
identified
15
other
VCS
that
were
potentially
applicable
to
this
proposed
rule
in
lieu
of
EPA
reference
methods.
After
reviewing
the
available
standards,
EPA
determined
that
13
of
the
15
candidate
VCS
(
ASME
PTC
19­
10­
1981­
Part
10,
ASTM
D3154­
00,
ASTM
D3464­
96
(
2001),
ASTM
D5835­
95
(
2001),
ASTM
D6522­
00,
CAN/
CSA
Z223.2­
M86
(
1999),
CAN/
CSA
Z223.26­
M1987,
EN
13211
(
2001),
ISO
10396:
1993,
ISO
10780:
1994,
ISO
3
10849:
1996,
ISO
12039:
2001,
prEN
14884
(
draft
January
2004))
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
13
methods
are
listed
in
Attachment
1,
along
with
the
EPA
review
comments.
Two
of
the
15
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:
Bill
Maxwell,
ESD
(
C439­
01),
w/
attachments
John
Bosch,
EMC
(
D243­
02)
Mike
Ciolek,
EMC
(
D243­
02),
w/
attachments
William
Grimley,
EMC
(
D243­
02),
Conniesue
Oldham,
EMC
(
D205­
02),
w/
attachments
Peter
Tsirigotis,
EMAD
(
C304­
02)

OAQPS/
EMAD/
SMAG/
MCIOLEK/
lalston/
D243­
02/
541­
4921/
03­
05/
04
FILE
#
_______________
DOC
NAME:
__________________________
1
Attachment
1.
List
of
Voluntary
Consensus
Standards
Not
Applicable
to
the
Supplemental
Notice
for
the
Proposed
National
Emission
Standards
for
Hazardous
Air
Pollutants;
and,
in
the
Alternative,

Proposed
Standards
of
Performance
for
New
and
Existing
Stationary
Sources
Electric
Utility
Steam
Generating
Units
SIMILAR
EPA
STANDARD
REFERENCE
METHOD
VOLUNTARY
CONSENSUS
STANDARD
EPA'S
COMMENTS
ON
VOLUNTARY
CONSENSUS
STANDARD
EPA
Methods
1,
2,
2C,
3,
3B,
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
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.

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
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.
SIMILAR
EPA
STANDARD
REFERENCE
METHOD
VOLUNTARY
CONSENSUS
STANDARD
EPA'S
COMMENTS
ON
VOLUNTARY
CONSENSUS
STANDARD
2
EPA
Methods
3A,
6C,
7A,
7B,
7E,

20
(
nitrogen
oxides
and
oxygen)
ASME
PTC
19­
10­
1981­
Part
10­­
Flue
and
Exhaust
Gas
Analyses
This
standard
includes
manual
and
instrumental
methods
of
analyses
for
carbon
dioxide,
carbon
monoxide,
hydrogen
sulfide,
nitrogen
oxides,

oxygen,
and
sulfur
dioxide.
The
VCS
method
analytes
that
include
one
or
more
of
the
same
instrumental
techniques
as
the
EPA
methods
required
in
this
rule
are
as
follows:
carbon
dioxide
[
3A];
nitrogen
oxides
[
7A,
7B,
7E,
20],
oxygen
[
3A,
20];
sulfur
dioxide
[
6C].
For
the
standard's
instrumental
procedures,
only
general
descriptions
of
the
procedures
are
included
which
are
not
true
methods.
Therefore,
while
some
of
the
manual
methods
are
acceptable
alternatives
to
the
corresponding
EPA
methods,
the
instrumental
procedures
are
not.
SIMILAR
EPA
STANDARD
REFERENCE
METHOD
VOLUNTARY
CONSENSUS
STANDARD
EPA'S
COMMENTS
ON
VOLUNTARY
CONSENSUS
STANDARD
3
EPA
Methods
3A,
6C,
7E,
20
(
nitrogen
oxides
and
oxygen
parts
only)
ISO
10396:
1993
­
Stationary
Source
Emissions:
Sampling
for
the
Automated
Determination
of
Gas
Concentrations
This
standard
is
similar
to
EPA
Methods
3A,
6C,

