United States      Office of Air Quality      EPA-450/3-82-002
             Environmental Protection  Planning and Standards     January 1982
             Agency         Research Triangle Park NC 27711
             _
  &ERA     Revised Test Methods
             106  and 107-
             Summary  of Comments
             and  Responses
I

-------
                                         EPA-450/3-82-002
       Revised Test Methods 106 And 107-
      (Proposed November 18, 1980, 45 FR 76346)

*             Summary Of Comments
                    And  Responses
                  Emission Standards and Engineering Division
                 U.S. ENVIRONMENTAL PROTECTION AGENCY
                    Office of Air, Noise, and Radiation
                  Office of Air Quality Planning and Standards
                 Research Triangle Park, North Carolina 27711
                         January 1982

-------
This report has been  reviewed by the Emission  Standards and Engineering Division
of the  Office 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 Office  (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.
                                          11

-------
                           TABLE OF CONTENTS
                                                         Page
Chapter 1.  INTRODUCTION	    1
Chapter 2.   SUMMARY OF CHANGES SINCE PROPOSAL
Chapter 3.   SUMMARY OF PUBLIC COMMENTS AND RESPONSES.  .     5
            Table 1.   LIST OF COMMENTERS	    19
                               n i

-------
                              CHAPTER 1
                            INTRODUCTION
      On November 18,  1980,  the U.  S.  Environmental  Protection
 Agency published in  the Federal  Register (45 FR 76346)  revised
 Methods 106  and  107,  "Determination  of  Vinyl  Chloride from
 Stationary Sources,"  and "Determination of Vinyl  Chloride Content
 of Inprocess  Wastewater Samples, and  Vinyl  Chloride Content of
 Polyvinyl  Chloride Resin, Slurry,  Wet Cake,  and Latex Samples,"
 respectively.  These  revised methods  were  proposed  under  the
 authority  of  Sections 112,  114, and 301(a) of the Clean Air Act
 as amended.
     Public comments were solicited at  the time of  proposal.   The
 public  comment period was from November  18, 1980, to  January  19,
 1981, and was extended  to February 19, 1981.
     Five comment letters were received concerning  issues relative
 to the  proposed test methods.  A detailed discussion of these  comments
 and responses are summarized in this  document.  The summary of comments
 and responses serves  as  the basis for the revisions  which have been
made to the test  methods between proposal and promulgation..

-------
                               CHAPTER  2
                  SUMMARY OF CHANGES SINCE PROPOSAL
      1.  Section 4.1, Method 106.  Section 4.1.11 was added  to
 list  tubing fittings and connectors.
      2.  Section 5.2.3.2(b), Method 106 and Section 7.2.1.2(b),
 Method  107.  The optional requirement  of  "...having it analyzed by
 the National Bureau of Standards," was changed to "...calibrating
 it against vinyl chloride cylinder standard reference materials
 (SRM's) prepared by the National Bureau of Standards, if such SRM's
 are available."
      3.  Section 5.2.4, Method 106.  The last sentence of this section
was deleted, and the following sentences were added:   "Audit cylinders
obtained from a commercial  gas manufacturer may be used provided:
 (a) the gas manufacturer certifies the audit cylinders as described
 in Section 5.2.3.1   and (b)  the gas manufacturer obtains an
 independent analysis of the audit cylinders to verify his analysis.
 Independent analysis is defined here to mean analysis performed by
an individual  different than the individual  who performs the gas
manufacturer's analysis,  while using calibration standards and analysis
equipment different from those used for the gas manufacturer's analysis.
Verification is complete  and acceptable when the independent analysis
concentration  is within +5  percent of the  gas  manufacturer's
concentration."
     4.   Section 6.1,  Method 106.   The  second  sentence was  revised to
read,  "A bag leak check should  have been  performed previously according
to Section 7.3.2."   The fifth  sentence  was revised to  read,  "After

