Robin:

I looked through the docket and did not find any comment s 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 l ate, 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 ju st 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, M ethod 26-Determination of Hydrogen Halide...,Non-Isokinetic, Method section 6.1.3 Impingers states: “Four 30-ml midget impingers with leak-free glass c onnectors.” (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 Page 1 of 3

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...Halide

... Isokinetic Method, section 6.1.6 Impinger Train stat es:

“...five or six impingers connected in series with l eak-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 nece ssarily affect the validity of the results and it is recognized that alternative and equi valent methods exist. Section 60.8 provides authority for the Administrator specify or a pprove ... (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 halid e 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 us e 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. P lease 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 

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