Robin: 

I looked through the docket and did not find any comments from Covanta nor Joe on the revision of Method 202. 

 As you know, we have received comments on the toxicity of MeCl and are addressing the use of MeCl in the 

promulgation package. Although the comment is quite late, we will consider whether to include it in comments 

that we have already received on the issue. 

_________________________________

Ron Myers 

U.S. Environmental Protection Agency 

Office of Air Quality Planning and Standards 

Sector Policy and Programs Division 

Monitoring Policy Group, D243-05 

RTP NC 27711 

Tel. 919.541.5407 

Fax 919.541.1039 

E-mail myers.ron@epa.gov 

Ron and Jason, 

Please see Joe Aldina's "comment" on OTM-28 highlighted in blue below. I realize it is probably late, but just 

wanted to be sure that you were aware of it, 

Robin 

----- Forwarded by Robin Segall/RTP/USEPA/US on 02/04/2010 11:52 AM ----- 

The procedures at 40CFR60 Appendix A-8 to Part 60, Method 26-Determination of 

Hydrogen Halide...,Non-Isokinetic, Method section 6.1.3 Impingers states: 

“Four 30-ml midget impingers with leak-free glass connectors.” (Figure 26-1) should be 

used in the sample train.  

 

The procedures at 40CFR60 Appendix A-8, Method 26A-Determination of Hydrogen 

From: Robin Segall/RTP/USEPA/US

To: Ron Myers/RTP/USEPA/US@EPA, Jason Dewees/RTP/USEPA/US@EPA

Date: 02/04/2010 11:56 AM

Subject: Fw: OTM28 Comment

From: "Aldina,Joe" <JAldina@CovantaEnergy.com>

To: Robin Segall/RTP/USEPA/US@EPA

Date: 02/02/2010 05:08 PM

Subject: Procedures for RM26 and OTM28

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Halide...Isokinetic Method, section 6.1.6 Impinger Train states: 

“...five or six impingers connected in series with leak-free ground glass fittings.” (Figure 

26A-1) should be used in the sample train. 

 

The preamble of Appendix A-8 to Part 60 states: 

 “Minor changes in the test methods should not necessarily affect the validity of the 

results and it is recognized that alternative and equivalent methods exist. Section 60.8 

provides authority for the Administrator specify or approve ... (3) minor changes in the 

methodology of the of the test methods.” 

 

The use of the sampling train in Figure 26A-1 is a minor modification to the sampling train 

shown in Figure 26-1. This train improves leak checks for sampling and increases the 

sample volume for more reliable analysis of the halide concentration collected. I request 

that the sample train in Figure 26A-1 be approved by EPA as a minor modification to 

Method 26 and be given Administrator approval for use in Method 26. 

 

Methylene Chloride versus Toluene 

 

This is a problem. EPA has recognizes the problems with using the known carcinogen 

MeCl2 in the field for cleaning RM23 glassware and has approved the use of Toluene. 

The use of MeCL2 as the solvent for RM202 and OTM28 continues and inquiries to EPA 

still recommend only MeCL2. The use of this solvent will require Safety Departments to 

develop procedures for appropriate handling on site and personal protection equipment 

for personnel that may be exposed to the material. The use of Toluene is as in the RM23 

cleaning is a technically acceptable alternative. Please review the use of this solvent for 

these methods. I have attached my comments on this issue.  

 

 

 

 

_____________________________________________________ 

G.J. Aldina 

Vice President CEM/Testing 

 

Covanta Energy Corporation 

40 Lane Road Fairfield, NJ 07004 

201.826.9244 Fax: 973.882.4167 

www.CovantaHolding.com 

 Please don't print this e-mail unless you really need to. Be Green! 

 

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