-------
  allowing  sufficient  time  to  purge  the  line  several  times,  change the
  vacuum  line from the container to  the  bag and  evacuate  the bag  until
  the rotameter indicates no flow."
      5.   Section 6.4, Method 106.  The sixth sentence was  revised  to
  read, "Purge the sample loop for 30 seconds at the  rate of 100 ml/min,
  shut off  flow, allow the sample loop pressure to reach atmospheric
  pressure as indicated by the H20 manometer, then activate  the sample
  valve."
      6.   Section 7.1, Method 106.   Reference to Figure 106-2 was
 deleted, and Figure 106-2  was deleted.
      7.   Section 7.2.2,  Method  106.  The  last sentence was revised
 to read, "Perform  calibration daily,  or before  and  after the analysis
 of each  emission test set  of bag  samples, whichever is more frequent."
 Two sentences were  added that read, "For  each group of sample analyses,
 use the  average  of  the two calibration  curves which bracket that  group
 to determine the respective  sample  concentrations.   If the  two
 calibration curves  differ  by  more than  5  percent from  their mean  value,
 then report the  final results by both calibration curves."
     8.  Section 8.2, Method  106.   The second sentence was  revised  to
 read, "From the calibration curves  described in Section 7.2.2,
 determine the average concentration value of vinyl  chloride, C , that
 corresponds to A ,  the sample peak area."
     9.   Section 6.2, Method 107.    In Section 6.2.1, the part numbers
were revised to indicate  the  new,  correct  numbers.

-------
      10.   Section  6.2, Method  107.   Section  6.2.4 was  added  to  list
 a  100 yl  syringe  (optional).
      11.   Section  8.2.1,-Method 107.  The fifth sentence was  revised
 to  read,  "Obtain the exact sample weight, add 100 ul or about two
 equal  drops of distilled water, and  immediately seal the vial."
      12,   Section  8.2.4, Method 107.  The last sentence was  revised
 to  read,  "Prepressurize the vial, and then condition for 1 to 2 hours
 as  required at 90° C in the analyzer bath."
      13.   Section 8.3.1.1, Method 107.  A sentence was added to
 indicate  that a clean burr-free needle is mandatory.
      14.  Section 8.3.1.2(b),  Method 107.  The dosing line temperature
was changed from 170° C to 150° C.
      15.  Section 8.3.2,  Method 107.  Quotation  marks were added to
the term "analysis time."
     16.  Section 9.1,  Method  107.   Wording was  added to optionally
allow the addition of 100  pi  of distilled water  in  place of two  drops.

-------
                                CHAPTER 3
               SUMMARIES OF PUBLIC COMMENTS AND RESPONSES
 1.  IV-D-1
      Summary of Comment:  The Agency (EPA) should publish a notice
 in the Federal Register to clarify the November 18, 1980 notice on
 Test Methods 106 and 107 as to whether the changes in the methods are
 proposed or final  amendments.
      Response to Comment:   A notice was published in the Federal
 Register on January 6,  1981,  Volume 46, No.  3,  p.  1318,  to clarify
 that the changes in Methods  106  and 107 published  on November 13,  1980,
 were proposed changes.
 2.   IV-0-2
      Summary of  Comment:   Commenter  IV-D-2 requests  that Section 5.2.4
 of Test  Method 106,  entitled   "Audit  Cylinder Standards"  further
 describe  commercial  gas manufacturers as an alternative  source  of
 these standards.  Section  5.2.4 of Method 106 as proposed  November  18,
 1980, contains the  following statements:
     "When  available, the  tester may obtain audit cylinders by
     contacting:  Environmental Protection Agency, Environmental
     Monitoring Systems Laboratory, Quality Assurance Division
     (MD-77), Research Triangle Park, North Carolina 27711.  If
     Audit cylinders are not available at the Environmental Protection
     Agency, the tester must secure an alternative source."
     Response to Comment:   The  last sentence  of  Section 5.2.4  will  be
deleted  and several  sentences will  be added  to describe the acceptability
of audit cylinders  obtained from  commercial gas  manufacturers.

