United States      Office of Air Quality       EPA-450/3-82-028
           Environmental Protection  Planning and Standards      October 1984
           Agency        Research Triangle Park NC 27711

           Air
&EPA      Method 16A for
           Determination of
           Total Reduced
           Sulfur Emissions -
           Summary of
           Comments and
           Responses

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                                   EPA-450/3-82-028
    Method  16A for Determination of
    Total  Reduced Sulfur Emissions -
Summary of Comments and Responses
            Emission Standards and Engineering Division
           U.S. ENVIRONMENTAL PROTECTION AGENCY
                Office of Air and Radiation
           Office of Air Quality Planning and Standards
           Research Triangle Park, North Carolina 27711

                   October 1984

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This report has been reviewed by the Emission Standards and Engineering Division of the Off ice of Air Quality Planning
and Standards, EPA, and approved for publication. Mention of trade names or commercial products is not intended to
constitute endorsement or recommendation for use. Copies of this report are available through the Library Services
Off ice (MD-35), U.S. Environmental Protection Agency, Research Triangle Park, N.C. 27711, or from National Technical
Information Services, 5285 Port Royal Road, Springfield, Virginia 22161.

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                             TABLE OF CONTENTS


                                                                     Page
Chapter 1.  INTRODUCTION 	     1

Chapter 2.  SUMMARY OF CHANGES SINCE PROPOSAL	     2

Chapter 3.  SUMMARY OF PUBLIC COMMENTS AND RESPONSES  	     4

            Table 1.   LIST  OF COMMENTERS	    18

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                                  Chapter 1
                                 INTRODUCTION
      On June 18, 1981, the U.S. Environmental  Protection Agency  published
 Method 16A, "Determination of Total  Reduced Sulfur Emissions  from  Stationary
 Sources," in the Federal  Register (46 FR 31904).   This method can  be used
 by affected facilities to determine  compliance  with  the  regulations.  This
 method was proposed under the authority  of Sections  111,  114,  and 301(a) of
 the Clean Air  Act,  as  amended.
      Public comments were solicited  at the  time of proposal.  An invitation
 to request a public hearing was issued to  provide interested persons the
 opportunity for  oral presentation of  data, views, or arguments concerning
 the  proposed test method,  but no person desired to make an oral presentation.
 The  public  comment period was from June 18, 1981, to August 17, 1981.
     Letters concerning issues relative to the proposed test method were
 received from 10 commenters.  A detailed  discussion of these comments and
 responses are summarized in this document.   The  summary of comments  and
 responses serve as the  basis for the  revisions which  have been made  to the
test method between proposal  and promulgation.

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                                 Chapter 2
                     SUMMARY OF CHANGES SINCE  PROPOSAL
     1.  Section 1.  A new section discussing  interferences,  precision  and
bias has been added.
     2.  Section 1.1.  New minimum detection limits for the method when
sampling for 1 and 3 hours have been added.
     3.  Section 2.  The probe specifications  have  been changed to minimize
the sampling of particulates.   A heated filter has  been added to the
sampling train.
     4.  Section 2.1.  A 250-ml polyethylene bottle is needed for the
peroxide solution recovery.
     5.  Section 2.1.1.   The two midget impingers used for  the S02 scrubber
have been replaced by three larger Teflon impingers.
     6.  Section 2.1.3.   The combustion tube furnace  should be capable  of
maintaining a temperature of 800 +_ 100  °C instead of  815 ;*  15 °C.
     7.  Section 2.1.4.   The rate meters should be  capable  of measuring
flow rate to within 5 percent  of the selected  flow  rate.
     8.  Section 2.3.  The 10-ml buret  should  have  0.05 ml  graduations.
     9.  Section 3.1.3.   A pH  adjustment of  the citrate buffer solution is
requi red.
     10.  Section 3.1.4.   The  standard  deviation for  Method 11 analyses of
the calibration gas is specified.   Gravimetrically  calibrated permeation
devices are an allowable option for generating the  calibration gas.  The
gas concentration should be generated in the range  of the stack  concentration
or within 20 percent of the applicable  standard level,,

