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From: Palazzolo, Michael A. [Michael.Palazzolo@alcoa.com]

Sent: Friday, May 27, 2011 1:24 PM

To: Putney.David@epamail.epa.gov

Cc: Boyd.Rochelle@epamail.epa.gov; Bahner, Mark A.; Green, David A.

Subject: RE: Analytical methods for PAL 114

David, 

Following my exchange with Gerri on Tuesday 5/24. We have found a lab that can do 

the analytical methods requested and are setting up a contract so people can ship their 

samples to the lab. Once samples are received, the analysis takes two weeks, so I 

believe you should have results on or before June 17th. 

You should be receiving answers to the questionnaire by May 31st as planned.

Thanks, 

Mike 

Michael Palazzolo 

Alcoa, Inc. 

201 Isabella Street

Pittsburgh, PA 15212-5858

Ph: 412-553-4832

From: Putney.David@epamail.epa.gov [mailto:Putney.David@epamail.epa.gov] 

Sent: Friday, May 27, 2011 12:30 PM

To: Palazzolo, Michael A.

Cc: Boyd.Rochelle@epamail.epa.gov; bahner@rti.org; green@rti.org

Subject: RE: Analytical methods for PAL 114

Mike, 

Looks like you and Gerri were able to sort out the metals analysis questions quickly. That's great. Can I get the 

test results by the following Monday (06/06/11) after the original ICR due date (05/31/11)? I do not have any 

relevant laboratory experience but I've been told by people around here that do that the metal analyses are 

relatively quick. The contractors have assured me that they will be able to keep busy with all the information in the 

questionnaire portion of the ICR until 06/06/11. (Since the testing questions did not involve the questionnaire I'm 

assuming I will still get those responses by the original due date.) 

The quicker we get these laboratory results for your facilities the more time we will have to analyze them and be 

creative in how to address any associated issues that may be discovered. 

Thanks, 

David Putney, Environmental Engineer

U.S. Environmental Protection Agency

Office of Air Quality Planning and Standards

Sector Policies and Programs Division
2

109 T.W. Alexander Drive, RTP, NC 27711

Mail Drop D243-02

Ph: (919) 541-2016 Fax: (919) 541-3207

Email: putney.david@epa.gov

From: "Palazzolo, Michael A." <Michael.Palazzolo@alcoa.com>

To: Gerri Garwood/RTP/USEPA/US@EPA

Cc: David Putney/RTP/USEPA/US@EPA

Date: 05/24/2011 05:44 PM

Subject: RE: Analytical methods for PAL 114

Thanks for the quick reply Gerri. We did not ask why Test America does not do 

the microwave digestion. We have also called Columbia Analytical in Rochester, 

Consol Energy R&D and Air Toxics in CA. Columbia and Consol do not have the 

capability to do microwave digestion and Air Toxics only does air canister analyses. 

We will start contacting additional labs to find someone that can use the desired 

methods. 

Regards, 

Mike

Michael Palazzolo

Alcoa, Inc.

201 Isabella Street

Pittsburgh, PA 15212-5858

Ph: 412-553-4832

From: Garwood.Gerri@epamail.epa.gov [mailto:Garwood.Gerri@epamail.epa.gov] 

Sent: Tuesday, May 24, 2011 4:28 PM

To: Palazzolo, Michael A.

Cc: Putney.David@epamail.epa.gov

Subject: Re: Analytical methods for PAL 114

Mike,

I'm sorry that I missed your call earlier, and I apologize for any confusion caused by the emails. This is your table, 

filled in with the recommended and alternative methods.

Sample Type Compound Sample Preparation Method Sample Analysis 

Method

Liquid samples HAP Metals Suggested: 3015 Suggested: 6020 

Hexavalent 

chromium 

Suggested: 218.6 

Alternates: 3060A 

Suggested: 218.6 

Alumina HAP Metals Suggested: 3052 Suggested: 6020 
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samples Alternates: 3051A 

Hexavalent 

chromium 

Suggested: From 5/6/11 

email 

Alternates: 3060A 

Suggested: 7199 

I unfortunately do not have a list of labs that perform each of the methods above. Can you provide more 

information on why Test America doesn't perform the analysis on baghouse dust since they do it on soils? This 

seems unusual to me. 

Gerri G. Garwood, P.E.

U.S. Environmental Protection Agency

Measurement Policy Group

OAR/OAQPS/SPPD

From: "Palazzolo, Michael A." <Michael.Palazzolo@alcoa.com>

To: Gerri Garwood/RTP/USEPA/US@EPA, David Putney/RTP/USEPA/US@EPA

Cc: "Shelby, Laurie M." <Laurie.Shelby@alcoa.com>, "Allen, Chris" <Chris.Allen@alcoa.com>, "Parent, Jordan J." <Jordan.Parent@alc oa.com>, 

"Bilskis, Patricia A." <Patricia.Bilskis@alcoa.com>

Date: 05/24/2011 02:39 PM

Subject: Analytical methods for PAL 114

Gerri,

Alcoa needs clarification from EPA on the specific sample preparation

and analytical methods to be used in response to the April 25th 114

letter. We have collected samples. However, between Table 1.2 in

Enclosure 2 of the 114 letter, the "corrections" email provided by David

on May 6, and discussion with various laboratories (and your responses)

regarding which methods apply to solid or liquid samples, we are

confused and at a standstill. 

Will you please fill in the attached table with the methods EPA would

like us to use along with acceptable alternate methods for each matrix?

Also, if you have laboratories known to perform all of the methods

requested, will you please provide the names of those laboratories?

We have spoken with Test America in Knoxville and were told they perform

microwave digestion on tissue and soil samples only. They will not

perform this digestion on alumina dust samples (which is our "baghouse

dust").

David - As soon as we sort this out, we will contract with a capable

laboratory and provide a date by which the analytical results can be

submitted. Clearly the data will not be available by May 31st as the

analysis typically takes about two weeks and we will need time to
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arrange a purchase agreement.

Thanks for your help,

Mike

Michael Palazzolo

Alcoa, Inc.

201 Isabella Street

Pittsburgh, PA 15212-5858

Ph: 412-553-4832

<<PAL Analytical Methods.docx>> 

[attachment "PAL Analytical Methods.docx" deleted by Gerri Garwood/RTP/USEPA/US]