United States      Office of Air Quality
Environmental Protection  Planning and Standards
Agency        Research Tnangle Pa'k NC 2771 1
                       EPA-450/3-84-006
                       March 1984
Air
Methods 6 and 7
Quality Assurance
and Quality Control
Revisions —

Summary of
Comments and
Responses
                          \

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                                 EPA-450/3-84-006
   Methods 6 and 7 Quality Assurance
     and Quality Control Revisions —

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

                      March 1984

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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.

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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	    19
                                  m

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                                CHAPTER 1



                               INTRODUCTION



     On March 30, 1983,  the U.S.  Environmental  Protection Agency  (EPA)



published "Quality Assurance and  Quality Control  Revisions  to Methods 6 and



7," in the Federal Register (48 FR 13388).   These revisions will  require



source testers to analyze audit samples when making compliance determi-



nations in order to assess their  analytical  accuracy.  These revisions were



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 revisions,  but no  person desired to  make an oral presentation.



The public comment period was from March 30, 1983, to June  13, 1983.



     Letters concerning  issues  relative to the proposed revisions were



received from 15 commenters.  A detailed discussion of these comments and



responses is summarized  in this document.  The summary of comments and



responses serves as the  basis for the revisions which have  been made



between proposal  and  promulgation.

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                                 CHAPTER 2
                     SUMMARY OF CHANGES SINCE  PROPOSAL
Method 6
     1.  Section 3.3.6.  The audit sample set  will  not  include  a known
sample.  The tester is requested to notify  the quality  assurance (QA)
office or the appropriate enforcement agency at least 30  days prior to the
test date to allow sufficient time for sample  del i very-
     2.  Section 4.4.  EPA's Source Branch  is  listed as one  source of known
quality control samples.  A single audit per 30-day period for  the same
enforcement agency is allowed, and the proposed provision for quarterly
audits when samples are analyzed frequently has been dropped.   The
analyst's name is to be included when reporting audit and compliance results,
If a reanalysis is required, the initial and reanalysis audit values are to
be reported.
     3.  Section 6.4.  The equation for calculating the relative error for
the QA audit samples is included.
Method 7
     The changes for Method 7 are the same as  listed for  Method 6 except
for Section 6.4.

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                               CHAPTER 3



                   SUMMARY OF COMMENTS AND  RESPONSES



            QUALITY ASSURANCE AND QUALITY CONTROL  REVISIONS



                           TO METHODS  6 AND 7





1.  D-l, D-5, D-14



     Comment:  We support the proposed additions which  appear  to be



both adequate and reasonable.   Although they may require additional



work and expense, the resultant benefits should justify it.  The



proposed measures will  provide greater uniformity  and confidence to



the analytical  results,  and the improved scientific data base  should



also enhance decision making during  the development of  future  standards.



     Response:   No response necessary.



2.  D-4



     Comment:  Some regulating agencies already require audit  analysis



for compliance testing,  monitor certification, and for  data to be used



for background studies.   We suggest  that audit analysis be required for



compliance determinations and  that the Administrator have the  option



of requiring audits for  other  tests.



     Response:   Audit analysis as a  part of monitor certification and for



data to be used for background studies  is an allowable  option, and in some



cases,  may be required by the Administrator.  The Agency, however, does



not have the authority to make this  mandatory in all cases.



3.  D-4



     Comment:  It is not clear what  criteria should be  used for



determining if audit samples are required only on  a quarterly  basis.