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       11.  Section 3.1.5.  For the combustion gas, an example system for
 purifying ambient air is listed.
       12.  Section 4.1.  An S02 scrubber conditioning period is specified.
       13.  Section 4.1.1.  New directions for the S02 scrubber are given.
 The oxidation furnace temperature is maintained at 800  + 100°C.
       14.  Section 4.1.3.  The sample is collected over  a 1- or 3-hour
 period.  The three-hour sample should not be intermittent and should have
 a total volume of 360 liters.   It is recommended that the probe  be washed,
 the filter replaced,  and the S02  scrubber changed after  each  test run.
      15.  Section 4.3.   The  sample analysis  has  been modified  to allow for
 duplicate  analysis.
      16.   Section 5.2.   The  performance check calibration  system has been
 changed by replacing  the dry gas  meters used to measure the calibration
 and combustion gases  with calibrated  rotameters.  The results of the recovery
 check  will be reported but will not be used to correct the emission  data.
 A recovery of 100 + 20 percent must be obtained for the  data to be valid.
 The performance check prior to testing is recommended but is not  mandatory,
 and no precision for this check is specified.
     17.  Section 6.   This section has been expanded to  include sample
 volume, TRS concentration, and recovery check calculations.
     18.  Section 7.   Two additional  references  have been  added to the
bibliography.

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                                 Chapter 3



                  SUMMARY OF PUBLIC  COMMENTS AND RESPONSES



                                 Method 16A





1.  D-2



     Comment:   The definition of total  reduced  sulfur compounds (TRS) in 40



CFR 60.281 does not make reference to  Method 16A.  This should be done or



mention of Method 16 should be dropped.



     Response:   Mention of Method 16 is essential  in defining the individual



components that make up TRS because  the compounds  are identified using gas



chromatography.  Since Method 16A is an alternative method and makes no



distinction between sulfur compounds,  there is  no  advantage in including it



in the definition.



2.  D-2



     Comment:   When calculating compliance with §  60.283(a)(4), a total



mass emission  rate is needed and relies on the  known concentration of each



reduced sulfur compound.  Since Method 16A oxidizes all sulfur compounds to



sulfur dioxide before analysis, the  concentrations needed in § 60.285(d)(3)



are not available.



     Response:   Section 60.285(d)(3) is being revised to allow the calculation



of TRS concentrations on an equivalent H2S basis.  This revision was proposed



in the Federal  Register on January 19,  1984 (49 FR 2448) and will eliminate



the need to quantify individual TRS  compounds.



3.  0-5, D-6,  D-8, D-9



     Comment:   The following changes or additions  are recommended for the



    scrubber system.

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      a.   The  specified 40 ml of citrate scrubber solution may not be
 sufficient  to collect high levels of S02 for extended periods of time.
 Two  large impingers containing 200 ml of scrubber each will  effectively
 remove  the  S02«
      b.   The  midget impingers will not have the capacity to hold the volumes
 of condensed  moisture present in the streams of some sources.
      c.   The  pH of the scrubber solution should be adjusted to 5.5 - 5.6
 with  citric acid or potassium citrate.
      d.   The  scrubber should be conditioned with 5 to 10 ppm H£S in nitrogen
 or source gas for 15 minutes prior to initiation of sampling.
      Response:  The scrubber system has been changed to use  three large
 Teflon  impingers in series.  The first two impingers will  contain 100  ml  of
 scrubber  solution each, while the third impinger will be initially dry.   An
 addition  to Section 3.1.2 has been made requiring the pH adjustment of the
 scrubber  solution.  A requirement to condition the scrubber  before sampling
 has also  been added.   Our studies show that a 10-minute purge with stack
 gas provides  sufficient conditioning.
 4.  D-5,  D-8
     Comment:   In the background paper referenced in Section 7.1,  it is
 indicated that 83 ppm H2S is  completely oxidized at 2 liters per  minute but
 not at 3  liters per minute with  the  furnace temperature at 850°C.   An
 earlier study  suggests a  temperature  of 1000°C  for  the  oxidation  of TRS
compounds.  The testing reported in  the background  paper also  primarily
used H2$.   It  would appear that  additional  effort  should be  spent  in
optimizing the oxidation  temperature  and flow rates for  complete  conversion
of mixtures  of TRS compounds.

