15
Tech
Valley
Drive

East
Greenbush,
New
York
12061

Phone:
518­
880­
1500

Fax:
518­
880­
1510
July
12,
2004
Attn:
Ms.
Suzanne
Rudzinski
Director
Transportation
and
Regional
Programs
Division
Environmental
Protection
Agency
1200
Pennsylvania
Ave.
N.
W.
6406J
Washington,
DC
20460
Dear
Ms.
Rudzinski,

Our
company
recently
participated
in
meetings
with
EPA
staff
in
Washington,
DC
and
Ann
Arbor,
MI.
Pursuant
to
these
meetings
I
am
writing
to
request
that
ASTM
Standard
Test
Method
D
7039­
04
be
designated
by
the
EPA
as
an
alternative
method
for
measuring
sulfur
concentration
in
gasoline
fuels.

D
7039­
04
is
a
recently
approved
ASTM
test
method
for
measuring
sulfur
in
gasoline
and
diesel
fuel
using
Monochromatic
Wavelength
Dispersive
X­
ray
Fluorescence
Spectrometry
(
MWD
XRF).
The
Federal
Register
(
Volume
68,
No.
194,
Tuesday
October
7,
2003/
Rules
and
Regulations
page
57815
and
57816),
currently
stipulates
D
2622­
98
as
the
designated
method
and
D
5453­
00,
D
6428­
99
and
D
3120­
96
as
alternative
test
methods
for
measuring
sulfur
in
gasoline.

An
extensive
Inter­
Laboratory
Study
(
ILS)
was
conducted
in
2002,
as
part
of
the
application
process
for
D
7039
standard.
This
study
concluded
that
the
test
method
presents
a
significant
improvement
in
detection
capability
over
existing
x­
ray
fluorescence
based
methods,
notably
D­
2622
and
D­
4294.
The
EPA's
Ann
Arbor
facility
was
one
of
the
6
participating
laboratories
in
this
Inter­
Laboratory
Study.
The
attached
table
reviews
the
PLOQ
(
Pooled
Limit
of
Quantification)
and
repeatability
values
for
EPA­
approved
methods
for
measuring
sulfur
in
gasoline.
Within
the
ASTM
community
and
elsewhere,
PLOQ
and
repeatability
are
widely
used
measures
of
a
method's
detection
capability.
The
values
are
obtained
directly
from
the
respective
published
ASTM
standards.
The
PLOQ
and
repeatability
values
for
the
new
method
D
7039
are
also
listed.

These
reported
values
demonstrate
that
the
detection
capability
of
the
new
standard
D
7039
compares
favorably
with
the
designated
method
D
2622
and
is
generally
equivalent
to
alternative
methods
D
5453
and
D
3120.

Wavelength
Dispersive
X­
Ray
Fluorescence
is
already
a
widely
accepted
and
cost
effective
measurement
technique
in
the
petroleum
industry
for
determination
of
sulfur.
We
kindly
request
that
the
EPA
designate
D
7039
as
an
alternative
method
(
based
on
Monochromatic
Wavelength
Dispersive
XRF),
allowing
refiners
and
importers
to
use
this
method
to
comply
with
the
requirements
to
test
gasoline
for
sulfur
content.
15
Tech
Valley
Drive

East
Greenbush,
New
York
12061

Phone:
518­
880­
1500

Fax:
518­
880­
1510
Page
2.
S.
Rudzinski
July
12,
2004
ASTM
Standard
Test
Methods
and
their
PLOQ
and
Repeatability
(
r)
Values
ASTM
Method
Analytical
Technique
EPA
Designation
Status
PLOQ:
(
Pooled
Limit
of
Quantification)
Repeatability
D
2622­
98
WD
XRF
technique
Designated
method
19
ppm
and
10
ppm
based
on
two
separate
studies
For
5ppm:
r=
4ppm
10ppm:
r=
5
ppm
100ppm:
r=
12ppm
D
5453­
00
UV
Fluorescence
Alternative
method
<
1ppm
and
<
5ppm
based
on
various
studies
For
5ppm:
r=
0.6
ppm
10ppm:
r=
1.0ppm
100ppm:
r=
5.7ppm
D
3120­
96
Microcoulometry
Alternative
method
3
ppm
For
5ppm:
r=
1.4ppm
10ppm:
r=
2.8ppm
100ppm:
r=
28ppm
D
6428­
99
Oxidative
Combustion
and
Electrochemical
Detection
Alternative
method
No
PLOQ
listed,
Applicable
range:
0.05­
100ppm
Not
available
D
7039­
04
Monochromatic
WD
XRF
Currently
no
EPA
designation
4
ppm
For
5ppm:
r=
1.2ppm
10ppm:
r=
1.8ppm
100ppm:
r=
5.6ppm
I
greatly
appreciate
your
consideration
of
this
request
and
look
forward
to
your
response.
Please
contact
me
if
I
can
be
of
further
assistance.

Sincerely,

Berry
Beumer
Vice
President
XOS,
Inc.
t.
518
880
1504
cc:
Bruce
Kolowich,
EPA
Dave
Kortum,
EPA
Joe
Sopata,
EPA
Mike
Pohl,
Horiba
Instruments
Inc.