We have had the experience where testing contractors have assured us

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that they participate in and pass the quarterly  audits yet  still do
not analyze the audit samples within the specified  range  on  the first
try.  We do not desire to be overly burdensome on the QA  aspect, but
we feel that there is a definite need for the audit samples, or a
well-defined method of determining the analytical accuracy  of the
laboratory.
     Response:  The quarterly auditing allowance for analyses performed
on a frequent basis has been changed.  The revised  requirement is to
analyze audit samples at least once per month.  This discourages the
use of 3 month-old analytical reagents as allowed in the  quarterly
audit and also eliminates the need to perform an audit with  each set of
compliance samples if samples are analyzed on a.  frequent  basis.
4.  D-ll
     Comment:  In general, we agree with the need for QA  in  source
emission data that are obtained to demonstrate compliance with emission
standards.  However, we feel the requirements should be based upon
sound statistical analysis of available data, and this does  not appear
to be the case with this proposal.  The likely impact of  the proposed
rule can be determined by examining the 1977 through 1980 Environmental
Protection Agency (EPA) inter!aboratory data. If the proposed 5 percent
criterion for S02 were used, anywhere from 8 to  42  percent of the
laboratories would have had unacceptable performance.  If the proposed
10 percent were used for NOX, between 27 and 70  percent of the
laboratories would have failed the test.  There  is  also a strong
indication that samples of lower concentration were more  likely to be
found unacceptable than those of higher concentration.

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     It is suggested that,  initially,  the EPA  audit  samples  be  used  to
identify sources of error in the Methods  6 and 7  analyses and
calculations.  Once these are identified,  a  guideline document  should
be prepared to assist analysts performing  these analyses.  Then, accuracy
criteria for the two methods can be developed  and  implemented.
     Response:   The rationale and data used  to support the proposed  rule
are listed in the background information  report that was announced in
the preamble to the regulations.   The  report is based upon previous  EPA
inter!aboratory audit surveys.   The survey data were studied to
determine the sources of  tester errors and to  find some indications  of
laboratory capabilities.  The sources  of correctable errors  (e.g.,
analytical  biases,  calculation,  and  reporting  errors) were identified
and corrected,  and  the data  were reanalyzed.   The  resultant  figures
showed  that 95  percent of the laboratory tests  for S02 were within
5 percent,  and 86 percent of the tests for NOX were within 10 percent
of the  true values.   The  audit samples will not be prepared in low
concentrations.
5.  D-6
     Comment:  The  proposed  acceptance levels, within 5 percent for
S02 and 10 percent  for N02,  are more restrictive than the respective
7 and 20 percent levels recommended  by the EPA QA Handbook for Air
Pollution Measurement Systems (Redbook).   The  Redbook values are based
on interlaboratory  performance surveys for reference Methods 6 and 7.
If a more recent interlaboratory  survey has been performed and the

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results justify the stricter tolerances,  the data should be presented
for review.   If the data are not available,  the stricter tolerances  are
not justifiabl e.
     Response:  See the response to Comment 4.   The background
information report shows that by eliminating correctable mistakes,
much of the error margin is eliminated.
6.  D-12
     Comment:  Notwithstanding brief mention of a background document,
the proposal does not indicate the existence of a data base that
demonstrates the need for or reasonableness of additional  QA
requirements.  The given justification is that "the current regulation
includes only limited QA requirements and as a" result of this proposed
regulation, the quality of compliance data will  improve."   Regulation
should not be founded on such a generalized, unsupported statement but
upon statistically sound and representative data.
     Response:  See the response to Comment 4.   The analytical  errors
revealed in the inter!aboratory survey indicate the need to have  an
auditing requirement.
7.  0-2
     Comment:  The rulemaking ignores the logistic problems that  will
be created with a one-on-one audit requirement,  especially for  control
agencies conducting numerous tests.
          a.  How will EPA guarantee delivery of the audit samples?
          b.  Will EPA ensure that the concentrations are  within  the
analytical range of the samples?

