From: 
Jones, DonnaLee <Jones.Donnalee@epa.gov>
Sent:
Friday, March 11, 2016 2:24 PM
To: 
David Ailor <dailor@accci.org>
Cc:
Raymond, Gabrielle <graymond@rti.org>
Subject: 
REVISED Enclosure 2, EPA Responses to Industry Comments, New testing facility Listing


David - Here is revised draft of Enclosure 2 that reflects comments made by industry and some of our own editorial changes.  Also a separate file that responds to some of the specific industry comments. Also a revised facility list.

Major changes are as follows:
1. While we cannot change the length of sampling as per the method requirements, but I have reduced the # of facilities testing so that it is 2+2+2, where the 2 Group B facilities is a change from the previous three (3). Other groups A&C were previously 2. See attached scheme. I had prescribed which facilities that need to do what for group B to keep one foundry in the pushing tests. The Quench Tower testing table has been updated to reflect this change but the requirements for just two facilities to do quench tower testing still stands. This 2+2+2 scheme is as low as we can go and still have some confidence that we assessing the risk accurately. We may need to do additional testing if others at EPA do not agree after the risk analysis is run, so need to give you all a heads up now.
2. We are requiring three "successful' runs since if we will not be getting the minimum of 7 runs for a normal data set, we need to at least make sure we get 6 total good runs that we can keep.
3. I gave revised the lists of pollutants in section 1.0 for specific semi-volatile and volatile HAP targeted by the methods. Because of complaints with previous methods for semi-volatiles, we have had to go to two methods instead of one. But the CARB tests are possibly as alternatives and these are both in the ERT.
4. I have added COMS as a method to determine opacity, where already performed as per the rule (Note COMS is not a pollutant therefore does not belong in section 1.0) _____________________________________________________________
Regards,
Donna Lee Jones, Ph.D.
Senior Technical Advisor, Metals Sector
U. S. Environmental Protection Agency
Office of Air Quality Planning and Standards Sector Policies and Programs Division / Metals & Inorganic Chemicals Group (D 243-02) Research Triangle Park, NC  27711  Tele:  (919)  541-5251  Fax  (919)  541-3207 ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
"Reasonableness never fails to be appreciated."  - anon.



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