Need to return call by / at/between and . Signature: 

Project No.: 0172.08.005.604 Page 1 of 1

Project Name: TRI2009 CBI? 

 Yes 

 No 

TELEPHONE CALL RECORD

 Incoming 

 Outgoing 

Date: 01/28/11 Time: 3:00 am

 pm 

Company Name: Sasol North America Inc. ERG Staff Name: Kimberly Landick 

Contact Name: Michael Hayes Contact Phone Number: (337) 494-5038 

General Subject: 2009 TRI Dioxin Discharges 

TOPICS DISCUSSED AND ACTION TAKEN 

On January 28, 2011 at 3pm, I called Sasol North America Inc. to speak with Michael Hayes regarding 2009 

TRI dioxin discharges. I left a message stating my name, the reason for calling, and if he could call me back or 

pass my information to the correct personnel for TRI data. 

On February 2, 2011 at 3:15pm, I called Sasol North America Inc. to speak with Michael Hayes regarding 2009 

TRI dioxin discharges. I left a message stating my name, the reason for calling, and if he could call me back or 

pass my information to the correct personnel for TRI data. 

On February 3, 2011 at 9:45am, I called Sasol North American Inc. to speak with Michael Hayes regarding 

2009 TRI dioxin discharges. After explaining the reason for calling he stated that he was the correct person to 

talk to. I stated the questions that we had and he requested an e-mail with the questions. He also asked that we 

state which group within the EPA that we are working with and our contract number. Michael Hayes stated his 

email address as: Michael.hayes@us.sasol.com. I sent him an e-mail at 10:43am on 2/3/11. Please see the 

attached e-mail correspondence. 

On February 9, 2011 at 7:55am I called Michael Hayes and left a message stating that I was following up on my 

e-mail and asked him to call me back with any further questions he may have. 

. 
From: Kimberly Landick [mailto:Kimberly.Landick@erg.com] 

Sent: Tuesday, March 01, 2011 3:02 PM 

To: Hayes, Michael (MG) 

Subject: RE: FW: Request for 2009 TRI Data Clarification 

Hi Mike, 

 

Thanks for getting back to me so quickly, I appreciate it! 

 

Kimberly 

 

---------------------------------------- 

Kimberly D. Landick 

Environmental Engineer 

Eastern Research Group, Inc. 

14555 Avion Parkway, Suite 200 

Chantilly, VA 20151 

kimberly.landick@erg.com

Phone: 703-633-1119 

From: "Hayes, Michael (MG)" <Michael.Hayes@us.sasol.com> 

To: "Kimberly Landick" <Kimberly.Landick@erg.com> 

Date: 3/1/2011 2:47 PM 

Subject: RE: Request for 2009 TRI Data Clarification 

Hello Kimberly 

We apparently have one of those mail systems that automatically assigns the blanket confidentiality 

statement to our correspondence. Please ignore the footer for our purposes. That information is not 

confidential and should be made available to the public. 

Best regards 

Mike 

Michael Hayes 

337-494-5038 Office 

337-842-7839 Mobile

From: Kimberly Landick [mailto:Kimberly.Landick@erg.com] 

Sent: Tuesday, March 01, 2011 12:58 PM 

To: Hayes, Michael (MG) 

Subject: RE: FW: Request for 2009 TRI Data Clarification 

Hi Mike, 

 

I am sorry to hear about your loss as well. It is a difficult time and my thoughts are with you and your 

family. 
 

I apologize for not including this in my previous e-mail but I would like to request your permission to 

include the information you sent below as part of documentation made available at regulations.gov. 

 

EPA is working towards the publication of its 2011 Final Plan and hopes to include the email (and 

spreadsheet attachment) below as part of the documentation that describes the corrections made to the 

2009 screening-level review database. However, when there is an email signature/footer that claims 

information as confidential, EPA cannot include it a part of the public docket and handles it as CBI. If 

you approve, we will simply remove the following footer from the email correspondence and include this 

information in the public docket. 

 

Please reply to this e-mail to let us know if it is ok to include the information in EPA's public docket. 

 

Thank you, 

Kimberly 

 

*FOOTER LANGUAGE BELOW* 

This eMail message is from Sasol and is for the sole use of the intended recipient(s), and may contain 

confidential and privileged information. Any unauthorized review, use, disclosure or distribution is 

prohibited. If you are not the intended recipient(s), please contact the sender or email@sasol.com by 

reply eMail, and destroy all copies of the original message. You may not distribute, disseminate or copy 

this eMail. Please note that all eMail within Sasol is subject to continuous and ad hoc filtering, scrutiny 

and reporting. This policy also applies to incoming eMail. 

