1

From: Putney.David@epamail.epa.gov

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

To: Palazzolo, Michael A.

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

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

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 
2

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 samples HAP Metals Suggested: 3052 

Alternates: 3051A 

Suggested: 6020 

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
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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

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]