ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003)
Test/QA Plan for Testing of Dust Suppressant Products
at Maricopa County, Arizona
EPA Cooperative Agreement No. R 82943401 with RTI
RTI Subcontract No. 1-93U-8281
MRI Project No. 101494
MRI®
INTERNATIONAL
Prepared by:
Midwest Research Institute
425 Volker Boulevard
Kansas City, MO 64110-2299
816-753-7600
816-753-8420 (fax)
Post Office Box 12194
Research Triangle Park, NC 27709-2194
919-541-6072
919-541-6936 (fax)
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003)
Test/QA Plan for Testing of Dust Suppressant Products
at Maricopa County, Arizona
EPA Cooperative Agreement No. CR 826152-01-2 with RTI
Subcontract No. 1-93U-7012
MRI Project No. 101494
Prepared for:
U. S. Environmental Protection Agency
National Risk Management Research Laboratory
Research Triangle Park, NC 27711
APPROVED BY:
MRI Project Manager: Original signed by J.M. Hosenfeld, 10/1/2002
MRI Task QA Manager: Original signed by James Dworak for M.A. Grelinger, 10/1/2002
RTI Project Manager: Original signed by J.R. Farmer, 10/2/2002
RTI Quality Manager: Original signed by R.S. Wright, 10/2/2002
EPA Project Manager: Original signed by J.H. Wasser for T. G. Brna, 10/8/2002
EPA Quality Manager:
Original signed by Paul W. Groff, 10/8/2002
-------
ETV/APCTVC/Maricopa Test/QA Plan Rev 3 (7/24/2003) - Page v
TABLE OF CONTENTS
Title and Approval Sheet iii
List of Figures viii
List of Tables viii
List of Acronyms/Abbreviations ix
Distribution List x
Preface xi
SECTION A: PROJECT MANAGEMENT 1
Al: Project/Task Organization 1
Al.l Management Responsibilities 1
Al. 1.1 EPA Program Manager 3
Al. 1.2 RTI/APCTVC Director and RTI Task Leader 3
Al. 1.3 MRI Proj ect Manager 3
Al.1.4 MRI Test Leader 3
Al. 1.5 MRI Data Reviewer 5
Al.1.6 Facility Contact 5
A1.2 Quality Assurance Responsibilities 5
Al.2.1 EPA Quality Manager 5
Al.2.2 RTI Quality Manager 6
Al .2.3 MRI Task QA Officer 6
A2: Problem Definition/Background 7
A3: Project Description and Schedule 8
A3.1 Proj ect Description 8
A3.2 Test Site Description 8
A3.3 Product Descriptions 8
A3.4 Schedule 8
A4: Quality Objectives and Criteria for Measurement Data 9
A4.1 Performance of the Products (DQO for Dust Suppression) 9
A4.2 Test Conditions 10
A4.3 Associated Environmental Impacts for the Technology 10
A4.4 Associated Resources for the Technology 10
A5: Special Training Requirements/Certification 10
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page vi
A6: Documentation and Records 10
A6.1 Field Test Documentation 11
A6.2 Quality Control Records 11
A6.3 Reports 12
SECTION B: MEASUREMENT/DATA ACQUISITION 13
Bl: Test Design 13
Bl.l Product Application 13
B1.2 Data Design 14
B2: Sampling Methods 14
B2.1 Sampling Locations 14
B2.2 Measurement Methods 15
B2.2.1 Mobile Dust Sampling 18
B2.2.2 Maricopa County Dust Collector Test 22
B2.2.3 Surface Sampling 22
B2.2.4 Ambient and Service Environment Records 23
B2.2.5 Product Application Rates 23
B3: Sample Handling 25
B4: Analytical Methods 26
B5: Quality Control Requirements 27
B6: Instrument/Equipment Testing, Inspection, and Maintenance Requirements 27
B7: Instrument Calibration and Frequency 27
B8: Inspection/Acceptance Requirements for Supplies and Consumables 29
B9: Data Acquisition Requirements 29
BIO: Data Management 29
B10.1 DataFlow 29
B10.1.1 Data Origination from Test Site 29
BIO. 1.2 Data Reduction 32
BIO. 1.3 Outline of the Test Report 32
B10.1.4 Draft Report Preparation 33
B10.1.5 Long-Term Storage 34
-------
ETV/APCTVC/Maricopa Test/QA Plan Rev 3 (7/24/2003) - Page vii
BIO.2 Data Recording 34
B10.3 Data Quality Assurance Checks 34
BIO.4 Data Analysis 34
B10.5 Data Storage and Retrieval 34
SECTION C: ASSESSMENT/OVERSIGHT 35
CI: Assessments and Response Actions 35
Cl.l Project Reviews 35
CI.2 Inspections 35
CI.3 Audits 36
CI.3.1 Technical System Audit 36
CI.3.2 Performance Evaluation Audit 37
CI.3.3 Audit of Data Quality 37
CI.4 Quality Systems Assessments 37
C2: Reports to Management 38
C2.1 Status and Activity Reports 38
C2.2 Corrective Action Reports 38
C2.3 Test and Assessment Reports 39
SECTION D: DATA VALIDATION AND USABILITY 41
D1: Data Review and Validation Requirements 41
D1.1 Mobile Sampler QC Criteria for Quarterly Test Runs 41
D1.2 DQO for CE for 6-month Test 42
D2: Validation Methods 43
D3: Reconciliation with Data Quality Objectives 43
Appendix A. Mobile Sampler Operating Procedures 47
Appendix B. FormMRI-86. Report Review/Approval/Distribution 51
Appendix C. Mobile Sampler QC Criteria and DQO Derivation 55
Appendix D. References 63
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page viii
LIST OF FIGURES
Figure 1. Organizational chart 4
Figure 2. Projected schedule for the dust suppressant test 9
Figure 3. Location of test sites to be used during the field program 15
Figure 4. Hi-vol unit (fitted with PM2 5 cyclone) 19
Figure 5. Cyclone preseparator 19
Figure 6. Suppressant sampling pan 24
Figure 7. Data collection activities 30
Figure 8. Corrective action report 39
LIST OF TABLES
Table 1. Quality Management Documents Applicable to This Test of Dust Suppressant
Products at Maricopa County 2
Table 2. Measurement Methods 16
Table 3. Quality Control Procedures for Sampling Media 28
Table 4. Quality Control Procedures for Sampling Equipment 28
Table 5. Quality Control for Miscellaneous Instrumentation 29
Table 6. Half-Widths of 90 Percent Confidence Intervals for 6-month CEs 42
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page ix
LIST OF ACR
ADQ audit of data quality
AED MRI's Applied Engineering
Division
ANSI American National Standards
Institute
APCTVC Air Pollution Control
Technology Verification Center
(ETV program at RTI)
ASTM American Society for Testing
and Materials
CAR corrective action report
CE control efficiency
cfm cubic feet per minute
cm centimeter(s)
cm2 square centimeter(s)
cmh cubic meter(s) per hour
cms cubic meter(s) per second
DQO data quality objective
EPA U.S. Environmental Protection
Agency
ETV Environmental Technology
Verification (EPA program)
FLW F ort Leonard W ood
ft feet
g gram(s)
g/L gram(s) per liter
gal gallon(s)
gal/yd2 gallon(s) per square yard
GVP generic verification protocol
HAP hazardous air pollutant
hi-vol high-volume
IFR isokinetic flow rate
in.
inch(es)
kg
kilogram(s)
kph
kilometer(s) per hour
L
liter(s)
L/m2
liter(s) per square meter
lb
pound(s)
m
meter(s)
m/s
meter(s) per second
m2
square meter(s)
m3/s
cubic meter(s) per second
mg
milligram(s)
mg/ft
milligram(s) per foot
mm
millimeter(s)
mph
mile(s) per hour
MRI
Midwest Research Institute
NIST
National Institute of Standards
and Technology
PEA
performance evaluation audit
PM
particulate matter
QA
quality assurance
QC
quality control
QMP
quality management plan
QSM
quality system manual
RSD
relative standard deviation
RTI
Research Triangle Institute
SOP
standard operating procedure
TP
total particulate
TSA
technical systems audit
VOC
volatile organic compound
|im
micrometer(s)
-------
ETV/APCTVC/Maricopa Test/QA Plan Rev 3 (7/24/2003) - Page x
DISTRIBUTION LIST
U. S. Environmental Protection Agency Maricopa County. Arizona
Ted Brna Eric Mayer
Paul Groff
Product Manufacturers/Di stributors
Research Triangle Institute
Todd Hawkins, Midwest Industrial Supply, Inc.
Jack Farmer
Deborah Franke Civil Engineering Research Foundation
Robert Wright
C. E. Tatsch Larry Jiang
Andrew Trenholm
Midwest Research Institute
John Hosenfeld
Greg Muleski
Mary Ann Grelinger
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page xi
PREFACE
This test/QA plan was prepared by Midwest Research Institute (MRI) and Research Triangle
Institute (RTI) for the Air Pollution Control Technology Verification Center (APCTVC). The
test/QA plan provides a detailed plan for conducting and reporting results from a test of dust
suppressant products in Maricopa County, Arizona. The plan was reviewed by Maricopa
County, Midwest Industrial Supply, Inc., RTI, MRI, and EPA.
