EPA/600/R-05/127
                                  January 2006
Environmental Technology Verification

Dust Suppressant Products
North American Salt Company's DustGard
                 Prepared by


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

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              THE ENVIRONMENTAL TECHNOLOGY VERIFICATION
                                   PROGRAM
U.S. Environmental Protection Agency
                             ~~             '          INTERNATIONAL
                              ET
                ETV Joint Verification Statement
                                              +        ERTT
                                                           ^^J M ^^_ M   M
 TECHNOLOGY TYPE:    DUST SUPPRESSANT

 APPLICATION:          CONTROL OF DUST ON UNPAVED ROADS

 TECHNOLOGY NAME:   DustGard

 COMPANY:              NORTH AMERICAN SALT COMPANY

 ADDRESS:               9900 W. 109th STREET, STE 600
                          OVERLAND PARK, KS  66210
                          PHONE:    913-344-9391

 WEB SITE:               http://www.nasalt.com/
 E-MAIL:                 kubalikb@compassminerals.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 RTI International (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 North American Salt Company's
DustGard was conducted at Fort Leonard Wood, Missouri (FLW).  A July 2003 test/QA plan for
the field testing was developed and approved by EPA.  The test/QA plan describes the
procedures and methods used for the tests. The July 2003 version of the test/QA plan was based
on an October 2002 version and a subsequent test/QA plan addendum (dated February 19, 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 plan was revised (Rev 3) to address those issues.  Test
periods occurred per the test/QA plan for three roughly 6-month periods. Two of those test
periods are summarized below and are considered most representative of product performance;
the third testing period occurred after unexpected road maintenance, and those data 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. 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
(PM2.5).

The host facility  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.
DustGard was applied to test section E, located on Road PA; and 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 was  conducted during  October 2002, May 2003, and
October 2003.

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

                                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 weeks, % — controlled road
Soil silt during test weeks, % — uncontrolled road
Soil silt during test weeks, % — controlled road
FLW,
October 2003
2.5
2.5
122
0.2
1.8
39
0.62-1.5
1.9-3.5
1.7-5.4
1.2-1.7
FLW,
May 2003
2.5
2.4
79
3.7
3.2
24
0.01-1.8
0.20-0.42
1.6-4.3
1.2-2.6

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The DustGard 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
Acute LCSO
for survival
> 1,000 mg/L (48-hr)
>1,000 mg/L (96-hr)
> 1,000 mg/L (96-hr)
Chronic LCSO
for survival
> 1,000 mg/L (7-d)
> 1,000 mg/L (7-d)
> 1,000 mg/L (7-d)
Chronic ECSO
>1,000 mg/L (7-d),
reproduction
>1,000 mg/L (7-d),
growth
>1,000 mg/L (7-d), growth,
fecundity
     d      = day
     EC50   = effective concentration which affects 50% of sample population
     hr     = hour
     LC50   = lethal concentration which kills 50% of sample population
     LOEC  = lowest observed effective concentration
     mg/L   = milligrams per liter
     NOEC  = no observed effect concentration
VERIFIED TECHNOLOGY DESCRIPTION

This verification statement is applicable to North American Salt Company's DustGard, which is
a hygroscopic product made of magnesium chloride. The material safety data sheet (MSDS) for
DustGard is retained in the RTI project files and is available at http://www.nasalt.com/msds/
Magnesium%20Chloride%20(liquid).pdf [accessed July 2005].

VERIFICATION OF PERFORMANCE

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

                            Table 2.  Summary of Test Results
Test location and
period
FLW, October 2003
FLW, May 2003
Average control efficiency, %
TP
86
75
PM10
>90
88
PM25
59
58
Noted events
Rain events the day before test.3
Rain events the morning of test.b
       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 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.
                                            iii

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This verification statement verifies the effectiveness ofNorth American Salt Company's
DustGardto 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 North American Salt Company's
DustGardto control dust on unpaved roads.
Signed by Sally Gutierrez        9/25/2005   Signed by Andrew Trenholm       9/16/2005
Sally Gutierrez, Director            Date     Andrew R. Trenholm, Director        Date
National Risk Management Research         Air Pollution Control Technology
 Laboratory                                 Verification Center
Office of Research and Development
United States Environmental Protection
 Agency
                                           IV

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Environmental Technology Verification

       Dust Suppressant Products

    North American Salt Company's
                   DustGard
                      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
                      January 2006