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          c.  Can it ensure a different audit concentration for each
request?
          d.  Can EPA guarantee fast delivery of audit samples?  Our
regulations require analysis within 48  hours  of  sample collection.
     Response:   EPA will  be able to respond if notified soon  after  a
decision has been made to perform a compliance test.   The  quality
assurance revisions will  have instructions  to notify  the EPA  Quality
Assurance Management Office 30 days prior to  the actual  test.
     Since the compliance sample concentrations  have  to fall  within  the
calibration range of the  standards for  Method 7  and within  the  titration
volume range for Method 6,  the audit sample concentrations  will  be
within these analytical ranges.   Coordination within  the auditing
program will assure that  sources receive different audits  on  different
requests.
8.  D-7
     Comment:   Laboratories performing  Methods 6  and  7  analyses
should be required to participate in the semiannual EPA inter!aboratory
surveys to evaluate their analytical  procedures  and personnel.   Perhaps,
certain standards of performance on their work should be specified.  The
survey offers  enough time for submittal  of  results to allow freedom  in
scheduling the analysis to  coincide with compliance tests.
     Response:   The semiannual  interlaboratory survey will  be modified to
place primary  emphasis on the new auditing  program.   Standards  of performance
are specified  in the new  requirements which evaluate  analytical  procedures
and personnel.

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9.  D-9
     Comment:  The proposed rule apparently ignores the ongoing EPA
interlaboratory audit program for Methods 6 and 7 which is  done
semi annually.  Since this program is underway, we feel  that it is
redundant and unnecessary to add a second program requiring more
frequent audits.  More frequent audit analyses should only  be
required in those cases where the ongoing interlaboratory program
points out a deficiency in a laboratory's quality control program.
     Response:  See the response to Comment 8.  Participation in the
interlaboratory auditing program gave laboratories an indication of
their relative analytical performance but did not identify  or eliminate
inaccuracies experienced on an actual test due to using different  or
inexperienced personnel, mistakes in the standards preparation,
calculations, reporting, etc.  There is a need to audit each compliance
test whenever there is a change in the analyst, analytical  reagents, or
analytical system to maximize the accuracy of the determined results.
A more frequent auditing program than the current EPA interlaboratory
survey is needed.
10.  D-6
     Comment:  The EPA Redbook recommends the appropriate enforcement
agency should provide the audit samples after notification  of intent to
demonstrate compliance by the source.  This recommendation  allows  the
Agency the option to distribute the audit samples to the sources of
unproven analytical  abilities and minimize the workload of  both  the
Agency and the source.
                                   8

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     If QA procedures are to be added,  they  should  allow  for  the
continued discretion of the Agency in  requiring  the audit in  contrast
to forcing the source to perform the audit regardless  of  the  known
analytical abilities of that source.
     Response:  All  testers should be  audited  to detect possible errors
in their analytical  technique.   Even laboratories of proven ability
occasionally experience oversights that affect the  results of compliance
analyses.
11.  D-13
     Comment:   We suggest that  a voluntary audit program  be developed
that allows interested parties  to run compliance samples  on a
predetermined  schedule.   Any interested laboratory  could  be audited by
the Agency and be supplied with  written confirmation of the audit
results.  In this manner an owner or operator  could know  the
qualifications of a  contractor  prior to the  issuance of a contract, the
Agency would be assured of the  laboratory results,  and the documented
record of the  QA program and compliance testing  will be preserved.
     Response:  See  the response to Comment  9.   A voluntary auditing
program that would make known the qualifications  of contractors for
the source operator  to evaluate would be weakened and  its importance
lessened by the number of laboratories  that  opt  to  abstain from
participation.
12.  D-10
     Comment:   We have very serious reservations  regarding both the
necessity and  practicability for analyzing audit samples  at least
once each quarter for all  compliance determinations.   In  view of the