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 1 of 65
SECTION A: PROJECT MANAGEMENT
Al: Project/Task Organization
The U.S. Environmental Protection Agency (EPA) has overall responsibility for the
Environmental Technology Verification (ETV) Program and the Air Pollution Control
Technology Verification Center (APCTVC). Research Triangle Institute (RTI) is EPA's
verification partner in this effort. For this work, Midwest Research Institute (MRI) is the testing
organization for the APCTVC. The APCTVC has selected Maricopa County, Arizona as the site
for this test of the following dust suppressant products.
1. Midwest Industrial Supply, Inc. - EK® 35 (dust suppressant)
2. Midwest Industrial Supply, Inc. - EnviroKleen® C (dust suppressant)
Management and testing of dust suppressants within the APCTVC are performed in accordance
with procedures and protocols defined by a series of quality management documents. The
primary source for the APCTVC quality system is EPA Order 5360.1 A2 (May 2000).1 The
quality system is in compliance with
1. EPA's Requirements for Quality Management Plan Plans (EPA QA/R-2),2
2. EPA's Quality and Management Plan for the overall ETV program (EPA ETV QMP),3
3. MRI's Applied Engineering Division (AED) Quality System Manuals,4
4. RTFs APCTVC QMP,5
5. The Generic Verification Protocol (GVP) for Dust Suppression and Soil Stabilization
Products,6 and
6. This test/QA Plan.
Table 1 summarizes these documents. This test/QA plan is in conformance with EPA
Requirements for Quality Assurance Project Plans (EPA QA/R-5).7
MRI will, for RTI, conduct a field test of dust suppression products at Maricopa County,
Arizona, analyze data, and prepare a report. The various quality assurance (QA) and
management responsibilities are divided between EPA, RTI, and MRI key project personnel as
defined below. The lines of authority between key personnel for this project are shown on the
project organization chart in Figure 1.
Al.l Management Responsibilities
Project management responsibilities are divided among the EPA, RTI, and MRI personnel as
listed in Sections A. 1.1.1 through A. 1.1.6 below.
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 2 of 65
Table 1. Quality Management Documents Applicable to This Test of
Dust Suppressant Products at Maricopa County
Document
Description
EPA Order 5360.1
A2 (May 2000)1
EPA Order 5360.1 A21 includes quality specifications for EPA organizations that
produce or use environmental data. The Agency-wide Quality System is a management
system that provides the necessary elements to plan, implement, document, and assess
the effectiveness of quality assurance (QA) and QA activities applied to environmental
programs conducted by or for EPA. A consistent Agency-wide Quality System provides
the needed management and technical practices to assure that environmental data used to
support Agency decisions are of adequate quality and usability for their intended
purpose.
EPA Requirements
for Quality
Management Plan,
EPA QA/R-22
This document provides the development and content requirements for Quality
Management Plans for organizations that conduct environmental data operations for EPA
through contracts, assistance agreements, and interagency agreements.
EPA ETV QMP3
EPA ETV QMP3 lays out the definitions, procedures, processes, inter-organizational
relationships, and outputs that will assure the quality of both the data and the
programmatic elements of ETV. Part A of the ETV QMP contains the specifications and
guidelines that are applicable to common or routine quality management functions and
activities necessary to support the ETV program. Part B of the ETV QMP contains the
specifications and guidelines that apply to test-specific environmental activities involving
the generation, collection, analysis, evaluation, and reporting of test data. (EPA's
Quality and Management Plan for the Pilot Period (1995-2000), May 1998.)
MRI AED Quality
System Manuals4
There are two Quality System Manuals for Environmental Systems including: Quality
Management Systems, January 24, 2000, Revision 04 and Quality Systems for the
Collection and Evaluation of Environmental Data, August 1, 2000, Revision 04. These
documents describe the quality systems in place for MRI's technical research unit
participating in the APCT program. EED's quality manuals comply with American
National Standards / American Society for Quality Control (ANSI/ASQC) Standard E4-
1994 s The scope of these manuals encompasses performance criteria, requirements, and
procedures for managing the quality of all work conducted by or on behalf of AED.
Therefore, AED's quality manuals apply to all AED staff as well as people who perform
work on behalf of AED, such as staff from other MRI research and administrative units,
and others who contribute to projects managed by AED.
APCTVC QMP5
APCTVC QMP5 describes the quality systems in place for the APCTVC. It was
prepared by RTI and approved by EPA. Among other quality management items, it
defines what must be covered in the GVPs and test/QA plans for technologies
undergoing verification testing.
GVP for Dust
Suppression and
Soil Stabilization
Products6
GVPs are prepared for each type of technology to be verified. These documents describe
the overall procedures to be used for testing a specific technology and define the data
quality objectives (DQO). With input from the Dust Suppressant Product Technical
Panel, RTI and MRI prepared the GVP for Dust Suppression and Soil Stabilization
Products6 jointly with the Environmental Technology Evaluation Center and the
Highway Innovative Technology Evaluation Center. The document was reviewed and
approved by RTI and EPA.
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 3 of 65
Table 1. (continued)
Document
Description
This Test/QA Plan
This test/QA plan describes, in detail, how the testing organization will implement and
meet the requirements of the GVP for Dust Suppression and Soil Stabilization Producti.
The test/QA plan addresses issues such as the test organization's management structure,
test schedule, test documentation, analytical methods, data collection requirements, and
instrument calibration and traceability, and it specifies the QA and quality control (QC)
requirements for obtaining verification data of sufficient quantity and quality to satisfy
the DQO of the GVP.
EPA Requirements
for Quality
Assurance Project
Plans, EPA QA/R-51
This document provides the Quality Assurance Project Plans requirements for
organizations that conduct environmental data operations on behalf of EPA through
contracts, financial assistance agreements, and interagency agreements. It provides
suggestions on preparing, reviewing, and implementing QA Project Plans.
Al.1.1 EPA Program Manager
The EPA Program Manager, Theodore Brna, has overall coordination responsibility for the
APCTVC. He is responsible for obtaining final EPA approval of project test/QA plans and
reports.
Al.1.2 RTI/APCTVC Director and RTI Task Leader
The RTI/APCTVC Director is Jack Farmer. He has overall responsibility for the APCTVC and
technology-specific verification tests. He will assign technology verification task leaders;
oversee verifications; review technical panel makeup; and review GVP and test-specific
documents. These responsibilities are described in greater detail in Section 2 of the APCTVC
QMP.
The RTI Task Leader, Deborah Franke, reports to the RTI/APCTVC Director. The Task Leader
is responsible for any functions delegated to her by the RTI/APCTVC Director.
Al.1.3 MRI Project Manager
The MRI Project Manager for this verification test is John Hosenfeld. He will manage MRI's
conduct of the dust suppressant test, select a test leader, develop staffing requirements, and
propose a budget for the test. After a technical assessment, the MRI Project Manager is
responsible for developing and implementing corrective actions within MRI. These
responsibilities are described in greater detail in Section 1 of MRI's AED QSM. Mr. Hosenfeld
has more than 30 years of experience in environmental regulation and measurements with
research organizations and private industry.
Al.1.4 MRI Test Leader
The MRI Test Leader for this dust suppressant test is Greg Muleski. Dr. Muleski will manage
the field testing and has responsibility for QC and on-site field activities. If test method QC
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 4 of 65
Manufacturers/Distributors
Midwest Industrial Supply, Inc.
Technical Report
Reviewer
Not Specified
Maricopa County Contact
Eric Mayer
Test Leader
G. Muleski
Report Writer and
Data Analyst
Not Specified
Data Reviewer
S. Klamm
Figure 1. Organizational chart.
(Dashed lines indicate organizational independence)
criteria are not met, he has the authority to halt testing until the sampling system is corrected and
proven to meet the QC criteria. As the MRI Test Leader, he will oversee development of this
test/QA plan and any standard operating procedures (SOPs) that are needed and prepare the draft
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 5 of 65
test report. Dr. Muleski is a principal scientist at MRI with more than 20 years of experience in
the field of dust emission measurements.
Al.1.5 MRI Data Reviewer
The MRI Data Reviewer for the test is Scott Klamm. Mr. Klamm will, after the field test, be
responsible for reviewing the field data package for completeness and general data quality. His
function will be to serve as the first line, independent data quality reviewer of the field test data.
Mr. Klamm has more than 10 years of direct experience in air pollutant measurements and
related QA/QC procedures.
Al.1.6 Facility Contact
Eric Mayer will be the primary Maricopa County point of contact. Data provided by Maricopa
County will be passed to the MRI Test Leader.
A1.2 Quality Assurance Responsibilities
QA responsibilities are divided among the EPA, RTI, and MRI personnel as listed below.
Al.2.1 EPA Quality Manager
The EPA Quality Manager for the APCTVC is Paul W. Groff of EPA's Air Pollution Prevention
and Control Division. In general, his responsibilities include:
1. Communicating quality systems requirements, quality procedures, and quality issues to the
EPA Program Manager and the RTI APCTVC Director;
2. Reviewing and approving APCTVC quality systems documents to verify conformance with
the quality provisions of the ETV Program's quality systems documents;
3. Performing technical systems audits (TSAs) and performance evaluation audits (PEAs) of
APCTVC tests, as appropriate; and
4. Providing assistance to APCTVC personnel in resolving QA issues.
The EPA Quality Manager (or his designee) will perform the following specific activities
associated with the tests of dust suppressants at Maricopa County:
1. Review and approve the GVP;
2. Review and approve the test/QA plan and the reports for dust suppressants verified at
Maricopa County;
3. Conduct independent on-site technical and quality assessments of the tests of dust
suppressants at Maricopa County; and
4. Determine whether the results of the tests of dust suppressants at Maricopa County conform
to EPA quality requirements and whether test results attain the DQO.