 

 

---------------------------------------- 

Kimberly D. Landick 

Environmental Engineer 

Eastern Research Group, Inc. 

14555 Avion Parkway, Suite 200 

Chantilly, VA 20151 

kimberly.landick@erg.com

Phone: 703-633-1119 

From: "Hayes, Michael (MG)" <Michael.Hayes@us.sasol.com> 

To: "Kimberly Landick" <Kimberly.Landick@erg.com> 

Date: 2/28/2011 2:43 PM 

Subject: RE: Request for 2009 TRI Data Clarification 

Hello Kimberly 

My deepest condolences for your loss. Actually my reply to you was delayed for the same reason. 

All the best to you and your family. 

Regards 

Mike 

Michael Hayes 
337-494-5038 Office 

337-842-7839 Mobile

From: Kimberly Landick [mailto:Kimberly.Landick@erg.com] 

Sent: Thursday, February 24, 2011 6:36 AM 

To: Hayes, Michael (MG) 

Subject: Re: FW: Request for 2009 TRI Data Clarification 

Hi Mr. Hayes, 

 

Thank you for sending us this information. I apologize for not responding to you sooner, I've been out of 

the office due to a death in my family. I have looked over the data you sent and at this point we do not 

need any further information. We will contact you if additional questions arise. 

 

Thank you, 

Kimberly 

 

---------------------------------------- 

Kimberly D. Landick 

Environmental Engineer 

Eastern Research Group, Inc. 

14555 Avion Parkway, Suite 200 

Chantilly, VA 20151 

kimberly.landick@erg.com

Phone: 703-633-1119 

From: "Hayes, Michael (MG)" <Michael.Hayes@us.sasol.com> 

To: "Kimberly Landick" <Kimberly.Landick@erg.com> 

Date: 2/16/2011 5:01 PM 

Subject: RE: Request for 2009 TRI Data Clarification 

Kimberly 

My apologies. Please reply to confirm that I finally passed along the information you requested. 

Best regards 

Mike 

Michael Hayes 

337-494-5038 Office 

337-842-7839 Mobile

From: Kimberly Landick 

Sent: 2/11/2011, 3:27:53 PM 

To: Hayes, Michael (MG) 

Subject: RE: Request for 2009 TRI Data Clarification 
Mr. Hayes, 

 

Thank you for your response to these questions. Your attachments for the 2008 water dioxin distribution 

and a summary table of sample results were not included. Please attach those documents for review. 

 

Thank you, 

Kimberly 

 

 

---------------------------------------- 

Kimberly D. Landick 

Environmental Engineer 

Eastern Research Group, Inc. 

14555 Avion Parkway, Suite 200 

Chantilly, VA 20151 

kimberly.landick@erg.com

Phone: 703-633-1119 

From: "Hayes, Michael (MG)" <Michael.Hayes@us.sasol.com> 

To: "Kimberly Landick" <Kimberly.Landick@erg.com> 

CC: "William Swietlik" <Swietlik.William@epamail.epa.gov>, "Eleanor Codding" 

<Eleanor.Codding@erg.com>, "Jessica Gray" <Jessica.Gray@erg.com> 

Date: 2/10/2011 4:25 PM 

Subject: RE: Request for 2009 TRI Data Clarification 

Kimberly, 

Apologies for the delay in my response to your questions. Responses are 

as follows: 

Q1. Please confirm the pounds of dioxin released in 2009: 0.0009 pounds 

(0.408 grams) 

Answer 1- The total dioxins released to water in 2009 was reported by 

Sasol as 0.4041 grams (0.0009 pounds). 

 

Q2. Please confirm the facility reported dioxin distribution in the 

attached spreadsheet. 

 

Answer 2 - The dioxin distribution attached to your email accurately 

represents the 2009 Sasol dioxin releases to water. 

 

Q3. How did you determine the 2009 water dioxin distribution as there 

was no distribution reported in 2008. 
 