-------
  3.   IV-D-3
       Summary  of  Comment:   Section  7.2.2  of  Test  Method  106  should be
  changed to require calibration at  least  once every 8  hours  of
  continuous operation of the gas chromatograph, whereas  the  method
  presently requires daily calibration.  If this change would require
  too much time to analyze all standards,  then at  least two of the
  standard mixtures could be analyzed every 8 hours.  Then the values
  generated could be compared to the last  complete calibration curve.
  If the new values deviate more than 5 percent from the curve, then a
 new calibration curve would have to be prepared.
      Response  to  Comment:   Section  7.2.2  requires that calibration be
 performed  daily,  or before and after each set of  bag  samples,  whichever
 is more frequent.   While  analysis of a set of Method  106 samples rarely
 takes  more than 8 hours,  it would be an unnecessary burden  to
 arbitrarily set 8 hours as  a cutoff point for  valid calibrations.   A
 sentence will  be  added, however, to indicate that if  calibration
 curves  deviate by more than  5  percent  from their  mean, then  the  results
 must be reported  by both calibration curves.
 4.  IV-0-4
     Summary of Comment:   For Method 106,  a  leak  between the bag inlet
 and probe can have a significant effect on the sample.  Therefore,
 there should be a requirement for leak checking this portion of the
 sample  system.
     Response to Comment:   There are no significant pressure drops
when sample is  flowing through  this  portion of the sample train;

-------
  therefore,  the requirement to  check that all  connectors between the
  bag  and  probe  are  tight  should be  sufficient.
  5.   IV-D-4
      Summary of Comment:'  Add  a Section  4.1.11  to  Method  106  as follows:
      "4.1.11,  Fittings and  Connectors.   All fittings  (compression  type
      or otherwise) used  in  connecting the sample line  from  the  probe
      to the box should be Teflon or stainless steel.   Tygon or
      surgical  rubber tubing may be used  to hold two pieces  of Teflon
      tubing together, provided one tubing end is flush against  the
      other or fits inside the other."
      Response to Comment:  This suggested addition may be helpful to
 some, and will  therefore  be added.   However,  slip connections will  not
 be suggested as they  are  prone  to  leakage.
 6.   IV-D-4
      Summary of Comment:   Section 4.3.1  of Method  106  should be  revised
 to  include a  combination  plotter/integrator, thereby precluding  the
 problem of sources  having to ask if they  can be  used.
      Response to Comment:   Section  4.3.8  already describes a strip  chart
 recorder as optionally equipped with either a disc  or electronic
 integrator, so  no further description should be  necessary.
 7.  IV-D-4
     Summary of Comment:   In reference to Section 4.3.1, heating  the
 sample loop should not be mandatory because not all labs will have a
 heated valve.  It should be sufficient to insulate the valve/loop and
 insert a thermometer tip underneath  the insulation so that the
temperature is known.

-------
      Response to Comment:  A heated sample loop is necessary to prevent
 sample intercontamination.   A sample valve can be heated by using a
 heat tape and rheostat, both of which are readily obtainable.
 8.   IV-0-4
      Summary of Comment:   Section 4.3.4 of Method 106 should be
 revised to indicate that  the regulators used  be ones specified by
 the gas manufacturer,  because it is especially important that  proper
 regulators be used  on  calibration gas  cylinders.
      Response to  Comment:   No contamination problems  resulting  from the
 interchange of regulators can be foreseen.  If  only  the  regulators
 specified  by the  gas manufacturer are  required,  then  unnecessary
 expenses may be incurred.
 9.   IV-D-4
     Summary of Comment:  Add  a  Section 4.4.5  to Method  106  as  follows:
     "4.4.5.  Midget Impinger.   For use in preparation of vinyl chloride
     standards; made of Pyrex  glass, with a minimum of grease applied  to
     the ground glass joint."
     Response to Comment:   The midget impinger is not required, as
Figure 106-2  is in error.   Refer to the response to the comment about
Section 7.1  (See No. 13).
10.   IV-D-4
     Summary of Comment:  Section 6.1  of Method 106  should be revised
to read as follows (changes  are underlined):
     "Assemble the sample  train as shown in Figure 106-1.   The  bag  and
     rigid container should  have been  leak-checked (7.3.2)  prior to