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Environmental Technology Verification Report                          Dust Suppressant Products
                                        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
                                 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, Missouri, and of all the North
American Salt Company 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 North American  Salt Company (the
participating vendor).
For more information on DustGard dust suppressant, contact:

Mr. Brian Kubalik
North American Salt Company
9900 W.  109th Street, Ste 600
Overland Park, Kansas  66210
Telephone:    (913) 344-9391
Email:       kubalikb@compassminerals.com
Web Site:    http://www.nasalt.com/

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
                                       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 (PMio), and
particulate matter less than or equal to 2.5 micrometers (|im) in aerodynamic diameter (PM^.s).
       North American Salt Company submitted the DustGard dust suppressant to the APCT
Center for testing. The test and quality assurance (QA) plan, prepared in accordance with the
Generic Verification Protocol (GVP), addressed the  site-specific issues associated with these
1-year verification tests.  The 1-year testing was conducted at Fort Leonard Wood, Missouri,
during October 2002, May 2003, and October 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

                                  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	4
     2.3  Discussion of QA/QC	4
     2.4  Deviations from Test Plan	5
3.0  Test Conditions	7
     3.1  General Test Site Conditions	7
          3.1.1   Traffic	9
          3.1.2   Area Climatic Conditions	9
          3.1.3   Background Particulate  Concentration	11
     3.2  Application of Dust Suppressant	12
     3.3  Conditions During Dust Suppressant Test Runs	14
4.0  References	15
Appendix A - Environmental  Testing Results	A-l
Appendix B - Chemical Testing Results	B-l
Appendix C - Method 24 Results	C-2
                                           IX

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Environmental Technology Verification Report                         Dust Suppressant Products


                                   List of Figures

1   Test locations at FLW [[[ 8
2   Application of DustGard product at FLW [[[ 13
                                   List of Tables

1   Summary of Test Results for DustGard (No Road Maintenance) ........................................... 3
2   Summary of Test Results for DustGard (After Road Maintenance Occurred) ....................... 3
3   DQOs versus Final Control Efficiency Variability for DustGard ........................................... 5
4   Summary of Test Event Deviations for FLW [[[ 5
5   Weekly Weather for FLW [[[ 9
6   Summary of Precipitation for all Test Periods at FLW [[[ 11
7   Measured Background PM Concentrations at FLW [[[ 11
8   Estimated Background Contribution to Sampler Catch at FLW Compared to Mean

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Environmental Technology Verification Report
Dust Suppressant Products
                    List of Acronyms and Abbreviations
ADT      average daily traffic
ANOVA  analysis of variance
APCT    air pollution control technology
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
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
PMio      particulate matter equal to or less than 10 |im in aerodynamic diameter
PM2.5     particulate matter equal to or less than 2.5 |im in aerodynamic diameter
QA       quality assurance
QC       quality control
                                          XI

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Environmental Technology Verification Report                          Dust Suppressant Products


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: DustGard
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 micrometers (|-im) 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 DustGard, developed by North American Salt
Company. DustGard is a hygroscopic (attracts moisture) dust control and soil stabilization
product made of magnesium chloride. The material safety data sheet (MSDS) for DustGard is
retained in the RTI project files and is available on North American Salt Company's Web site
(http://www.nasalt.com/msds/Magnesium%20Chloride%20niquid). pdf)  [accessed July 2005].
       The field test program for DustGard was conducted at FLW.  In July 2003, the
test/quality assurance (QA) plan for the field testing was developed and approved by EPA.3 The
July 2003 version of the test/QA plan was based on an October 2002 version and a subsequent
test/QA plan addendum (dated February 19, 2003).  This test/QA plan describes 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 winter weather
conditions and then maintenance activities on the roads of interest arose, and the test/QA plan
was revised (Rev 3) to address those issues.  Test periods occurred per the test/QA plan for three
roughly 6-month periods, during October 2002, May 2003, and October 2003. Emissions
measurements were made for total parti culate (TP), parti culate matter less than or equal to 10 |_im
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
DustGard during testing at FLW.  Complete documentation of the FLW test results is provided in
a separate test report4 and a data quality audit report.5 Those reports include the raw test data

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Environmental Technology Verification Report                 Dust Suppressant Products: DustGard


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 North American Salt
Company's DustGard dust suppressant as applied to unpaved roads at FLW. 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.
       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 plan provides 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 plan 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 particulate 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.
       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 period 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.