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 6 of 65
Al.2.2 RTI Quality Manager
The RTI Quality Manager for the APCTVC is Robert S. Wright of RTFs Center for
Environmental Measurements and Quality Assurance. He is responsible for ensuring that all
tests are performed in compliance with the QA requirements of the APCTVC QMP, GVPs, and
test/QA plans. He has resources available to ensure conformance with the requirements and
ensures that all personnel understand the requirements. Following are the general responsibilities
of the RTI Quality Manager:
1. Preparing the APCTVC QMP and assisting the RTI APCTVC Director in the annual review
and revision of this document, as needed;
2. Communicating with test-specific quality managers for specific tests;
3. Reviewing and approving the GVPs, test/QA plans, and any needed SOPs that will be
developed by technology verification test leaders and test-specific quality managers;
4. Overseeing test-specific quality training;
5. Conducting independent technical and quality assessments in cooperation with the EPA
Quality Manager and test-specific quality managers;
6. Reviewing and approving the test results and the QC results from tests;
7. Storing APCTVC documentation and data; and
8. Preparing the QA section of each test report.
The RTI Quality Manager will be assisted by the RTI Task QA Officer, C. E. Tatsch. They will
perform the following specific activities associated with the tests of dust suppressants at
Maricopa County:
1. Review the GVP;
2. Review the test/QA plan, test results, QC results, and the reports for dust suppression
products;
3. Perform independent technical and quality assessments of the test of dust suppression
products at Maricopa County; and
4. Determine whether the results of the tests of dust suppressants at Maricopa County conform
to the APCTVC QMP and the test/QA plan and whether test results attain the DQO.
Al.2.3 MRI Task QA Officer
The MRI Task QA Officer for this test is Mary Ann Grelinger. She will handle the QA activities
directly associated with MRI's data collection and reporting for the dust suppressant test at
Maricopa County. These activities will include:
1. Assist the Test Feader in preparing task-specific test/QA plans and SOPs to ensure that tests
are implemented in conformance with these documents;
2. Conduct internal assessments of equipment calibration, equipment operation, sample
handling, and data collection and reduction through oral communication with the testing team
before the data packet has been prepared;
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 7 of 65
3. Perform internal on-site technical and quality assessments of the test of dust suppression
products at Maricopa County to determine whether the tests of dust suppressants at Maricopa
County are being implemented in accordance with the MRI quality system and the test/QA
plan and prepare a written report of the assessment findings;.
4. Review test results within 30 days after each quarterly test campaign to make an independent
determination whether QC criteria have been met and whether the project is on track to attain
the DQO;
5. After all data has been analyzed, determine whether the tests of dust suppressants at
Maricopa County conform with the MRI quality system and the test/QA plan and whether
test results attain the DQO;
6. Upon completion of the testing and approval of the data packet by the MRI test leader,
conduct an audit of data quality of a minimum of 10 percent of the quantitative data obtained
in the field and laboratory to determine if they meet the specifications of the project and
prepare a written report on the audit findings. Pseudo-random, systematic, and judgmental
methods may be used to select the data to be reviewed;
7. Submit an assessment of test activities to MRI's program management and to RTI; and
8. Review the draft test report and participate in meetings with RTFs and MRI's program
management.
For this project, Ms. Grelinger will report to MRI's QA Unit and will have no direct or indirect
role in the data collection process. Fhe QA Unit is a MRI corporate function that reports to
senior corporate management and is independent of the section and division generating the data.
Ms. Grelinger is a Senior Environmental Scientist/Analyst with more than 20 years experience
with emissions measurement and QA/QC activities. She has performed quality audits, directed
quality reviews of emission inventories, and developed computer procedures to check emission
inventory databases for completeness, consistency, and correctness.
A2: Problem Definition/Background
Fhe objective of the EFV APCFVC is to verify, with high data quality, the performance of air
pollution control technologies. A subset of air pollution control technologies is products used to
control dust emissions from unpaved roads. Control of dust emissions from unpaved roads is of
increasing interest, particularly related to attainment of the ambient particulate matter (PM)
standard. EPA recently issued a new ambient standard for particulate matter that specifies new
air quality levels for particulate matter 2.5 micrometers (|im) or less in aerodynamic diameter
(pm25).
There are many products manufactured and sold to reduce unpaved road dust emissions. Fwo of
these products, manufactured/distributed by one firm, are the subject of this test. Fhe
performance of these products will be assessed within a specified range of applicability as
detailed in Section B1 of this test/QA plan, and reports will be produced. Fhe goal of the test is
to measure the performance of the products relative to uncontrolled sections of road.
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 8 of 65
A3: Project Description and Schedule
A3.1 Project Description
Testing will be performed on two dust suppressant products on a rural, unpaved road in Maricopa
County, Arizona. Test campaigns will be conducted at quarterly intervals over a 6-month period.
Each test campaign will consist of five replicate dust emission measurements of controlled and
uncontrolled road sections. Performance of the products will be determined in terms of dust
control efficiency (CE) relative to uncontrolled roads. The CE will be determined relative to its
decay over time and with traffic. The mobile dust sampler9 will be used to obtain dust CE data
for the products. The tests will gather information and data for evaluating the performance of the
products as applied by the manufacturers/distributors. The critical measurement is the dust
suppression CE. The specific conditions used during the testing will be documented. Table 2, in
Section B2 of this test/QA plan, presents a summary of all measurements that will be made to
either (1) evaluate the performance of the products or (2) document the test conditions.
A3.2 Test Site Description
The test will be conducted on rural, unpaved roads in Maricopa County, Arizona, approximately
50 miles west of Phoenix, near the towns of Buckeye and Wintersburg. The specific test
locations are described in Section B2.1.
A3.3 Product Descriptions
The dust suppressant products to be evaluated during this test are described below.
Midwest Industrial Supply. Inc. - EK® 35: This product is a patent-pending dust control and soil
stabilization agent formulated with continuous acting, long life synthetic fluids and naturally
occurring rosons. It is uniquely developed with optimum environmental sensitivity especially for
air, water, and stormwater criteria.
Midwest Industrial Supply. Inc. - EnviroKleen: This product is a patent-pending dust control
and soil stabilization agent formulated with continuous acting, long life synthetic fluids and dust
control modifiers. It is uniquely developed with optimum environmental sensitivity especially
for air, water, and stormwater criteria.
http://www.midwestind.com/envirokleen/envirobrochpgl .pdf (for EnviroKleen)
A3.4 Schedule
The projected schedule for the dust suppressant test at Maricopa County is defined in Figure 2
and will start in February 2003.
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 9 of 65
A4: Quality Objectives and Criteria for Measurement Data
A4.1 Performance of the Products (DQO for Dust Suppression)
The performance of the dust suppressant products will be assessed using an experiment designed
to achieve the DQO described below. The MRI Test Leader has the specific responsibility for
QA of the on-site field testing and to run a mobile sampler quarterly criteria check as defined in
the GVP. If method QC criteria are not met, he has the authority to halt testing until the
sampling system is corrected and proven to meet the QC criteria. In addition, both the MRI Test
Leader and the MRI Task QA Officer have responsibility to ensure that the tests conform to the
MRI quality system and the test/QA plan. They both will determine independently within
30 days after each test campaign that the test results attain QC criteria and that the project is on
track to meet the DQO. The critical measurement is the CE for the mobile dust sampler.
Product performance is the major determinant of the absolute magnitude of CE; however, CE is
also influenced by climate and road characteristics. Climate may vary throughout the 6-month
test, and both climate and road characteristics may vary with the location of the test site. Neither
of these factors can be controlled to provide standardization of their effects on the measured
product performance. The CE values will be provided; however, their primary value is to
distinguish differences in product performance, e.g., at different times after application. Thus,
the DQO focuses on the variability of the mobile dust sampler measurements, expressed in terms
of CE. The DQO varies with CE and is set at (100-CE)/5, expressed in percent as the half-width
interval for the 90 percent confidence limits. Use of a 90 percent confidence limit was judged
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 10 of 65
appropriate for open-source dust emission measurements that are subject to greater inherent
variability than many environmental measurements. The DQO values are tabulated in Section
D1.2. Compliance with the DQO calculation will be checked by the MRI Test Leader at the end
of the last field test series. The derivation of this DQO is discussed in Section D1.2 and
Appendix C.. There is also a mobile sampler quarterly criteria check defined in Section Dl.l
which will help determine if the project is on track to meet the DQO.
A4.2 Test Conditions
While not critical, accurate measurement of test conditions such as road surface, traffic type and
volume, and ambient conditions are important because the measurements define the conditions of
the test. As specified in Section B2, Maricopa County personnel will obtain some of the
measurements, while others will be supplied by MRI.
A4.3 Associated Environmental Impacts for the Technology
Associated environmental impacts will be measured by analysis of the products using
composition and toxicity tests as specified in Table 2.
A4.4 Associated Resources for the Technology
Resources associated with use of the products are only the products and the equipment use and
labor effort to apply them to the road. These measurements are specified in Table 2.
