United States Office of Air Quality EPA-450/3-82-004
Environmental Protection Planning and Standards February 1982
Agency Research Triangle Park NC 27711
_
&EPA Test Method 107A-
Summary of Comments
and Responses
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EPA-450/3-82-004
Revised Test Method 107A-
(Proposed February 12, 1981; 46 FR 12188)
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
February 1982
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This report has been rev.ewed by the Emission Standards and Engineering Division of the Office of Air Quality Plannin<
and Standards, EPA, and approved for publication. Mention of trade names or commercial products is not intended u
™ /Mn6^6"16"1 °r recommendation f°r use. Copies of this report are available through the Library Service-
^fnrmL^n Q ^LT^"^1 ^^^^ency' Research Triangle Park, N. C. 27711, orfrom National Technica
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 3
Table 1. LIST OF COMMENTERS 7
n
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CHAPTER 1
INTRODUCTION
On February 12, 1981, the U. S. Environmental Protection Agency
published in the Federal Register (46 FR 12188) Method 107A,
"Determination of Vinyl Chloride Content of Solvents, Resin - Solvent
Solution, Polyvinyl Chloride Resin, Resin Slurry, Wet Resin, and Latex
Samples." This method was 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. To
provide interested persons the opportunity of oral presentation of
data, views, or arguments concerning the proposed revisions and test
methods, a public hearing was scheduled for March 26, 1981, at the
Research Triangle Park, North Carolina, but no person desired to make
an oral presentation. The public comment period was from February 12,
1981, to April 13, 1981.
Seven comment letters were received concerning issues relative
to the proposed test method. A detailed discussion of these comments
and responses is summarized in this document. The comments have been
carefully considered, and it was determined that no changes were
necessary in the proposed test method.
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CHAPTER 2
SUMMARY OF CHANGES SINCE PROPOSAL
No changes to the method were required.
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CHAPTER 3
SUMMARY OF PUBLIC COMMENTS AND RESPONSES
Commenter IV-D-1
1.1 Comment: The commenter felt that Method 107A is very similar
to methods in use before the regulation containing Method 107 was
promulgated in 1977, and a great deal of time and money could have been
saved had Method 107A been permitted originally.
Response: The commenter apparently failed to recognize that Part 61
of Title 40, CFR, provides for approval by the Administrator of methods
which have been demonstrated to the Administrator's satisfaction to
produce results adequate for determination of compliance. Method 107
is an automated analytical technique that is best suited for the high-volume
quality control analyses that are an integral part of most polyvinyl
chloride facilities, but for those who may prefer to use another method,
that option has always been a"possibility.
Commenter IV-D-2
2.1 Comment: The proposed alternative method should generally
be satisfactory.
Response: No response is required.
2.2 Comment: In Section 6.3.2, the specified column packing,
Tergitol E-35 has not been manufactured since 1973, and may not be
generally available. Therefore, alternative column packings should
be specified.
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Response: Tergitol E-35 was the column packing used when data
to support Method 107-A was generated. Rather than require someone
to formally revalidate an alternative method to the Environmental
Protection Agency (EPA) each time a column packing becomes obsolete,
EPA prefers to use the language in Section 6.3.2, which says that
it is the analyst's responsibility to determine that the precision
and accuracy are not impaired, and resolution of the vinyl chloride
peak is satisfactory.
Commenter IV-D-3
3.1 Comment: Due to the hazards involved, EPA should not
recommend the use of pure vinyl chloride to prepare liquid calibration
standards. Furthermore, due to the availability of standard reference
materials from the National Bureau of Standards, the accuracy of
commercially prepared gaseous vinyl chloride mixtures is probably
far superior to any liquid standards prepared by the procedure
described in the proposed method.
Response: The Agency recognizes the need to exercise great
caution in the use of pure vinyl chloride in Section 5, Safety, and
Section 9.1, Preparation of Standards. Liquid standards are an
integral part of the method, and gas standards would add considerable
cost to the method without increasing the accuracy to a significant
or necessary degree.