-------
       setting up for sample collection.   Using a suitable coupler.
       connect the vacuum line to the sample line.   Place the end of
       the probe at the centroid of the stack,  and  start the pump with
       the needle valve adjusted to yield  a  flow that will  fill  over
       50  percent of the bag  volume in  the specified  sample period.
       After allowing  sufficient purge  time  to  displace  the sample  line
       volume  several  times,  disconnect the  vacuum and sample  lines;
       then connect  the  vacuum line  to  the bag,  and evacuate the  bag
       until the  rotameter indicates no flow.   (If the bag  has been
       leak-checked and flow  is still indicated, there may  be a leak
       in the bag-to-guick-connect connection.  This should be fixed
      before proceeding further.)  Start the sample by connecting
      the  sample line to the bag and the  vacuum line  to  the container.
      as illustrated in Figure 106-1.   During the sampling period,  keep
      a constant proportionality between  the sample  flow rate  and stack
      flow rate.   At all  times  .  .  .  ."
      Response to Comment:   The  procedure  is essentially correct  as
 proposed.  The  intent is to  prefill  the sample bag with some  sample,
 and  then  reevacuate  the bag  while  simultaneously making another  leak
 check.  The proposed  wording of this section will be slightly changed
 to clarify this  intent.
 11.   IV-D-4
     Summary of Comment:  Section 6.3 of Method 106 needs  refinement.
 If a pump is used, it should be placed upstream of the rotameter and
downstream of the pressure  gauge.  Obviously, some  vacuum will  be

-------
 created in the line.  In the case of micro sampling valves (Carle
 or Valco) with 1/16-inch tubing connections, the vacuum may be too
 high for measurement with a 1-inch water manometer.  In using the
 option of container pressurization,  flow control should be by means
 of a needle valve upstream of the sample valve.   Otherwise, there is
 a possibility of pressurizing the sample loop.   Having the water
 manometer downstream of the charcoal  filter may  not result in an
 accurate measurement of the absolute  sample loop pressure.
      Response to  Comment:   The  object of the  1-inch H^O pressure gauge
 (not  manometer) is  to  determine that  gas in the  sample  loop has
 returned  to atmospheric  pressure,  after  sample flow has been  stopped.
 Container  pressurization to move  sample  gas through the sample loop
 should not harm the  sample  loop.
 12.   IV-D-4
      Summary  of Comment:  In Section  6.4 of Method  106  as proposed,
 the sixth sentence apparently has  a phrase  missing.  It  should read
 "Purge the sample loop for 30 seconds at the rate of 100 ml/min,
 shut  off flow, allow the pressure  to drop to atmospheric, as indicated
 by manometer  zero, then activate the sample valve."
    Response  to Comment:  While Section 6.3 already describes  this
operation, it may clarify the procedure to repeat it in Section 6.4,
so Section 6.4 will  be revised to include this suggestion.
13.  IV-D-4
     Summary of Comment:   Section 7.1  of  Method  106, as  proposed,  makes
reference to Figure  106-2.   However,  instructions say to inject  vinyl

                                 10

-------
 chloride through the wall of the bag.  Figure 106-2 indicates that the
 vinyl chloride is to be injected through a septum on the top of the
 midget impinger.
      Response to  Comment:  -Figure 106-2 illustrates a  standards
 preparation procedure not described in the optional standard
 preparation section, and therefore  Figure 106-2  will  be dropped.   It
 is also felt that the actual  standards preparation  procedure would  not
 be enhanced by a  figure, so  none will  be  added.
 14.   IV-D-5
      Summary of Comment:   The commenter had  previously  requested and
 received  approval of an  alternative procedure to Test Method  107.   The
 commenter (IV-D-5) is concerned  as to  whether or not the promulgation
 of a  modified  Method  107 will mean that approval of his alternative
 procedure will  be recinded.
      Response  to Comment:  The proposed changes in EPA Method 107 are
 meant to enhance the performance of that method, and should not
 be interpreted as having any bearing on the prior approval  of alternative
 test methods.
 15.   IV-D-5
     Summary of Comment:   In  reference to  Section 6.2.1  of  Method  107
as proposed, Perkin-Elmer Part No. 105-0118 is  no longer a  valid part
number for vials,  seals,  and  caps.  The correct  part numbers  are as
follows:
     Vials:   0105-0129,  Septa:   BOO!-0728  (gray  butyl  rubber  septum,
     plug  style) and  0105-0131  (butyl  rubber  septa).
                                n

