EPA/600/R-05/128
                                 January 2006
Environmental Technology Verification

Dust Suppressant Products
Midwest Industrial Supply, Inc.'s EK35
                 Prepared by


    Midwest Research Institute         RTI International
     MRII&       HRTI
                       INTERNATIONAL
           Under a Cooperative Agreement with
           U.S. Environmental Protection Agency
                 &EPA
             EW   ET

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              THE ENVIRONMENTAL TECHNOLOGY VERIFICATION
                                  PROGRAM
                                                         HRTI
U.S. Environmental Protection Agency
                                      *"* '  '           INTERNATIONAL
                ETV Joint Verification  Statement
 TECHNOLOGY TYPE:   DUST SUPPRESSANT

 APPLICATION:         CONTROL OF DUST ON UNPAVED ROADS

 TECHNOLOGY NAME:  EK35

 COMPANY:             MIDWEST INDUSTRIAL SUPPLY, INC.
 ADDRESS:              1101 3rd STEET SE
                         CANTON, OH 44707
                         PHONE:     800-321-0699
                         FAX:        330-456-3247
 WEB SITE:              http://www.midwestind.com/
 E-MAIL:                custserv(o)midwestind.com
The U.S. Environmental Protection Agency (EPA) has created the Environmental Technology
Verification (ETV) Program to facilitate the deployment of innovative or improved
environmental technologies through performance verification and dissemination of information.
The goal of the ETV Program is to further environmental protection by accelerating the
acceptance and use of improved and cost-effective technologies. ETV seeks to achieve this goal
by providing high-quality, peer-reviewed data on technology performance to those involved in
the design, distribution, financing, permitting, purchase, and use of environmental technologies.

ETV works in partnership with recognized standards and testing organizations; stakeholder
groups, which consist of buyers, vendor organizations, permitters, and other interested parties;
and with the full participation of individual technology developers.  The program evaluates the
performance of innovative technologies by developing test plans that are responsive to the needs
of stakeholders, conducting field or laboratory tests (as appropriate), collecting and analyzing
data, and preparing peer-reviewed reports. All evaluations are conducted in accordance with
rigorous quality assurance (QA) protocols to ensure that data of known and adequate quality are
generated and that the results are defensible.

The Air Pollution Control Technology (APCT) Verification Center, a center under the ETV
Program, is operated by Research Triangle Institute (RTI) in cooperation with EPA's National
Risk Management Research Laboratory. The APCT Center has evaluated the performance of a
dust suppressant product for control of dust on an unpaved road.

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ETV TEST DESCRIPTION

A field test program was designed by RTI and Midwest Research Institute (MRI) to evaluate the
performance of dust suppressant products. Five dust suppressants manufactured or distributed
by three firms were tested in this program. The field test for Midwest Industrial Supply's EK35
was conducted at two sites:  Fort Leonard Wood, Missouri (FLW), and Maricopa County,
Arizona (MC). Test/QA plans for the field testing at FLW and MC were developed and
approved by EPA in July 2003. These test/QA plans describe the procedures and methods used
for the tests. The July 2003 versions of the test/QA plans were based on October 2002 versions
and subsequent test/QA plan addenda (dated February 2003). The goal of each test was to
measure the performance of the products relative to uncontrolled sections of road over a 1-year
period. Field testing was planned quarterly over a 1-year period; however, some logistical
difficulties related to winter weather and then maintenance activities on the roads of interest
arose, and the test/QA plans were revised (Rev 3) to address those issues.  At FLW, testing
occurred per the test/QA plan for three roughly 6-month periods. At MC, testing was conducted
for only two quarterly test periods, per the test/QA plan.  At FLW, two of those test periods are
summarized below and are considered most representative of product performance; the third
testing period at FLW occurred after unexpected road maintenance, and those data may be seen
in the verification report. At MC, one of the two test periods is summarized below and is
considered representative of product performance; data from the second testing period at MC
that occurred after unexpected road maintenance may be  seen in the verification report. The
verification report also contains 90 percent confidence limits for the data collected during all of
the test periods at each site.  Emissions measurements were made for total particulate (TP),
particulate matter less than or equal to 10 micrometers (|-im) in aerodynamic diameter (PMio),
and for particulate matter less than or equal to 2.5 |_im in aerodynamic diameter (PM2.s).

One of the host facilities for the field test program, FLW, is a U.S. Army base.  The test site used
unpaved Roads P and PA in training area (TA) 236. Roads P and PA are the main access routes
to TA 236 and are traveled by truck convoys, as well as traffic into and out of TA 236. EK35
was applied to test section A located on Road PA; test section F, located on Road P, was left
untreated as the experimental control. Section 3.1 of the verification report provides a figure
showing the test locations.  Testing at FLW was conducted during October 2002, May 2003, and
October 2003.

The other host facility for the field test program, MC, is located on Broadway Road (a county
road) near the towns of Buckeye and Wintersburg, Arizona.  The sections used for dust
suppressant testing were on portions of the road constructed of shale.  The road typically
experiences approximately 150 vehicle passes per day, with the majority of passes by light-duty
cars and trucks. Much of the traffic appears to be associated with local residents commuting to
their workplaces and thus occurs during the early morning and late afternoon hours.  Test
sections were located on Broadway Road east of 355th Avenue. EK35 was evaluated on the
section farther east of 355th Avenue. The uncontrolled measurements were conducted on a
separate section of Broadway Road.  Section 3.1 of the verification report provides a figure
showing the test locations.  Testing at MC was conducted during May 2003 and August 2003.

Table 1 presents test conditions for key parameters that may affect the performance of dust
suppressants on unpaved roads.

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Table 1. Test Conditions
Parameter
Initial application rate, 1/m2
Follow-up application rate, 1/m2
Time between application and testing, days
Precipitation during test week, cm
Precipitation during week before testing, cm
Precipitation between application and
testing, total, cm
Soil moisture during test weeks, (%) —
uncontrolled road
Soil moisture during test
controlled road
weeks, (%)—
Soil silt during test weeks, (%) —
uncontrolled road
Soil silt during test weeks, (%) — controlled
road
FLW,
October 2003
1.3
0.75
119
0.2
1.8
39
0.62-1.5
0.71-1.0
1.7-5.4
1.1-1.7
FLW,
May 2003
1.3
0.30
77
3.7
3.2
24
0.01-1
0.31-1
1.6-4
2.3-6
.8
.1
3
6
MC,
May 2003
0.85
0.33
70
0
0
1.3
0.22
0.17
4.7
1.7
The EK35 product was analyzed using an array of chemical and toxicity tests. The results of
these tests are included in the appendices to the verification report. A summary of the toxicity
data is presented in Table 2.
Table 2. Toxicity Test Results
Species
Ceriodaphnia dubia
Fathead minnow
Americamysis bahia
d = day
EC50 = effective cone
hr = hour
LC50 = lethal concen
LOEC = lowest observ
mg/L = milligrams pe
NOEC = no observed e
VERIFIED TECHNOIX
This verification statemen
for dust control and soil st
a durable reworkable bind
RTI project files and is av
productmaterials/EK3 5M£

Acute LC50
for survival
> 1,000 mg/L (48-hr)
271 mg/L (96-hr)
111 mg/L (96-hr)
Chronic LCgo
for survival
> 1,000 mg/L (7-d)
97 mg/L (7-d)
59 mg/L (7-d)
Chronic EC50
375 mg/L (7-d),
reproduction
114 mg/L (7-d), growth
>50 mg/L (7-d),
growth, fecundity
;entration which affects 50% of sample population
[ration which kills 50% of sample population
ed effective concentration
r liter
ffect concentration
)GY DESCRIPTION
t is applicable to Midwest Industrial Supply 's EK35, which is a product
abilization that provides a dust suppressing mechanism while acting as
er. The material safety data sheet (MSDS) for EK35 is retained in the
ailable at http://www.midwestind.com/Droblemsolver/
•iDS.pdf [accessed

July 2005].
iii


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VERIFICATION OF PERFORMANCE

The overall reduction in particulate matter emissions achieved by the EK35 dust suppressant
compared to uncontrolled sections of road is shown in Table 3.

                            Table 3. Summary of Test Results

         Test location and     Average control efficiency, %
period
FLW, October 2003
FLW, May 2003
MC, May 2003
TP
63
74
87
PM10
84
86
90
PM25
a
56
>94
Noted events
Rain events the day before test. b
Rain events the morning of test. °
None.
        a No emissions reduction was observed.
        b All test sections were wet from rain the previous day. The uncontrolled section was heavily
         potholed and another section was used for the test. MRI used traffic to dry the road before
         testing.
        0 Rainfall in the morning meant that the uncontrolled section of the road was wet and another
         section was used for the test.
The APCT Center QA officer has reviewed the test results and quality control data and has
concluded that the data quality objectives given in the generic verification protocol and test/QA
plan have been attained. EPA and APCT Center QA staff have conducted technical assessments
at the test organization and of the data handling.  These confirm that the ETV tests were
conducted in accordance with the EPA-approved test/QA plan.

This verification statement verifies the effectiveness ofMidwest Industrial Supply's EK35 to
control dust on unpaved roads as described above. Extrapolation outside that range should be
done with caution and an understanding of the scientific principles that control the performance
of the technologies. This verification focused on emissions.  Potential technology users may
obtain other types of performance information from the manufacturer.

In accordance with the generic verification protocol, this verification statement is valid,
commencing on the date below, indefinitely for application of Midwest Industrial Supply's EK35
to control dust on unpaved roads.
Signed by Sally Gutierrez          9/25/2005
Sally Gutierrez, Director              Date
National Risk Management Research
 Laboratory
Office of Research and Development
United States Environmental Protection
 Agency
Signed by Andrew Trenholm       9/16/2005
Andrew R. Trenholm, Director        Date
Air Pollution Control Technology
 Verification Center
                                            IV

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Environmental Technology Verification

        Dust Suppressant Products

Midwest Industrial Supply, Inc.'s EK35
                      Prepared by:

                     RTI International
                  Midwest Research Institute
            EPA Cooperative Agreement No. CR829434-01-1
                   RTI Project No. 09309

                   EPA Project Manager:
                     Michael Kosusko
            National Risk Management Research Laboratory
             Air Pollution Prevention and Control Division
               Office of Research and Development
               U.S. Environmental Protection Agency
                Research Triangle Park, NC 27711
                     September 2005

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Environmental Technology Verification Report                   Dust Suppressant Products: EK35
                                        Notice

       RTI International  (RTI) and Midwest Research Institute (MRI) prepared this document
with funding from RTFs Cooperative Agreement No. CR829434-01-1 with the U.S.
Environmental Protection Agency (EPA). Mention of corporation names, trade names, or
commercial products does not constitute endorsement or recommendation for use of specific
products.
 : RTI International is a trade name of Research Triangle Institute.
                                           VI

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Environmental Technology Verification Report                    Dust Suppressant Products: EK35
                                 Acknowledgments

       The authors acknowledge the support of all of those who helped plan and conduct the
verification activities. In particular, we would like to thank Michael Kosusko, U.S.
Environmental Protection Agency's (EPA's) project manager, and Paul Groff, EPA's quality
assurance manager, both of EPA's National Risk Management Research Laboratory in Research
Triangle Park, North Carolina. We would also like to acknowledge the assistance and
participation of Joe Proffitt and staff at Fort Leonard Wood, Eric Mayer and staff at Maricopa
County, and of all the Midwest Industrial Supply, Inc., personnel who supported the test effort.
Funding for this verification effort was provided from multiple sources, including EPA's
Environmental Technology Verification Program, U.S. Army Corps of Engineers, and Midwest
Industrial Supply, Inc. (the participating vendor).

For more information on EK35 dust suppressant, contact:
Mr. Todd Hawkins
Midwest  Industrial Supply, Inc.
1101 3rd Street SE
Canton, Ohio 44707
Telephone:   (800) 321-0699
Fax:         (330) 456-3247
Email:       custserv@midwestind.com
Web site:     http://www.midwestind.com/

A draft report with additional information on environmental and toxicological analysis
conducted by the Civil Engineering Research Foundation (CERF) may be obtained from
Midwest  Industrial Supply, Inc.