7E,
10,
20
(
nitrogen
oxides
and
oxygen
parts
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.
SIMILAR
EPA
STANDARD
REFERENCE
METHOD
VOLUNTARY
CONSENSUS
STANDARD
EPA'S
COMMENTS
ON
VOLUNTARY
CONSENSUS
STANDARD
4
EPA
Methods
3A
and
20
(
oxygen
portion
only)
ISO
12039:
2001
­
Stationary
Source
Emissions­­
Determination
of
Carbon
Monoxide,
Carbon
Dioxide,
and
Oxygen­­
Automated
Methods
This
method
is
similar
to
EPA
Methods
3A,
10,

and
20
(
oxygen
portion
only).
However,

ISO
12039
is
missing
some
key
features.
In
terms
of
sampling,
the
hardware
required
by
ISO
12039
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
only
specifies
a
two­
point
calibration
while
the
EPA
methods
specify
a
3­
point
calibration.
Also,
ISO
12039
does
not
specify
performance
criteria
for
calibration
error,
calibration
drift,
or
sampling
system
bias
tests,
although
checks
of
these
quality
control
features
are
required
by
the
ISO
standard.
In
addition,
ISO
12039
does
not
include
procedures
for
removal
of
CO
2
when
CO
is
being
tested,
as
in
EPA
Method
10.
SIMILAR
EPA
STANDARD
REFERENCE
METHOD
VOLUNTARY
CONSENSUS
STANDARD
EPA'S
COMMENTS
ON
VOLUNTARY
CONSENSUS
STANDARD
5
EPA
Methods
3A,
6C,
7E,
20
(
nitrogen
oxides
and
oxygen
parts
only),
ASTM
D5835­
95
(
2001)
­
Standard
Practice
for
Sampling
Stationary
Source
Emissions
for
Automated
Determination
of
Gas
Concentration
This
standard
is
similar
to
EPA
Methods
3A,
6C,

7E,
10,
20
(
nitrogen
oxides
and
oxygen
parts
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.

EPA
Methods
3A;
7E;
20
(
nitrogen
oxides
and
oxygen
parts
only)
ASTM
D6522­
00
­
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
ASTM
D6522
has
been
determined
to
be
technically
appropriate
for
identifying
nitrogen
oxides,
carbon
monoxide,
and
oxygen
concentrations
when
the
fuel
is
natural
gas.
SIMILAR
EPA
STANDARD
REFERENCE
METHOD
VOLUNTARY
CONSENSUS
STANDARD
EPA'S
COMMENTS
ON
VOLUNTARY
CONSENSUS
STANDARD
6
EPA
Methods
3A,
6C,
7E,
20
(
nitrogen
oxides
and
oxygen
parts
only)
CAN/
CSA
Z223.2­
M86
(
1999)
­
Method
for
the
Continuous
Measurement
of
Oxygen,
Carbon
Dioxide,
Carbon
Monoxide,
Sulphur
Dioxide,
and
Oxides
of
Nitrogen
in
Enclosed
Combustion
Flue
Gas
Streams
This
standard
is
unacceptable
as
a
substitute
for
EPA
Methods
3A,
6C,
7E,
10,
10A,
and
20
(
nitrogen
oxides
and
oxygen
parts
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
nonmandatory
and
also
do
not
provide
the
same
level
of
quality
assurance
as
the
EPA
methods.
For
example,
the
zero
and
span/
calibration
drift
is
only
checked
weekly,
whereas
the
EPA
methods
requires
drift
checks
after
each
run.
SIMILAR
EPA
STANDARD
REFERENCE
METHOD
VOLUNTARY
CONSENSUS
STANDARD
EPA'S
COMMENTS
ON
VOLUNTARY
CONSENSUS
STANDARD
7
EPA
Method
324
EN
13211
(
2001)
­
Air
Quality­­

Stationary
Source
Emissions­­

Determination
of
the
Concentration
of
Total
Mercury
EN
13211
is
not
acceptable
as
an
alternative
to
the
mercury
portion
of
EPA
Method
29
and
101A
primarily
because
it
is
not
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
of
fritted
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
and
101A
require
the
use
of
six
impinges.
In
addition,
EN
13211
does
not
include
many
of
the
quality
control
procedures
of
EPA
Method
29
and
101A,
especially
for
the
use
and
calibration
of
temperature
sensors
and
controllers,

sampling
train
assembly
and
disassembly,
and
filter
weighing.
SIMILAR
EPA
STANDARD
REFERENCE
METHOD
VOLUNTARY
CONSENSUS
STANDARD
EPA'S
COMMENTS
ON
VOLUNTARY
CONSENSUS
STANDARD
8
EPA
Method
324
CAN/
CSA
Z223.26­
M1987
­