-------
      Response to Comment:   The commenter is correct,  and the revised
 part numbers  will  be included.
 16.   IV-D-5
      Summary  of Comment:   The  proposed  procedure  of Section  6.3.2 of
 Method  107  suggests  the  use  of Porapak  Q columns.   The  commenter has
 not  been  able to get separation of  vinyl chloride and acetaldehyde
 with the  Porapak Q column.   The commenter uses  two  1.83 meter  columns
 containing  1  percent Supelco 1000 on Carbopak B,  which  give  adequate
 separation  of vinyl  chloride and acetaldehyde.
      Response to Comment:  Section  6.3.2 of Method  107,  as proposed,
 already lists  columns for  the  separation of vinyl chloride and
 acetaldehyde.  Other columns can also be acceptable,  as  described  in
 Section 6.3.2.
 17.   IV-D-5
      Summary  of  Comment:    Section 6.3.10 of Method  107,   as proposed,
 deals with a  proposed addition  to this procedure, the head space vial
 prepressurizer.  The  commenter1s analysts indicate  that  the
 prepressurization step was introduced because the authors of Method  107
 felt  that pressurization just prior to injection, as  in   the old
 procedure, did not allow adequate time for the vapors and the head
 space to reach equilibrium.  A spot comparison by the commenter shows
 no significant difference between the old procedure and  the new
 prepressurization procedure.   In addition, the commenter has  had
 several  problems with leakage once the vials have been prepressurized.
They have found that when butyl rubber septa are used, leaks  appear
                                  12

-------
 through  the  hole  in  the septum made  by  the  prepressurization  apparatus
 after the vial has been pressurized;  in addition, when  Teflon-faced
 septa are used as specified in sampling waste water,  they  have
 experienced  great difficulty in sealing the vials so  as  to preclude
                                                    •
 leaks around the sides of the septa.  They  have  found,  however,  that
 the use  of butyl rubber septa is more appropriate in  the sampling  of
 waste water, both from the standpoint of expense and  seal ability.
 These comments on the prepressurization also apply to paragraphs
 8.2, 8.2.3, and 8.2.4 of the proposed Method 107.
     Response to Comment:   A reference will be added  to  Section  11,
 Bibliography, that explains the need for vial prepressurization.
 The Environmental Protection Agency agrees that Teflon septa  should
 not be used on sample analysis vials.  Rather, butyl  rubber septa must
 be used  as specified.  Leaks can be greatly reduced by using  a clean,
 burr-free injection needle, and a statement will be added  to  that
 effect.
 18.  IV-D-5
     Summary of Comment:   Section 8.2.1  of the proposed Method 107
 requires the two drops of distilled water be added to the contents of
 the vial, i.e., resin samples,  prior to  sealing.   The old procedure
 required that 100 micro!iters  of distilled water must be injected
 into the vial after sealing and weighing using a 100 micro!iter
 syringe.   Although it is  just  as  easy to add two drops of water as it
 is to inject 100 microliters  of water, most facilities are  adapted to
the old  procedure and such  a  change could  cause  confusion in day-to-day
laboratory operations.
                                  13