For more information on verification testing of dust suppressant and soil stabilization products,
contact:
Ms. Debbie Franke
RTI International
P.O. Box 12194
Research Triangle Park, North Carolina 27709-2194
Telephone:   (919) 541-6826
Email:       dlf@rti.org
Web site:     http://etv.rti.org/apct/index.html
                                          vn

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Environmental Technology Verification Report                   Dust Suppressant Products: EK35
                                       Abstract

       Dust suppressant products used to control particulate emissions from unpaved roads are
among the technologies evaluated by the Air Pollution Control Technology (APCT) Verification
Center, part of the U.S. Environmental Protection Agency's Environmental Technology
Verification (ETV) Program. The critical performance factor for dust suppressant verification is
the dust control efficiency (CE). CE was evaluated in terms of total particulate (TP), particulate
matter less than or equal to 10 micrometers (|im) in aerodynamic diameter (PMi0), and
particulate matter less than or equal to 2.5 micrometers (|im) in aerodynamic diameter
       Midwest Industrial Supply, Inc., submitted the EK35 dust suppressant to the APCT
Center for testing. The test and quality assurance (QA) plans, prepared in accordance with the
Generic Verification Protocol (GVP), addressed the site-specific issues associated with these
verification tests.  The 1-year testing was conducted at two sites: Fort Leonard Wood, Missouri,
and Maricopa County, Arizona.  Testing at Fort Leonard Wood was conducted during October
2002, May 2003, and October 2003.  Testing at Maricopa County was conducted during May
2003 and August 2003. This verification report summarizes the results of the  1-year test. The
verified CE will be based on all tests at each site, as specified in the test/QA plan. Test
conditions were measured and documented.
                                          Vlll

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Environmental Technology Verification Report                   Dust Suppressant Products: EK35

                                  Table of Contents

Section                                                                           Page
Notice	vi
Acknowledgments	vii
Abstract	viii
List of Figures	x
List of Tables	x
List of Acronyms and Abbreviations	xi
1.0  Introduction	1
2.0  Summary and Discussion of Results	2
     2.1  Verification Results	2
     2.2  Laboratory Toxicity TestResults	5
     2.3  Discussion of QA/QC	5
     2.4  Deviations from Test Plan	6
3.0  Test Conditions	9
     3.1  General Test Site Conditions	9
          3.1.1   Traffic	11
          3.1.2   Area Climatic Conditions	12
          3.1.3   Background Particulate  Concentration	15
     3.2  Application of Dust Suppressant	16
     3.3  Conditions During Dust Suppressant Test Runs	19
4.0  References	21
Appendix A - Environmental Testing Results	A-l
Appendix B - Chemical Testing  Results	B-l
Appendix C - Method 24 Results	C-l
                                           IX

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Environmental Technology Verification Report                    Dust Suppressant Products: EK35


                                  List of Figures

1   Test locations at FLW	10
2   Test locations at MC	11
3   Application of EK3 5 product at FLW	18
4   Application of EK3 5 product at MC	18
                                   List of Tables

1   Summary of Test Results for EK35 (No Road Maintenance)	3
2   Summary of Test Results for EK3 5 (After Road Maintenance Occurred)	4
3   DQOs versus Final Control Efficiency Variability for EK35	6
4   Summary of Test Event Deviations for FLW	6
5   Summary of Test Event Deviations for MC	7
6   Weekly Weather for FLW	12
7   Weekly Weather for Buckeye, Arizona	14
8   Summary of Precipitation for All Test Periods at FLW andMC	15
9   Measured Background PM Concentrations at FLW	15
10  Estimated Background Contribution to Sampler Catch at FLW Compared to Mean
    Blank Filter Data	16
11  Background Concentration Measurements at Palo Verde, Arizona	16
12  Application History	17
13  Test Run Parameters	19
14  Road  Surface Properties	21

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Environmental Technology Verification Report
Dust Suppressant Products: EK35
                    List of Acronyms and Abbreviations

ADEQ    Arizona Department of Environmental Quality
ADT      average daily traffic
ANOVA  analysis of variance
APCT     air pollution control technology
AZMET  Arizona Meteorological Network
BOD      biological oxygen demand
CE       control efficiency
cfm       cubic feet per minute
CI        confidence interval
cm       centimeters
COD      chemical oxygen demand
DQO      data quality objective
DPW      Directorate of Public Works
ECso      effective concentration, 50 percent
EPA      U.S. Environmental Protection Agency
ETV      environmental technology verification
FLW      Fort Leonard Wood, Missouri
ft         feet
g         grams
g/mL      grams per milliliter
gal       gallons
GPS      global positioning system
GVP      generic verification protocol
hi-vol     high volume
in.        inches
km       kilometer
1 or L      liters
Ib         pounds
LCso      lethal concentration, 50 percent
LOEC     lowest observed effective concentration
1pm       liters per minute
jig        micrograms
|im       micrometer
m         meters
MC       Maricopa County, Arizona
mg       milligrams
min       minutes
ml        milliliters
mph      miles per hour
MRI      Midwest Research Institute
MSDS    material safety data sheet
NA       not applicable
NOEC    no observed effect concentration
PM       particulate matter
                                         XI

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Environmental Technology Verification Report                     Dust Suppressant Products: EK35
          parti culate matter equal to or less than 10 jim in aerodynamic diameter
PM2.5     particulate matter equal to or less than 2.5 jim in aerodynamic diameter
QA       quality assurance
QC       quality control
RSD      relative standard deviation
RTI      RTI International
s         seconds
TA       training area
TCLP     toxicity characteristic leaching procedure
TP       total particulate
WAF     water accommodated fractions
yd        yard
                                           xn

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Environmental Technology Verification Report                    Dust Suppressant Products:  EK35
1.0   Introduction

       The objective of the Air Pollution Control Technology (APCT) Verification Center, part
of the U.S. Environmental Protection Agency's (EPA's) Environmental Technology Verification
(ETV) Program, is to verify, with high data quality, the performance of air pollution control
technologies. One such set of air pollution control technologies consists of products used to
control dust emissions from unpaved roads. Dust suppressant products are, in general, designed
to alter the roadway by lightly cementing the particles together or by forming a surface that
attracts and retains moisture.  Control of dust emissions from unpaved roads is of increasing
interest, particularly related to attainment of the ambient parti culate matter (PM) standard. EPA
issued a new ambient standard for PM in 1997 that specifies new air quality levels for parti culate
matter less than or equal to 2.5 micrometer (|am) in aerodynamic diameter
       The APCT Center's verification of dust suppression products started with a preliminary
3-month testing program at Fort Leonard Wood, Missouri (FLW). The objective of this
preliminary test program was to develop a cost-effective technique to measure the relative
performance of dust suppressant products. The more common, but resource intensive, exposure
profiling method to measure fugitive dust was compared to a mobile dust sampler.  It was
concluded that the mobile dust sampler could be used for future testing.  A total of seven dust
suppressant products were evaluated in the preliminary testing.  Seven reports documenting the
performance of these products were finalized in November 2002. 2

       After completion of the preliminary study, a 1-year field test program was designed by
RTI and Midwest Research Institute (MRI) to evaluate the performance of dust suppressant
products. Five dust suppressants manufactured or distributed by three firms were tested in this
program. One of those dust suppressants was EK35, developed by Midwest Industrial Supply,
Inc. EK35 is a product for dust control and soil stabilization that acts as  a durable reworkable
binder.  The material safety data sheet (MSDS) for EK35 is retained in the RTI project files and
is available on Midwest Industrial Supply's Web site (http://www.midwestind.
com/problemsolver/productmaterials/EK3 5MSDS.pdf) [accessed July 2005].

       The field test program for EK35 was  conducted at two sites:  FLW  and Maricopa County,
Arizona (MC). Testing was conducted at two different sites to account for differences in climate
and soil types.  In July 2003, test and quality assurance (QA) plans for the field testing at FLW
and MC were developed and approved by EPA.3'4 The July 2003 versions  of each test/QA plan
were based on an October 2002 version and a subsequent test/QA plan addendum (dated
February 19, 2003, for FLW, and February 10, 2003, for MC). These test/QA plans describe the
procedures and methods used for the tests. The goal of each test was to measure the
performance of the products relative to uncontrolled sections of road over a 1-year period. Field
testing was planned quarterly over a 1-year period; however, some logistical difficulties related
to the weather and maintenance activities on  the roads of interest arose, and the test/QA plans
were modified (Rev 3) to address those issues.  At FLW, test periods occurred per the test/QA
plan for three roughly 6-month periods, during October 2002, May 2003, and October 2003. At
MC, testing was conducted per the test/QA plans for only two quarterly test periods, during May

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Environmental Technology Verification Report                    Dust Suppressant Products: EK35


2003 and August 2003. Emissions measurements were made for total particulate (TP),
particulate matter less than or equal to 10 |am in aerodynamic diameter (PMio), and for PM2.5.

       This report contains only summary information and data from the 1-year test program, as
well as the verification statement related to the dust control efficiency (CE) measured for EK35
during testing at FLW and MC.  Complete documentation of the test results is provided in a
separate test report5 for FLW and MC and a data quality audit report.6 Those reports include the
raw test data from product testing and supplemental testing, equipment calibration results, and
QA and quality control (QC) activities and results. Complete documentation of QA/QC
activities and results, raw test data, and equipment calibration results are retained in MRI's files
for 7 years.

       The results of the tests are summarized and discussed in Section 2. The conditions in
which the tests were conducted are presented in Section 3, and references are presented in
Section 4.


2.0   Summary and Discussion of Results

       Verification tests were conducted over a 1-year period on Midwest Industrial Supply's
EK35 dust suppressant as applied to unpaved roads at FLW and MC. Original plans called for
testing to occur on a quarterly basis; however, one quarterly test was abandoned due to
persistently unfavorable wintertime weather at FLW.  In addition, at MC, the original test site
(Lower Buckeye Road) was disturbed after the original treatment.  As a result, a 6-month (rather
than 1-year) verification study was conducted with quarterly measurements at a second site
(Broadway Road) in MC.

       The mobile dust sampling system used in this test program provides quantitative
information on relative emissions levels.  The mobile system consists of a high-volume (hi-vol)
PMio cyclone combined with a PM2.5 cyclone.  The sampler inlet sits above the densest portion of
the dust plume, immediately behind the test vehicle.  In this location, the sampler collects PM
that is truly airborne. The hi-vol sampler is operated with a nozzle matched to the test vehicle's
travel speed to best approximate isokinetic sampling.  The test plans provide additional details
on the construction and operation of the mobile sampler.

       The results of the quarterly tests are summarized in Section 2.1. The results of laboratory
toxicity tests on the product are included in Section 2.2. The results of QC checks performed
during these quarterly tests are summarized in Section 2.3.  Deviations from the test plans are
discussed in Section 2.4.

2.1    Verification Results

       Tables 1 and 2 present summary statistics for results from each test period. The mobile
sampler provides a test result in terms of parti culate mass collected per distance traveled
[milligrams per 1,000 feet (mg/1,000 ft)].  The tables show the number of days after product
application, the mean controlled and uncontrolled emissions values, and the resulting CEs.  The
relative standard deviation (RSD) for the emissions values is shown in parentheses.

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Environmental Technology Verification Report
Dust Suppressant Products: EK35
       The uncontrolled and controlled emissions values for the mobile dust sampler are means
of five replicate measurements.  Each of the five replicate measurements consisted of twelve
passes over a 500-ft length test section of the treated road segment, to total approximately 6,000
ft of distance covered. Detection limits were set at two standard deviations above the average
filter blank correction for sample mass. Values below the detection limits (quantification level)
were included in the averaging process at half the detection limit.

