Steve, I've been a dedicated reader of your column in PF for many years. In fact, I save most of your articles in a notebook for future reference. I have a degree in hazardous waste management from Wayne State, but have worked mainly on air permit issues in automotive painting operations for the last 14 years, so your past columns are very helpful references when I must deal with RCRA issues.
I read the question from R.W. in your March, 2005 column (Testing for All Eight TCLP Metals) about the need to test for all eight TCLP metals. You answered the question the same way I would have.
I do have an additional suggestion. R.W. may want to implement a Data Quality Objective program based upon USEPA guidance. The document, QA/G-4, EPA/600/R-96/055, can be found at www.epa.gov/quality/qa_docs.html. I'd refer you to a couple of articles in the Journal of Air & Waste Management Association by Michael J. McFarland and Glenn R. Palmer for the "Cliff" notes version. To quote from the introduction of one of their papers: "To effectively reduce the environmental compliance costs associated with meeting hazardous air pollutant emission requirements, the U.S. Environmental Protection Agency's Data Quality Objective (DQO) process has proposed a suitable framework for establishing a defensible monitoring program."
The DQO process could provide R.W. with a statistically sound basis for deciding which of the eight metals to test and how frequently. F.H.
Thank you for your compliments, and I am grateful that you find our input valuable enough to keep for reference. Readers, for those of you who love to work with statistics, enjoy.
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