-------
      Response to Comment:  Calculations by EPA show that either
 100 yl or two drops of water will saturate the sample analysis vial,
 so the method will  be changed to indicate that either amount is
 satisfactory.
 19.  IV-D-5
      Summary of Comment:   Section 8.2.2 of Method 107, as proposed,
 specifies a dewatering procedure which is  different from that in the
 old procedure.   The commenter's  alternative method is  based upon the
 idea  that an accurate weight  of  the  dewatered resin be obtained,  and
 further that the sample must  be  weighed to  a  specified weight to
 provide for ease in calculation.   In  this  respect,  the resulting  wet
 cake, when  dewatered  by the proposed  procedure,  is  much  wetter  than
 that  in the  old  procedure, which makes  accurate weighing  to  a specified
 weight  virtually impossible.  Therefore, it is suggested  that the old
 dewatering  procedure,  i.e., that which  is employed  in  existing  Method
 107,  be retained in favor of  the proposed dewatering procedure.
      Response to Comment:   The dewatering procedure was changed due  to
 a concern that in vacuum filtering a sample,  vinyl chloride might be
 removed from the  sample wet cake.  The Agency does not, however,  have
 reason  to disallow the old procedure as long as some control  is
exercised to keep the vacuum filtering of each sample to a minimum.
Since in the revised procedure,  all samples are weighed after placing
in the sample analysis vial,  no  difficulty  should be experienced with
the requirement to weigh  to a  constant weight.
                                   14

-------
  20.   IV-D-5
       Summary of Comment:  Section 8.2.4 of  the proposed Method  107
  specifies a 2-hour conditioning time.  Comparisons the commenter  has
  made  show that a 1-hour conditioning time gives the same result as a
  2-hour conditioning time.  Therefore, it is suggested that the
  procedure for a 1-hour conditioning time be retained.
      Response to Comment:  The change to 2-hours for sample conditioning
 was made as a result of a revised industry procedure.   However,  as
 1 hour may be sufficient, EPA will  change  the  procedure to  allow a
 shorter conditioning  time.
 21.   IV-D-5
      Summary  of Comment:   Section 8.3.1.2  of the proposed Method 107
 specifies a 170° C temperature for the dosing  line.  However,  the
 F42 and F45 model chromatographs, do not provide for a temperature
 setting of 170°.  These models only provide  for selection of
 temperatures of 50, 100, 150, 200, and 250°.  Table 1 shows a
 comparison of temperatures specified by the proposed procedure, by
 the old procedure,  and the temperatures that the commenter uses both
with an F42 and an  F45 unit.
                                 15

-------
                               TABLE 1
 Analysis (Temperature)
                 Revised
Old
Commenter's

Oven
Dosing Line
Injection block

140° C
170° C
170° C

50° C
140° C
140° C
F42
105
150
170
F45
105
150
170
      The  commenter believes  that  a  temperature setting of 150° C
 should  be specified for  the  dosing  line.
      Response to  Comment:  The  commenter  is  correct  as to the  available
 temperature settings, so a change will  be made to  specify a  temperature
 of 150° C for the  dosing line.
 22.   IV-D-5
      Summary of Comment:  Section 8.3.2.b of the proposed Method  107
 states, in programming the chromatograph analysis  time, that "the  normal
 setting is approximately 70  percent of  the VCM  retention  time."  This  is
 a misstatement.  The correct statement  should  be "VCM  retention time  is
 normally  70 percent of the analysis time."  Table 2 sets  forth the
 typical values the commenter has obtained using the F42 and F45 models.
     Response to Comment:  The commenter is correct in that the term
 "analysis time" as used in Section 8.3.2.b is a misnomer.   The term is
 used to signal when backflushing is  to occur, and the specified setting
 is correct.  Quotation marks  will  be placed around  the term to  alleviate
any further confusion.
                                  16

-------
                               TABLE 2

 Retention and Analysis Time
                                                F42          F45
 V.C. retention                                 2.2
 Analysis time                                  3.4
 Analysis time
    (V.C. RT/.70)                                3.1
2.4
3.8

3.4
 23.   IV-D-5
      Summary  of  Comment:   In  reference  to  Section  9.1  of the  proposed
 Method  107, the  commenter  questions  adding two  drops  of  water prior to
 sealing  the vial  as opposed to  injection of 100 micro!iters of water
 after sealing.   Table 3 provided by  the commenter  shows  responses
 for two  trials on a 52 ppm VC standard comparing the  addition  of two
 drops of water vs. the injection of  100 microliters  of water.  These
 results show both a reduced and a more variable response when  two
 drops of water are added as opposed  to injection of 100 microliters.
Therefore, the commenter suggests that in  this paragraph, in addition
to Section 8.2.1, that the method specify  the injection of 100
microliters of distilled water after sealing of the vial.
                                 17