Commenter IV-D-4
4.1 Comment: The proposed alternative test method has been
reviewed by members of a plastic trade association and is endorsed
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as both straightforward and sound, and is a simplified and less
costly alternative to the present reference method.
Response: No response is required.
Commenter IV-D-5, IV-D-7
5.1 Comment: The commenter agrees that the proposed alternative
method is desirable from the standpoints previously mentioned.
Response: No response is required.
5.2 Comment: The peak shape and the baseline in the sample
chromatograph of the solvent impurities are not very good and may
present problems in quantitating small amounts of vinyl chloride.
One reason for the poor chromatography may be the rather large
injection of 10 micro!iters of sample. A technique that would improve
the chromatography involves the addition of low levels of N20 to the
carrier gas of an electron capture detector. This technique is
-12
capable of detecting about 2 x 10 g of vinyl chloride, which is
2
about 10 times more sensitive than a flame detector.
Response: While an electron capture detector will permit the
determination of very low levels of vinyl chloride, the enhanced
sensitivity is not necessary to measure the vinyl chloride concentration
of concern in the application specified for Method 107A. However, if
someone requested EPA approval of the use of an electron capture
detector, no problem with that approval would be expected.
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Commenter IV-D-6
6.1 Comment: A manufacturer of gas chromatographs and
accessories objects to the citations of brand name products
(Sections 6.3.1, 6.3.2, 6.3.7), and suggests they be replaced with
generic equivalents. In their opinion, many potential method users will
never question a particular brand selection if one is cited.
Response: Most method users find it helpful to know which
particular brand has been shown to produce satisfactory results.
However, as the EPA does not have the capability to screen all
products to determine acceptability, it believes the best course
of action is to clearly leave the method users the option to choose
some other brand by adding the phrase "or equivalent" to each brand
product cited.
Commenter IV-D-7
7.1 Comment: Refer to Comment and Response 5.2.
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Table 1. LIST OF COMMENTERS
Docket Number A-80-37
Docket item number
IV-D-1
IV-D-2
IV-D-3
IV-D-4
IV-D-5
IV-D-6
IV-0-7
Commenter/affilIation
John T. Barr, Manager, Regulatory Response
Air Products and Chemicals, Inc.
Box 538
Allentown, Pennsylvania 18105
R.T. Gottesman, Vice President
Tenneco Chemicals
Park 80 Plaza West-One
Saddle Brook, New Jersey 07662
Robert Denyszyh, Manager of R and D
Scott Specialty Gases
Scott Environmental Technology, Inc.
Plumsteadville, Pennsylvania 18949
Peter L. de la Cruz, Assistant General
Council,
The Society of the Plastics Industry, Inc.
c/o Keller and Heckman
1150 17th Street, N.W.
Suite 1000
Washington, D.C. 20036
Robert E. Sievers, Director
Cooperative Institute for Research in
Environmental Sciences
Campus Box 449
University of Colorado at Boulder
Boulder, Colorado 80309
Milton D. Siege!, Director,
Product Regulatory Affairs
Varian
611 Hansen Way
Palo Alto, California 94303
Robert E. Sievers, Director
Cooperative Institute for Research in
Environmental Sciences
Campus Box 449
University of Colorado at Boulder
Boulder, Colorado 80309
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before comoleting)
1 REPORT NO. 2.
EPA-450/3-82-004
4 TITLE AND SUBTITLE
Test Method 107A - (Proposed February 12, 1981; 46 FR
12188) Summary of Comments and Responses
7. AUTHOR(S)
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
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
3. RECIPIENT'S ACCESSION NO.
5. RE°ORT DATE
February 1982
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO.
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
13. TYPE OF REPORT AND PERIOD COVERED
14 SPONSORING AGENCY CODE
EPA/200/04
This document addresses the public comments submitted after proposal of
Method 107A in the Federal Register. A detailed discussion of these comments
and responses is summarized in this document.
7.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.IDENTIFIERS/OPEN ENDED TERMS
COSATI field/Group
13B
Release Unlimited
19 SECURITY CLASS /This Report,
Unclassified
21 NO OF PAGES
11
SPA ror-i 2220-1 /R«v. -1-771
5 O=SC'_E-E
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