       Table 1 presents data for the test periods when no unexpected road maintenance occurred
between product application and testing. These data are considered the most representative of
the product's performance.  Table 2 presents data when unexpected road maintenance occurred.
These data provide an example of performance under the described circumstances.
           Table 1.  Summary of Test Results for EK35 (No Road Maintenance)
Uncontrolled
emissions, mg/1,000 ft
(RSD, %)
Test period
TP
PM10
PM25
Time since
last
application,
days
Controlled emissions,
mg/1,000 ft
(RSD, %)
TP
PM10
PM25
Control efficiency, %
TP
PM10
PM25
FLW
October 2003a
May 2003C
7.9
(59)
9.1
(14)
0.68
(78)
1.2
(21)
1.5
(27)
0.71
(29)
119
77
2.9
(30)
2.4
(54)
0.11
(53)
0.13
(78)
1.6
(10)
0.31
(41)
63
74
84
86
b
56
MC
May 2003
50
(76)
14
(84)
3.7
(65)
70
6.5
(32)
1.4
(45)
<0.24d
(0.0)
87
90
>94
a All test sections were wet from rain the previous day. The uncontrolled section was heavily potholed and another
 section was used for the test. MRI used traffic to dry the road before testing.
b No emissions reduction was observed.
0 Rainfall in the morning meant that the uncontrolled section of the road was wet and another section was used for
 the test.
d All values were below the detection limit.

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Environmental Technology Verification Report
Dust Suppressant Products:  EK35
     Table 2.  Summary of Test Results for EK35 (After Road Maintenance Occurred)
Uncontrolled Time since
emissions, mg/1,000 ft last
(RSD, %) application,
Test period >pp pjy
lio PM2.5 da?s
Controlled emissions,
mg/1,000 ft
(RSD, %)
TP
PM10
PM25
Control efficiency, %
TP
PM10
PM25
FLW
October 2002a
9.5
(36)
2.3
(55)
2.5
(41)
121
11
(30)
1.1
(21)
<0.65b
(0.0)
c
52
>74
MC
August 2003d
74
(34)
24
(47)
4.5
(37)
84
60
(17)
16
(37)
2.6
(22)
18
34
42
a Unexpected road maintenance activity occurred at FLW in September 2002 prior to the October 2002 test period.
 After consideration, it was decided to continue with planned testing; however, in retrospect, the treated surface
 evaluated during this test period was not representative, and controlled values from the test period should be
 viewed as conservatively low.
b All values were below the detection limit.
0 No emissions reduction was observed.
d Unexpected road maintenance activity appeared to have occurred at MC after the time of the May 2003 visit and
 prior to the August 2003 test period. The entire test road appeared to have been bladed.  The vendor interviewed
 persons living near the test site who remarked that the road had been bladed prior to the test visit. In this case, the
 control efficiency values from this test period should be viewed as conservatively low.
       The dust emissions CE is calculated as follows:
                                  CE= 100x(eum-ecm)/em
                          Eq. 1
where
       CE   =  control efficiency (percent)

       eum   =  uncontrolled emissions value, expressed as sample mass divided by the
                cumulative length of road traveled by the mobile sampler (mg/1,000 ft)

       ecm   =  controlled emissions value, expressed as  sample mass divided by the cumulative
                length of road traveled by the mobile sampler (mg/1,000 ft).

       Control efficiencies can vary considerably between test periods, and some of the
variation can be related to two factors:  (1) the time since the most recent application and (2) the
application rate of the dust suppressant.  A complete history of the test road treatment is given in
Section 3.2.  The time since the most recent application is shown in Tables 1 and 2, in addition to
information on road maintenance activities and rainfall. Beyond the application rate and the
time since application factors, additional variation can arise from changing site conditions.  For
example, unplanned road maintenance occurred at both sites, as noted in Table 2.  In addition,
precipitation before or during a field test could cause variation in both uncontrolled and
controlled test results.  That is to say, measured emissions could change after precipitation so
that back-to-back tests would not necessarily be "replicates" in the sense of having identical test
conditions.  MRI always attempted to dry the road with traffic to the point that it appeared
visibly dry before beginning a test period.

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Environmental Technology Verification Report                    Dust Suppressant Products: EK35


2.2    Laboratory Toxicity Test Results

       A sample of EK35 was taken when the product was applied at FLW. The product was
sent to ABC Laboratories, Columbia, Missouri, and to Tri-State Laboratories, Inc., Youngstown,
Ohio, for analysis.  The following test methods were used in accordance with the test/QA plan:3

 •  Environmental/Chemical Testing
        EPA Method 247         Volatile Organics
        EPA Method 405.18      5-day Biochemical Oxygen Demand (BOD) of product
        EPA Method 410.49      Chemical Oxygen Demand (COD)
        EPA Method 131110      Toxicity Characteristics Leaching Procedure (TCLP)
    -   EPA Method 601 OB10    Inorganics/Metals
    -   EPA Method 601 OB10    Title 22 Metals
    -   EPA Method 8260B10    Volatile Organics
        EPA Method 827010      Semivolatile Organics
        EPA Method 8270D10    Semivolatile Organics
        EPA Method 8270D10    Pesticides and Herbicides


•   Effluent Toxicity Testing
        EPA600/4-90/027F11     Acute toxicity: Water fleas lethal concentration, 50 percent
                                (LCso), Fathead minnow LCso, and Mysid shrimp LCso
        EPA/600/4-91/00212      Chronic Toxicity:  Water fleas LC50, Fathead minnow LC50,
                                and Mysid shrimp LC50.

       See Appendices A and B for the environmental and chemical test results,
respectively.13'14 RTI also conducted Method 24 tests on the product samples;15 see Appendix
C for those results.

2.3    Discussion of QA/QC

       The testing process was based on the approved Generic Verification Protocol for Dust
Suppression and Soil Stabilization Products (GVP);16 the Test/QA Plan for Testing of Dust
Suppressant Products at Fort Leonard Wood, Missouri, Rev 3 (July 24, 2003 );3 and the Test/QA
Plan for Testing of Dust Suppressant Products atMaricopa County, Arizona, Rev 3 (July 24,
2003).4 The MRI task leader and QA manager verified that the quality criteria specified in these
test plans (Sections 3.4 and A4, respectively) were met (see Section 2.4) for the overall test (the
within-site, -suppressant, and -particle size fraction variability was often higher than planned).
Assessments specified in Section 8 of the GVP were performed.  Reconciliation of the data
quality objectives (DQOs) with test results is summarized in Table 3. Data from all three test
periods are included in the analysis, including those data collected during the test period
following unexpected road maintenance.

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Environmental Technology Verification Report
Dust Suppressant Products: EK35
           Table 3. DQOs versus Final Control Efficiency Variability for EK35

TP
PM10
PM25

FLW
MC
FLW
MC
FLW
MC
Number
of test
periods
3
2
3
2
3
2
Final CE,
fractional
0.41
0.53
0.74
0.62
0.39
0.67
90% confidence interval
Lower
limit
0.31
0.43
0.69
0.56
0.28
0.61
Upper
limit
0.51
0.62
0.79
0.69
0.50
0.73
Half
width
0.10
0.097
0.051
0.066
0.11
0.063
DQOa
0.14
0.11
0.060
0.087
0.14
0.076
Is the half-
width interval
less than the
DQO (i.e.,
DQO met)?
Yes
Yes
Yes
Yes
Yes
Yes
 a Final CE DQO is interpolated from Table 6 in the test/QA plans using the equation:
              Half width DQO = -0.2295 CE + 0.22972.

       In all cases, the testing process and the resulting data were determined by the MRI QA
manager to have met the specified quality criteria, although there were significant uncontrollable
plan deviations related to field conditions.

       The RTI quality manager has reviewed the above information (including the deviations
from the test plan, noted in Section 2.4), has sampled the data against the specified criteria, and
concurs with the MRI assessment that the DQOs were met for the overall test. The APCT
director has determined that the data are usable as intended in the planning documents.

2.4    Deviations from Test Plan

       Significant deviations from the test/QA plan are discussed below and are shown in
Tables 4 and 5 for FLW and MC, respectively. Changes in the application dates are also
summarized in the tables.
                   Table 4.  Summary of Test Event Deviations for FLW
Project activities
Unexpected road maintenance
End of 1st test period
Suppressant reapplication
End of 2nd test period
Suppressant reapplication
End of 3rd test period
Suppressant reapplication
Road traffic increased with
construction
End of 4th test period
Planned date
Not planned
September 2002
September 2002
January 2003
January 2003
April 2003
April 2003
Not planned
July 2003
Actual date
September 16, 2002
October 12-14, 2002
October 18-28, 2002
Not performed because of
consistently bad weather
March 8, 2003
May 24-26, 2003
June 14, 2003
July21-OctoberlO, 2003
October 10-12, 2003
Test period"
Not applicable (NA)
5U, 5C
NA
None, per modified
Test/QA Plan
NA
5U, 5C
NA
NA
5U, 5C
 "5U means five uncontrolled replicate measurements; 5C means five controlled replicate measurements.

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Environmental Technology Verification Report
Dust Suppressant Products: EK35
                   Table 5.  Summary of Test Event Deviations for MCa
Test event deviations
Initial suppressant application, site #2
End of 1st test period
Suppressant reapplication
Unexpected road maintenance
End of 2nd test period
Planned
February 2003
May 2003
May 2003
Not planned
August 2003
Actual
March 5, 2003
May 13-15, 2003
May 14, 2003
Late July 2003
August 6-7, 2003
Test periodb
NA
5U, 5C
NA
NA
5U, 5C
 a Due to early, unauthorized test road disturbance, this summary is based on Rev 3 of the test/QA plan, which
  specified 6 months of testing (2 quarterly test periods).
 b5U means five uncontrolled replicate measurements; 5C means five controlled replicate measurements.
       The FLW test/QA plan stated that background PM concentration values would be
collected from an ambient PM monitor; however, the monitoring station in question collects only
meteorological data and does not contain a PM monitor. Therefore, MRI operated a background
PM sampler at the Range 12 building [located approximately 1 kilometer (km) east of the test
section] where line electrical power was available.

       The FLW and MC test/QA plans stated that the CE "will be determined relative to its
decay over time and with traffic." Because the vendor chose to reapply the dust suppressants
following each test period, this was not achievable. At least three test periods between
applications would have been required to calculate a CE decay rate. Moreover, the decay rate
would have changed from application to application because of the increasing inventory of dust
suppressant in a specific road segment.

       The projected schedule for the dust suppressant tests at FLW called for four quarters of
planned tests starting in June 2002. The time between test periods was originally planned to be
approximately 90 days, to represent seasonal differences in CE; however, not all of the planned
four quarters of testing were conducted. Testing was conducted for three 6-month periods at
FLW and was conducted for two quarterly test periods at MC.

       As noted earlier, damage to the original controlled test section led to the revision of the
MC test/QA plan. This revised plan substituted a 6-month study, with test periods in May and
August, in place  of the original year-long verification  program and four test periods.

       Both the FLW and MC test plans mentioned a  pneumatic traffic counter and a data logger
for on-site wind measurements; however, neither of these was deployed during the test program.
 Instead, training records supplied by the Army were used to estimate the total convoy traffic
during the field program at FLW.  Maricopa County Department of Transportation personnel
were asked to provide an estimate for the average daily traffic (ADT) value for the Arizona test
site.  Traffic data are described in Section 3.1.1.  The Army supplied meteorological records for
both the Forney Army Airfield (located within 5 km of the test site) and the Bailey wind station
(located immediately west of the test site). Meteorological data for the MC site were obtained
through Arizona Meteorological Network (AZMET) for a station 12 km to the east of the
Broadway test site.  Meteorological data are described in Section 3.1.2.

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Environmental Technology Verification Report                    Dust Suppressant Products: EK35


       Deviations during the individual test periods at FLW and in MC are discussed in the
following paragraphs.

