From: <French.Chuck@epamail.epa.gov>

To: Michael Buckantz <mike.buckantz@gmail.com>

CC: <hhine@rsrcorp.com>, Danny Greene <Danny.Greene@erg.com>, Donna Lazzari 

<Donna.Lazzari@erg.com>

Date: 7/15/2010 10:36 AM

Subject: Re: Questions Regarding Test Matrix - RSR Corporation

Hi Mike,

 Please see responses to your questions below. Let us know if

you have any more questions or issues, etc...

 Thank You.

 Chuck

1) Regarding the scope of testing at each facility, I'm planning to

adhere strictly to the list of compounds for each facility and emissions

source. For example, I'm assuming that asking for Hexavalent Chromium

testing on Busch Unit D but not on Busch Unit G for the City of Industry

facility is intentional.

Response: O.K. Yes, follow the test matrix as written.

2) Test Methods: I am concerned about the footnote “**”...the

language seems backwards because the general intent is to “detect”

constituents of concern or report detection limits at or below the

target MDL (i.e., a higher detection limit is counter-productive). The

footnote would make more sense if it read: “**Note: Sample volumes at

or LESS THAN 2.3 m3 are acceptable provided each test run provides

measured results at or above the method detection level. “ Can you

please clarify the intent of this footnote?

Response: We think your suggestion makes sense (that the footnote

should refer to minimum volumes below the specified volume rather than

above). However, the footnote should likely be consistent with the

table (i.e., 3.4 m3 instead of 2.3 m3). So, the footnote should say:

"**Note: Sample volumes at or LESS THAN 3.4 m3 are acceptable provided

each test run provides measured results at or above the method detection

level.

3a) Test Methods: EPA Method 29: Full digestion per method

satisfies requirements for “+ compounds”, i.e., no further action

required.

Response: O.K.

3b) Test Methods: EPA Method 29: Is it acceptable to test

for Mercury per Method 29 instead of using a separate sampling train?

Alternatively, Mercury may be incorporated into CARB Method 436 (as

promulgated) rather than a separate test per CARB Method 101/101A.

Response: Yes. Method 29 or CARB Method 436 are acceptable for

mercury. You do not need to do a separate test for mercury with

101/101A.
4) Test Methods: Hexavalent Chromium per SW-846 Method 0061: Test

Method requires use of KOH, which may be contaminated (like NaOH). We

have substituted NaHCO3 in lieu of NaOH with great success for WESP Air

Toxics Testing at City of Industry. We had an issue with low alkalinity

last year so the laboratory recommended buffering the solution with a

small amount of NaOH (enough to buffer the solution without

contaminating it). We recommend this substitution in lieu of KOH if

allowed.

Response: O.K. We conclude that it would be OK to substitute a

buffer solution of NaHCO3 and NaOH for the KOH provided that the tester

maintains the required pH (8.5) in the collection solution.

5) Test Methods: Total Hydrocarbons, specifically PAHs?: Confirm

that testing for PAH (i.e., CARB Method 429) is NOT required if testing

for THC is performed per EPA Method 25A (CEMS/FIA).

Response: Correct! You do not need to speciate the PAH compounds

using CARB M429.

6) Test Methods: Dioxins/Furans: Analytical detection limits for

EPA Method 23 and CARB Method 428 are comparable...why are sample

times/volumes different (when they don’t have to be)?

Response: O.K. We agree. With either CARB Method 428 or EPA

method 23 minimum sample volumes of 3.4 m3 are acceptable.

 

From: Michael Buckantz <mike.buckantz@gmail.com> 

 

To: Chuck French/RTP/USEPA/US@EPA 

 

Cc: hhine@rsrcorp.com 

 

Date: 07/13/2010 08:30 AM 

 

Subject: Questions Regarding Test Matrix - RSR Corporation 

 

Chuck -

Just wanted to prepare you slightly in advance for some of the questions

I'll have during our call this morning related to the test matrix for

RSR Corporation.

1) Regarding the scope of testing at each facility, I'm planning to

adhere strictly to the list of compounds for each facility and emissions

source. For example, I'm assuming that asking for Hexavalent Chromium

testing on Busch Unit D but not on Busch Unit G for the City of Industry
facility is intentional.

2) Test Methods: I am concerned about the footnote “**”...the

language seems backwards because the general intent is to “detect”

constituents of concern or report detection limits at or below the

target MDL (i.e., a higher detection limit is counter-productive). The

footnote would make more sense if it read: “**Note: Sample volumes at

or LESS THAN 2.3 m3 are acceptable provided each test run provides

measured results at or above the method detection level. “ Can you

please clarify the intent of this footnote?

3a) Test Methods: EPA Method 29: Full digestion per method

satisfies requirements for “+ compounds”, i.e., no further action

required.

3b) Test Methods: EPA Method 29: Is it acceptable to test

for Mercury per Method 29 instead of using a separate sampling train?

Alternatively, Mercury may be incorporated into CARB Method 436 (as

promulgated) rather than a separate test per CARB Method 101/101A.

4) Test Methods: Hexavalent Chromium per SW-846 Method 0061: Test

Method requires use of KOH, which may be contaminated (like NaOH). We

have substituted NaHCO3 in lieu of NaOH with great success for WESP Air

Toxics Testing at City of Industry. We had an issue with low alkalinity

last year so the laboratory recommended buffering the solution with a

small amount of NaOH (enough to buffer the solution without

contaminating it). We recommend this substitution in lieu of KOH if

allowed.

5) Test Methods: Total Hydrocarbons, specifically PAHs?: Confirm

that testing for PAH (i.e., CARB Method 429) is NOT required if testing

for THC is performed per EPA Method 25A (CEMS/FIA).

6) Test Methods: Dioxins/Furans: Analytical detection limits for

EPA Method 23 and CARB Method 428 are comparable...why are sample

times/volumes different (when they don’t have to be)?

That should handle it from my standpoint. I will call you at 10:00 AM

your time and then we'll conference in Homer.

Thanks in advance for your time and consideration.

--

Mike Buckantz

RSR Corporation

(714) 625-7020