Answer 3 - Sasol reported a water dioxin distribution in 2008. Attached 

is the 2008 Form R submitted in 2009 which includes a water dioxin 

distribution (shown in Schedule 1 of the Form R). (Please see the 

attached copy of the RY2008 Dioxin Form R Schedule 1) 

 

Q4. If you used monitoring data to determine the dioxin distribution, 

where was the monitoring conducted and how are non-detect results 

included in the distribution? If available, please provide a copy of the 

monitoring results. 

 

Answer 4 - The distribution is based on 12 different samples dating from 

1994 to 2004. The samples were all taken at the outlet of our onsite 

Activated Sludge Wastewater Treatment Unit. An average of all the 

sample results was used. Per EPA protocol, Sasol assumed that all 

non-detect results are equal to one half of the method detection limit 

reported for that particular congener, with the exception of 2 samples. 

One particular test result for one congener from 2001 was included as 0 

because of method blank contamination. Additionally, Sasol decided not 

to adjust the calculated average total dioxin content of the wastewater 

downward after the 2006 sample results came back less than the

previously calculated average. We have laboratory reports on file, but 

for the purposes of this inquiry, we have not taken the time to make 

scanned copies. Instead, we have included a table showing a summary of 

the sample results. If you need copies of the analytical results we 

have them available. 

 

Q5. If you don't have monitoring data, please describe how the 

distribution and pounds were reported in 2009. 

 

Answer 5 - Sasol used the total effluent from our Activated Sludge 

Wastewater Unit and the concentrations from the analytical results 

described above. 

 

Q6. What is the source of the dioxin compounds in the wastewater? 

 

Answer 6- The source of the dioxins in Sasol's wastewater is the 

Georgia Gulf Vinyl Chloride plant wastewater. Sasol receives and 

treats wastewater from Georgia Gulf in our above ground, tank based 

activated sludge treatment unit. The wastewater treatment process does 

not destroy the dioxins. 

Should you require further information, please let me know. 

Regards 
Michael Hayes 

Michael Hayes 

337-494-5038 Office 

337-842-7839 Mobile 

________________________________ 

From: Kimberly Landick [mailto:Kimberly.Landick@erg.com] 

Sent: Thursday, February 03, 2011 9:43 AM 

To: Hayes, Michael (MG) 

Cc: William Swietlik; Eleanor Codding; Jessica Gray 

Subject: Request for 2009 TRI Data Clarification 

Mr. Hayes, 

Thank you for your time on the phone this morning. As discussed, EPA is 

requesting clarification of 2009 TRI data as part of our 2011 annual 

review of industrial discharges under Section 304 of the Clean Water 

Act. I am writing to request clarification of dioxin compounds 

discharges, on EPA's behalf under Contract No. 68-C-02-095. Please see 

below for further background. 

 

EPA, Office of Water (OW), reviews TRI data to fulfill its review 

obligation under Section 304(b) of the Clean Water Act. The CWA requires 

EPA to annually review and, if appropriate, revise its water pollution 

control technology-based regulations, called "effluent limitations 

guidelines" or "effluent guidelines," that limit the discharge of 

pollutants to waters of the U.S. from various categories of industrial 

facilities. EPA is currently conducting its 2011 annual review of 

existing effluent guidelines and potential industrial guidelines which 

may need to be included (see http://www.epa.gov/guide/304m/ for further 

information). EPA will discuss this review and the results in its 2011 

Effluent Guidelines Program Plan scheduled for publication in the 

Federal Register in 2011. 

As part of the 2011 annual review, EPA is evaluating the data reported 

to the 2009 TRI and needs further information to complete the review. 

Specifically, we would like to clarify the amount of dioxin compounds 

reported to the 2009 TRI. Please confirm/review the following data and 

questions below. 

 

1. Please confirm the pounds of dioxin released in 2009: 0.0009 pounds 

(0.408 grams) 
2. Please confirm the facility reported dioxin distribution in the 

attached spreadsheet. 

3. How did you determine the 2009 water dioxin distribution as there was 

no distribution reported in 2008. 

4. If you used monitoring data to determine the dioxin distribution, 

where was the monitoring conducted and how are non-detect results 

included in the distribution? If available, please provide a copy of the 

monitoring results. 

5. If you don't have monitoring data, please describe how the 

distribution and pounds were reported in 2009. 

6. What is the source of the dioxin compounds in the wastewater? 

We appreciate your help in interpreting TRI data correctly. If you have 

any questions regarding this request, please call me at (703) 633-1119. 