       October 2002 Test Period at FL W.  Both the field tests and the reporting of results
occurred later than originally called for in the test/QA plan.  The delay in testing was directly
due to the unexpected road maintenance during the week of September 16, 2002, which occurred
at the request of a Directorate of Public Works (DPW) contractor. This action required a delay
of approximately 2 weeks to assess the extent to which the treated surface had been affected and
whether testing of the surface would produce results useful to the program. Based on anecdotal
information from the grader operator as well as photographs of the surface, it was determined
that the surface had been covered with loose material  (pulled from the side of the road).
Subsequent discussions between DPW, the product vendors, RTI, and MRI led to general
agreement to continue with conducting a first test in October 2002.

       January 2003 Test Period at FLW.  As noted above, persistently unfavorable winter
weather during January and February 2003 forced the abandonment of the second quarterly test.

       May 2003 Test Period at FLW.  During the field audit conducted on May 26, 2003, it
was determined that the PM2 5 background monitor operated at a flow of approximately 9 liters
per minute  (1pm) [0.32 cubic feet per minute (cfm)] rather than the target of 16.7 1pm (0.59 cfm).
Because the background concentration was used only to estimate the maximum contribution that
ambient PM levels could contribute to the mass collected by the mobile sampler, the contribution
for PM2.5 was conservatively estimated using the PMi0 background level. This point is discussed
further in Section 3.1.

       Another deviation concerned the location of the uncontrolled test section during the
May 26, 2003, tests.  On that day, a portion of uncontrolled test section (Section F in the test
plan) was still  damp from rain during the morning of May 25.  For that reason,  an uncontrolled
150-m (500-ft) section farther west along the same road was substituted.

       October 2003 Test Period at FL W.  Both the field tests and the reporting of results
occurred later than originally called for in the test/QA plan.  The delay in testing was due to
rainfall over Labor Day weekend.  Testing was rescheduled for Columbus Day weekend. No
quarterly test report was prepared pending preparation of the final report.

       Rainfall on the day before MRI's arrival left all sections damp. In addition, the
uncontrolled test site (Section F) was so heavily potholed that the mobile sampler could not be
safely operated at the designated vehicle speed. Uncontrolled tests were moved to an untreated
section of the same road to the west that exhibited better drainage than Section F. As  noted
earlier, MRI used traffic to dry the road before beginning a test period.

       May 2003 Test Period at MC.  The speedometer on the test vehicle was inoperative
because of  a fuse problem. For that reason, vehicle speed was monitored using a new handheld
global positioning system (GPS) unit.  The GPS readings were checked against a rental car's
speedometer and were found to agree within 2 mph at 25 and 35  miles per hour (mph).

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Environmental Technology Verification Report                    Dust Suppressant Products: EK35


       A filter used on test run CKO-131 did not pass initial audit during the tare weighing, but
was not reweighed as required by MRI SOP-8403.

       August 2003 Test Period at MC. No quarterly report was prepared for this test period,
pending preparation of the final report. Test speeds were monitored using the same handheld
GPS as used during the May 2003 tests.  Some unexpected road maintenance appeared to have
occurred since the time of the May 2003 visit.  The entire test road in MC appeared to have been
bladed. The vendor interviewed persons living near the test site who remarked that the road had
been bladed prior to the test visit.


3.0    Test Conditions

3.1    General Test Site Conditions

       The test/QA plans for FLW and MC document the sites and road sections used during
dust suppressant testing.

       One of the host facilities for the field test program, FLW, is a U.S. Army base.  The test
site at FLW used unpaved Roads P and PA in training area (TA) 236.  Roads P and PA are the
main access routes to TA 236 and are traveled by truck convoys, as well as traffic  into and out of
TA 236. Test sections A, B, C, and D are located on Road PA, while test section E is located
along Road P.  EK35  was applied to test section A.  Other products tested during this program
were applied to the other test sections. The  sixth test section (F), also located on Road P, was
left untreated as the experimental control. The EK35 product was tested on a curved section of
road, which would have subjected the treated road surface to greater shear stress. Figure 1
shows the test locations at FLW.3

       The other host facility for the field test program, MC, is located on Broadway Road (a
county road) near the towns of Buckeye and Wintersburg, Arizona. The sections used for dust
suppressant testing were on portions of the road constructed of shale. The road typically
experiences approximately  150 vehicle passes per day, with the majority of passes by light-duty
cars and trucks. Much of the traffic appears to be associated with local residents commuting to
their workplaces and thus occurs during the  early morning and late afternoon hours.  Test
sections were located on Broadway Road east  of 355thAvenue.  EK35 was evaluated on the
section farther east of 355th Avenue. The uncontrolled measurements were conducted on a
separate section of Broadway Road. Figure 2  shows the test locations at MC.4

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Environmental Technology Verification Report
Dust Suppressant Products: EK35
                             Figure 1.  Test locations at FLW
                                            10

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Environmental Technology Verification Report
Dust Suppressant Products: EK35
                                                               ->.WH
                              Figure 2.  Test locations at MC
3.1.1   Traffic
       All sections of the test site at FLW were exposed to military traffic, consisting of 2.5- and
5-ton trucks, as well as sport-utility type vehicles (such as Chevrolet Blazers). This traffic
occurred during training days (typically Monday through Friday).  Based on records supplied by
the Army, an estimated 3,650 convoy vehicles traveled over the test surface during the entire
field program.  This does not include other Army-related traffic, for which records are not kept.
Furthermore, additional light-duty vehicular traffic took place due to recreational use of the fort
during weekends.  Finally, an additional 60 passes by a Ford F-250 pickup occurred during each
of the test periods.  (Note that testing took place on days with no scheduled Army training
activities.)

       From July 21,  2003, to the final test period in October 2003, the EK35 test section at
FLW experienced  additional traffic associated with construction activities in TA 236.  This
traffic, which occurred Monday through Friday, averaged 40 loaded (27 ton) dump truck passes,
40 empty (11 ton)  dump truck passes, and 30 to 50 car/pickup passes per day.
                                            11

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Environmental Technology Verification Report
Dust Suppressant Products: EK35
       The Arizona test section was exposed to the naturally occurring traffic along Broadway
Road in MC. Traffic consisted mostly of light-duty vehicles such as cars and pickups, with a
few passes by school buses during weekdays. Based on the county's plans to pave the road in
the future, an approximate value of 200 ADT can be applied to the test section. (The ADT level
was measured at 247 in March 2004, approximately  7 months after the conclusion of the field
measurements.)  An additional 60 to 120 passes by a Ford F-150 pickup occurred during each of
the test periods.

3.1.2   Area Climatic Conditions

       Table 6 presents the weekly weather over the entire FLW verification period (i.e., from
June 2002 when the product was first  applied until the final set of tests in October 2003).  These
data were collected at Forney Airfield, which is located approximately 5 km (3 miles) north-
northeast from the test section. (Note that the Forney station operating hours were 0600-2100
Monday through Friday, 0700-1500 Saturday, and 1100-1900 Sunday.  The temperature extremes
are officially valid for those timeframes.)

       Table 7 contains weekly weather data for the MC site for the period of March to August
2003.  The meteorological data were taken at a station in Buckeye maintained by the Roosevelt
Irrigation District. The station, located at latitude 33° 24' north and longitude 112° 41' west, lies
approximately 12 km (8 miles) to the  east of the Broadway test site.
Table 8.
       A summary of the precipitation for all the test periods at FLW and MC is shown in
                           Table 6.  Weekly Weather for FLW
                                        Site weather
Week
beginning
06/02/02
06/09/02
06/16/02
06/23/02
06/30/02
07/07/02
07/14/02
07/21/02
07/28/02
08/04/02
08/11/02
08/18/02
08/25/02
09/01/02
09/08/02
Air temp, °C (°F)
Maximum
32 (90)
31 (87)
33(91)
33 (92)
33 (92)
36 (97)
35 (95)
37 (98)
37 (99)
36 (97)
31 (87)
33 (92)
29 (85)
31 (88)
32 (90)
Minimum
13(56)
14(58)
13(56)
19(66)
20 (68)
20 (68)
18(64)
19(67)
21 (69)
16(61)
18(64)
20 (68)
17(62)
17(63)
14(58)
Precipitation, cm (in.)
Liquid
2.2 (0.88)
1.2(0.48)
0(0)
0.61 (0.24)
2.0 (0.79)
1.0(0.41)
0.03(0.01)
2.6(1.0)
0.03(0.01)
0.2 (0.07)
4.1(1.6)
0.89(0.35)
0(0)
0(0)
0(0)
Frozen
0(0)
0(0)
0(0)
0(0)
0(0)
0(0)
0(0)
0(0)
0(0)
0(0)
0(0)
0(0)
0(0)
0(0)
0(0)
                                                                     (continued)
                                           12

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Environmental Technology Verification Report
Dust Suppressant Products:  EK35
                                    Table 6. (continued)
                                          Site weather
Week
beginning
09/15/02
09/22/02
09/29/02
10/06/02
10/13/02
10/20/02
10/27/02
11/03/02
11/10/02
11/17/02
11/24/02
12/01/02
12/08/02
12/15/02
12/22/02
12/29/02
01/05/03
01/12/03
01/19/03
01/26/03
02/02/03
02/09/03
02/16/03
02/23/03
03/02/03
03/09/03
03/16/03
03/23/03
03/30/03
04/06/03
04/13/03
04/20/03
04/27/03
05/04/03
05/11/03
05/18/03
05/25/03
06/01/03
06/08/03
06/15/03
Air temp, °C (°F)
Maximum
31 (87)
27(81)
32 (89)
20 (68)
18 (64)
19 (67)
11 (52)
22(71)
18 (64)
18 (65)
16(61)
15 (59)
11 (52)
18 (65)
4(40)
18 (65)
21 (70)
6(43)
13 (56)
19(67)
23 (74)
14 (57)
12 (54)
4(40)
24 (76)
25 (77)
22 (72)
25 (77)
29 (85)
27(81)
29 (85)
22(71)
30 (86)
30 (86)
26 (79)
26 (79)
31 (87)
25 (77)
28 (83)
29 (84)
Minimum
17(63)
8(46)
16 (60)
5(41)
1(33)
2(36)
0(32)
2(36)
-2 (28)
0(32)
-6 (21)
-9(15)
-4 (24)
1(33)
-12(11)
-7(19)
-6 (22)
-14 (7)
-19 (-2)
-10(14)
-15(5)
-4 (24)
-6 (22)
-14 (6)
-7 (20)
-8(17)
4(39)
0(32)
2(35)
0(32)
9(48)
5(41)
10(50)
14 (57)
9(48)
9(48)
9(48)
9(48)
13(56)
14 (57)
Precipitation, cm (in.)
Liquid
3.6(1.4)
0(0)
0.58(0.23)
0.48(0.19)
0.56 (0.22)
5.1(2.0)
4.1(1.6)
1.8(0.72)
1.7(0.65)
0(0)
0.03(0.01)
1.7(0.68)
0.38(0.15)
3.7(1.4)
3.4(1.4)
1.3(0.52)
0.43(0.17)
0.33(0.13)
0.43(0.17)
0.38(0.15)
0.69 (0.27)
2.7(1.1)
2.1 (0.83)
1.7(0.66)
0.05 (0.02)
1.7(0.66)
3.6(1.4)
2 (0.7)
0.03(0.01)
4.7(1.8)
0.91 (0.36)
4.2(1.7)
1.7(0.67)
2.3 (0.92)
3.2(1.3)
2.1 (0.83)
1.6(0.63)
3.7(1.4)
6.6 (2.6)
2 (0.6)
Frozen
0(0)
0(0)
0(0)
0(0)
0(0)
0(0)
0(0)
0(0)
0(0)
0(0)
0(0)
16 (6.2)
0(0)
0(0)
34(14)
0.8(0.3)
0(0)
4.8(1.9)
4.3(1.7)
0(0)
7.9(3.1)
2(0.9)
0.3(0.1)
18(7.2)
0(0)
0(0)
0(0)
0(0)
0(0)
0(0)
0(0)
0(0)
0(0)
0(0)
0(0)
0(0)
0(0)
0(0)
0(0)
0(0)
                                                                         (continued)
                                             13