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     Response:  Studies by the EPA and other sources have shown that
temperatures significantly lower than 850°C will  completely oxidize TRS
compounds at levels encountered e,t most sources.   A temperature range of
800 +_ 100 °C will be specified for the oxidation  furnace.   The  data listed
in the background paper included one sample set that showed complete
oxidation of a mixture of TRS compounds.   Other laboratory  studies  have
verified the complete oxidation of all TRS compounds at the 2  liter per
minute flow rate.
5.  D-B
     Comment:  Specifying a combustion furnace temperature  of 815 + 15°C in
Section 2.1.3 is not critical.  Our studies indicate that 460°C is  sufficient
to oxidize all TRS compounds.
     Response:  We agree that the ^15°C range is  not critical,  but  to
maintain uniformity in application, the furnace temperature range will  be
specified as 800 + 100 °C.
6.  D-5
     Comment:  At some facilities, the tube furnace may not be  permitted
due to safety restrictions.
     Response:  At facilities where this  alternative method is  restricted,
Method 16 should be used.
7.  D-5
     Comment:  In the background paper referenced in Section 7.1, the results
of a field study are presented wherein Method l&A is compared to Method 16
and the Barton Coulometric Method at a lime kiln,  recovery  furnace,  and
smelt dissolving tank.   From the data, it is very clear that Methods  16  and
16A do not give the same results on the kiln emissions.  The report states

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 that the difference was caused by C02 quenching of the photometric detector
 used in Method 16, whereas Method 16A is not affected by C02.  The emission
 standard for pulp mills, however, is stated to be 5 ppm of TRS emissions
 based on the use of reference Method 16.  If Method 16A does not give
 comparable results to the reference method, it cannot be used to regulate
 emissions at this source without either changing the standard by specifying
 different values for the method or by revising the reference method.  The
 values obtained on the H2S  calibration standards during the  field  work
 indicate that both methods  give low  values.   In  comparison,  in  the laboratory
 portion  of  the study,  high  values were obtained  by  Method 16A.   Further
 study  is needed in this  area.
     Response:   Method 16 lists C02  as  having  a  substantial  desensitizing
 effect on the flame  photometric detector and states that acceptable systems
 must demonstrate  that  they  have eliminated this  interference.  The Method
 16  system used  at the  lime  kiln had  not corrected this C02 problem; hence,
 the values  it gave were  substantially lower than those obtained using Method
 16A.  The values  obtained for the field calibration gases show that both
 methods had recoveries around 90 percent.  Recoveries above 80 percent are
 acceptable.   The  recoveries for the Method 16A laboratory sample sets
 averaged 102 percent, with all  sets within 9 percent of the  known sample
 value.
     Method  16A is proposed  as  an  alternative method.   This  does  not require
equivalency  to Method 16, but  that the method produce  results adequate to
determine compliance.

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8.  D-5
     Comment:  A considerably longer sampling  time  should  be  used  in  order
to provide a higher concentration sample that  would reduce errors  due  to
the small amount of titrant needed,  the faintness of the  indicator endpoint,
and other errors common to sampling.
     Response:  Laboratory and field studies have shown that  Method 16A can
accurately measure TRS in the range  of the emission standards when 1-  or  3-
hour samples are taken.  If a 1-hour sample is collected  from a  source
emitting 5 ppm TRS, the amount of titrant needed for analysis would be
approximately 2 ml.  This titration  volume can be accurately  measured to
within 0.025 ml using the buret specified in the method.   The precision in
distinguishing the indicator endpoint for an experienced  analyst is normally
within 1 drop (0.05 ml) of titrant.   Therefore, the error  associated  with
this small titrant volume (less than 2 percent) and indicator endpoint
detection (2.5 percent) should be less than 5  percent.
9.  D-8
     Comment:  The amount of thorin indicator  added for titration is
critical to  the end point.  Consistency should be used  for blanks  and
samples.
     Response:  Four drops will be  specified for samples  and blanks.
10.  D-5, D-6, D-7, D-8, D-9
     Comment:  More flexibility should be allowed in the  calibration system.
The use  of permeation  devices should be permitted in place of the cylinder
gas for  the  following  reasons:

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       a.  Method  16 uses  permeation tubes.
       b.  Gas cylinders are not as safe as permeation systems.
       c.  It is difficult to accurately analyze H2S cylinder gas by
 Method 11 when the concentration is less than 50 ppm.  This would affect
 the ability to meet the +15 percent accuracy criterion specified in the
 method.
      d.  The dilution required to bring 30 to 50 ppm H2S into the applicable
 range would introduce significant errors.
      e.  If desired,  H2S  from cylinders can  be calibrated against permeation
 tubes traceable to the National  Bureau of  Standards  (NBS).  This  would
 eliminate the  need for dilution.
      Response:   Permeation  devices will  be allowed as alternative calibration
 systems as  long as they meet  the  performance  check of Section 4.3.  A recent
 EPA study evaluating Method 11 placed  the minimum detectable limit at 2.4
 ppm and showed  that accurate analyses  could be performed in the 2-20 ppm range.
 The Method 11 analysis is required due to the instability of cylinder gas
 H2S over  periods  of time.  The + 15 percent accuracy criterion has been
 changed to +_ 20 percent.
 11.  0-6, 0-8, 0-9
     Comment:  The field calibration system includes  two gas cylinders  and
 two dry gas meters.  It is fairly complex and requires adjusting several
 flows and then taking simultaneous meter readings when starting  and  stopping.
The dilution factor cannot be  accurately determined because  it is  calculated
by taking the difference between  two  large  volumes.   This setup  should be
listed as an  example system  only.   A  setup  that  has been  shown to  work,

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uses a rotameter to monitor the flow from the H^S cylinder and a dry gas
meter to record the total flow.  The flow rate through  the rotameter will
remain constant during sample recovery checks.
     Response:  The proposed calibration system has been  revised to  make it
simpler and less prone to inaccuracies.   The new example  system utilizes
calibrated rotameters to set the HgS and combustion gas flow rates.   This
will eliminate the need for dry gas meters to determine the individual
volumes of these gases.  Alternative systems may be used  provided the
acceptability criteria of Section 4.3 is met.
12.  0-6, D-9
     Comment:  The post-test procedure calls for introducing the recovery
gas through the probe.  This is different from the more desirable Method 16
requirement of introducing the gas after the probe and  filter.   Why  was
this change made?  If the probe is heated, there should be no TRS loss.
This post-test loss check should oe performed after each  third sample or
earlier, if desired.
     Response:  It has been found that components emitted by some facilities
may collect in the probe and attribute to significant TRS losses through
adsorption.  This loss can be effectively determined by including the
uncleaned probe in the post-test procedure.   This loss check through the
probe is not required for Method L6 because higher sampling rates are
employed and a very large amount of calibration gas would be needed.
     Field tests have shown that one field recovery sample after each test
run is sufficient when using the modified probe design, the heated in-line
                                     10

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  filter, and when changing the S02 scrubber after each run.  Recovery
  checks performed on a more frequent basis are allowed.
  13.  D-6, D-8
      Comment:  Section 4.1.3 requires that a run consists of three 1-hour
  samples or one 3-hour sample to be consistent with Method 16.   One 3-hour
  sample would not give any indication of precision.   Also,  Method  16 needs a
 3-hour run to get a reasonable average of 16 individual  injections.  A
 2-hour run has been found ideal  since three  can  be performed in addition  to
 calibration in a single day,  whereas the 3-hour  runs  would  require  an
 additional day.   A  continuous sample for 2 hours  gives a better average
 than sixteen  10-second  grab  samples  and  does  not  invalidate  the intent of
 Method 16.
      Response:   The test  run  time was  chosen  primarily to be consistent
 with reference Method 16  since this  is an alternative method.  A shorter
 time would offset the similarity of  the  two methods.
      Neither a 2- nor 3-hour  sample  would give any indication of precision.
 The  option to collect one continuous 3-hour sample as opposed to three
 individual 1-hour samples may be preferred in certain situations.
 14.  D-6
     Comment:   More flexibility to use different  apparatus  should  be allowed
 provided the quality assurance tests are met.
     Response:   This flexibility is allowed and is stated  in Section  2.1.
15.  D-8
     Comment:   The preamble  to the  proposed method states that it has few
interferences.   We have  found  that  calcium and sulfate particulate from
                                    11

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some lime kilns and recovery furnaces are severe interferences.   These



compounds should be noted in the applicability  section.   Provisions  should



be made to place a filter in the sample train to remove  participate  matter.