A5: Special Training Requirements/Certification
The MRI Test Leader has extensive experience (20+ years) in field testing of dust emissions
from roads and other fugitive dust sources. He is familiar with the requirements of all of the test
methods that will be used in the test. The MRI Test Leader will ensure that all persons assigned
to the field crew have appropriate training and are fully capable of performing the tasks assigned
to them. Each field crew member is thoroughly familiar with this test/QA plan, the measurement
equipment, procedures, and methods for their assigned jobs. All field test personnel will receive
the required and appropriate safety training, and a safety briefing will be given to all test team
members by the MRI Test Leader.
A6: Documentation and Records
Requirements for recordkeeping and data management for the overall APCTVC program are
found in Section 3.6 of the APCTVC QMP. All test data, calibration data, certificates of
calibration, assessment reports, and test reports will be retained by MRI's APCTVC project files
for a period of not less than 7 years after the final payment of the assistance agreement as per
Part A, Section 5 .3 of the EPA ETV QMP.
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 11 of 65
A6.1 Field Test Documentation
The MRI Test Leader will oversee the recording of all field activities. The MRI Test Leader
reviews all data sheets and maintains them in an organized file. The required test information is
described in Section B. The MRI Test Leader or his designee also maintains a field notebook
that documents the activities of the field team each day and any deviations from the schedule,
test plan, or any other significant event.
Following the completion of a test run, the test technician will review the data recorded on the
test run data sheets for completeness and accuracy. At the end of the test day, the MRI Test
Leader will collect all data sheets completed during the day and will perform his own review of
the sheets for completeness and accuracy. Of particular interest in this review is the notation of
any significant deviation from planned test operations. The reviewed data will include field test
data sheets, filter log sheets, and traffic logs. The electronic data logger used to record on-site
wind data will be downloaded with the relevant files saved to two separate diskettes. Completed
data forms associated with the tests will be removed from the site at the end of the day for
safekeeping.
At the completion of individual field test campaigns (i.e., upon return to MRI's main
laboratories), the MRI Test Leader will have copied two sets of data sheets and the electronic
files containing the meteorological wind data. The MRI Test Leader will submit one copy of the
data sheets and electronic files to the MRI Data Reviewer. The MRI Data Reviewer will ensure
that all necessary information is available for input to the data analysis computer templates and
review the field data package for completeness and general data quality. Following this review
and confirmation that the appropriate data were collected, the MRI Data Reviewer will pass the
data back to the MRI Test Leader.
The MRI Test Leader will independently oversee input of information to the same computer
templates. The resulting files will be directly compared in a spreadsheet program and
discrepancies noted and resolved. A final data analysis template will be created by the MRI Test
Leader. He will run a mobile sampler quarterly criteria check as defined in the GVP, and with the
MRI Task QA Officer, will determine if the project is on track to meet the DQO. If not,
corrective action will be taken to ensure that the quarterly QC criterion is attained in subsequent
test series. After completing all test campaigns, the data will be analyzed to determine if the
DQO was met. The DQO analysis will be done using a statistical analysis technique, as
discussed in Section 3 of the GVP. The reconciliation of the measurement data with the DQO
will be done as discussed in Section D3 of this test/QA plan.
A6.2 Quality Control Records
After the completion of tests, control test data, sample inventory logs, calibration records, and
certificates of calibration will be stored with the test data in MRI's APCTVC project files.
Calibration records will include such information as equipment being calibrated, date, person
performing the calibration, standards used in the calibration, and raw data related to the
calibration. To the extent practical, calibration records will be kept with the same data records
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 12 of 65
used with the calibrated equipment. For example, balance checks associated with filter weighing
will be recorded in the filter weight book. Air sampler calibration records generated in the field
will be kept with the field data sheets used to record the operation of those samplers. For
equipment that has been calibrated prior to arriving at the field site (e.g., rotameters calibrated by
MRI's instrument services, high-volume transfer standards, or miscellaneous field equipment
such as thermometers and altimeters), the original data form or an exact copy of the original data
form will be maintained in the MRI Test Leader's project file during the testing and then
transferred to MRI's APCTVC project files. Final reports of self-assessments and independent
assessments (i.e., TSA and audits of data quality (ADQ) will be retained in the MRI's APCTVC
project files, and copies of these reports will be included in the data packets that are sent to the
APCTVC for review and retained by the APCTVC. Each report will contain a QA section,
which will describe the extent that test data comply with the DQO.
A6.3 Reports
The content and format for the reports are specified in Section 5 of the GVP. An outline of the
Test Report is shown below in Section BIO. 1.3. Test reports will be prepared by the MRI Test
Leader, will be reviewed by the MRI Project Manager and Task QA Officer, and will be
submitted to the RTI Task Leader for review and approval by the APCTVC.
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 13 of 65
SECTION B: MEASUREMENT/DATA ACQUISITION
Bl: Test Design
This test program is designed to determine the control performance of dust suppressants applied
to unpaved roads. The test approach for dust suppressants is to measure the source emission
strength of both the treated and untreated unpaved road surface. However, there are several
features inherent to open dust sources (as opposed to more traditional stack sources) that must be
addressed in the test design:
1. Unlike stack sources with "end of the pipe" controls, one cannot test simultaneously at the
front and back ends to determine controlled and uncontrolled emission levels. In contrast,
one must either (a) perform uncontrolled testing followed by a separate set of controlled tests
after the suppressant is applied to the same section of road or (b) perform uncontrolled and
controlled tests on separate sections of the test road. In other words, one must always
separate the controlled and uncontrolled tests either spatially or temporally.
2. Next, all unpaved road dust suppression is time-dependent, decaying from roughly complete
control at the time of application to essentially no control after some period of time (ranging
from hours in the case of watering to months for chemical dust suppressants). Thus, no set of
measurements during a single time period can characterize the long-term, average control
performance. The extended period of time necessary to complete the test program as well as
the method used to present the emissions control as a meaningful long-term average must be
considered.
3. The extended period of time in Item 2 is further complicated by the open nature of the
emission source. Unlike stacks, roads are exposed for a long period to the ambient
conditions of precipitation and water erosion from neighboring areas, etc. Furthermore, the
test program may be affected because of human intervention (such as damage to the treated
surface from very heavy or tracked vehicles or vandalism).
The test program described in this plan is designed to address the above issues. Controlled and
uncontrolled tests will be conducted on physically separated road sections. To guard against
variability between different road sections, the test sections are located at nearby sites along the
same road. This approach provides uniformity of both road construction and traffic. Control
efficiency results will be plotted versus time (or cumulative number of vehicle passes). Ambient
conditions and visible effects of human intervention will be monitored and any potential effect
on the results will be assessed.
Bl.l Product Application
The manufacturers/distributors are responsible for applying their products to the assigned test
sections. Manufacturers/distributors have been asked to supply written descriptions of their
applications that discuss items such as: any preparation (grading) of the surface, any dilution of
the product with water, equipment used to apply the product, target application intensity (i.e.,
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 14 of 65
volume of product per unit road surface area), number of application passes, and desired curing
time without vehicle traffic. Manufacturers/distributors must make arrangements directly with
Maricopa County to schedule application of their products. MRI will independently observe and
record all application activities that occur on-site. The manufacturers/distributors and the county
will keep MRI informed of all arrangements and scheduling. Scheduling should minimize any
manufacturer/distributor needing to travel over another's freshly treated surface. The application
method must comply with any Maricopa County requirements. The county will provide road
traffic control during the application.
All steps at the test site in the application of each dust suppressant by the manufacturer/
distributor will be observed. This includes surface preparation, mixing of the suppressant with
water, and final application onto the road surface. A field notebook will be used to record these
activities. Samples will be collected to quantify the volume of material applied to the road
surface and to characterize the spatial distribution of material over the roadway.
B1.2 Data Design
This test is designed to determine the performance of the subject dust suppressant products in
terms of dust CE relative to uncontrolled roads. The CE will be determined relative to its decay
over time and with traffic. Figure 2 shows the test schedule that will be conducted during the
6-month test. During each quarterly test, five replicate measurements will be made at the
uncontrolled test section and at each product's test section. The mobile dust sampling method
will be used at all of the test locations to measure dust emissions.
B2: Sampling Methods
B2.1 Sampling Locations
Figure 3 shows the test site and test sections. All test sections are located on Broadway Road (a
county road) near the towns of Buckeye and Wintersburg in Maricopa County, Arizona. The
sections used for dust suppressant testing will be on portions of the road constructed of shale.
Based on information received from the Maricopa County Department of Transportation, the
road 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. Traffic between 9 a.m. and 4 p.m. is infrequent. To accommodate the needs of different
products, test sections have been established on Broadway Road near 355th Avenue. The
uncontrolled measurements will be conducted on a separate section of Broadway Road as shown
on Figure 3.
-------
ETV/A PCT VCVMaricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 15 of 65
O1 ' 1 1 'lKm 01 ' 1 1 '.5Mi
Figure 3. Location of test sites to be used during the field program.
B2.2 Measurement Methods
Table 2 lists the measurement methods and they are discussed below.
Mobile dust sampling, an airborne dust sampling method, will be used during the test program to
develop CE performance data. Testing of the road surface without product application
(uncontrolled) and also after treatment will be conducted. The performance of road dust controls
will be delineated by particle size: total particulate (TP or PM30), PM10, and PM2 5.