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Environmental Technology Verification Report
                                                           Dust Suppressant Products: DustGard
         Table 1.  Summary of Test Results for DustGard (No Road Maintenance)



Test period
Ortnber 9003a


May 2003C

Uncontrolled
emissions, mg/1,000 ft
(RSD, %)
TP
7.9
(59)
9 1


(14)
PM10
0.68
(78)
12


(21)
PM25
1.5
(27;
071


(29)
Time since
last
application,
days



79

Controlled emissions,
mg/1,000 ft
(RSD, %)
TP
1.2
00;
23


(¥7;
PM10
<0.07b
(0.0;
0 14


(55;
PM25
0.61
(24)
029


(7?;


Control efficiency, %
TP
86


75

PM10
>90


88

PM25
•S9


58

 1 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 All values were below the detection limit.
 "Rainfall in the morning meant that the uncontrolled section of the road was wet and another section was used for
  the test.
   Table 2. Summary of Test Results for DustGard (After Road Maintenance Occurred)



Test period
October
2002a
Uncontrolled
emissions, mg/1,000
ft (RSD, %)
TP
9.5
(36)
PM10
2.3
(55)
PM25
2.5
(41)
Time since
last
application,
days


Controlled emissions,
mg/1,000 ft
(RSD, %)
TP
12
(16)
PM10
1.2
(10)
PM25
<0.65b
(0.0)


Control efficiency, %
TP
C

PM10
46

PM25
>74

   1 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 control efficiency values from the
   test period should be viewed as conservatively low.
   3 All values were below the detection limit.
   : No emissions reduction was observed.
where
       The dust emissions CE is calculated as follows:
                                  CE = 100 x (eum - ecm)/eum                             Eq. 1


       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

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Environmental Technology Verification Report                 Dust Suppressant Products: DustGard


since application factors, additional variation can arise from changing site conditions. For
example, unplanned road maintenance occurred, as noted in Table 2. In addition, precipitation
before or during a field test could cause variation in both uncontrolled and controlled test results:
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.

2.2    Laboratory Toxicity Test Results
       A sample of DustGard 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 246         Volatile Organics
        EPA Method 405.17      5-day Biochemical Oxygen Demand (BOD) of product
     -   EPA Method 410.48      Chemical Oxygen Demand (COD)
        EPA Method 13119      Toxicity Characteristics Leaching Procedure (TCLP)
        EPA Method 601 OB9     Inorganics/Metals
     -   EPA Method 601 OB9     Title 22 Metals
     -   EPA Method 8260B9     Volatile Organics
        EPA Method 82709      Semivolatile Organics
        EPA Method 8270D9     Semivolatile Organics
        EPA Method 8270D9     Pesticides and Herbicides


•   Effluent Toxicity Testing
        EPA600/4-90/027F10     Acute toxicity: Water fleas lethal concentration (LC50),
                                Fathead minnow LCso, and Mysid shrimp LCso
     -   EPA/600/4-91/00211      Chronic Toxicity:  Water fleas LC50, Fathead minnow LC50,
                                and Mysid shrimp LCso.

       See Appendices A and B for the environmental and chemical test results,
respectively.12'13 RTI also conducted Method 24 tests on the product samples;14 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);15 and the Test/QA Plan for Testing of Dust
Suppressant Products at Fort Leonard Wood, Missouri,  Rev 3 (July 24, 2003).3  The MRI task
leader and QA manager verified that the quality criteria specified in the test plan were effectively
met for the overall test. Section 2.4 of this report discusses deviations from the test plan.
Section 3.4 and A.4 of the test plan present the criteria. Assessments specified in Section 8 of the
GVP were performed.  Reconciliation of the data quality objectives (DQOs) with test results is

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Environmental Technology Verification Report
Dust Suppressant Products: DustGard
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.

         Table 3. DQOs versus Final Control Efficiency Variability for DustGard

TP
PM10
PM25
Number
of test
periods
3
3
3
Final CE,
fractional
0.45
0.75
0.62
90% confidence interval
Lower
limit
0.33
0.69
0.56
Upper
limit
0.57
0.81
0.68
Half
width
0.12
0.059
0.063
DQOa
0.13
0.058
0.087
Is the half-width
interval less than
the DQO (i.e., DQO
met)?
Yes
Nob
Yes
 a Final CE DQO is interpolated from Table 6 of the test/QA plans using the equation:
                    Half width DQO = -0.2295 CE + 0.22972.
 b For PMio, the half width interval is greater than the DQO, i.e., the comparison for PM10 is a borderline failure.
       Based on the overall DQO values, the PM2.5 and TP half width intervals meet the DQO.
The comparison for PMi0 was a "borderline failure" to meet the DQO (i.e., 0.058 as compared to
0.059).  However, this calculation results from one outlier test of five (CKO 215) occurring
during a noted "drizzle" and, understandably, having no weighable catch.
       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; the DQOs were effectively 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
Table 4.  Changes in the application dates are also summarized in the table.
       The 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.