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finite resources of both EPA and industry,  it is strongly  recommended.
that sample auditing for critical  or suspect compliance determinations
only be considered.
     Response:  See the responses to Comments 5 and 9.   In view  of  the
need for improved analytical performance as indicated by past
interlaboratory audit surveys, we feel  the small increase  in resources
that will be experienced will be justified  by the increased reliability
of the compliance results.
13.  D-8
     Comment:  The proposed rules impose an additional  level of
regulation.  The rules state the Administrator may choose  to use
compliance test results to determine the compliance or noncompliance
status of the affected facility regardless  of the audit sample results;
and he may waive reanalysis if the audit analysis fails.  Therefore,
the rationale for the need to have QA regulations is missing.
Reputable analytical facilities have and continually update their
QA procedures.  The proposed requirements are limited in nature  and
probably less comprehensive than existing laboratory QA procedures.
     Response:  Administrator discretion comes into play in only two
cases:  when the test shows the source is substantially below the
standard, but the audit is marginally failed; and when the source is
substantially above the standard,  but the audit is marginally failed.
In each case, the application of a correction factor would not change
the compliance or noncompliance status of the source.   Acceptance of
the test results in each case is allowed because compliance or
noncompl iance is clearly shown and would not be affected by the
additional  error above that normally allowed.
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14.  D-8
     Comment:   The proposed rules  do  not provide  recourse  if  the
analyses are not within the specified boundaries.  There needs to be a
mechanism for a laboratory  to resolve any differences  in analytical
results without necessarily performing a reanalysis.
     Response:   The mechanism for  resolving  analytical differences
will  depend upon the source of error.   If the  standards were  incorrectly
made, a new set would have  to be prepared and  the samples  reanalyzed.  If
only a calculation error is made,  then data  correction without reanalysis
would correct the problem.   It is  recommended  that a known quality
control sample be analyzed  prior to the audit  and compliance  samples to
optimize the system accuracy and precision.
15.  D-13
     Comment:   Administrator discretion in accepting failed audit
results is wholly inconsistent with accepted QA practice.  It is not
known whether the data will  be used as submitted or a correction factor
developed from the audit results.  If the Agency has determined that 5
percent is the maximum allowable error,  all  associated data with such
an error should be invalidated with no exceptions and no corrections.
The results should not be left to  the arbitrary discretion of an
individual.
     Response:   See the response to Comment  13.  The data will be used
as submitted without applying a correction factor.
16.  D-5, D-14
     Comment:   The proposed audit  would not  guarantee the  accuracy of
emission data since the evaluation is on the analysis and  not on the

                                  11

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sampling portion.   Although the proposed additions  are a  step  in  the
right direction, it would be hetter to have a  procedure to  evaluate both
the sampling and analysis, even though this would not be  ideal  because
of possible matrix or interference effects in  the actual  source
samp! es.
     Response:  We agree.  However, the Agency's  experience in  auditing
the sampling procedure (using gas cylinders) has  found this approach
to be impractical, expensive, and the benefits received would  not
justify the effort required to perform it.  If a  simple auditing  technique
can be developed,  EPA will consider such an audit in  the  future.
17.  D-2, D-9
     Comment:  An  audit per set of compliance-samp! es is  over-
regulation.  The proposed quarterly exemption  only  covers repetitive
testing at a given source.  Most control agencies will  have a  central
laboratory and will use different personnel  and analytical  systems.
The NOX analyses are very time consuming, and  a team  of chemists  may
be routinely assigned to analyze the samples so they  can  be completed
in a timely manner.  The requirement that only one  person analyze NOX
samples (Paragraph 4.4) could delay the preparation of the  compliance
test report past deadlines now set by the States  and  EPA.  The proposal
should be amended  to allow more than one person to  analyze  the  samples.
Any analytical variations would be checked by  quality control
procedures currently incorporated in EPA methods  (e.g., equipment
calibrations, duplicate testing and analysis,  and inter!aboratory
testing).  Furthermore, since the "oneness" rationale is  not and  should
                                   12