In addition to the airborne dust sampling, a number of additional samples/records that will
provide supplementary information are also discussed below. These include:
1. Samples of the treated and untreated road surface material,
2. Visual evaluation of emissions from controlled and uncontrolled road surfaces,
3. Record of traffic over the treated road surface,
4. General meteorological records for the period from application to the end of testing, and
5. Documentation of the amount of water mixed with the product and product application.
-------
ETV/APCTVC/Maricopa Test/QA Plan Rev 3 (7/24/2003) - Page 16 of 65
Table 2. Measurement Methods
Factor to
be Verified
Parameter to
be Measured
Measurement Method
Frequency
Comment
Performance Factor Parameters
Dust suppressant
control efficiency
Uncontrolled dust
emissions
Mobile dust sampler9
Quarterly (5
replicate test runs)
MRI to conduct tests
for two dust
suppressant products.
Controlled dust
emissions
Associated Parameters
Qualitative
effectiveness of
dust suppression
Dust emission
Maricopa County sampling
device similar to the
Colorado State University -
Dustometer10
Quarterly (3 test
runs)
Maricopa Co. to
conduct tests for two
dust suppressant
products. *
Associated Impacts of Using the Products
Whole effluent
toxicity 40 CFR
Part 136
Acute toxicity of
product
EPA/600/4-90/027F11
•Water fleas LC50
• Fathead minnow LC50
• Mysid shrimp LC50
Once for each
product at start of
test
MRI to conduct
sampling. Analysis
by ABC Labs.
Chronic toxicity of
product
EPA/600/4-91/00212
•Water fleas LC50
• Fathead minnow LC50
• Mysid shrimp LC50
Biochemical
oxygen demand
(BOD) of product
5-day BOD
EPA Method 405.113
Once for each
product at start of
test
MRI to conduct
sampling. Analysis
by Tri-State Labs.
Chemical oxygen
demand (COD)
COD
EPA Method 410.414
Once for each
product at start of
test
MRI to conduct
sampling. Analysis
by Tri-State Labs.
Evaporative VOC
or HAP emissions
from use of
product
Composition of
product
Manufacturer's/
distributor's MSDS sheet
Once for each
product at start of
test
Supplied by vendor
before testing.
VOC content of
product
EPA Method 2415
MRI to conduct
sampling. Analysis
by RTI.
Hazardous waste
impacts
Toxicity of product
Toxicity Characteristics
Leaching Procedure
(TCLP) (EPA
Method 1311)16
• Inorganics/metals, EPA
Method 601 OB
• Semivolatile organics,
EPA Method 8270D
• Volatile organics, EPA
Method 8260B
• Pesticides & herbicides,
EPA Method 8270D
Once for each
product at start of
test
MRI to conduct
sampling. Analysis
by Tri-State Labs.
-------
ETV/APCTVC/Maricopa Test/QA Plan Rev 3 (7/24/2003) - Page 17 of 65
Table 2. Measurement Methods (continued)
Factor to
be Verified
Parameter to
be Measured
Measurement Method
Frequency
Comment
Total product
testing
Chemical
composition of
product
TCLP (EPA
Method 1311)16
• Semivolatile organics,
EPA Method 8270
• Volatile organics, EPA
Method 8260B
• Title 22 Metals, EPA
Method 601 OB
Once for each
product at start of
test
MRI to conduct
sampling. Analysis
by Tri-State Labs.
Polyaromatic
hydrocarbons
using tentatively
identified
compounds (TIC)
Chemical
composition of
product
Semivolatile organics, EPA
Method 827016
Once for each
product at start of
test
MRI to conduct
sampling. Analysis
by Tri-State Labs.
Associated Resource Usage Parameters
Product
application
intensity
Number of test
pans
Recordkeeping
During each
application
MRI to conduct
recordkeeping,
measurements and
calculations.
Test pan tare mass/
final mass
Balance
Test pan area
Measuring tape
Product density
Graduated cylinder and
balance
Product
application
resources
Description of
equipment
Recordkeeping
During each
application
MRI to conduct.
Labor
Test Conditions Documentation Measurements
Method of
application of
product
Amount of water
added to amount of
product
Recordkeeping
During each
application
MRI to conduct
recordkeeping.
How each product
was applied
Untreated soil
properties
Type of soil
USGS17
Once at start of
field testing
program
MRI to collect
samples and
Maricopa Co. to
analyze.*
Road surface
samples
Silt loading
Dry sieving18
Once at start of
field testing
program
Maricopa Co. to
collect samples.
Analysis by MRI.
Moisture content
Weight loss test18,19
General
observation of
road conditions
Visual observation
Not applicable
Monthly or when
on site
Maricopa Co. to
conduct.*
-------
ETV/APCTVC/Maricopa Test/QA Plan Rev 3 (7/24/2003) - Page 18 of 65
Table 2. Measurement Methods (continued)
Factor to
be Verified
Parameter to
be Measured
Measurement Method
Frequency
Comment
Traffic
Vehicle type
Vehicle weight
Number of axles
Vehicle passes
Periodic visual observation
coupled with use of
pneumatic traffic counter
Continuously
Maricopa Co. to
conduct.*
Size of
uncontrolled and
controlled test
sections
Length and width
Measuring device
Once
Maricopa Co. to
conduct.*
Area climatic
conditions
Wind speed and
direction, rainfall,
and ambient
temperature
Local records of climatic
conditions
Continuously
Information obtained
from Arizona DEQ,
see Section B2.2.4.
* Maricopa County will provide all information to MRI for completion of the test reports.
B2.2.1 Mobile Dust Sampling
The objective of the mobile dust sampling system is to produce relative (i.e., control efficiency)
rather than absolute (i.e., mass emitted per vehicle-mile-traveled) emissions information. Also
the emissions source, dust emissions from unpaved roads, has considerable variability at any
time both when controlled and when uncontrolled. Thus, the mobile sampler and its operation
were developed with the idea that precision is more important than accuracy9. Also its operation
should avoid or "even out" potential systematic biases to the extent practical. This objective led
to the physical placement of the sampler with its intake aligned along the truck centerline to
avoid any possibility of bias related to crossroad winds. Other operating procedures were
established to address wind-related issues as follows.
1. The truck travel speed is set well above ambient wind speeds (at the sampler height) so that
plume flow dynamics at the sampler intake are dominated by the vehicle wake rather than
ambient winds.
2. A nozzle is used that matches the sampling intake velocity to the truck travel speed.
3. A test consists of an equal number of multiple trips in both directions along the test road to
"average out" the effect of wind direction and speed.
The mobile system consists of a high-volume (hi-vol) PM10 cyclone combined with a PM2 5
cyclone, as shown in Figure 4. The hi-vol sampler inlet is located approximately 1 meter (m)
[3.3 feet (ft)] above the road surface and 2.5 m (8.2 ft) behind the pickup truck's (closed) tailgate.
The sampler is located above the heaviest portion of the dust plume immediately behind the
vehicle where it samples material that is truly airborne. The same truck, tires, and driver are used
during all sampling runs at a location.
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 19 of 65
Transition Piece
The primary air sampling device is a
standard hi-vol air sampler fitted with a
cyclone preseparator. The cyclone
preseparator is shown in Figure 5. The
cyclone exhibits an effective 50 percent
cutoff diameter (D50) of approximately
10 micrometers (|im) in aerodynamic
diameter when operated at a flow rate of
68 cubic meters per hour (cmh) [40 cubic
feet per minute (cfm)]. Thus, mass
collected on the 20- by 25-centimeter
(cm) [8- by 10-inch (in)] backup filter
represents a PM10 sample.
Three PM size fractions will be sampled:
PM10 on the 20- by 25-cm (8- by 10-in)
filter, PM25 on the 47-millimeter (mm)
(1.9-in) glass fiber filter (URG-2000-
30EH cyclones, fitted with filter holders),
and coarse TP greater than PM10 within
the main body of the cyclone. To avoid
interference by large particles, intakes to
the PM2 5 devices sample a small portion
of the total flow through the hi-vol unit
(Figure 4). To determine the sample
weight of material that collects on the
interior of the cyclone preseparator, the
cyclone is washed with distilled water,
and the wash water is collected in clean
sample jars, which are capped and taped
shut. The entire wash solution is passed
through a Buchner-type funnel holding a
tared glass fiber filter under suction. This
ensures the collection of all suspended material on the filter.
Cyclone Body
Outlet Tube
SIDE VIEW
Figure 4. Hi-vol unit (fitted with PM2 5 cyclone).
Cyclone Preseparator
5"
(12.7 cm)
Filter Holder
Figure 5. Cyclone preseparator.
Determination of the number of passes (or equivalently, the total distance over which the mobile
sampler is operated) is an iterative process. The objective is to determine how to collect
adequate sample mass within each of the three PM size ranges and avoid overloading the
sampler. Secondly, the range of travel distances needs to accommodate a range of source
conditions (i.e., from uncontrolled [0 percent CE] to very high levels of control [greater than
90 percent CE]). Furthermore, to maintain the mobile sampler's principal advantages over other
sampling methods, the travel distance should not be so great as to require cycle times greater
than 1 hour between back-to-back tests.
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 20 of 65
Based on experience, the default number of passes for uncontrolled and controlled surfaces is 6
and 12, respectively. These defaults can be modified in several instances. During the initial
uncontrolled tests, the exposed 20- by 25-cm (8- by 10-in.) filter and the cyclone wash can be
visually examined to determine (a) if adequate or possibly excessive mass has been captured and
(b) whether the number of vehicle passes should be increased or reduced, respectively.