                   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 periods"
Not applicable (NA)
5U, 5C
NA
None, per modified
Test/QA Plan
NA
5U, 5C
NA
NA
5U, 5C

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Environmental Technology Verification Report                  Dust Suppressant Products: DustGard
Project activities
Planned date
Actual date
Test periods"
 a 5U means five uncontrolled replicate measurements; 5C means five controlled replicate measurements.

       The test/QA plan stated that the CE "will be determined relative to its decay over time
and with traffic." Because the vendor chose to reapply the dust suppressant 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 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.
       The test plan 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.  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 are described in Section
3.1.2.
       Deviations during the individual test periods are discussed in the following paragraphs.
       October 2002 Test Period. 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, 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 series of tests in October 2002.
       January 2003 Test Period.  As noted above, persistently unfavorable winter weather
during January and February 2003 forced the abandonment of the second quarterly test.
       May 2003 Test Period. 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 PMio 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

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Environmental Technology Verification Report                 Dust Suppressant Products: DustGard


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. 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.

3.0   Test Conditions

3.1    General Test Site Conditions
       The test/QA plan documents the site and road sections used during dust suppressant
testing. The host facility for the field test program 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. Test
sections A, B, C, and D are located on Road PA, while test section E is located along Road P.
DustGard was applied to test section E.  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.  Figure  1 shows the test locations at FLW.3

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Environmental Technology Verification Report
Dust Suppressant Products: DustGard

                             Figure 1. Test locations at FLW

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Environmental Technology Verification Report
Dust Suppressant Products: DustGard
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 DustGard 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 and pickup passes per day.
3.1.2   Area Climatic Conditions
       Table 5 presents a weekly weather summary over the entire 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.)   A summary of the precipitation for all the test periods
is shown in Table 6.

                           Table 5. 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)

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Environmental Technology Verification Report
Dust Suppressant Products: DustGard
                                    Table 5.  (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
1 1/03/02
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
06/22/03
06/29/03
07/06/03
07/13/03
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)
32 (90)
34 (94)
34 (93)
36 (96)
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)
13(56)
19(66)
17(63)
21 (69)
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)
0.68 (0.27)
2.7(1.1)
2.1 (0.83)
1.7(0.66)
0.051 (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)
2.6(1.0)
0(0)
1.2(0.46)
3.9(1.5)
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)
0(0)
0(0)
0(0)
0(0)
                                                                          (continued)
                                              10

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Environmental Technology Verification Report
Dust Suppressant Products: DustGard
                                  Table 5. (continued)
                                        Site weather
Week
beginning
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
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
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
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)
              Table 6.  Summary of Precipitation for all Test Periods at FLW

                                                          Weekly precipitation
                             Parameter                         range, cm
Precipitation during test week
Precipitation during week before testing
Precipitation between application and testing, total
0.2-3.7
0.58-3.2
17-39
3.1.3   Background Particulate Concentration
       During the test period, 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 7.
               Table 7.  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
                                           11

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Environmental Technology Verification Report
Dust Suppressant Products: DustGard
       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 mph is only
160 s or 2.7 min.  The conservatively high estimates of background contributions to sampler
catches at FLW are compared to blank filter data in Table 8. 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.

         Table 8. 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.

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.  DustGard is applied as received and requires no mixing with
water for application. The road may be "prewetted" with water if the surface is not already
wetted from antecedent precipitation.  Table 9 presents the application intensity as determined
through use of sampling pans located on a grid each time the product was applied.
                                           12

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Environmental Technology Verification Report
Dust Suppressant Products: DustGard
                              Table 9. Application History
Date
June 7, 2002
October 26, 2002
March 8, 2003
June 13, 2003
Application intensity
Mean,
1/m2 (gal/yd2) a
2.5 (0.54)
2.5 (0.55)
2.4 (0.52)
2.5 (0.56)
Standard deviation,
1/m2 (gal/yd2)
0.91 (0.20)
0.77(0.17)
0.85(0.19)
0.29 (0.06)
Comments
Applied in two passes, centerline of road less
heavily treated than are sides.
Applied in two passes, centerline treatment
slightly less than sides.
Applied in two passes, centerline of road less
heavily treated than are sides.
Applied in three passes, centerline of road
less heavily treated than are sides.
 a The mean is based on the total amount applied to the surface of the road summed over all passes.