     Response:  The sampling train has been modified to  include  a filter.



Proper use of the filter to eliminate particulate interferences  is now



mentioned in the applicability section.



16.  D-8



     Comment:  The sample analysis procedure should be changed to follow



Method b exactly.  The proposed procedure generates a large  titration  volume



with only enough sample for one analysis.



     Response:  The sample analysis procedure has been changed to reduce



the large titration volume and allow for duplicate analysis.  The small



sample aliquot specified by Method 6 would create a dilute sample wherein



analytical accuracy would be lowered due to the decreased amount of  titrant



required.



17.  D-8



     Comment:  The preamble to the method states several  advantages  of



Method 16A over Method 16.  The following comments are made.



     a.  It is stated that no gas dilution system is needed.  A  gas  dilution



system is required for the system performance check.



     b.  We disagree that samples need not be analyzed in the field.   Due



to the need to check system performance prior to, during, and after  testing,



all samples must be analyzed on site, and all  results must be calculated



at that time.
                                     12

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       c.  The proposed method will  not necessarily  reduce the cost of
  emission testing to demonstrate compliance with  the  standards.   Our  experience
  with Method 16 and 16A indicates that Method  16A requires 80- to  100-1abor
  hours to test a source whereas  Method 16 would require 40 labor hours to
  test the same source.
       Response:   The dilution  system mentioned in the preamble refers to the
  collection  of the  sample gas.   A gas  dilution system is used in the system
  performance check  but  is not  needed while collecting samples.  The method
  makes no  requirement to analyze any samples in the field.  It is wise to
  analyze  the  system performance  samples in the field to determine the  validity
  of the samples, but this is not mandatory.   We agree  that the amount  of  time
  required to use a test method depends on the proficiency  of  the  tester.
  If it is determined by individuals that Method 16A  is more costly  and time
 consuming than Method 16,  then the individual  has the option  of  not using
 the alternative method.
 18.   D-l
      Comment:   The  new  method  is a  welcome  change.  We agree with  the five
 advantages noted in the preamble and as an  additional  advantage, the
 availability of  this  technique in lieu of such traditional methods as  the
 continuous titrimetric  techique  which has been plagued with frequent
 equipment malfunctions  in field  applications.
     Response:   No  response needed.
19.  D-8
     Comment:  We calculate the minimum detectable limit  for  the  method to
be 1 ppm instead of 0.04 ppm.
                                    13

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     Response:   Minimum detectable limits  of 0.3  ppm  for 1-hour  samples
and 0.1 ppm for 3-hour samples  based  on  the blank volume plus two standard
deviations have been calculated and will be listed.
20.  D-8
     Comment:   The +2 percent flowmeters specified in Section 2.1.4 are
excessive.  A flow rate of 2 liters +1Q  percent  is sufficient.
     Response:   The 2 percent specification refers to f'lowmeter  accuracy,
not flow rate precision.   This  has been  clarified by  rephrasing  the sentence.
21.  D-a
     Comment:   The combustion gas  in  Section 3.1.5 should  be air only since
dry gas meters  are not calibrated  for oxygen.
     Response:   Calibration of  the dry gas meter  is independent  of gas
type.  One liter of oxygen would occupy  the same  volume as 1 liter of air.
The ary gas meters are no longer used in the system performance  check.
22.  D-8
     Comment:   The system performance check should be performed  before any
cleaning of the system is done.
     Response:   We agree, and this has been stated in Section 4.1.4.
23.  D-8, D-9
     Comment:   Based on past studies  with  Method  16A, the  5 percent precision
for the system performance check is too  stringent. This is also unnecessarily
restrictive for those sources which generally  operate well below the
applicable standard.  Precision within 10  percent and the  option to run the
system performance check at the level of the applicable standard +20 percent
is more reasonable.
                                     14