Upon return to the main laboratories, the gravimetric analysis of the exposed and blank filters
provides a more quantitative basis for judgment. It can be computed based on Equation 1:
M(exposed filter) — M(blank filter) ^ ^
STD of M(blank filters)
where:
R
M (exposed filter) =
M (blank filter) =
STD of M (blank filters) =
measure of the level of quantifiable mass needed to
achieve a reliable test
mass collected (exposed filter), milligrams (mg),
mass collected (blank filter), mg, and
standard deviation of M for blank filters determined
from previous experience.
In general, one desires the ratio R to be 2 or more. This goal is more easily achieved for
uncontrolled rather than controlled surfaces. In addition, it is easier to meet the goal for the
coarser PM size ranges (i.e., TP and PM10) than for PM2 5.
Although one can collect more PM2 5 mass by sampling for more passes (i.e., over a longer
cumulative distance), two factors limit this approach. First, extended sampling will also produce
additional mass in the PM10 and TP size ranges and one must guard against overloading either the
cyclone body or the 20- by 25-cm (8- by 10-in.) filter. Overloading in the first case would
overstate the "true" amount of PM10 mass attributable to the road. In the second case, sample
mass could be easily lost from the overloaded filter and thus lead to erroneous results.
Calibration, maintenance, and operation of the hi-vol samplers incorporates the essential features
of EPA's guidance on PM10 ambient air monitoring20 with modifications allowing for the
differences between ambient monitoring and mobile sampling. For example, individual sampler
operating times are much less than the standard 24-hour period. Furthermore, because of the
much higher than ambient concentration levels that will be encountered, the PM10 and PM2 5
sampler inlets are cleaned and the entire sampler inspected between each sampling event rather
than at manufacturer-specified intervals. In addition, because calibration is performed more
frequently, there is no need to incorporate anticipated seasonal variations in calibration of the
device. For that reason, different formats are used to calibrate the transfer standard and the hi-
vol devices for source-testing purposes. Additional details on sampler calibration, maintenance,
and operation are provided in Section B7. Operating procedures for the mobile sampler are
described in Appendix A.
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 21 of 65
The mass of dust collected during a sampling or blank run is calculated using Equation 2:
m = (wp-wt) Eci-2
where:
M = mass collected, mg,
WF = final mass of the filter, mg, and
Wx = tare mass of the filter, mg.
An emissions value is determined by dividing the sample mass by the cumulative length of road
traveled by the mobile sampler using Equation 3:
e = — Eq. 3
m D
where:
em = emission value expressed as milligrams per meter of road traveled by the operating
sampler, milligrams per meter (mg/m),
M = mass, mg, and
D = length of road traveled by the operating sampler, m.
The isokinetic flow ratio (IFR) is the ratio of a directional sampler's intake air speed to the mean
wind speed approaching the sampler. It is given by Equation 4:
IFR = — Eq. 4
aU
where:
Q = volumetric flow rate of the sampler, cubic meters per second (m3/s),
a = sampler intake area, square meters (m2), and
U = vehicle speed, meters per second (m/s).
This ratio is of interest in the sampling of TP, since isokinetic sampling ensures that particles of
all sizes are sampled without bias. Specially designed nozzles are available for the hi-vol
cyclone preseparators to maintain isokinetic (within 20 percent) sampling for wind speeds in the
range of approximately 4.5 to 18 m/s [10 to 40 miles per hour (mph)]. Because the primary
interest in this program is directed to PM10 and PM2 5 emissions, sampling under moderately
nonisokinetic conditions should cause little bias. It is readily recognized that 10 |im
(aerodynamic diameter) and smaller particles have weak inertial characteristics at normal wind
speeds and therefore are relatively unaffected by anisokinesis.
On highly controlled surfaces, background PM concentrations may constitute a significant
fraction of the total mass sampled. For that reason, background PM data will be collected from
the nearest available ambient PM monitor. PM10 and PM2 5 are monitored on a l-day-in-6
schedule at the Palo Verde station in Arlington, Arizona. The site, located at 36248 W. Elliott
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 22 of 65
Road, is within 10 miles of the ETV test sites. Sampling employs reference method dichotomous
samplers. The site is maintained by the Arizona Department of Environmental Quality (DEQ).
Continuous meteorological monitoring for the area is performed at the Allegheny site. This, too,
is approximately 10 miles from the ETV test areas. Data will be obtained on a quarterly basis
through the Arizona DEQ.
B2.2.2 Maricopa County Dust Collector Test
A dust collecting unit mounted on a truck provides qualitative dust rating information on the
relative effectiveness of the products. The dust collector device collects dust generated by the
moving vehicle. The dust collector device consists of a filter box (with coffee filter) and a
vacuum unit located in a truck bed; the sampler intake is located below the vehicle's rear bumper
and samples dust thrown up from one of the rear tires. The vehicle makes one pass at 35 mph
over a 0.5-mile test section. The filter is bagged, identified, and weighed. Three paired test runs
are conducted to provide sufficient data to obtain a statistically significant average dust rating for
the product. Note, that MRI will not provide QA on these data.
B2.2.3 Surface Sampling
Surface samples will be collected from each test section (uncontrolled or controlled) evaluated.
Duplicate samples will be collected. The samples will be analyzed for moisture and silt (i.e.,
fraction passing 200 mesh upon dry sieving). Sample collection and analysis will conform to
EPA guidance in Appendices C.l and C.2, respectively, to AP-42.18 All sampling should be
completed on the same day, with as short a time as practical between the sampling of the first
and last sections.
MRI will coordinate Maricopa County's collection of samples at the time of the first quarterly
test campaign. Roads must be dry to be sampled. If the road is visibly wet in the morning,
sampling should wait until traffic and the sun have dried the surface. The road surface will be
sampled and analyzed by the following procedure:
1. Ensure that the site offers an unobstructed view of traffic and that sampling personnel are
visible to drivers. If the road is heavily traveled, use one person to "spot" and route traffic
safely around another person collecting the surface sample (increment).
2. Using string or other suitable markers, mark a 0.3 m (1 ft) width across the road. (See the
sample specifications given in Item 5 below.) Do not mark the collection area with a chalk
line or in any other method likely to introduce fine material into the sample.
3. With a whisk broom and dustpan, remove the loose surface material from the hard road base.
Do not abrade the base during sweeping. Sweeping should be performed slowly so that fine
surface material is not injected into the air. Collect material only from the portion of the road
over which the wheels and carriages routinely travel (i.e., not from berms or any "mounds"
along the road centerline).
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 23 of 65
4. Periodically deposit the swept material into a clean, labeled container of suitable size (such as
a metal or plastic 19-liter (L) [5-gallon (gal)) bucket] with a sealable polyethylene liner.
Increments may be mixed within this container.
5. For uncontrolled unpaved road surfaces, a gross sample of 5 to 20 kilograms (kg) is desired.
For surfaces treated with chemical dust suppressant, the above goal may not be achieved
unless a very large area is swept. Continue taking additional increments from the controlled
unpaved surface until the minimum sample mass of 200 grams (g) is achieved.
6. Measure and record the area that was sampled. Record necessary information on a data form.
7. Prepare the sample for storage. In general, a minimum of 400 g is required for silt and
moisture analysis. Heavy samples may be split in the field with a riffle-type splitter to
approximately 1000 g prior to shipment. The split sample should be placed in a clean (glass
or plastic) sample jar with a screw-on lid. (If a splitter is not available, store the sample in
multiple jars). Seal the jar lid using electrical tape for storage. If two jars are necessary, there
should be notations "1 of 2 jars" and "2 of 2 jars" placed on the appropriate containers. Jars
should be identified either by directly writing on the jar with a permanent marker or using an
adhesive label. The label should contain sample identification (including test number if the
sample is associated with a particular emission test), date of collection, initials of person
collecting the sample, pertinent dimensions of the area sampled, and the number of sample
splits (if any). Groups of approximately 12 samples are then placed in a container that also
contains a sample inventory (tracking) sheet.
B2.2.4 Ambient and Service Environment Records
The degree of control achieved by an unpaved road dust suppressant depends on many types of
factors. It is important that the test plan make provisions to quantify how the suppressant was
applied and what service environment was experienced during the testing program.
The host facility will supply records on traffic over the test roads from the time that suppressants
are first applied through the end of the test program. In addition, the nearest meteorological
stations will supply ambient meteorological data for the period from product application until
completion of the test program. At a minimum, the records will include daily precipitation,
minimum and maximum temperatures, and wind speed and direction. Locations of the stations
are defined in Section B2.2.1.
B2.2.5 Product Application Rates
Prior to application if water is added to or mixed with the product, the amount of water added
will be documented. Product application rates will be measured by the following procedure:
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 24 of 65
Figure 6. Suppressant sampling pan.
1. Approximately 12 prepared
suppressant spray sampling pans
will be used for each test section
being treated. The bottom of the
pans (Figure 6) will be lined with
an absorbent material (such as
several layers of paper towels
attached with duct tape, glue, etc.).
In addition, the pans should have
duct tape "wings" for nailing to
the surface or should have a "hold-
down" weight (such as a large bolt
or washer). Each pan will be
identified by a unique number or
letter. Pans are tare weighed after
being labeled and with wings or hold-down weights attached.