If you would like to speak directly with EPA regarding this request, you 

can contact William F. Swietlik of EPA's Office of Water/Engineering 

Analysis Division by phone at (202) 566-1129 or by email: 

swietlik.william@epa.gov. 

Thank you, 

Kimberly Landick 

 

---------------------------------------- 

Kimberly D. Landick 

Environmental Engineer 

Eastern Research Group, Inc. 

14555 Avion Parkway, Suite 200 

Chantilly, VA 20151 

kimberly.landick@erg.com 

Phone: 703-633-1119 

"This eMail message is from Sasol and is for the sole use of the intended recipient(s), and may contain 

confidential and privileged information. Any unauthorized review, use, disclosure or distribution is 

prohibited. If you are not the intended recipient(s), please contact the sender or email@sasol.com by 

reply eMail, and destroy all copies of the original message. You may not distribute, disseminate or copy 
this eMail. Please note that all eMail within Sasol is subject to continuous and ad hoc filtering, scrutiny 

and reporting. This policy also applies to incoming eMail." 
ASU Effluent(001) Samples

Test Results 

(ppq)

Assumed 

Conc.(ppq)

Test Results 

(ppq)

Assumed 

Conc.(ppq) Test Results (ppq)

Assumed 

Conc.(ppq)

Test Results 

(pg/L) Assumed Conc.(ppq) Test Results (pg/L)

Assumed 

Conc.(ppq)

Test Results 

(pg/L) Assumed Conc.(ppq)

Test Results 

(pg/L) Assumed Conc.(ppq)

Test Results 

(pg/L) Assumed Conc.(ppq)

Test Results 

(pg/L)

Assumed 

Conc.(ppq)

Test Results 

(pg/L)

Assumed 

Conc.(ppq) Test Results (p

2,3,7,8 TCDF ND 2.5 ND 3.05 ND 1.3 ND 0.85 ND 1.45 ND 2.25 ND 1.55 ND 2.5 ND 1.8 ND 1.3 ND 1,2,3,7,8 PeCDF ND 2.15 ND 2.4 ND 3.05 ND 1.55 ND 1.7 ND 3 ND 5 ND 4.2 ND 5.5 ND 6.5 ND 2,3,4,7,8 PeCDF ND 2.1 ND 2.35 ND 2.65 ND 1.5 ND 1.75 ND 3.2 ND 4.05 ND 4.15 ND 5.5 ND 6.5 ND 1,2,3,4,7,8 HxCDF ND 2.7 ND 4.65 ND 1.2 ND 1.85 ND 8 ND 2.15 ND 5.5 ND 4.15 ND 5.5 ND 6.5 ND 1,2,3,6,7,8 HxCDF ND 2.05 ND 3.45 ND 1.15 ND 1.75 ND 3.1 ND 2.1 ND 4.25 ND 4.45 ND 5.5 ND 6.5 ND 2,3,4,6,7,8 HxCDF ND 2.55 ND 4.35 ND 1.2 ND 1.95 ND 3.9 ND 1.8 ND 4.6 ND 3.6 ND 5.5 ND 6.5 ND 1,2,3,7,8,9 HxCDF ND 3.3 ND 5.65 ND 1.15 ND 2.15 ND 2.9 ND 1.8 ND 5 ND 3.5 ND 5.5 ND 6.5 ND 1,2,3,4,6,7,8 HpCDF ND 2.45 ND 3.8 ND 2.75 28J* 28 62 62 ND 8.5 ND 10.5 29J* 29 60I 60 16I 16 ND 1,2,3,4,7,8,9 HpCDF ND 4.5 ND 6.95 ND 3.1 ND 1.75 ND 7.5 ND 1.9 ND 4.95 ND 3.45 15J 15 ND 6.5 ND OCDF ND 6.2 ND 8.3 18 18 ND 15.5 120J* 120 ND 15 ND 19 ND 15.5 160 160 33J 33 24J 2,3,7,8 TCDD ND 3.4 ND 4.05 ND 3 ND 1.25 ND 1.65 ND 2.35 ND 1.05 ND 1.7 ND 1.5 ND 1.3 ND 1,2,3,7,8 PeCDD ND 3.1 ND 4.05 ND 1.55 ND 2.35 ND 2.85 ND 4.1 ND 3.65 ND 6 ND 5.5 ND 6.5 ND 1,2,3,4,7,8 HxCDD ND 4 ND 6.65 ND 2.15 ND 2.4 ND 5 ND 2.75 ND 3.8 ND 4.7 ND 5.5 ND 6.5 ND 1,2,3,6,7,8 HxCDD ND 3.35 ND 5.6 ND 2 ND 2.45 ND 4.75 ND 2.85 ND 4.9 ND 5 ND 5.5 ND 6.5 ND 1,2,3,7,8,9 HxCDD ND 3.6 ND 6.05 ND 1.9 ND 2.25 ND 4.5 ND 2.65 ND 4.95 ND 4.65 ND 5.5 ND 6.5 ND 1,2,3,4,6,7,8 HpCDD ND 4.95 ND 6.65 ND 5 ND 1.7 ND 9 ND 3.8 ND 8 ND 5.5 15J 15 ND 6.5 ND OCDD 51.1 51.1 ND 9.8 ND 23.5 ND 6.5 110J*B* 0 60J* 60 ND 23 60J* 60 42J 42 ND 13 ND 

