Roger, if EPA has approved other alternate methods for determining sulfur in 
fuel gas, can you approve of these for our sulfur methods?   The reason I ask 
is that we are not set up to do any of the applications mentioned in Appendix 
D.  We  have approved custom fuel monitoring schedules in place at 5 other 
compressor station locations and have been approved to use "stain tubes" or 
total sulfur analyzers.  These were issued by Region IX and Region VI.  I can 
send you copies of the approvals from the other Regions if that will help.  
If not, I would recommend that you write the permit with all the below 
referenced test methods and we will work out the details.  WIll it be 
possible to make a change to the permit after things quiet down a bit and we 
have more time to taylor the permit  for you and us?




Kohn.Roger@epamail.epa.gov on 10/18/2001 05:54:40 PM
To: Larry.Campbell@enron.com
cc:  

Subject: Sulfur Content Test Method



Larry,

I am going on vacation for two weeks - my last day will be Oct. 31,
which is a little before the end of the comment period.  I am doing
everything I can to make sure the permits are ready to issue when the
comment period ends.  You have asked about using a sulfur analyzer.
Since that is not typical practice for facilities subject to NSPS GG, I
would have to research that.  Frankly, if you want your permits ASAP,
there really isn't time for that.  Does one of the test methods in
Appendix D of Part 75, which I've pasted below, work for you?  (I know
some don't.)  Please advise so we can keep the process moving.  Thanks.

2.3.3.1.2      Use one of the following methods when using manual
sampling (as applicable to the type of gas combusted) to determine the
sulfur
content of the fuel: ASTM D1072-90, "Standard Test Method for Total
Sulfur in Fuel Gases", ASTM D4468-85 (Reapproved 1989) "Standard
Test Method for Total Sulfur in Gaseous Fuels by Hydrogenolysis and
Radiometric Colorimetry," ASTM D5504-94 "Standard Test Method for
Determination of Sulfur Compounds in Natural Gas and Gaseous Fuels by
Gas Chromatography and Chemiluminescence," or ASTM D3246-81
(Reapproved 1987) "Standard Test Method for Sulfur in Petroleum Gas By
Oxidative Microcoulometry" (incorporated by reference under
o  75.6).

Roger Kohn
U.S. EPA Region 9
75 Hawthorne St., Mail Code AIR-3
San Francisco, CA  94105
phone: (415) 744-1238
fax:   (415) 744-1076