2. Distribute the sampling pans near the midpoint of the road section to be treated, with more
pans toward the center of the test section than near the ends. Attempt to place pans so that
the spray truck will straddle them. Record the location of each pan on a sketch of the test
section in the field notebook.
3. Instruct the spray truck driver to (a) apply the suppressant to the test section in as normal a
fashion as possible and (b) not attempt to "dodge" the sampling pans. Record spraying start
and stop times. Photograph the application.
4. Once the test section has been treated, retrieve and reweigh the intact sampling pans. Record
weights in the field notebook. Indicate which pans were crushed.
5. Collect a liquid sample in a tared, disposable graduated container. Record the mass of the
container as well as the volume of liquid contained. Pour the liquid onto bare spots left by
the pans on the road. The density of the recovered liquid is determined from a composite of
the product caught in all of the pans, a portion of which is decanted into a graduated cylinder,
using Equation 5:
where:
Y =
Cf =
Ct =
Vf =
r=
C -C
^^t
ve
Eq. 5
density of recovered liquid, g/L,
mass, g, of the graduated cylinder containing recovered liquid,
tare mass, g, of the graduated cylinder, and
volume of liquid, L, in the graduated cylinder.
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 25 of 65
6. Using the density calculated above, determine the application intensity using Equation 6:
P - P
I = io4 * — 1 Eq. 6
ap*r
where:
I =
application intensity for each pan, liters per square meter (L/m2),
Pf =
full pan mass, g,
Pt =
pan tare mass, g,
aP =
top surface area of pan, cm2, and
Y =
density of recovered liquid, grams per liter (g/L).
7. Convert the results to units of gallons per square yard (gal/yd2) or L/m2. Calculate a mean
and standard deviation over all intact pans. Record each value on a sketch of the test site.
Examine if there is any discernible difference between one side of the road to another.
8. Record the application in the field notebook. Include data forms, photos, etc.
B3: Sample Handling
The majority of environmental samples collected during the test program consists of PM
captured on a filter medium. Analysis of these samples will be gravimetric, as described in
Section B4.
To maintain sample integrity, the following procedure will be used. Each hi-vol filter will be
stamped with a unique seven-digit identification number. A file folder will also be stamped with
the identification number and the filter will be placed in the corresponding folder. Other filters
also will be associated with a unique seven-digit identification number, although the number will
be placed on the filter container rather than stamped on the filter itself.
Particulate samples are collected on glass fiber filters (20- by 25-cm [8- by 10-in.]) or on 47-mm
(1.9-in.) glass fiber/quartz filters. Prior to the initial (tare) weighing, the filter media are
equilibrated for 24 hours at constant temperature and humidity in a special weighing room.
During weighing, the balance is checked at frequent intervals with standard American Society for
Testing and Materials (ASTM) Class 1 weights to ensure accuracy. The filters remain in the
same controlled environment for at least 24 hours after which a second analyst reweighs them as
a precision check. A minimum of 10 percent of the filters and collection media used in the field
will serve as blanks to account for the effects of handling. (Wash blanks are obtained by
washing "clean" (unexposed) cyclone preseparators in the field.) The QC guidelines pertaining
to preparation of sample collection media are presented in Section B5.
The hi-vol filters are placed in their folders. Groups of approximately 50 are sealed in heavy-
duty plastic bags and stored in a heavy corrugated cardboard or plastic filing box equipped with a
tight-fitting lid. Unexposed filters are transported to the field in the same truck as the sampling
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 26 of 65
equipment and are then kept in the field laboratory. The 47-mm (1,9-in.) filters are kept in
separate holders, "face up" in groups of approximately 20.
Once they have been used, exposed filters are placed in individual glassine envelopes and then
into numbered file folders. Groups of up to 50 file folders are sealed within heavy-duty plastic
bags and then placed into a heavy-duty cardboard or plastic filing box fitted with a tight-fitting
lid. Exposed 47-mm (1.9-in) filters are returned to their individual holders. All exposed and
unexposed filters are always kept separate to avoid any cross-contamination. When exposed
filters and the associated blanks are returned to the laboratory, they are equilibrated under the
same conditions as the initial weighing. After reweighing, a minimum of 10 percent of each type
are audited to check weighing accuracy.
B4: Analytical Methods
All analytical methods required to determine dust CE for this testing program are gravimetric
methods. The final and tare weights are used to determine the net mass of particulate captured
on filters and other collection media. The tare and final weights of blank filters are used to
account for the systematic effects of filter handling. The determination of surface moisture and
silt contents are also gravimetric in nature and are described in Appendix C.2 of AP-42.18 The
following procedures are followed whenever a sample-related weighing is performed:
1. An accuracy check at the minimum of one level, equal to approximately the tare weight and
actual weight of the sample or standard. Standard weights should be ASTM Class 4 or
better.
2. The acceptance criterion for the balance mass QC will be three times the balance's
repeatability.
3. If the balance calibration does not pass this test at the beginning of the weighing, the balance
should be repaired or another properly calibrated balance should be used. If the balance
calibration does not pass this test at the end of the weighing, the samples or standards should
be reweighed using a balance that can meet these requirements.
4. Prior to weighing filters, the balance will be checked with ASTM Class 1 weights and will be
checked at least once during every 4 hours of the weighing period. The balance checks
should encompass the range of filter weights encountered.
5. ASTM Class 1 weights will be verified on an annual basis in accordance with ANSI/ASTM
E617 requirements.21
Other analytical methods for this testing program are specified in Table 2.
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 27 of 65
B5: Quality Control Requirements
A quantitative QC criterion for the five replicate measures that comprise a test run during the
quarterly tests was set. The estimated criterion is to achieve a relative standard deviation (RSD)
for a test run of 0.334 or less. The RSD is calculated as:
This value is calculated by the MRI Test Leader after each quarterly series of tests. The quarterly
criterion is described in more detail in Section Dl.l
Tables 3, 4, and 5 list the QC procedures for sampling media, sampling equipment, and
miscellaneous instrumentation, respectively, for gravimetric methods used for dust CE. For the
analytical methods used in Table 2, all QC specified by the referenced methods will be followed.
B6: Instrument/Equipment Testing, Inspection, and Maintenance Requirements
This is covered in the calibration and maintenance of sampling and analytical equipment.
B7: Instrument Calibration and Frequency
Calibration and frequency requirements for the balances used in the filter gravimetric analyses
are given in Table 3.
Requirements for hi-vol sampler flow rates rely on the use of secondary and primary flow
standards. The Roots meter is the primary volumetric standard and the BGI orifice is the
secondary standard for calibration of hi-vol sampler flow rates. The Roots meter is calibrated
and traceable to a National Institute of Standards and Technology (NIST) standard by the
manufacturer. As noted in EPA's Quality Assurance Guidance Document 2.77, periodic
recertification is not normally required under clean service conditions unless the meter has been
damaged and must be repaired.20 The BGI orifice is calibrated by MRI against the primary
standard on an annual basis. Before going to the field, the BGI orifice is first checked to assure
that it has not been damaged. In the field, the orifice is used to calibrate the flow rate of each hi-
vol sampler. Table 4 specifies the frequency of calibration and other QC checks regarding air
samplers.
Eq. 7
where:
Xj = ith measurement, and
X = mean of 5 measurements.
Table 5 outlines the QC checks employed for the miscellaneous instrumentation needed.
-------
ETV/APCTVC/Maricopa Test/QA Plan Rev 3 (7/24/2003) - Page 28 of 65
Table 3. Quality Control Procedures for Sampling Media
Activity
QC Check/Requirement
Preparation
Inspect and imprint hi-vol glass fiber or quartz media with identification numbers. Inspect 47-mm filters
and place in appropriate container (such as a polycarbonate petri dish). Place unique identification
numbers on the filter container.
Conditioning
Equilibrate media for 24 hours in clean controlled room with relative humidity (RH) of 35% (variation of
less than ±5% RH) and with temperature of 21 degrees Celsius (°C)[(70 degrees Fahrenheit (°F)] [variation
of less than ±3°C (±5.4 °F)].
Weighing
Weigh hi-vol filters to nearest 0.1 mg. Weigh 47-mm (1.9-in.) filters to nearest 0.01 mg.
Auditing of
filter mass
Independently verify the mass of at least 10% of filters and substrates. Reweigh entire batch if the mass of
any hi-vol filters deviate by more than ±2.0 mg. For tare mass, conduct a 100% audit. Reweigh any hi-vol
filter whose mass deviates by more than ±1.0 mg.
Collection of
field blanks
Conduct at least one complete field blank test for every 1 to 9 emission tests.
Field filter blanks are loaded into sampling devices (which are then uncovered but never activated) and
then retrieved. In all other respects, these blanks are handled in exactly the same manner as all other filters.
Field wash blanks are collected by cleanly washing cyclone preseparators. These samples are then handled
in exactly the same manner as all other wash samples.
Calibration of
balance
Balance to be calibrated once per year by manufacturer's certified representative. Check prior to each use
with ASTM Class 1 weights.
Table 4. Quality Control Procedures for Sampling Equipment
Activity
QC Check/Requirementa
Maintenance
• All samplers
Check motors, brushes, gaskets, timers, and flow measuring devices prior to loading onto the
truck and upon arrival at each site prior to testing. Repair/replace as necessary. Recalibrate
before use.
Clean sampler interior surfaces between individual tests.
