Date: May 2, 2011 

To: Docket ID No. EPA-HQ-OAR-2007-0011 

From: Kristin Sroka 

Subject: NSPS Subpart J Review: Meeting Minutes for June 29, 2010, Meeting Between 

the U.S. EPA and Representatives of Thermo Fisher Scientific 

Introduction

On June 29, 2010, representatives of the U.S. Environmental Protection Agency (EPA) 

and their contractor (RTI International) participated in a stakeholder meeting with 

representatives of Thermo Fisher Scientific (Thermo Fisher). The names and affiliations of the 

participants are included in Attachment 1. Attachment 2 is a copy of the meeting invitation and 

meeting description. A copy of the product information provided by Thermo Fisher is provided 

in Attachment 3. The purpose of the meeting was to discuss total sulfur monitoring for flares in 

NSPS subpart Ja. 

Discussion

The Thermo Fisher representative began by noting that five of the seven refineries in the 

South Coast Air Quality Management District (SCAQMD) of California use the SOLA II Flare 

total sulfur analyzer to comply with the SCAQMD regulations, so they fully expect that the 

SOLA II Flare will meet the specifications in NSPS subpart Ja when it is finalized. However, he 

stated that sales have been slow because many refinery owners and operators are waiting for the 

final NSPS subpart Ja before purchasing their monitors. 

In response to EPA questions, the Thermo Fisher representative provided more details 

about the SOLA II Flare total sulfur analyzer. The SOLA II Flare total sulfur analyzer is a single 

analyzer system with two independent measurement ranges. The analyzer calculates a 240-

second rolling average, updating every second. Thermo Fisher representative recommends that 

the sensor be placed after the flare’s water seal. 

The Thermo Fisher representative noted that an external stimulus is needed to switch 

from the low range tube to the high range tube. If the system has a flow meter, a high flow rate 

reading will provide that stimulus; the water level in the water seal may also be used. Thermo 

Fisher has found that the pressure difference between a low flow and a high flow is not large 

enough to cause the switch. With dilution, the gas stream reaching the detector typically has a 

maximum sulfur concentration of 1 percent. However, if gas with a high sulfur content enters 
 

2

the system in the low measurement range, it will “peg” the detector. Once that happens, it will 

take the detector about 6 to 10 minutes to recover (depending on the sulfur content of the gas 

stream that pegged it). 

The Thermo Fisher representative noted that the analyzer can take samples during flaring 

events; however, he stated that refinery owners and operators that do so should be reheating the 

sample prior to analysis to make sure the sulfur compounds have not condensed in the water, 

which would bias the results low. Similarly, he noted that some refiners send their samples to a 

knockout drum to get a dry sample, but that may also bias the results low if the sulfur 

compounds condensed in the water. 

The Thermo Fisher representative stated that typically, analyzer checks are conducted 

daily, while more comprehensive whole-system calibrations are less frequent (usually quarterly 

or annually). Most of the time, three gas cylinders are used to calibrate the system. One cylinder 

is used to test the low end of the low range (e.g., 50 ppm), one cylinder is used to test the high 

end of the high range (e.g., 500,000 ppm), and a third cylinder is used to test both the high end of 

the low range and the low end of the high range (e.g., 5,000 ppm). The Thermo Fisher 

representative also stated that at some refineries in the SCAQMD, they tried using carbonyl 

sulfide (COS) in the cylinders as an alternative to hydrogen sulfide (H2S), but COS has to be 

maintained at 70 °F, so they went back to using H2S. 

The Thermo Fisher representative stated that the SOLA II Flare analyzer typically costs 

about $125,000. The company has heard estimates of $450,000 to 500,000 for the full shelter 

system and sampling line. A refiner would also incur costs for site preparation, electrical work, 

and tapping the flare line, so the overall estimated cost for the system would be about $1 million. 

Finally, the Thermo Fisher representative stated they would be interested in an EPA 

certification process for analyzers. He noted that the SCAQMD has a process to certify 

analyzers for use in complying with their regulations. The process requires the system to be 

tested with several standard compounds to evaluate its performance. 
Attachment 1 

Participants in June 29, 2010 Meeting 

Thermo Fisher Representatives

Greg Brumfield 

Daniel Merriman 

U.S. EPA Representatives

Jason Dewees 

Brenda Shine 

Peter Westlin 

RTI International (EPA contractor)

Jeff Coburn 

Kristin Sroka 
Attachment 2 

Meeting Invitation and Description 
ThermoFisher: Total Sulfur Analyzer for Refinery Flare Gas 

Tue 06/29/2010 9:00 AM - 10:30 AM 

Chair: Peter Westlin/RTP/USEPA/US 

Rooms: Conf. Rm. E101/RTP-Bldg E@EPA 

Required: Barrett Parker/RTP/USEPA/US@EPA, Brenda Shine/RTP/USEPA/US@EPA, Dan 

Bivins/RTP/USEPA/US@EPA, daniel.merriman@thermofisher.com, Foston 

Curtis/RTP/USEPA/US@EPA, greg.brumfield@thermofisher.com, Jason 

Dewees/RTP/USEPA/US@EPA, Robin Segall/RTP/USEPA/US@EPA 

Optional: Rachel Agnew/RTP/USEPA/US@EPA, Ron Myers/RTP/USEPA/US@EPA, Tom 

Driscoll/RTP/USEPA/US@EPA 

Presentation led by Greg Brumfield - ThermoFisher Scientific manufactures the majority of Total 

Sulfur Analyzers for SCAQMD's Rule 1118 in Southern California. The latest analyzer can 

accurately measure from 15 ppm to 100% total sulfur. The latest SOLA Flare Analyzer removes 

the need for the refinery to do "Engineering Calculations.” This analyzer monitors ALL of the 

sulfur in the flare gas, not just MOST (which is what TRS is), or SOME (which is what H2S is). 

Every sulfur compound from light mercaptans to heavy sulfur compounds are efficiently and 

effectively converted to SO2 (Total Sulfur).