Measurement
of
Total
Mercury
in
Air
Cold
Vapour
Atomic
Absorption
Spectrophotometeric
Method
This
standard
is
not
acceptable
as
an
alternative
to
EPA
Methods
101A
and
324,
for
the
cold
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,
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.
SIMILAR
EPA
STANDARD
REFERENCE
METHOD
VOLUNTARY
CONSENSUS
STANDARD
EPA'S
COMMENTS
ON
VOLUNTARY
CONSENSUS
STANDARD
9
EPA
Performance
Specification
2
(
nitrogen
oxide
portion
only)
ISO
10849:
1996
­
Determination
of
the
Mass
Concentration
of
Nitrogen
Oxides
­

Performance
Characteristics
of
Automated
Measuring
Systems
This
standard
is
not
acceptable
as
an
alternative
to
EPA
Performance
Specification
(
PS)
2
because
it
is
missing
key
components
included
in
the
EPA
PS,
as
follows:
1)
the
calibration
drift
performance
specification
of
EPA
PS
2
is
not
one
of
the
main
performance
specifications
of
the
VCS;

the
allowable
value
for
the
drift
is
offered
as
a
"
guideline"
in
an
"
informative"
appendix
rather
than
in
a
required
section
of
the
standard
.
Also,
the
standard
only
requires
that
the
calibration
drift
checks
made
only
at
"
regular"
intervals
rather
than
the
specified
24­
hour
checks
of
PS
2;
2)
the
standard
does
not
specify
the
measurement
locations
and
traverse
points
needed
to
obtain
a
representative
sample
for
the
performance
tests;
3)
no
specifications
are
included
for
data
recorder
use
or
operation;
4)
the
high
level
values
used
to
calibrate
the
CEMS
in
the
standard
are
derived
from
the
instrument
scale
and
not
the
maximum
potential
emissions
at
the
source,
as
in
EPA
PS
2;
5)
the
standards
does
not
require
moisture
measurement
or
show
how
to
correct
results
for
moisture
as
in
PS2,
and
does
not
show
how
to
standardize
to
a
specific
diluent
concentration
(
e.
g.,
7
percent
oxygen).
SIMILAR
EPA
STANDARD
REFERENCE
METHOD
VOLUNTARY
CONSENSUS
STANDARD
EPA'S
COMMENTS
ON
VOLUNTARY
CONSENSUS
STANDARD
10
EPA
Performance
Specification
12A
prEN
14884
(
draft
January
2004)
­
Air
Quality­­
Stationary
Source
Emissions
B
Determination
of
Total
Mercury:
Automated
measuring
Systems
prEN
14884
(
draft
01/
04)
is
not
acceptable
as
an
alternative
to
PS
12A
because
it
is
not
specifically
intended
as
a
method
for
measurement
of
gaseous
mercury.
Also,
prEN
14884
is
missing
some
critical
QA
measures
that
are
included
in
PS
12A.
prEN
14884
also
specifies
using
a
linear
regression
of
the
reference
method
(
RM)
and
CEMS
data
to
report
CEMS
results
during
normal
operation,
whereas
EPA
PS
12A
uses
the
RM
results
as
a
quality
control
criteria
for
improper
CEMS
installation
when
the
CEMS
data
is
greater
than
20
percent
of
the
mean
RM
data
or
10
percent
of
the
applicable
standard.
Other
deficiencies
in
this
EN
standard
are
as
follows:
(
1)
prEN
14884
only
requires
two
(
zero
and
span)

of
the
three
reference
gas
concentrations
(
zero,
mid­
level,

and
high­
level)
required
by
EPA
PS
12A
to
determine
the
measurement
error;
(
2)
prEN
14884
is
missing
much
of
the
detail
of
PS
12A
as
in,
for
example,
the
siting
of
the
CEMS,

reference
gas
delivery
system
design,
data
recorder
ranges
and
response,
and
correlation
of
the
RM
and
CEMS
stack
conditions
during
RA
tests;
and
(
3)
prEN
14884
does
not
require
as
many
RM
tests
as
EPA
PS
12A
and
a
shorter
minimum
sampling
period.
PrEN
14884
only
requires
15
single
tests
as
compared
to
the
nine
paired
tests
(
18
total)
in
EPA
PS
12A;
prEN
14884
allows
as
little
as
7.5
hours
of
sampling
time
(
with
8
to
10
hours
recommended)
as
compared
to
the
minimum
of
18
hours
sampling
time
in
PS
12A.
1
Attachment
2.
List
of
Voluntary
Consensus
Standards
Not
Final
for
the
Supplemental
Notice
for
the
Proposed
National
Emission
Standards
for
Hazardous
Air
Pollutants;
and,
in
the
Alternative,

Proposed
Standards
of
Performance
for
New
and
Existing
Stationary
Sources
Electric
Utility
Steam
Generating
Units
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.