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 not apply  to  the  sample  collection phase, it should not be mandated for
 the analyst and analytical  equipment phase.
      Response: See  the response to Comment 3.  The intention of the
 rule is  not to restrict  the analysis to one person but to ensure that
 all  parties involved  in  the analysis of the compliance samples likewise
 take part  in  the  analysis of the audits.  The names of all persons
 participating in  the  audit analysis are to be included in the report
 that is  submitted to  the appropriate enforcement agency.
 18.   D-6
      Comment:  The  requirement to analyze two unknown samples as well
 as  a known sample prior  to the analysis is redundant.   Each component
 of  the analysis is  either checked for impurities or standardized
 against  a  primary standard.
      Response:  The QA audit is an overall check of the method's quality
 control.  These quality control checks in the methods are beneficial  but do
 not guarantee accuracy.  Standardization against primary  standards is
 subject  to such inaccuracies as weighing errors, dilution errors,
 calculation errors, etc.; the QA audit will  detect such errors.   Analysis
 of  the known  sample is optional.
 19.   D-15
      Comment:  We oppose the proposed rule because it will increase the
 cost of  conducting  a  compliance test considerably and will put the smaller
 stack sampling firms  at a competitive disadvantage.   These firms may  be
.forced to discontinue the testing services because they will  not be
 able to  absorb the  additional  cost and remain competitive.  In our
 opinion, the  benefit  gained by the improved QA does  not justify  the

                                   13

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increased cost.  Both methods.currently provide for adequate
standardization of reagents and provide detailed analytical procedures
that should yield acceptable results with an acceptable  degree of
accuracy.
     Response:  See the responses to Comments 12 and 18.  The increased
cost associated with implementing QA requirements should  not be
substantial enough to give larger firms a competitive advantage.
20.  D-8, D-12
     Comment:  One-concern of the proposed rule is cost.  The first
time cost to analyze the audit samples would not be significant since
analysis would be done with the compliance samples.   However, costs
may be very significant if reanalysis is necessary due to audit samples
of poor quality, failure to acquire audit samples when needed, or a
subsequent determination that the specifications are unduly stringent.
Moreover, there is no evidence in the proposal  that EPA considered
compliance retesting costs to any extent in the determination of
economic impact.
     Response:  The background information report shows  that a very
high percentage of representative laboratories  are capable of analyzing
EPA-prepared audit samples and passing the proposed acceptance levels
once correctable mistakes have been eliminated.   Past experience also
indicates that increased familiarity with the methods (especially
Method 7) tends to increase operator accuracy.   The known quality control
sample will point out deficiencies in the analysis which  can be corrected
and eliminated for subsequent tests.   Laboratories employing qualified
personnel and good quality control procedures will  incur  little additional
expense due to reanalysis.
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21.  D-7
     Comment:   We are concerned about the delay  that  would  be caused
by repeating the entire analysis procedure if  audit results  fall
outside the acceptable range.   The delay  due to  reordering,  receiving,
and finally reanalyzing the audit samples could  impede  laboratory
routine and delay report submittal  which, in some  instances,  is
required within 30 days.   The  entire  procedure is  cumbersome  and
counterproductive to lab efficiency.
     Response:   The entire procedure  should  increase  lab efficiency
and accuracy since analysis error will  be kept within an acceptable
level.   Each S02 and NOX audit vial contains enough solution  for at least
two duplicate tests, so reordering samples for reanalysis should
not be necessary.   In the event a reanalysis is  required, retesting can
be avoided by  saving the remainder of the samples  for reanalysis.
22.  D-7
     Comment:   Rather than performing an  analysis  on  unknown  samples,
it may be more beneficial  to analyze  EPA-supplied  specimens of known
concentration  prior to running compliance test samples.  If necessary,
require that results of the standards analysis be  included with the
compliance test report.  In this way, mistakes can be immediately
identified and resolved before continuing further.
     Response:   Known samples  are available  from EPA and can  be used
for that purpose.   The incentive to maximize accuracy by a tester would
be lessened if analysis of the known  were required instead of the blind
audit.   It would be easiest to resolve mistakes  by reporting  the audit
results by telephone.  In this manner,  mistakes  will  be immediately

