From: 
Jones, DonnaLee <Jones.Donnalee@epa.gov>
Sent:
Monday, April 4, 2016 1:51 PM
To: 
cdavis@uss.com; fanningd@dteenergy.com; fredric.kiechle@arcelormittal.com; james.kemp@aksteel.com; jsscheetz@uss.com; katie.kistler@aksteel.com; KMBatten@suncoke.com; KMBatten@suncoke.com; marian.gammon@arcelormittal.com; patricksmith@mscarbonllc.com; psaffrin@eriecoke.com; rich.zavoda@arcelormittal.com; rich.zavoda@arcelormittal.com; rich.zavoda@arcelormittal.com; russ.dudek@aksteel.com; rwiler@eriecoke.com; traci.self@arcelormittal.com; zervas@dteenergy.com
Cc:
David Ailor (dailor@accci.org) <dailor@accci.org>; Raymond, Gabrielle <graymond@rti.org>; Shappley, Ned <Shappley.Ned@epa.gov>; Johnson, Steffan <johnson.steffan@epa.gov>; French, Chuck <French.Chuck@epa.gov>; Lowe, Theresa <Lowe.Theresa@epa.gov>
Subject: 
changes to Coke ICR Enclosure 2 after mailing


Hello all - In my first attempt to use my ICR email list, I'd like to let you know we had a late change in Enclosure 2 that did not make it into your packages. We are changing the use of benzene as a solvent in Method 315 (which calls for methylene chloride, as written) to toluene so that the new constituent will be called "toluene soluble emissions." The revised enclosure is attached here, labelled Enclosure 2-04-04B-16.

The reason for this change is that there is possibility of cross contamination associated with using benzene. The VOST train (and sampling media) is highly susceptible to contamination from other solvents used for recovery in the laboratory. Even with best lab practices, there is still a remarkable number of extraneous detections of the standard lab solvents (e.g., acetone and toluene). We are worried that the use of benzene as a solvent for this ICR will bias the VOST (or any other method used) higher and this bias could then drive the RISK higher for this source category. In addition, there is also the possibility of coincidental ambient emissions of benzene either from the benzene plant or the ovens. The toluene extraction should yield a very comparable result for PM when compared to a benzene extraction. Also, there a safety concerns with the use of benzene that have come to be known since the use of BSO years ago. 

One other change that likely did make it into your pages is the addition of Appendix B that includes the test matrix, by facility name, which I included in previous emails. I wanted to call your attention to this since it had not been in Enclosure 2 previously.

We already have had a few FAQs (frequently asked questions) that we will post as they come in on the Coke ICR Website and will be emailed weekly, as needed, so you don't have to check the website every day. I will post and mail the first edition of FAQs by the end of this week.

Signed letters (pdf) will go out later today by email to the individual companies; all hard copies, original letters, and discs will be sent today by Federal Express. I will develop a calendar soon with due dates based on April 4[th] stamped date of letters. 

Best of luck to you in all your tests.
_____________________________________________________________
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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