Fwd: Questions Regarding Test Matrix - RSR Corporation 

 

Danny - 

The test-related e-mail we're currently on the phone discussing. 

Looking forward to your response. 

Mike. 

---------- Forwarded message ---------- 

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

Date: Tue, Jul 13, 2010 at 5:30 AM 

Subject: Questions Regarding Test Matrix - RSR Corporation 

To: french.chuck@epa.gov

Cc: hhine@rsrcorp.com

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

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

To: Danny.Greene@erg.com

Date: 7/13/2010 10:24 AM

Subject: Fwd: Questions Regarding Test Matrix - RSR Corporation

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R

SRCorporation 

(714) 625-7020 

-- Mi

keBuckantz 

7662RhineDrive 

HuntingtonBeach,CA 92647-4613 

(714) 625-7020

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