**USED HIGHEST OF SAMPLE & FIELD DUPLICATE 

NOTE: The VI Study used EPA Method 1613A (5), the 1994 and 2000 samples were analyzed using Method 8290Method 1613 treats non-detects as zero per EPA-745-B-00-00X 

Method 8290 does not say how to treat non-detects. Assumed results<DL are 1/2 DL since all congeners detected in sludge. Note: the 2006 NPDES sample is less than t*J = Estimated result. Result is less than the reporting limit.*B=Method Blank Contamination*I = Interference

7/27/1994 - Method 8290 7/26/1994 - Method 8290 1997 VI Study - Method 1613 2000 NPDES Sample - Method 8290 11/01NPDES Sample Method 1613** 12/01 NPDES Sample Method 1613** 1/02 NPDES Sample Method 1613 2/02 NPDES Sample Method 1613** 1/7/04 Sample - Method 8290 2/23/04 Sample - Method 8290 3/16/04 Sam
ERG Revised Facility Data

Notes: From research on U and J values as reviewed by EAD, ERG zeroed ND, Method Blank Contaminations, and kept J and I values.ASU Effluent(001) Samples

Test Results 

(ppq)

Assumed 

Conc.(ppq) ERG Result

Test Results 

(ppq)

Assumed 

Conc.(ppq) ERG Result Test Results (ppq)

Assumed 

Conc.(ppq) ERG Result

Test Results 

(pg/L) Assumed Conc.(ppq) ERG Result Test Results (pg/L)

Assumed 

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Test Results 

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(pg/L) Assumed Conc.(ppq) ERG Result

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(pg/L) Assumed Conc.(ppq) ERG Result

Test Results 

(pg/L)

Assumed 

Conc.(ppq) ERG Result

Test Results 

(pg/L)

Assumed 

Conc.(ppq) ERG Result Test Results (pg/L)

Assumed 

Conc.(ppq) ERG Result

Test Results 

(pg/L)