-------
            TABLE 3.  INTEGRATOR RESPONSE FOR 52 PPM VC STD
Trial 1
2 Drops
water
13100
14049
13578
Avg. 13576
SD 474
Injection .
100 yl
14724
14595
14353
14558
190
Trial 2
2 Drops
water
12648
11997

Avg. 12322
SD 460
Injection
100 ul
13621
13874
14216
14558
299
      Response to Comment:  A change will be made to allow either
 100 yl  or 2 drops of water.   Refer to the response to the comment
 about Section 8.2.1.
 24.   IV-0-5
      Summary of Comment:   In  reference to Section 9.2 of the proposed
 Method  107,  the commenter feels  that  the proposed requirement that
 a  straight  line be  drawn  through  the  calibration  points  as  derived
 by the  Least  Squares Method is an  improvement  over  the old  procedure.
      Response to  Comment:  No response  is  required.
 25.   IV-0-5
                                 «,
     Summary  of Comment:  In reference to Section 10.1 of the proposed
Method 107, the commenter feels that the use of the calibration curve
as proposed is an improvement over the old procedure.
     Response to Comment:   No  response is required.

-------
                    TABLE 1.   LIST OF COMMENTERS

                         Docket  No.  A-80-50

Docket item No.                             Commenter/Affi1iation

    IV-D-1                          Scott  W.  Bowen,  Associate, Beveridge,
                                   Fairbanks  and  Diamond
                                   1333 New Hampshire Avenue, N.W.
                                   Washington, D.C.  20036

    IV-D-2                          Robert E.  Squires, Operations Manager
                                   Scott  Specialty  Gases Division
                                   Scott  Environmental Technology,  Inc.
                                   Plumsteadville,  Pa.  18949

    IV-D-3                         G. Vinson  Hellwig, Senior Environmental
                                     Engineer
                                  PEDCo  Environmental, Inc.
                                  Suite  503
                                  505 South  Duke Street
                                  Durham, N.C.  27701

    IV-D-4                         Robert E. James, Ph.D., Senior Scientist
                                  Engineering-Science
                                  3109 North Interregional
                                  Austin, Texas  78722

    IV-D-5                         Thomas V. Malorzo, Senior Regulations
                                    Analyst
                                  717 North Harwood Street
                                  Dallas, Texas  75201
                                19

-------
                                    TECHNICAL REPORT DATA
                            (Please read Instructions on the reverse before completing;
1. REPORT NO.
 EPA 450/3-82-002
              3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
 Revised Test Methods  106 and 107 -  (Proposed November
 18,  1980, 45 FR 76346)  Summary of Comments and
 Responses
              5. REPORT DATE
               January  1982
              6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
                                                            8. PERFORMING ORGANIZATION REPORT NO
 Emission Standards  and  Engineering Division
9. PERFORMING ORGANIZATION NAME AND ADDRESS
 Emission Measurement  Branch (MD-19)
 Emission Standards  and  Engineering Division
 U.  S.  Environmental Protection Agency
 Research Triangle Park,  N.  C. 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, Noise,  and Radiation
U.  S.  Environmental  Protection Agency
Research Triangle  Park,  N.  C. 27711
              13. TYPE OF REPORT AND PERIOD COVERS.
              14. SPONSORING AGENCY CODE
               EPA/200/04
15. SUPPLEMENTARY NOTES
16. ABSTRACT                                      ~  ~~	—	

      This document addresses the public  comments submitted  after proposal of
 the vinyl chloride methods in the Federal  Register.  Changes  made to the methods
 as  a result of these  comments are included.   This document  serves as the basis
 for the revisions which  have been made to  the test methods  between proposal and
 promulgation.
7.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
                                              b.IDENTIFIERS/OPEN ENDED TERMS
                                                                          c. COSATl Field/Group
                                                                              13  B
8. DISTRIBUTION STATEMENT

Release Unlimited
19. SECURITY CLASS (Tins Report/
  Unclassified
21 NO OF PAGES
     23
                                                 Unclassified
                                            20

-------