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Dust Suppressant Products:  EK35
                                   Table 6.  (continued)
                                        Site weather
Week
beginning
06/22/03
06/29/03
07/06/03
07/13/03
07/20/03
07/27/03
08/03/03
08/10/03
08/17/03
08/24/03
08/31/03
09/07/03
09/14/03
09/21/03
09/28/03
10/05/03
10/12/03
Air temp, °C (°F)
Maximum
32 (90)
34 (94)
34 (93)
36 (96)
35 (95)
37 (98)
33(91)
34 (94)
39(102)
37 (98)
28 (82)
31 (87)
29 (84)
29 (85)
20 (68)
24 (76)
23 (74)
Minimum
13(56)
19(66)
17(63)
21 (69)
14(58)
17(63)
18(64)
18(65)
21 (69)
21 (69)
12 (54)
14 (57)
7(45)
11(52)
4(39)
8(47)
8(46)
Precipitation, cm (in.)
Liquid
2.6(1.0)
0(0)
1.2(0.46)
3.9(1.5)
0.03(0.01)
4.0(1.6)
0.1 (0.04)
0.03(0.01)
1.5(0.59)
4.2(1.6)
6.4 (2.5)
2.0 (0.78)
3.3(1.3)
3.8(1.5)
1.7(0.68)
1.8(0.72)
0.2 (0.07)
Frozen
0(0)
0(0)
0(0)
0(0)
0(0)
0(0)
0(0)
0(0)
0(0)
0(0)
0(0)
0(0)
0(0)
0(0)
0(0)
0(0)
0(0)
                     Table 7. Weekly Weather for Buckeye, Arizona
                                        Site weather
Week
beginning
03/02/03
03/09/03
03/16/03
03/23/03
03/30/03
04/06/03
04/13/03
04/20/03
04/27/03
05/04/03
05/11/03
05/18/03
05/25/03
06/01/03
06/08/03
06/15/03
06/22/03
06/29/03
07/06/03
07/13/03
07/20/03
07/27/03
08/03/03
Air temperature, °C (°F)
Maximum
27 (80)
30 (86)
27(81)
31 (88)
32 (90)
33(91)
30 (86)
31 (88)
32 (90)
29 (85)
39(102)
40 (104)
42(108)
41(105)
42 (107)
42(108)
44(111)
43(110)
43(109)
46(115)
43(109)
39(103)
43(109)
Minimum
4(40)
7(45)
4(39)
8(47)
4(40)
2(35)
7(44)
6(42)
8(47)
7(44)
9(48)
15(59)
16 (60)
20 (68)
15(59)
17(62)
18(64)
21 (70)
20 (68)
26 (79)
24 (75)
22 (72)
23 (74)
Precipitation, cm (in.)
0(0)
0(0)
0.97(0.38)
0(0)
0(0)
0(0)
0.30(0.12)
0(0)
0(0)
0(0)
0(0)
0(0)
0(0)
0(0)
0(0)
0(0)
0(0)
0(0)
0(0)
0.1 (0.05)
0.38(0.15)
2.4 (0.96)
0(0)
                                            14

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Environmental Technology Verification Report
Dust Suppressant Products: EK35
         Table 8. Summary of Precipitation for All Test Periods at FLW and MC
Parameter
Precipitation during test week
Precipitation during week before testing
Precipitation between application and testing, total
FLW,
weekly precipitation
range, cm
0.2-3.7
0.58-3.2
17-39
MC,
weekly precipitation
range, cm
0
0-2.4
1.3-2.9
3.1.3   Background Particulate Concentration

       During the FLW test periods, TP and PMio background concentrations were measured
approximately 1 km (0.6 miles) east of the test site. Background concentration data are
presented in Table 9.
              Table 9. Measured Background PM Concentrations at FLW
                                            Concentration, jig/m3
Date
10/12/02
10/13/02
10/14/02
5/24/03
5/26/03
10/11/03
10/12/03
10/13/03
Average
Maximum
PM10
7.1
6.5
9.1
19
19
13
5.7
7.2
11
19
TP
14
16
28
23
38
19
7.9
14
20
38
       Because of the previously mentioned problem with the PM2.5 background monitor at
FLW (see Section 2.4), it was not possible to measure background PM2 5 concentrations
accurately.  Therefore, the PM2.5 concentration was assumed equal to the PMio concentration
value.  This yielded a conservatively high estimate for the contribution of background PM
concentrations to the PM2.5 sample mass catches at FLW.

       Estimates made of the contributions to net sampler catches at FLW by background
concentrations of TP and PMio are also conservatively high because estimates assume a
30-minute (min) sampling period.  As noted in the test/QA plan, the hi-vol sampler is activated
only when passing over the test section; 12 passes over a 500-ft test section at 25 rnph is only
160 s or 2.7 min.  The conservatively high estimates of background  contributions to sample
catches at FLW are compared to blank filter data in Table 10. Background mass contributions
were estimated by multiplying background concentration times flow rate and sampling time to
arrive at a mass collected that could have been contributed by ambient air.
                                          15

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Dust Suppressant Products: EK35
           Table 10.  Estimated Background Contribution to Sampler Catch at
                      FLW Compared to Mean Blank Filter Data

                                                        Weight, mg

Average estimated background contribution
Average blank filter weight
TP
0.67
2.5
PM10
0.37
2.2
PM25
0.0055
0.029
       The estimated background contributions are significantly lower than the mean blank filter
masses collected at FLW.  Thus, background PM contributed negligibly to the net catches for the
mobile sampler.

       The Arizona Department of Environmental Quality (ADEQ) maintains the Palo Verde
ambient air monitoring site at 36248 W. Elliott Road.  The Palo Verde monitoring site is 16 km
(10 miles) from the general test site area.  PMi0 and PM2 5 are monitored on a one-day-in-six
basis using reference method dichotomous samplers. The site was established to determine
background concentrations on a regional scale.

       The ADEQ provided the data in Table 11 for the Palo Verde site.
                 Table 11. Background Concentration Measurements at
                                 Palo Verde, Arizona

                                         Concentration, jig/m3
Date
5/9/03
5/15/03
5/21/03
PM10
24
103
41
PM25
9.0
20
12
       Note that the May 15 and May 21, 2003, values represent the highest and second highest
concentrations monitored at the Palo Verde site in 2003 through May 21.  Conservatively high
estimates of background contribution were developed for the MC site in the same manner as
described above for FLW. Based on these assumptions, background particulate would account
for no more than 3.5 mg of PMio or 0.010 mg of PM2.5 sample mass. The mean sample mass
corresponding to the EK35 entries in Tables 1 and 2 was more than five times higher than these
maximum background contributions.

3.2    Application of Dust  Suppressant

       MRI observed and documented all steps in the various applications of the dust
suppressant to the road test section. EK35 is applied as received and requires no mixing with
water for application.  Table 12 presents the application intensity for both FLW and MC as
determined through use of sampling pans located on a grid each time the product was applied.
                                          16

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Environmental Technology Verification Report
Dust Suppressant Products: EK35
                             Table 12. Application History
Date
Application intensity
Mean,
1/m2 (gal/yd2)3
Standard
deviation,
1/m2 (gal/yd2)
Comments
 FLW
June 7-8, 2002
October 26, 2002
March 8, 2003
June 14, 2003
1.3 (0.28)
0.52(0.12)
0.30 (0.067)
0.75(0.16)
0.15(0.034)
0.13(0.029)
0.027 (0.0059)
0.03 (0.01)
Applied in five passes, east half of road received
slightly less than west half.
Applied in two passes, west half slightly less than
east half.
Applied in three passes, very even spray pattern.
Applied in four passes, intensity based on only
two pans (misunderstanding between driver and
MRI field personnel). Applied using pallet-
mounted spray system housed in box truck.
 MC
March 5, 2003
May 14, 2003
0.85(0.19)
0.33 (0.074)
0.063 (0.014)
0.055 (0.012)
Applied in four passes, very even spray pattern.
Applied in four passes, upon completion of
quarterly test. Pull-behind trailer used rather than
spray truck used in March 2003 application.
 a The mean is based on the total amount applied to the surface of the road summed over all passes.

       Three different pieces of spray equipment were used to apply the product. As noted in
Table 12, the June 14, 2003, application at FLW and the May 14, 2003, application at MC relied
on pallet- and trailer-mounted spray systems, respectively. All other applications were by a
spray truck.  Figure 3 shows application of EK35 product at FLW, and Figure 4 shows
application of product at MC.

       Treatment of the 270-m (900-ft) road segment required approximately 1 man-hour using
the spray truck. Treatment using the trailer- and pallet-mounted systems required approximately
50 percent more effort because of time required to set up the system.
                                           17

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Environmental Technology Verification Report
Dust Suppressant Products:  EK35
                     Figure 3. Application of EK35 product at FLW
                     Figure 4.  Application of EK35 product at MC
                                          18

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Environmental Technology Verification Report
Dust Suppressant Products: EK35
3.3    Conditions During Dust Suppressant Test Runs

       Table 13 presents the dates and times when dust suppressant testing was conducted at
FLW and MC, including the length of road measured and meteorological conditions during each
test run. As discussed previously, Tables 6 and 7 present the climatic conditions for the week
during which the dust emissions tests were conducted.

                            Table 13. Test Run Parameters

Run

Test section

Date

Test start
time

Total distance,
m(ft)

Temperature,
°C (°F)
Barometric
pressure,
mm Hg
(in. Hg)
 FLW
CKO-2
CKO-13
CKO-23
CKO-24
CKO-35
CKO-2 11
CKO-2 12
CKO-230
CKO-23 1
CKO-232
CKO-1022
CKO-1028
CKO-1029
CKO-1030
CKO-1031
CKO-25
CKO-26
CKO-27
CKO-28
CKO-29
CKO-201
CKO-202
CKO-203
CKO-204
CKO-205
CKO-1012
CKO-1013
Uncontrolled
Uncontrolled
Uncontrolled
Uncontrolled
Uncontrolled
Uncontrolled
Uncontrolled
Uncontrolled
Uncontrolled
Uncontrolled
Uncontrolled
Uncontrolled
Uncontrolled
Uncontrolled
Uncontrolled
EK35, A
EK35, A
EK35, A
EK35, A
EK35, A
EK35, A
EK35, A
EK35, A
EK35, A
EK35, A
EK35, A
EK35, A
10/12/02
10/12/02
10/13/02
10/14/02
10/14/02
5/24/03
5/24/03
5/26/03
5/26/03
5/26/03
10/12/03
10/13/03
10/13/03
10/13/03
10/13/03
10/14/02
10/14/02
10/14/02
10/14/02
10/14/02
5/24/03
5/24/03
5/24/03
5/24/03
5/24/03
10/11/03
10/11/03
10:36
16:50
17:14
9:28
16:21
16:15
16:40
16:16
16:45
17:08
15:35
11:07
11:28
11:49
12:12
10:17
10:42
11:06
11:28
11:52
8:40
9:14
9:42
10:12
10:44
17:03
17:28
1,800 (6,000)
1,800 (6,000)
1,800 (6,000)
1,800 (6,000)
1,800 (6,000)
1,800 (6,000)
1,800 (6,000)
1,800 (6,000)
1,800 (6,000)
1,800 (6,000)
1,800 (6,000)
1,800 (6,000)
1,800 (6,000)
1,800 (6,000)
1,800 (6,000)
1,800 (6,000)
1,800 (6,000)
1,800 (6,000)
1,800 (6,000)
1,800 (6,000)
1,800 (6,000)
1,800 (6,000)
1,800 (6,000)
1,800 (6,000)
1,800 (6,000)
1,800 (6,000)
1,800 (6,000)
22 (72)
23 (74)
13 (56)
13 (55)
19 (66)
24 (75)
26 (78)
26 (78)
26 (78)
24 (76)
24 (76)
21 (69)
23 (73)
23 (74)
24 (76)
11(52)
19 (67)
13 (55)
15 (59)
13 (56)
21 (69)
21 (70)
22 (72)
23 (73)
24 (76)
24 (75)
26 (78)
745 (29.4)
744 (29.3)
753 (29.6)
749 (29.5)
747 (29.4)
733 (28.8)
733 (28.8)
735 (29.0)
735 (29.0)
737 (29.0)
734 (28.9)
729 (28.7)
729 (28.7)
729 (28.7)
730 (28.8)
748 (29.4)
747 (29.4)
747 (29.4)
747 (29.4)
747 (29.4)
732 (28.8)
732 (28.8)
730 (28.8)
732 (28.8)
734 (28.9)
726 (28.6)
732 (28.8)
                                                                            (continued)
                                          19