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     Response:  The precision requirement for the system performance check
has been dropped.  An allowance to run this check at the level  of the
applicable standard +_ 20 percent has been made.
24.  D-8
     Comment:  The audit samples in Section 5.2  should be used to validate
the S02 titration but should not be needed as a  substitute for a  recovery
check.
     Response:  The original intent of this audit requirement was to
substitute an unknown HzS gas audit for one of the recovery checks during
a test.  This requirement has been dropped in favor of an S02 audit of the
analysis procedure.
25.  D-9
     Comment:  Method 16 measures TRS concentration on a dry basis.   If
oxygen correction is needed (as required for most kraft sources),  Method 3
should be specified to determine the oxygen content of the sample on a
dry basis.
     Response:  Use of Method 3 is already specified in paragraph 60.285 of
the regulations.
2fa.  D-9
     Comment:  Since the present TRS standards require 0^  correction of the
measured TRS concentration  for most sources,  the  calculation procedure  for
02 correction should be added to the method.
     Response:  The equation for Og correction is listed in paragraph  6U.284
of the regulations.
                                     15

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27.  D-10
     Comment:  The proposed method should be  revised  to  allow  the  use of 6
percent hydrogen peroxide and large impingers  containing 200 ml of absorbing
solution.
     Response:   The use of large impingers in  this method would be impractical
A large titration volume would result form taking an  aliquot of sufficient
size to analyze accurately.  A 20U-ml  sample  aliquot,  plus 800 ml  of
isopropanol, means titrating a 1-liter sample.
28.  D-10
     Comment:  Section 4.2 should oe revised  as  follows;:  "Pour contents of
the impingers of the Method 6 part of the train  into  separate leak-free
polyethylene bottles."
     Response:   The impinger contents of  the Method 6  part of the  train
should be poured into a container separate from  the contents of the spent
scrubber impingers.  The individual  Method 6  impinger  contents need not be
placed in separate bottles since the combined  contents are used in the
analysis.
29.  D-8
     Comment:  In Section 6.2, 12.020 y/meq should be  12.020 yl/meq.
     Response:   This correction has been  made.   This  factor has been
converted to 12025 yl/meq to allow Vm(stCj)  to  be expressed in dry  standard
liters instead  of dry standard cubic meters.
30.  D-8
     Comment:  The preamble to the method states that Method 16A reduces
the chances of  measurement error Decause  it involves  fewer and less
complicated components.  We think the chance  of  measurement error  using

                                     16

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  Method  16A  is  greatly  increased  due  to potential  interferences (calcium
  particulate) from the  source, the components required for checking system
  performance, and the method specified for calibration of the calibration
  gas cylinder.  The method should be modified and further field evaluations
  should  be performed to demonstrate that the method gives comparable results
  to Method 16.
      Response:   The potential  interferences from the source have  been
 eliminated by incorporating a  filter into the sampling train.   The  components
 required to check the system performance  have been simplified  by  allowing
 the use of permeation devices  and rotameters  to  determine dilution  ratios.
 The permeation  devices offer an  alternative to calibration  gas  dilution  and
 verification of concentration  by  Method 11.   In  a  recent evaluation of
 Method  11  by the  Agency,  the accuracy of Method  11 was verified down  to
 a concentration of 2  ppm.  Method 16A has been shown by the EPA and other
 companies  to give results comparable  to Method 16.
 31.  D-l,  0-3,  D-4, D-7
     Comment:   We approve of and  support the proposed method for the
 following  reasons:
     a.  Method 16A is superior to Method 16 and provides more  accurate
 data at  a lesser expense.
     b.   The unnecessary complexity of emission testing is  reduced.
     c.   Plants  will  have the option of  using  their own staff and  equipment
at a considerable savings over  using expensive outside  consultants having
the specialized  equipment and instrumentation  required  by existing Method 16.
     Response:   No response  needed.
                                    17

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                        Table 1.   LIST  OF  COMMENTERS
                           Docket Number  A-80-38
Document number                            Commenter/affillation

    IV-D-1                        Peter  E.  DeRossi, Corporate Environmental
                                   Engineer
                                  Green  Bay Packaging,  Inc.
                                  Post Office  Box"1107
                                  Green  Bay, Wisconsin  54305