2,3,7,8 TCDF ND 2.5 0 ND 3.05 0 ND 1.3 0 ND 0.85 0 ND 1.45 0 ND 2.25 0 ND 1.55 0 ND 2.5 0 ND 1.8 0 ND 1.3 0 ND 1.15 0 ND 1,2,3,7,8 PeCDF ND 2.15 0 ND 2.4 0 ND 3.05 0 ND 1.55 0 ND 1.7 0 ND 3 0 ND 5 0 ND 4.2 0 ND 5.5 0 ND 6.5 0 ND 5.5 0 ND 2,3,4,7,8 PeCDF ND 2.1 0 ND 2.35 0 ND 2.65 0 ND 1.5 0 ND 1.75 0 ND 3.2 0 ND 4.05 0 ND 4.15 0 ND 5.5 0 ND 6.5 0 ND 5.5 0 ND 1,2,3,4,7,8 HxCDF ND 2.7 0 ND 4.65 0 ND 1.2 0 ND 1.85 0 ND 8 0 ND 2.15 0 ND 5.5 0 ND 4.15 0 ND 5.5 0 ND 6.5 0 ND 5.5 0 ND 1,2,3,6,7,8 HxCDF ND 2.05 0 ND 3.45 0 ND 1.15 0 ND 1.75 0 ND 3.1 0 ND 2.1 0 ND 4.25 0 ND 4.45 0 ND 5.5 0 ND 6.5 0 ND 5.5 0 ND 2,3,4,6,7,8 HxCDF ND 2.55 0 ND 4.35 0 ND 1.2 0 ND 1.95 0 ND 3.9 0 ND 1.8 0 ND 4.6 0 ND 3.6 0 ND 5.5 0 ND 6.5 0 ND 5.5 0 ND 1,2,3,7,8,9 HxCDF ND 3.3 0 ND 5.65 0 ND 1.15 0 ND 2.15 0 ND 2.9 0 ND 1.8 0 ND 5 0 ND 3.5 0 ND 5.5 0 ND 6.5 0 ND 5.5 0 ND 1,2,3,4,6,7,8 HpCDF ND 2.45 0 ND 3.8 0 ND 2.75 0 28J* 28 28 62 62 0 ND 8.5 0 ND 10.5 0 29J* 29 29 60I 60 60 16I 16 16 ND 5.5 0 20J 1,2,3,4,7,8,9 HpCDF ND 4.5 0 ND 6.95 0 ND 3.1 0 ND 1.75 0 ND 7.5 0 ND 1.9 0 ND 4.95 0 ND 3.45 0 15J 15 15 ND 6.5 0 ND 5.5 0 ND OCDF ND 6.2 0 ND 8.3 0 18 18 18 ND 15.5 0 120J* 120 120 ND 15 0 ND 19 0 ND 15.5 0 160 160 160 33J 33 33 24J 24 24 29J 2,3,7,8 TCDD ND 3.4 0 ND 4.05 0 ND 3 0 ND 1.25 0 ND 1.65 0 ND 2.35 0 ND 1.05 0 ND 1.7 0 ND 1.5 0 ND 1.3 0 ND 1.15 0 ND 1,2,3,7,8 PeCDD ND 3.1 0 ND 4.05 0 ND 1.55 0 ND 2.35 0 ND 2.85 0 ND 4.1 0 ND 3.65 0 ND 6 0 ND 5.5 0 ND 6.5 0 ND 5.5 0 ND 1,2,3,4,7,8 HxCDD ND 4 0 ND 6.65 0 ND 2.15 0 ND 2.4 0 ND 5 0 ND 2.75 0 ND 3.8 0 ND 4.7 0 ND 5.5 0 ND 6.5 0 ND 5.5 0 ND 1,2,3,6,7,8 HxCDD ND 3.35 0 ND 5.6 0 ND 2 0 ND 2.45 0 ND 4.75 0 ND 2.85 0 ND 4.9 0 ND 5 0 ND 5.5 0 ND 6.5 0 ND 5.5 0 ND 1,2,3,7,8,9 HxCDD ND 3.6 0 ND 6.05 0 ND 1.9 0 ND 2.25 0 ND 4.5 0 ND 2.65 0 ND 4.95 0 ND 4.65 0 ND 5.5 0 ND 6.5 0 ND 5.5 0 ND 1,2,3,4,6,7,8 HpCDD ND 4.95 0 ND 6.65 0 ND 5 0 ND 1.7 0 ND 9 0 ND 3.8 0 ND 8 0 ND 5.5 0 15J 15 15 ND 6.5 0 ND 5.5 0 ND 

OCDD 51.1 51.1 51.1 ND 9.8 0 ND 23.5 0 ND 6.5 0 110J*B* 0 0 60J* 60 60 ND 23 0 60J* 60 60 42J 42 42 ND 13 0 ND 11.5 0 ND 

**USED HIGHEST OF SAMPLE & FIELD DUPLICATE 

NOTE: The VI Study used EPA Method 1613A (5), the 1994 and 2000 samples were analyzed using Method 8290Method 1613 treats non-detects as zero per EPA-745-B-00-00X 0Method 8290 does not say how to treat non-detects. 2006 NPDES 001 Sample = Assumed results<DL are 1/2 DL since all congeners detected in sludge. Note: the 2006 NPDES sample is less than the amount used for TRI calculation so do not change ass*J = Estimated result. Result is less than the reporting limit.*B=Method Blank Contamination*I = Interference

7/27/1994 - Method 8290 7/26/1994 - Method 8290 1997 VI Study - Method 1613 2000 NPDES Sample - Method 8290 11/01NPDES Sample Method 1613** 12/01 NPDES Sample Method 1613** 1/02 NPDES Sample Method 1613 2/02 NPDES Sample Method 1613** 1/7/04 Sample - Method 8290 2/23/04 Sample - Method 8290 3/16/04 Sample - Method 8290 4/12/04