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Environmental Technology Verification Report
Dust Suppressant Products:  EK35
                                  Table 13. (continued)

Run
CKO-1014
CKO-1015
CKO-1016

Test section
EK35, A
EK35, A
EK35, A

Date
10/11/03
10/11/03
10/11/03

Test start
time
17:53
18:16
18:40

Total distance,
m(ft)
1,800 (6,000)
1,800 (6,000)
1,800 (6,000)

Temperature,
°C (°F)
21 (69)
20 (68)
18 (65)
Barometric
pressure,
mm Hg
(in. Hg)
728 (28.6)
728 (28.6)
730 (28.8)
 MC
CKO-111
CKO-112
CKO-131
CKO-132
CKO-133
CKO-406
CKO-407
CKO-413
CKO-414
CKO-415
CKO-122
CKO-123
CKO-124
CKO-125
CKO-126
CKO-401
CKO-402
CKO-403
CKO-404
CKO-405
Uncontrolled
Uncontrolled
Uncontrolled
Uncontrolled
Uncontrolled
Uncontrolled
Uncontrolled
Uncontrolled
Uncontrolled
Uncontrolled
EK35, A
EK35, A
EK35, A
EK35, A
EK35, A
EK35, A
EK35, A
EK35, A
EK35, A
EK35, A
5/13/03
5/13/03
5/15/03
5/15/03
5/15/03
8/6/03
8/6/03
8/7/03
8/7/03
8/7/03
5/14/03
5/14/03
5/14/03
5/14/03
5/14/03
8/6/03
8/6/03
8/6/03
8/6/03
8/6/03
17:05
17:40
8:32
9:04
9:42
11:42
12:53
8:30
8:52
9:11
9:31
9:52
10:30
10:57
11:35
9:13
9:52
10:24
10:51
11:13
3,700 (12,000)
3,700 (12,000)
3,700 (12,000)
3,700 (12,000)
3,700 (12,000)
1,800 (6,000)
1,800 (6,000)
1,800 (6,000)
1,800 (6,000)
1,800 (6,000)
3,700 (12,000)
3,700 (12,000)
3,700 (12,000)
3,700 (12,000)
3,700 (12,000)
3,700 (12,000)
3,700 (12,000)
1,800 (6,000)
1,800 (6,000)
1,800 (6,000)
34 (94)
33 (92)
24 (76)
24 (76)
26 (79)
41 (106)
43(110)
34 (93)
35 (95)
35 (95)
28 (82)
29 (85)
33 (92)
32 (90)
33 (92)
38 (100)
39(103)
41 (105)
40 (104)
39(103)
734 (28.9)
734 (28.9)
734 (28.9)
734 (28.9)
734 (28.9)
737 (29.0)
735 (29.0)
735 (29.0)
737 (29.0)
734 (28.9)
733 (28.8)
733 (28.8)
733 (28.8)
732 (28.8)
734 (28.9)
737 (29.0)
737 (29.0)
737 (29.0)
737 (29.0)
737 (29.0)
       Road surface samples were collected on a section each day that section was tested.  The
surface samples were analyzed for moisture and silt (i.e., fraction passing 200 mesh upon dry
sieving). Table 14 presents the moisture content and silt content results for both FLW and MC.
With the exception of test periods when unexpected road maintenance occurred (i.e., October
2002 at FLW and August 2003 at MC), the silt content of the treated road surface tends to be less
than that for the untreated road section.
                                           20

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Environmental Technology Verification Report
Dust Suppressant Products:  EK35
                            Table 14.  Road Surface Properties
Test section
Date
Moisture content,
%
Silt content, %
           FLW
Uncontrolled
EK35
10/12/023
10/13/023
10/14/023
5/24/03
5/26/03
10/12/03
10/13/03
10/13/03
10/14/023
5/24/03
10/11/03
10/11/03
0.4
0.63
0.75
1.8
0.01
1.4
1.5
0.62
1.1
0.31
0.71
1.0
1.6
1.5
1.7
4.3
1.6
3.0
5.4
1.7
6.6
2.3
1.1
1.7
           MC
Uncontrolled
EK35
5/14/03
8/6/03b
8/6/03b
5/14/03
8/6/03b
0.22
0.32
0.32
0.17
0.33
4.7
8.8
9.2
1.7
2.9
           a Unexpected road maintenance activity occurred at FLW in September 2002 prior to
             the October 2002 test period.
           b Unexpected road maintenance activity appeared to have occurred at MC after the
             time of the May 2003 visit and prior to the August 2003 test period.
4.0   References

1.  Code of Federal Regulations, Title 40, Part 50.7, National Primary and Secondary Ambient
    Air Quality Standards for Paniculate Matter.  July 18, 1997.

2.  ETV.  2002. Reports of 3-Month Test of Dust Suppression Products, Preliminary Testing.
    RTI International, Research Triangle Park, NC and Midwest Research Institute, Kansas City,
    MO. November, http://etv.rti.org/apct/documents.cfm

3.  ETV. 2003.  Test/QA Plan for Testing of Dust Suppressant Products at Fort Leonard Wood,
    Missouri, Rev 3 dated July 24, 2003. RTI International, Research Triangle Park, NC and
    Midwest Research Institute, Kansas City, MO. http://etv.rti.org/apct/documents.cfm

4.  ETV. 2003.  Test/QA Plan for Testing of Dust Suppressant Products atMaricopa County,
    Arizona, Rev 3 dated July 24, 2003. RTI International, Research Triangle Park, NC and
    Midwest Research Institute, Kansas City, MO. http://etv.rti.org/apct/documents.cfm
                                           21

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Environmental Technology Verification Report                   Dust Suppressant Products:  EK35


5.  MRI. 2005. Test Report for EK3 5, Section A at Fort Leonard Wood, Missouri, and East
   Section atMaricopa County, Arizona.  Midwest Research Institute, Kansas City, MO.
   Report may be obtained from RTI International.

6.  MRI. 2005. Audit of Data from Testing of Dust Suppressant Products at Fort Leonard
   Wood, Missouri andMaricopa County, Arizona.  Midwest Research Institute, Kansas City,
   MO.  Report may be obtained from RTI International.

7.  U.S. EPA (Environmental Protection Agency). 2000. Test Method 24, Determination of
   Volatile Matter Content, Water Content, Density, Volume Solids, and Weight Solids of
   Surface Coatings. Office of Solid Waste. Washington, DC.

8.  U.S. EPA (Environmental Protection Agency). 2000. Test Method 405.1, Standard
   Operating Procedure for the Analysis of Biochemical Oxygen Demand in Water.  Region 5.
   Chicago, IL.

9.  U.S. EPA (Environmental Protection Agency). 1993. Methods for Chemical Analysis of
   Water and Wastes.  EPA/600/4-79/020. Cincinnati, OH. (Includes EPA Method 410.4,
   Chemical Oxygen Demand.)

10. U.S. EPA (Environmental Protection Agency). 1998. SW-846,  Test Methods for Evaluating
   Solid Waste, Physical/Chemical Methods.  Office of Solid Waste. Washington, DC. (Includes
   the following tests: Method 1311,  TCLP - Toxicity Characteristics Leaching Procedure;
   Method 6010 - Inorganics by ICP; Method 8260 - VOCs by GC/MS; and Method 8270 -
   SVOCs by GC/MS.)

11. U. S. EPA (Environmental Protection Agency). 1993. Methods for Measuring the Acute
   Toxicity of Effluents and Receiving Waters to Freshwater and Marine Organisms.
   EPA/600/4-90/027.

12. U.S. EPA (Environmental Protection Agency). 1994. Short-Term Methods for Estimating the
   Chronic Toxicity of Effluents and Receiving Water to Freshwater Organisms. EPA/4-
   91/002.

13. ABC Laboratories, Inc. 2002. Acute and Chronic Toxicity of Dust Suppression Products A,
   B, E, Perma-Zyme 11X, and Soil Sement Engineered Formula to Ceriodaphnia dubia,
   Fathead Minnow (Pimephalespromelas), and Americamysis bahia.  Columbia, Missouri.
   September.

14. Tri-State Laboratories, Inc. 2002. Laboratory Analysis Report. Youngstown, Ohio. July.
   Report may be obtained from RTI International.

15. Peterson, M. 2002. "Laboratory analysis report for dust suppressants."  E-mail and
   attachments from M. Peterson, RTI, to D. Franke, RTI.  November 18, 2002.

16. ETV. 2004. Generic Verification Protocol for Dust Suppression and Soil Stabilization
   Products. RTI International, Research Triangle Park, NC.
                                          22

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Environmental Technology Verification Report                    Dust Suppressant Products:  EK35



                                    Appendix A


                        Environmental Testing Results


       A copy of ABC Laboratories' summary report for aquatic toxicity testing on five dust
suppression products13 is retained in the RTI International project files. The results for EK35 are
summarized below.

Solution Preparation

       Solutions were prepared on a weight-to-volume basis for all compounds. The liquid
sample for EK35 was not water soluble and was conducted as Water Accommodated Fractions
(WAF). Liquid sample EK35 was weighed out on large glass microscope slides and suspended in
a beaker of water containing a Teflon stir bar.  The beakers were placed on a stir plate and stirred
overnight. Solutions were drawn off by siphoning the solutions into another glass container
leaving a small amount of solution in the beaker.  The remaining solution contained undissolved
test compound that was floating on the surface of the water in the beaker. This undissolved test
compound was not included in solutions for two reasons: (1) so that it would not cause a
decrease in dissolved oxygen transfer by covering the surface of the test vessels, and (2) so that it
would not cause secondary toxicity from impairment of the animal's respiratory system in the
case of the fathead minnow's gills or cause any impairment in the appendages of the
Ceriodaphnia dubia or Americamysis bahia.

Test Design

       Where preliminary testing indicated no mortality at concentrations of 1,000 milligrams
per liter (mg/L), abbreviated or limit studies were performed. Acute studies run as limit tests
were conducted with a control and a single concentration at 1,000 mg/L.  Chronic studies were
conducted with a control and three test levels: 250, 500, and 1,000 mg/L.  All other studies were
conducted with five or six test levels and a control.

Statistical Analysis

       Statistical analysis of the concentration versus effect data was performed using a custom
computer program, ToxCalc from Tidepool Scientific Software.  This program is designed to
calculate the lethal concentration, 50 percent (LCso) / effective concentration, 50 percent (ECso)
statistic and its 95 percent confidence interval (CI), as applicable, using the appropriate EPA
recommended analysis. Statistical significance of comparison of means for Ceriodaphnia dubia,
fathead minnow,  and Americamysis bahia survival and reproduction,  growth, and fecundity was
determined by hypothesis testing using  either Fisher's Exact test or Dunnett's test.  Point
estimate testing to calculate the LCso or ECso were determined with the Trimmed Spearman-
Karber method.
                                         A-l

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       Generally, the statistical approach was as follows: Analysis of each endpoint between
samples was evaluated by first analyzing the data for normality and homogeneity of variances
with Shapiro-Wilk's Test and Kolmogorov D's Test before comparison of means.  If the data
were normally distributed and the variances were homogeneous, then analysis of variances
(ANOVA) was used for the weight data, along with Fisher's Exact Test or Dunnett's procedure
for comparing the means. Survival data were analyzed using Fisher's Exact test, and growth or
reproduction data were analyzed using Dunnett's.  If the assumptions of normality or
homogeneity of variance were not met, transformations of the survival data were employed to
allow the use of parametric procedures.  If transformations (e.g., arc sine-square root
transformation) of the survival data still did not meet assumptions of normality and
homogeneity, then the nonparametric test, Steel's Many-One Rank Test, was used to analyze
these data.