    IV-D-2                        Michael E. Fogle, Unit Coordinator
                                  Georgia Department of Natural Resources
                                  270 Washington  Street, S.W.
                                  Atlanta,  Georgia 30334

    IV-D-3                        Jay Lipscomb
                                  Mostardi-Platt  Associates, Inc.
                                  1077 Entry Drive
                                  Bensenville,  Illinois 60106

    IV-D-4                        T.C. Owen, Corporate  Director
                                  Union  Camp Corporation
                                  Post Office  Box 1391
                                  Savannah, Georgia 31402

    IV-D-5                        C.D. Malloch, Regulatory Management Director
                                  Monsanto  Company
                                  800 N. Lindberg Blvd.
                                  St. Louis, Missouri 63166

    IV-D-6                        Alan S. Rosenfeld, Sr. Research Engineer
                                  Crown  Zellerbach Environmental Services
                                  904 N.W.  Drake  Street
                                  Camas, Washington 98607

    IV-D-7                        Karl C. Ayers,  Energy and Environmental
                                   Manager
                                  Mead
                                  Eighth and Hickory Streets
                                  Chillicothe,  Ohio 45601

    IV-D-8                        Bruce  B.  Ferguson, Vice President,
                                   Analytical  Services
                                  Harmon Engineering and Testing
                                  Auburn Industrial Park
                                  Auburn, A1abama 36830	
                                     18

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                         Table 1.   LIST  OF COMMENTERS

                                 (Continued)
                           Docket Number A-80-38
 Document  number                             Commenter/affiliation

     IV~D~9                        Russell 0. Blosser, Technical  Director
                                  National Council of the Paper  Industry
                                   for Air and Stream Improvement,  Inc.
                                  260 Madison Avenue
                                  New York, New York 10016

     IV~D~10                       Bill  Stewart, Executive Director
                                  Texas Air Control  Board
                                  6330  Hwy. 290 East
	Austin, Texas 78723
                                   19

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                                      TECHNICAL REPORT DATA
                              (Please read Instructions on the reverse before completing)
   EPA-450/3-82-028
                                                               3. RECIPIENT'S ACCESSION NO.
   Method  16A for the Determination of Total  Reduced
     Sulfur  Emissions
   Summary of Comments and Responses	
                              5. REPORT DATE
                                  October 1984
                              6. PERFORMING ORGANIZATION CODE
   Emission Standards and Engineering Division
                                                               8. PERFORMING ORGANIZATION REPORT NO
  9. PERFORMING ORGANIZATION NAME AND ADDRESS
   Emission Measurement Branch  (MD-19)
   Emission Standards and Engineering Division
   U.  S.  Environmental  Protection  Agency
   Research Triangle  Park, North Carolina  27711
                              10. PROGRAM ELEMENT NO.
                              11. CONTRACT/GRANT NO.
  12. SPONSORING AGENCY NAME AND ADDRESS
   DAA for Air Quality Planning and  Standards (MD-10)
   Office of Air and  Radiation
   U.  S.  Environmental  Protection Agency
   Research Triangle  Park.  N. C.  27711
                              13. TYPE OF REPORT AND PERIOD COVERED
                              4. SPONSORING AGENCY CODE
                                  EPA/200/04
  15. SUPPLEMENTARY NOTES
 16. ABSTRACT
       This  document addresses the public  comments submitted after proposal
  of Method  16A in the Federal Register.   Changes made to  the method as a
  result of  these comments  are included.   This  document serves as the basis
  for the revisions which have been made to  the test method  between
  proposal and  promulgation.
17.
a.
KEY WORDS AND DOCUMENT ANALYSIS
                   DESCRIPTORS
18. DISTRIBUTION STATEMENT
       Release Unlimited
EPA Form 2220-1 (Rev. 4-77)    PREVIOUS EDIT.ON ,s OBSOLETE
                                                b.lDENTIFIERS/OPEN ENDED TERMS
              19. SECURITY CLASS (This Report)"
                   Unclassified
                                               20. SE
                                                   CURITY CLASS.(Thispage/
                                                    Unclassified
                                                                           c.  COS AT I Field/Group
                                                                                 13B
21. NO. OF PAGES
     19
                                          22. PRICE

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