                                   15

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known and can be resolved before writing the test report  and  having to
wait for a reply.
23.  D-2
     Comment:  A single audit check per quarter should  be adequate.
Individual precision checks should be accomplished by requiring that
the known concentration be analyzed with each set of compliance samples
collected during the quarter.
     Response:  See the responses to Comments 3 and 22.
24.  D-8
     Comment:  The proposed rules do not address the origin,  quality,
or nature of the audit samples.   This is an important concern if a
laboratory's performance is being assessed based on these samples.
A reference standard for preparation of the audit samples should be
cited.
     Response:  The audit samples are to be obtained from EPA as detailed
in Sections 3.3.6 for Method 6 and 3.3.9 for Method 7.
25.  D-3, D-6
     Comment:  We object to the requirement that only EPA-derived
audit samples be accepted when making compliance analyses.  We
propose that internally-generated standards be allowed  in lieu of
the EPA standards.  The practice of analyzing standards is routinely
followed in good laboratories with good QA procedures.  These
laboratories should be allowed to continue such practices without the
added workload of EPA audit samples.
     In addition, the potential  exists for error in the audit sample
preparation or in documenting the actual  audit concentrations.
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     Response:  See the response to Comment 18.   The potential  for
errors in preparation and documentation of actual  concentrations  would
be compounded if each laboratory were allowed  to  generate  its own  audit
samples.   Any error in an EPA-derived audit would  be rapidly detected
since many laboratories will  be analyzing  them.  To  ensure fairness  in
meeting the audit accuracy levels,  a single source of  samples is  needed
to serve as a reference for all  laboratories.
26.  D-13
     Comment:  A serious concern is that the audit sample  results
can only be obtained if the audit and set  of compliance results are
telephoned to the Agency, presumably by the contractor.  It is
unthinkable to use telephone communication for compliance  determinations
as the Agency proposes.
     Response:   Reporting the audit results by telephone  is an option
and not a requirement.   Submission  of a written test report is still
mandatory in this case.   The allowance for telephone communication
enables the tester to determine  at  an early  stage  whether  the audit is
passed and hence the compliance  data acceptable, or whether the audit
is failed, and a reanalysis is necessary.   Determination of the audit
status before the test report is written and before  the audit and
compliance samples have aged  substantially  would eliminate much of the
unnecessary work and expense  created if it is determined at a later
date that a reanalysis  is needed.
                                   17

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27.  D-2, D-ll



     Comment:  In Method 6,  Section  6.4  is  lacking the relative error



equation for the QA audits.



     Response:  This addition has been made.
                                   18

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                        Table  1.  LIST OF COMMENTERS
                           Docket Number A-80-57
Document Number
    IV-D-1
    IV-D-2
    IV-D-3
    IV-D-4
    IV-D-5
        Commenter/Affi 1 i ati on

Dick Serdoz, Air Quality Officer
State of Nevada Dept. of
  Conservation and Natural  Resources
Division of Environmental  Protection
Carson City, Nevada 89710.
                  Chief
                  Services and
Ben A. Brodovicz,
Div. of Technical
  Monitoring
Commonwealth of Pennsylvania
Dept.  of Environmental  Resources
Post Office Box 2063
Harrisburg, Pennsylvania  17120
Thomas A. Lowe,  Manager
  Analytical  Research
Kaiser Aluminum  and Chemical
Center for Technology
Post Office Box  877
Pleasanton, California  94566
                                                                  Corp.
Charles S.  Krick,  Environmental
  Engineer
State of Delaware  Dept.  of  Natural
  Resources and Environmental  Control
Division of Environmental Control
Edward Tatnall  Building
Dover, Delaware 19901.