47551 Ceriodaphnia dubia Acute Tests (August 20-22, 2002)

       This test was conducted as a limit test with levels of control and 1,000 mg/L. Mortality
was 0 percent in both the control and the 1,000 mg/L concentration.  The 48-hour LCso for
survival was greater than (>) 1,000 mg/L.  The no observed effect concentration (NOEC) was
1,000 mg/L, and the lowest observed effective concentration (LOEC) was >1,000 mg/L.

47552 Fathead Minnow Acute Tests (August 14-21, 2002)

       This test was conducted as a multi-concentration test with levels of control, 31.3, 62.5,
125, 250, 500, and 1,000 mg/L. Mortality was 5 percent in the control. Mortality was 0, 5, 10,
30, 100, and  100  percent in the 31.3, 62.5, 125,250, 500, and 1,000 mg/L test levels,
respectively. The 96-hour LCso for survival was 271 mg/L with 95 percent CIs of 229 to 321
mg/L.  The NOEC was 125 mg/L and the LOEC was 250 mg/L.

47553 Americamysis bahia Acute Tests (August 22-26, 2002)

       This test was conducted as a multi-concentration test with levels of control, 31, 63, 130,
250, and 500 mg/L.  Mortality was 0 percent in the control. Mortality was 0, 5, 65, 100, and 100
percent in the 31, 63, 130, 250, and 500 mg/L test levels, respectively. The 96-hour LCso  for
survival was 111  mg/L with 95 percent CIs of 94 to  131 mg/L. The NOEC was 63 mg/L and the
LOEC was 130 mg/L.

47554 Ceriodaphnia dubia Chronic Tests (August 21-28, 2002)

       This test was conducted as a multi-concentration test with levels of control, 250, 500, and
1,000 mg/L.  Mortality was 0 percent in the control.  Mortality was 0, 20, and 50 percent in the
250, 500, and 1,000 mg/L concentrations, respectively. The 7-day LCso for survival was >1,000
mg/L.  For survival,  the NOEC was 500 mg/L and the LOEC was  1,000 mg/L.  The 7-day EC50
for reproduction was 375 mg/L with 95 percent CIs of 332 to 425 mg/L. For reproduction, the
NOEC was 250 mg/L and the LOEC was 500 mg/L.
                                         A-2

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Environmental Technology Verification Report                   Dust Suppressant Products:  EK35


47555 Fathead Minnow Chronic Tests (August 14-21, 2002)

       This test was conducted as a multi-concentration test with levels of control, 15.6, 31.3,
62.5, 125, and 250 mg/L.  Mortality was 3 percent in the control. Mortality was 3, 13, 23, 57,
and 100 percent in the 15.6, 31.3, 62.5, 125, and 250 mg/L test levels, respectively.  The 7-day
LCso for survival was 97 mg/L with 95 percent CIs of 81 to 116 mg/L. For survival, the NOEC
was 31.3 mg/L and the LOEC was 62.5 mg/L. The 7-day ECso for growth was 114 mg/L with 95
percent CIs of 14 to 959 mg/L.  For growth, the NOEC was 31.3 mg/L and the LOEC was 62.5
mg/L.

47556 Americamysis bahia Chronic Tests (August 29-September 5, 2002)

       This test was conducted as a multi-concentration test with levels of control, 25, 50, 100,
200, and 400 mg/L. Mortality was 8 percent in the control. Mortality was 13,33, 100, 100, and
100 percent in the 25, 50, 100, 200, and 400 mg/L test levels, respectively.  The 7-day LC50 for
survival was 59 mg/L. For survival, the NOEC was 25 mg/L and the LOEC was 50 mg/L. The
7-day ECso for growth was >50 mg/L. For growth, the NOEC was 50 mg/L and the LOEC was
>50 mg/L. The 7-day ECso for fecundity was >50 mg/L. For fecundity, the NOEC was 50 mg/L
and the LOEC was >50 mg/L.
                                        A-3

-------
Environmental Technology Verification Report                  Dust Suppressant Products: EK35
                                  Appendix B

                          Chemical Testing Results
                                                                   14
      Tri-State Laboratories' analysis report of five dust suppression products  is retained in
the RTI International project files. The results for EK35 are included on the pages that follow.
                                        B-l

-------
TSL
Tri-State
Laboratories, Inc.
2870 Salt Spring? Road • Youngstown, Ohio  44509
Ph: (330) 797-8844 • Fax:  (330) 797-3264 • 1-800-523-0347
E-mail: trislabs@aol.com
                           Laboratory Analysis Report
Client: RTT
Attn: DEBBIE FRANKE
PO BOX 12 194




Lab Number:
Sample ID:
22061405
SAMPLE

A-MIDWEST


KANSAS CITY
RESEARCH TRIANGLE PARK, NC 27709
Date Sampled:
Time Sampled:
Date Received: 6/14/2002
Report Date: 7/15/2002
Comments:
Analyte

Aliymiiiiitifl
Antimony
Arsenic-TCLP
Arsenic
Barium-TCLP
Barium
Beryllium
Cadmium-TCLP
Cadmium
Chromium
Chromium-TCLP
Copper
Iron
Lead
Lead-TCLP
Manganese
Mercury
Mercury-TCLP
Nickel
Selenium
Selemum-TCUP
Silver-TCLP
Silver
Thallium
Zinc
Herbicides
Pesticides
Polynucleai Aromatic Hydrocarbons
Semi-Volatile Organic Compounds
TCLP-Semi-Volatiles
TCLP-Volatiles (VOC)
Volatile Organic Compounds (VOC)





Result

1.25
BDL
BDL
BDL
BDL
BDL
BDL
0.040
0.044
BDL
BDL
0.044
31.8
BDL
BDL
0.160
BDL
BDL
BDL
BDL
BDL
0.0252
0.030
BDL
0.142
SEE ATTACHED
SEE ATTACHED
SEE ATTACHED
SEE ATTACHED
SEE ATTACHED
SEE ATTACHED
SEE ATTACHED





Unit

rag/kg
rag/kg
mg/L
Tng/lrg
mg/L
mg/kg
mg/kg
mg/L
mg/kg
mg/kg
mg/L
mg/kg
mg/kg
mg/kg
mg/L
mg/kg
mg/kg
mg/L
mg/kg
mg/kg
mg/L
mg/L
mg/kg
mg/kg
mg/kg



Sample Description:
Sampler Name:
Sample Matrix;
PO#:


Detection
Limit
0.44
0.044
0.10
0.13
0.040
0.044
0.007
0.020
0.022
0.022
0.020
0.022
0.44
0.11
0.10
0.044
0.0011
0.001
0.044
0.18
0.16
0.020
0.022
0.030
0.044





Aqueous
19820


Method

200.7
200.7
601 OB
200.7
6010B
200,7
200.7
601 OB
200.7
200.7
6010B
200.7
200.7
200.7
601 OB
200.7
245.2
7472
200.7
200.7
601 OB
601 OB
200.7
200.7
200.7
8270
8270
8270/610
8270A/625






1311/8270
1311/8260
8260/624






Analysis
Date
6/19/2002
6/19/2002
6/19/2002
6/19/2002
6/19/2002
6/19/2002
6/19/2002
6/19/2002
6/19/2002
6/19/2002
6/19/2002
6/19/2002
6/19/2002
6/19/2002
6/19/2002
6/19/2002
6/21/2002
6/21/2002
6/19/2002
6/19/2002
6/19/2002
6/19/2002
6/19/2002
6/19/2002
6/19/2002
6/19/2002
6/19/2002
6/19/2002
6/19/2002
6/19/2002
6/17/2002
6/17/2002






Analyst

SCB
SCB
SCB
SCB
SCB
SCB
SCB
SCB
SCB
SCB
SCB
SCB
SCB
SCB
SCB
SCB
SCB
SCB
SCB
SCB
SCB
SCB
SCB
SCB
SCB
JP
JP
JP
JP
JP
JP
JP

-------
                                                                             BDL = Below Detection Limit
Results ipproved by:
   John Pflugh, Lab Manager
   Scott Bolam, QA/QC Officer

-------
                         TRI-STA TE LABORA TORIES
                                2870 Salt Springs Road
                               Youngstown, OH 44509
                         Phone: (330) 797-8844/1-800-523-0347
                                 Fax: (330) 797-3264
Client: RTI

Sample: 22061405

Sample Description: A
              Date Received: 06.14.02

              Date Analyzed: 06.19.02

              Date Reported: 07.15.02
                                  HERBICIDES
                                   Method fc 8270
COMPOUND
CONCENTRATION (mg/L)
 MDL (mg/L)
2,4-D
Silvex
         BDL
         BDL
    0.138
    0.138
Surrogates

DCAA
       Recovery

         109
Accept. Limits

   35-114

-------
                        TRI-STATE LABORATORIES
                              2870 Salt Springs Road
                             Youngstown, OH 44509
                        Phone: (330) 797-8844/1-800-523-0347
                               Fax: (330) 797-3264
Client; RTI                                              Date Received: 06.14.02

Sample: 22061405                                          Date Analyzed: 06.19.02

Sample Description: A                                      Date Reported: 07.15.02
                                 PESTICIDES
                                 Method #: 8270


COMPOUND                               CONCENTRATION (mg/L)     MDL(mg/L)
TECHNICAL CHLORDANE                             BDL                 0.008
ENDRIN                                            BDL                 0.003
HEPTACHLOR                                      BDL                 0.003
LINDANE                                           BDL                 0.003
METHOXYCHLOR                                    BDL                 0.003
TOXAPHENE                                        BDL                 0.07


Surrogates                                       Recovery           Accept. Limits

TCMX                                              61                 35-114
DBCP                                              71                 43-116

-------
                         TRI-STATE LABORATORIES
                                2870 Salt Springs Road
                                Youngstown, OH 44509
                          Phone: (330) 797-8844/1-800-523-0347
                                 Fax: (330) 797-3264
 Client: RTI                                                  Date Received; 06/14/02

 Sample: 22061405                                             Date Analyzed; 06/19/02

 Sample Description: A                                         Date Reported: 06/28/02
                 POLYNUCLEAR AROMATIC HYDROCARBONS
                                   Method #: 8270

COMPOUND                                 CONCENTRATION (mg/kg)      MDL(mg/kg)

Acenaphthene                                          BDL                   50
Acenaphthylene                                        BDL                   50
Anthracene                                            BDL                   50
Benzo [a] anthracene                                    BDL                   50
Benzo [a] pyrene                                        BDL                   50
Benzo [b] fluoranthene                                   BDL                   50
Benzo [k] fluoranthene                                   BDL                   50
Benzo [g,h,l] perylene                                    BDL                   50
Chrysene                                              BDL                   50
Dibenzo [a,h] anthracene                                 BDL                   50
Fluoranthene                                          BDL                   50
Fluorene    .                                          BDL                   50
1ndeno(1,2,3-cd) pyrene                                 BDL                   50
Naphthalene                                           BDL                   50
Phenanthrene                                          BDL                   50
Pyrene                                               BDL                   50
Surrogates                                          Recovery           Accept.Limits
Nitrobenzene-d5                                         58                  23-123
2-Fluorobiphenyl                                         109                  30-107
p-Terphenyl                                             109                  18-129
BDL = below detection limit
MDL = method detection limit

