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