From: Peter Westlin/RTP/USEPA/US 

To: Rochelle Boyd/RTP/USEPA/US@EPA 

Cc: Robin Segall/RTP/USEPA/US@EPA, Gary McAlister/RTP/USEPA/US@EPA, 

Parker.Barrett@epa.gov, Ron Myers/RTP/USEPA/US@EPA, Jason 

Dewees/RTP/USEPA/US@EPA, William Grimley/RTP/USEPA/US@EPA, 

agnew.rachel@epa.gov, driscoll.tom@epa.gov, Jeff 

Ryan/RTP/USEPA/US@EPA 

Date: 07/12/2010 01:28 PM 

Subject: Re: Fw: Information Collection Request for the Secondary Aluminum 

Production Source Category

Rochelle: 

My responses (please share as broadly as needed): 

You may use SW 846 Method 6010C in lieu of Method 6020A for Hg analyses with the 

caveat that if the lab finds values less than the IDL documented for in accordance with 

the method, we would expect a re-analysis with Method 6020A. 

For the determining the Cr6 content, we recommend ASTM D5451-93(2008) the dust 

sampling, we recommend SW 846 Method 3060A and to Method 7195 or 7197 for 

analysis. You may report data analyzed with Method 7196 if you find levels above the 

test specific method detection level. If not, you should use one of the more sensitive 

methods. Instead of specifying a minimum expected method level, we refer to specific 

analytical methods, in this case, Method 7195 or Method 7197. Please report data in 

terms of the method detection level (e.g., below detection level, BDL) and not the 

method reporting limit. 

Peter Westlin

Measurement Policy Group

OAQPS, SPPD

919-541-1058

----- Forwarded by Rochelle Boyd/RTP/USEPA/US on 07/12/2010 07:45 AM -----

From: "Rick Moore" <rmoore@aal-inc.com> 

To: Rochelle Boyd/RTP/USEPA/US@EPA 

Date: 07/09/2010 03:34 PM 

Subject: Information Collection Request for the Secondary Aluminum Production Source 

Category

Dear Ms. Boyd: 

We have been asked to provide analytical support in the way of sample analysis and data 

report preparation in response to the “Information Collection Request for the Secondary
Aluminum Production Source Category”.

On review of the May 27, 2010 information request letter and the Enclosure 1, I have a 

few questions that need your clarification pertaining to the baghouse dust analysis portion 

of this request: 

1. Do you have an Excel report format for the baghouse dust data? 

2. In Table 2.2 a) is EPA Method 6020 (ICP/MS) the only method allowed for Hg 

analysis? While Hg can be analyzed by ICP/MS it is not the generally preferred method.

b) Is the sample preparation method EPA Method 3051 (Microwave Digestion) the only

sample preparation method allowed or would other sample preparation methods be

permitted (for example those that use a Parr bomb) or other digestion techniques? 

3. Concerning Hexavalent Cr analysis is EPA Method 218.6 the only acceptable method 

for this analysis? I have concerns that the method has been developed for aqueous 

matrices and that chlorides and 

other metals species can cause analytical problems for this ion chromatographic 

method. What is the desired Reporting Limit in the solid material? 

Your prompt assistance with these questions would be appreciated. If you need to 

discuss them further I will be available either by phone or by email at the address below. 

Thank you, 

Rick Moore 

President 

American Analytical Laboratories, Inc. 

840 South Main Street 

Akron OH 44311 

rmoore@aal-inc.com

ph: 330-535-1300 

fax: 330-535-7246