-------
                          TRI-STATELABORATORIES
                                 2870 Salt Springs Road
                                 Youngstown, OH 44509
                           Phone: (330) 797-8844/1-800-523-0347
                                   Fax:(330)797-3264
 Client: RT1

 Sample: 22061405

 Sample Description: A
              Date Received: 06/14/02

              Date Analyzed: 06/19/02

              Date Reported; 06/28/02
           BASE/NEUTRAL & ACID COMPOUNDS: PRIORITY POLLUTANTS
                                    Method #: EPA 8270
COMPOUND

Acenaphtene
Acenaphthylene
Anthracene
Benzidlne
Benzo [a] anthracene
Benzo [a] pyrene
3,4-Benzofluoranthene
Benzo (g,h,l) perylene
Benzo (b) fluoranthene
Benzo (k) fluoranthene
Bis {2-chloroettioxy) methane
Bis {2-chloroethyl} ether
Bis (2-chloroisopropyl) ether
Bis (2-ethylhexyi) phthalate
4-Bromophenyl phenyl ether
Butyl benzyl phthalate
Carbazote
2-Chloronaphthalene
4-Chlorophenyl phenyl ether
Chrysene
Dibenzo [a,h] anthracene
1,2-Dichlorobenzene
1,3-Dichlorobenzene
1,4-Dichlorobenzene
3,3'-Dichlorobenzidine
Diethyl phthalate
Dimethyl phthalate
Di-n-octyl phthalate
2,4-Dlnitrotoluene
2,6-Dlnitrotoluene
Di-n-octyl phthalate
1,2-Diphenylhydrazine (as azobenzene)
CONCENTRATION (mg/kg)

         BDL
         BDL
         BDL
         BDL
         BDL
         BDL
         BDL
         BDL
         BDL
         BDL
         BDL
         BDL
         BDL
         BDL
         BDL
         BDL
         BDL
         BDL
         BDL
         BDL
         BDL
         BDL
         BDL
         BDL
         BDL
         BDL
         BDL
         BDL
         BDL
         BDL
         BDL
         BDL
MDL {mg/kg}

    50
    50
    50
    500
    50
    50
    50
    50
    50
    50
    50
    50
    50
    50
    50
    50
    50
    50
    50
    50
    50
    50
    50
    50
    500
    50
    50
    50
    50
    50
    50
    50
BDL = below detection limit
MDL = method detection limit
                                                                                   Iof2

-------
Client: RTI
Sample: 22061405
COMPOUND

Fluoranthene
Fluorene
Hexachlorobenzene
Hexschlorobutadiene
Hexachlorocyclopentadiene
Hexachloroethane
Indeno (1,2,3-cd) pyrene
Isophorone
Naphthalene
Nitrobenzene
N-Nitrosodimethylamine (as diphenylamine)
N-Nitrosodl-n-propylamine
N-Nitrosodiphenylamine
Phenanthrene
Pyrene
1,2,4-Trichlorobenzene
2-Chlorophenol
2,4-Dichlorophenol
2,4-Dimethylphenol
4,6-Dinitro-o-cresol
2,4-Dinitrophenol
2-Methyl phenol
3&4-Methyl phenol
2-Nitrophenol
4-Nitrophenol
Pentachlorophenol
Phenol
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
4-Chloro-3-Methyl Phenol
Benzole Acid
2,3,7,8-tetrachloro-dibenzo-p-dioxin
   CONCENTRATION (mg/kg)

            BDL
            BDL
            BDL
            BDL
            BDL
            BDL
            BDL
            BDL
            BDL
            BDL
            BDL
            BDL
            BDL
            BDL
            BDL
            BDL
            BDL
            BDL
            BDL
            BDL
            BDL
            BDL
            BDL
            BDL
            BDL
            BDL
            BDL
            BDL
            BDL
            BDL
            BDL
          ABSENT
 MDL (me/kg)

     SO
     SO
     50
     50
     50
     50
     50
     50
     50
     50
     50
     50
     50
     50
     50
     50
     100
     100
     100
     100
     100
     100
     100
     100
     100
     100
     100
     100
     100
     100
     100
Surrogates
Nitrobenzen-d5
2-Fluorobiphenyl
p-Terphenyl
Phenol-d6
2-Fluorophenol
2,4,6- Tribromophenol
          Recovery
             58
             109
             109
             71
             61
             78
Accept.Llmits
   35-114
   43-116
   33-141
    11-94
   25-100
   16-123
BDL = below detection limit
MDL = method detection limit
                                                                                   2 of 2

-------
                          TRI-STA TE LABORATORIES
                                 2870 Salt Springs Road
                                Youngstown, OH 44509
                          Phone: (330) 797-8844/1-800-523-0347
                                  Fax: (330) 797-3264
Client: KIT

Sample: 22061405

Sample Description: A
                                                            Date Received: 06.14.02

                                                            Date Analyzed: 06.19.02

                                                            Date Reported: 06,28.02
                         TCLP SEMI-VOLATILES - GC/MS
                                  Method #: 1311/8270

                                             CONCENTRATION {mg/L)      MDL (mg/L)

                                                      BDL                   0,55
                                                      BDL                   0.66
                                                      BDL                   0.66
                                                      BDL                   0.66
                                                      BDL                   0.66
                                                      BDL                   0.66
                                                      BDL                   0.66
                                                      BDL                   0.55
                                                      BDL                   0.28
                                                      BDL                   0.55
                                                      BDL                   0.55
COMPOUND

Cresots
1,4-Dichlorobenzene
2,4-Dinitrotoluene
Hexschlorobenzene
Hexachloro-1,3-butadiene
Hexachloroe thane
Nitrobenzene
Pentachlorophenol
Pyridine
2.4,5-Trlchlorophenol
2,4,6-Trichlorophenol
Surrogates
Nitrobenzene-d5
2-Flurobiphenyl
p-Terphenyl
Phenol-d6
2-Fluorphenol
2,4,6-Tribromophenol
                                                    Recovery
                                                       64
                                                       99
                                                       120
                                                       67
                                                       78
                                                       86
Accept.Llmits
   35-114
   43-116
   33-141
   25-100
    11-94
   16-123
BDL = below detection limits
MDL = method detection limit
GC/MS = gas chromatography/mass
spectrometry

-------
                          TRI-STATE LABORATORIES
                                 2870 Salt Springs Road
                                Youngstown, OH 44509
                          Phone: (330) 797-8844/1-800-523-0347
                                  Fax: (330) 797-3264
 Client: RTJ

 Sample: 22061405

 Sample Description: A
               Date Received:  06.14.02

               Date Analyzed: 06.17.02

               Date Reported: 06.28.02
                            TCLP VOLATILES - GC/MS
                                  Method #: 1311/8260
COMPOUND

Benzene
Carbon Tetrachloride
Chlorobenzene
Chloroform
1,2-Dichloroetnane
1,1-Dichloroetnene
Methyl ethyl ketone (2-Butanone)
Tetrachloroettiene
Trichloroethene
Vinyl Chloride
CONCENTRATION (mg/L)

         BDL
         BDL
         BDL
         BDL
         BDL
         BDL
         BDL
         BDL
         BDL
         BDL
 MDL (mg/L)

     2.27
     2.27
     2.27
     2.27
     2.27
     2.27
     2.27
     2.27
     2.27
     4.53
Surrogates
Dibromofluorobenzene
Totuene-d8
Bromoflurobenzene
       Recovery
          115
          94
          100
Accept. Limits
    86-118
    88-110
    86-115
BDL = below detection limit
MDL = method detection limit
GC/MS = ges chromatography/mass spectrometry

-------
                           TRI-STATE LABORATORIES
                                  2870 Salt Springs Road
                                 Youngstown, OH 44509
                           Phone: (330) 797-8844/1-800-523-0347
                                   Fax:(330)797-3264
     t: HIT                                                    Date Received: 06.14.02

 Sample: 22061405                                               Date Analyzed; 06.17.02

 Sample Description: A                                           Date Reported: 06.22.02
                               8260 WASTE DILUTION
                                    Method #:82«V5Q30

COMPOUND                                      CONCENTRATION (mg/kg)        MDL(mgftg)

Acetone                                                   BDL                     25
Benzene                                                  BDL                     2.5
Bromobenzene                                             BDL                     2.5
Bromochloromethane                                        BDL                     2.5
Bromodlchloromethane                                       BDL                     2.5
Bromoform                                                BDL                     2.5
Bromomethane                                             BDL                     5.0
2-Butanone                                                BDL                     25
n-Butylbenzene                                             BDL                     2.5
seo-Butylbenzene                                           BDL                     2.5
tert-Butylbenzene                                           BDL                     2.5
Carbon Tetrachtoride                                        BDL                     2.5
Chlorobenzene                                             BDL                     2.5
Chtoroethane                                               BDL                     5.0
Chloroform                                                BDL                     2.5
Chtaromethane                                             BDL                     5.0
2-Chlorotohjene                                             BDL                     2.5
4-Chlorotoluene                                             BDL                     2.5
1,2-Dibromo-3-chtoropropane                                  BDL                     2,5
Dibromochloromethane                                       BDL                     2.5
1,2-Dibromoethane                                          BDL                     2.5
Dlbromomethane                                           BDL                     2.6
1,2-Dichlorobenzsna                                        BDL                     2.5
1,3-Dtahlorobenzene                                        BDL                     2,5
1,4-Dichlorobenzene                                        BDL                     2.5
Dichlorodifluoromethane                                      BDL                     5.0
1,1-DicMoroethane                                          BDL                     2.5
1.2-Dichloroethane                                           150                     2.5
1,1,-Dtahloroethene                                          BDL                     2.5
cte-1,2-Dfchloroethene                                       BDL                     2.5
tran&-1,2-DicMoroethene                                      BDL                     2.5    «
1,2-Dichloropropane                                        BDL                     2.5
1,3-Dtahloropropane                                        BDL                     2.5
2,2-Dichloropropane                                        BDL                     2.5
1,1-Dichloropropene                                        BDL                     2.5
Ethyl Benzene                                             BDL                     2.5
Hexachlorobutadiene                                        BDL                     2,5
 BDL = below detection limit
 MDL - method detection limit
                                                                                     Iof2

-------
Client: RTI                                 Sample: 22061405
COMPOUND                                   CONCENTRATION (mo/kg)
2-Hexanone
Isopropylbenzene
p-lsopropyltoluene
Methylene Chloride
Methyl Isobutyl Ketone
Naphthalene
n-Propylbenzene
Styrene
1,1,1 ,2-Tetrachloroethane
1,1 ,2,2-Tetrachloroethane
Tetrachloroethene
Toluene
1 ,2,3-Trichtorobenzene
1 ,2,4-Trichlorobenzene
1,1,1 -Trichloroethane
1 ,1 ,2-Trichtoroethane
Trichioroemene
Trichlorofluoromethane
1 ,2,3-Trichtoropropane
1 ,2,4-Trimethylbenzene
1 ,3,5-Trimethylbenzene
Vinyl Chloride
m,p-Xylene
o-Xylene
Surrogates
Dibromofluorobenzene
Toluene-d8
Bromofluorobenzene
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
Recovery
112
95
87
25
2,5
2.5
2.5
25
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2,5
2.5
5.0
2.5
2.5
2.5
5.0
2.5
2.5
AecBptLimKs
86-118
88-110
86-115
BDL = below detection limit
MDL = method detection limit
                                                                                2 of 2

-------
Environmental Technology Verification Report
Dust Suppressant Products:  EK35
                                   Appendix C

                               Method 24 Results
       Table C-l shows the results of the Method 24 analysis conducted by RTI International.

               Table C-l. Summary of EPA Method 24 Analysis for EK35
                          15
Sample ID
EK35
ASTM D1475
Density,
g/mL
0.8956
ASTM D2369
Total Volatiles,
wt %
10.963
ASTM D3792
Water,
wt%
0.00
         NOTE:  Each value is the average of two measurements.
         a Duplicate measurements did not meet criterion (analysis repeated four times).
                                         C-l

-------