Charles D.  Mai loch,  Director
  Regulatory Management,  Air
  Environmental  Policy Staff
Monsanto Company
800 N. Lindbergh Boulevard
St. Louis,  Missouri  63166.
                                    19

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                        Table 1.   LIST  OF  COMMENTERS
                           Docket Number  A-80-57
                                (Continued)
Document Number

    IV-D-6
    IV-D-7
    IV-D-8
    IV-D-9
    IV-D-10
    IV-D-11
       Commenter/Affi 1 i ati on

Douglas G.  Mercer,  Superintendent
  Environmental  Programs
Texas Gulf Chemicals Co.
Post Office Box 48
Aurora, North Carolina 27806

J.M. Reinke, Manager
  Survey and Evaluation
Stationary Source Environmental
  Control Office
Ford Motor Company
One Parklane Boulevard
Dearborn, Michigan  48126

Roger D. Dodds,  Air Quality Engineer
  Environmental  Dept.
Wisconsin Electric  Power  Co.
231 W. Michigan
Post Office Box 2046
Milwaukee,  Wisconsin 53201

Robert L. Pearson,  Administrator
  Environmental  Affairs
Public Service Company of Colorado
Post Office Box 840
Denver, Colorado 80201

V.C. Eissler, Vice  President
  North American Production
Conoco, Inc.
Post Office Box 2197
Houston, Texas 77252

Ashok K. Jain, Manager
Engineering Projects Research
National Council of the Paper
Industry for Air and Stream
  Improvement
Southern Regional Center
Post Office Box 14483
Gainesville. Florida 32604	
                                     20

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                       Table 1.  LIST OF COMMENTERS
                          Docket Number A-80-57
                               (Continued)
Document Number
    IV-D-12
    IV-D-13
    IV-D-14
    IV-D-15
        Commenter/Affiliation

T.C. Owen,  Director
  Corporate Office of Environmental
  Affairs
Union Camp  Corporation
Post Office Box 1391
Savannah, Georgia 31402

Wayne T. Swallow, Supervisor
  Regulatory and Environmental
  Monitoring
Public Service Indiana
Plainfield, Indiana 46168

Theodore L. Kinne, Director
  Construction and Operations
Interstate  Natural Gas Association
  of America
1660 L Street, N.W.
Washington, D.C. 20036

Herman A. Fritschen,  General Manager
Safety and  Environmental Services
Cities Service Company
Box 300
Tulsa, Oklahoma 74102
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                                    TECHNICAL REPORT DATA
                             (Please read Instructions on the reverse before completing)
1. REPORT NO.
  EPA-450/3-34-006
                                                              3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
  Quality Assurance  and Quality Control  Revisions to
  Methods 6 and  7
5. REPORT DATE
     March 1984
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
                                                              8. PERFORMING ORGANIZATION REPORT NO.
  Emission Standards  and Engeneerinq 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, North Carolina   27711
                                                              10. PROGRAM ELEMENT NO.
11, CONTRACT/GRANT NO.
 rj. SPONSORING AGENCY NAME AND ADDRESS
13. TYPE OF RE PORT AN D PERIOD COVERED
  DAA for Air Quality  Planning and Standards  (MD-10)
  Office of Air,  Noise,  and Radiation
  U.S. Environmental Protection Agency
  Research Triangle  Park, North Carolina   27711
14. SPONSORING AGENCY CODE
       EPA/200/04
   .UI-PLEMENTARY NOTES
 !u ABSTRACT
       This document  addresses the public  comments submitted after  proposal of the

  rulemaking in  the  Federal  Register.  Changes  made to this rulemaking as a result

  of these comments  are included.  This document serves as the basis  for the revisions

  which have been made to the rulemaking between proposal and promulgation.
                                  KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS

It! ui:.l HIQUTION STATEMENT
Release Unlimited
b.lOENTlFlERS/OPEN ENDED TERMS

19. SECURITY CLASS (This Reporr)
Unclassified
20. SECURITY CLASS (This page)
Unclassified
c. COSATi F-'ield/Croup

21. NO. OF PAGES
21
22. PRICE

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