       The same driver and truck applied the product each time at FLW. Treatment of the
270-m (900-ft) road segment required approximately 0.5 man-hour, when allowances are made
for placing and collecting the sampling pans. Figure 2 shows application of DustGard product at
FLW.
                sr*
                   Figure 2. Application of DustGard product at FLW
                                           13

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Environmental Technology Verification Report
Dust Suppressant Products: DustGard
3.3    Conditions During Dust Suppressant Test Runs
       Table 10 presents the dates and times when dust suppressant testing was conducted at
FLW, including the length of road measured and meteorological conditions during each test run.
As discussed previously, Table 5 presents the climatic conditions for the week during which the
dust emissions tests were conducted.

                           Table 10. Test Run Parameters
Run
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-30
CKO-31
CKO-32
CKO-33
CKO-34
CKO-2 13
CKO-2 14
CKO-2 15
CKO-23 3
CKO-234
CKO-1017
CKO-1018
CKO-1019
CKO-1020
CKO-1021
Test section
Uncontrolled
Uncontrolled
Uncontrolled
Uncontrolled
Uncontrolled
Uncontrolled
Uncontrolled
Uncontrolled
Uncontrolled
Uncontrolled
Uncontrolled
Uncontrolled
Uncontrolled
Uncontrolled
Uncontrolled
DustGard, E
DustGard, E
DustGard, E
DustGard, E
DustGard, E
DustGard, E
DustGard, E
DustGard, E
DustGard, E
DustGard, E
DustGard, E
DustGard, E
DustGard, E
DustGard, E
DustGard, E
Date
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
5/26/03
5/26/03
10/12/03
10/12/03
10/12/03
10/12/03
10/12/03
Test start
time
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
14:21
14:50
15:12
15:35
15:58
17:05
17:33
18:14
17:37
18:06
13:13
13:33
13:56
14:16
14:39
Total distance,
m(ft)
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)
1,800 (6,000)
1,800 (6,000)
1,800 (6,000)
Temperature,
°C (°F)
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)
20 (68)
20 (68)
20 (68)
20 (68)
20 (68)
26 (78)
23 (74)
21 (70)
26 (78)
23 (74)
22 (72)
25 (77)
24 (76)
25 (77)
26 (78)
Barometric
pressure,
mm Hg
(in. Hg)
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)
747 (29.4)
747 (29.4)
747 (29.4)
747 (29.4)
747 (29.4)
732 (28.8)
732 (28.8)
732 (28.8)
737 (29.0)
734 (28.9)
734 (28.9)
734 (28.9)
732 (28.8)
732 (28.8)
733 (28.8)
                                          14

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Environmental Technology Verification Report
Dust Suppressant Products: DustGard
       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 11 presents the moisture and silt content results.

                           Table 11. Road Surface Properties
Test section
Uncontrolled
DustGard
Date
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
5/26/03
10/12/03
10/12/03
Moisture content, %
0.4
0.63
0.75
1.8
0.01
1.4
1.5
0.62
0.74
0.42
0.20
3.5
1.9
Silt content, %
1.6
1.5
1.7
4.3
1.6
3.0
5.4
1.7
2.0
2.6
1.2
1.2
1.7
             Unexpected road maintenance activity occurred at FLW in September 2002 prior to
             the October 2002 test period.
4.0   References
1.  Code of Federal Regulations, Title 40, Part 50.7, National Primary and Secondary Ambient
    Air Quality Standards for Particulate 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.  MRI. 2005.  Test Report for DustGard, Section E at Fort LeonardWood, Missouri.
    Midwest Research Institute, Kansas City, MO. Report may be obtained from RTI
    International.
5.  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.
6.  U.S. EPA (Environmental  Protection Agency).  2000. Test Method 24, Determination of
    Volatile Matter Content, Water Content, Density, Volume Solids, and Weight Solids of
                                           15

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Environmental Technology Verification Report                Dust Suppressant Products: DustGard


   Surface Coatings. Office of Solid Waste. Washington, DC.  Report may be obtained from
   RTI International.
7.  U.S. EPA (Environmental Protect! on Agency). 2000. Test Method 405.1, Standard
   Operating Procedure for the Analysis of Biochemical Oxygen Demand in Water. Region 5.
   Chicago, IL.
8.  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.)
9.  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.)
10. 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.
11. 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.
12. 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.
13. Tri-State Laboratories, Inc. 2002. Laboratory Analysis Report. Youngstown, Ohio.  July.
14. Peterson, M.  2002. "Laboratory analysis report for dust suppressants." E-mail and
   attachments from M. Peterson, RTI, to D. Franke, RTI.  November 18, 2002.  Report may be
   obtained from RTI International.
15. ETV. 2004. Generic Verification Protocol for Dust Suppression and Soil Stabilization
   Products. RTI International, Research Triangle Park, NC.
                                          16

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Environmental Technology Verification Report                 Dust Suppressant Products: DustGard
                                    Appendix A

                        Environmental Testing Results
       A copy of ABC Laboratories' summary report for aquatic toxicity testing on dust
                   12
suppression products  is retained in the RTI International project files. The results for Dustgard
are summarized below.

Solution Preparation
       Solutions were prepared on a weight-to-volume basis for all compounds.

Test Design
       Where preliminary testing indicated no mortality at concentrations of 1,000 milligram 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. 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.
       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 Fishens 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 (July 18-20, 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.
                                          A-l

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Environmental Technology Verification Report                Dust Suppressant Products: DustGard


47552 Fathead Minnow Acute Tests (July 15-19, 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 96-hour LCso for
survival was > 1,000 mg/L. The NOEC was 1,000 mg/L and the LOEC was > 1,000 mg/L.
47553 Americamysis bahia Acute Tests (July 15-19, 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 96-hour LCso for
survival was > 1,000 mg/L. The NOEC was 1,000 mg/L and the LOEC was > 1,000 mg/L.
47554 Ceriodaphnia dubia Chronic Tests (August 6-13, 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 and all test levels. The 7-day LCso for
survival was >1,000 mg/L. For survival, the NOEC was  1,000 mg/L and the LOEC was >1,000
mg/L.  The 7-day ECso for reproduction was >1,000 mg/L. For reproduction, the NOEC was
1,000 mg/L and the LOEC was >1,000 mg/L.
47555 Fathead Minnow Chronic Tests (August 6-13, 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 3, 3, and 0 percent in the 250,
500,  and 1,000 mg/L test levels, respectively. The 7-day LC50 for survival was > 1,000 mg/L.
For survival, the NOEC was 1,000 mg/L and the LOEC was >1,000 mg/L. The 7-day EC50 for
growth was > 1,000 mg/L.  For growth, the NOEC was 1,000 mg/L and the LOEC was > 1,000
mg/L.
47556 Americamysis bahia Chronic Tests (July 23-30, 2002)
       This test was conducted as a multi-concentration test with levels of control, 250, 500, and
1,000 mg/L.  Mortality was 15 percent in the control.  Mortality was 15, 18, and 30 percent in the
250,  500, and 1,000 mg/L test levels, respectively. The 7-day LCso for survival was >1,000
mg/L.  For survival, the NOEC was 1,000 mg/L and the LOEC was >1,000 mg/L.  The 7-day
EC50 for growth was >1,000 mg/L. For growth, the NOEC was 1,000 mg/L and the LOEC was
>1,000 mg/L. The 7-day EC50 for fecundity was >1,000 mg/L. For fecundity, the NOEC was
1,000 mg/L and the LOEC was > 1,000 mg/L.
                                        A-2

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Environmental Technology Verification Report                Dust Suppressant Products: DustGard
                                  Appendix B

                          Chemical Testing Results
                                                                     13
        Tri-State Laboratories' analysis report of five dust suppression products  is retained in
the RTI International project files. The results for DustGard are included on the pages that
follow.
                                        B-l

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Environmental Technology Verification Report
Dust Suppressant Products: DustGard
                                  Appendix C

                              Method 24 Results
      Table C-l shows the results of the Method 24 analysis conducted by RTI International.14
            Table C-l. Summary of EPA Method 24 Analysis for DustGard
Sample ID
DustGard
ASTM D1475
Density,
g/mL
1.244
ASTM D2369
Total volatiles,
wt%
45.60
ASTM D3792
Water,
wt%
0.00
         NOTE: Each value is the average of two measurements.
                                        B-2

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