Calibration
• Transfer Standard
• Mobile dust sampler
• Rotameters
Orifice calibrated against displaced volume test meter annually.
For 68 cmh (40 cfm) devices, calibrate sampler back plate pressure drop against orifice prior to
use at each site. Recalibrate every 2 weeks. Flow rate should be within ± 10%.
Calibrate through MRI Instrument Services annually.
Operation
• General
Cover sampler inlets prior to and immediately after sampling to prevent static deposition from
active sources.
• PM10 cyclone (mobile
dust sampler)
Match nozzle to captive vehicle travel speed between 40 to 56 kph (25 to 35 mph).
Set sampler flow rate to 68 cmh (40 cfm) at start of individual test.
Activate sampler only during passage over 150-m (500-ft) test section.
• PM2 5 cyclone (mobile
dust sampler)
Sampling rates set manually at start of individual test.
Activate PMj 5 samplers before PM10 sampler and leave on during entire test period.
Deactivate hi-vol device before the PM2 5 sampler.
a "Mean" denotes a 5-minute average.
-------
ETV/APCTVC/Maricopa Test/QA Plan Rev 3 (7/24/2003) - Page 29 of 65
Table 5. Quality Control for Miscellaneous Instrumentation
Instrumentation
QC Check/Requirementa
W atches/ stopwatches
The MRI Test Leader will compare an elapsed time (> 4 hours) recorded by his watch against
the U.S. Naval Observatory master clock. Do not use if more than 3 minutes difference. All
crew members will synchronize watches (to the nearest minute) at the start of each test day.
Field balances (used for
application intensity
determination)
Units calibrated by MRI Instrument Services on annual basis. Check prior to each day's use in
the field with a calibration weight.
a Activities performed prior to going to the field, except as noted.
B8: Inspection/Acceptance Requirements for Supplies and Consumables
The primary supplies and consumables for this field exercise consist of the air filters and
collection media. Prior to stamping and initial weighing (Table 3), each filter is visually
inspected and is discarded for use if any pin-holes, tears, or other damage is found.
B9: Data Acquisition Requirements
No indirect measurements will be made.
BIO: Data Management
B10.1 Data Flow
B10.1.1 Data Origination from Test Site
Data and collection activities for dust emissions are shown in Figure 7. This flow chart includes
all data activities from the initial pretest QA steps to the passing of the data to the MRI Test
Leader.
The data activities include activities and assessments performed by the MRI Task QA Officer
immediately preceding, during, and immediately after the field tests. These will include:
Before tests:
1. Discuss program requirements and data acquisition activities with test team members to
verify that the personnel are aware of test requirements and are trained in proper QA
procedures.
2. Review data acquisition formats (forms, computer file formats) to be used in the test program
and make any recommendations for needed changes.
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 30 of 65
w
0
>
o
<
w
0
£
CL
W
0
>
o
<
0
CO
c
O
w
w
0
0
1-
>
(f)
n
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 31 of 65
Air Sampling
Equipment
Filters
Surface Samples
Figure 7. Data collection activities (continued).
During tests:
1. Communicate with on-site test personnel during first several days of testing to discuss any
problems and resolve any issues that will impact data quality.
2. Communicate with RTI QA staff to discuss any QA issues that they have observed that may
need resolution.
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 32 of 65
3. Conduct an independent, on-site assessment of technical systems that are used for the dust
suppression tests.
After each test campaign:
1. Review field test documentation.
2. Make an independent determination, based on the mobile sampler quarterly criteria check
(and other information), to see if the tests are on track to meet the DQO. The result of this
determination will be reported in the quarterly preliminary test report to the APCTVC.
3. Write short report summarizing QA program and assessing QC data.
B10.1.2 Data Reduction
Section B2 describes the calculations used to determine emission factors. Measurements of dust
suppressant CEs are calculated using Equation 8.
e — e Eq. 8
CE = 100 * — —
^ um
where:
CE = control efficiency, percent,
eum = uncontrolled emission value, mg/m, and
ecm = controlled emission value, mg/m.
The CE values determined by the above equations represent values for specific time and location
conditions. However, because all unpaved road dust suppressants exhibit time-varying control,
the CE values will be plotted against time (or cumulative vehicle passes) since the time of initial
application of the dust suppressants.
B10.1.3 Outline of the Test Report
The final test report for the 6-month verification will be outlined as follows.
1. Summary:
a. APCTVC manufacturer/distributor information,
2. Summary of test program,
3. Results of the test, and
4. Brief QA statement;
5. Introduction;
6. Description and identification of the dust suppressant products;
7. Procedures and methods used in testing;
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 33 of 65
8. Statement of operating range over which the test was conducted;
9. Summary and discussion of results;
10. Results,
11. Deviations from test plan and explanations,
12. Discussion of QA and QA statement, and
13. References;
14. Separate Documentation Report;
15. QA/QC activities and results,
16. Raw test data, and
17. Equipment calibration results.
B10.1.4 Draft Report Preparation
After each quarterly test series, the MRI Data Reviewer will review the data for the test series for
completeness and conduct spot checks. A preliminary test report summarizing the data for the
test series will be drafted by the MRI Test Leader, and a QA review will be conducted by the
MRI Task QA Officer, including the mobile sampler quarterly criteria check to determine if the
tests are on track to meet the DQO. These preliminary test reports will be submitted to the RTI
Task Leader, EPA, and the manufacturer/distributor for review.
At the conclusion of the field sampling effort, a copy of all electronic and paper data will be
made upon return to Kansas City by the MRI Test Leader. The MRI Test Leader will inspect the
data for completeness and make a copy of all data to be reviewed by the MRI Data Reviewer.
The MRI Data Reviewer will review the data packets for completeness and conduct spot checks
for common errors. The common error checks will be based on the Data Reviewer's experience
with dust emission testing.
The MRI Test Leader or designated assistant, under the guidance of the Test Leader, will prepare
the draft test report following the format presented in Section B10.1.3. After the draft test report
is completed by the MRI Test Leader, the report will be first reviewed by the MRI Project
Manager and then by the MRI Task QA Officer. Following all reviews by MRI, the draft test
report will be transferred to the RTI Task Leader for RTFs and product
manufacturer/distributor's reviews. After comments from RTI and the manufacturer/distributor
are addressed, the RTI Task Leader (with assistance and review by the MRI Test Leader) will
revise the draft report and prepare a draft verification statement and submit them for EPA's
review.
After EPA's approval of the report, the verification statement will be signed by an EPA official
and transmitted to RTI for the signature of its official. Verification statements containing
original signatures will be sent to EPA and the product manufacturer/distributor, and one original
will be retained by RTF The reports will also be posted on the APCTVC and EPA web sites.
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 34 of 65
B10.1.5 Long-Term Storage
All test data, calibration data, certificates of calibration, assessment reports, and test reports will
be retained by MRI's APCTVC Program Office for a period of not less than 7 years after the
final payment of the assistance agreement as per Part A, Section 5.3 of the EPA ETV QMP3.
B10.2 Data Recording
Data for this test will be collected electronically and manually. Observations and test run sheets
will be recorded manually in lab notebooks and on data forms developed exclusively for this
project. The printed output will be secured in the lab notebook.
B10.3 Data Quality Assurance Checks
Data QA checks have been discussed in Sections A1.2 and B10.1. Reconciliation with the DQO
is discussed in Section D3.
B10.4 Data Analysis
The data will be analyzed based on the DQO described in Section A4.1. A value of 12 percent is
set, expressed as the half-width interval for the 90 percent confidence limits on CE, for the dust
suppression DQO.
B10.5 Data Storage and Retrieval
After the completion of a test, labeled three-ring binders containing manually recorded
information and data output generated from instrumentation will be stored by MRI's APCTVC
Program Office. After the completion of a test, a computer diskette containing spreadsheet data
files will be stored by MRI's APCTVC Program Office.
All data and reports will be retained by MRI's APCTVC Program Office for a period of not less
than 7 years per Part A, Section 5.3 of the EPA ETV QMP3.
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 35 of 65
SECTION C: ASSESSMENT/OVERSIGHT
The quality of the project and associated data will be assessed within the project by the project
personnel, project manager, and peer reviewers. Management assessment and oversight of the
quality for the project activities will be performed through the review of data, memos, audits, and
reports by the program and department management and independently by the QA officer.
CI: Assessments and Response Actions
The effectiveness of implementing the test/QA plan and associated SOPs for a project will be
assessed through project reviews, inspections during test data collection, audits, and data quality
assessment as described below.
Cl.l Project Reviews
The review of project data and the writing of project reports are the responsibility of the MRI
Test Leader, who also is responsible for conducting the first complete assessment of the project.
Although the project's data will be reviewed by the project personnel and assessed to determine
that the data meet the measurement quality objectives, it is the MRI Test Leader who will assure
that overall the project activities meet the measurement objectives and DQO. The second review
is an independent assessment by a technical peer reviewer. The peer review will be conducted by
a technically competent person who is familiar with the technical aspects of the project but not
involved in the conduct of project activities. The peer reviewer will present to the MRI Test
Leader, MRI QA Task Officer, and project management an accurate and independent appraisal of
the technical aspects of the project. The third review of the project is performed by the MRI
Project Manager, who is responsible for ensuring that the project's activities adhere to the
requirements of the project. The MRI Project Manager's review of the project also will include
an assessment of the overall project operations to ensure that the MRI Test Leader has the
equipment, personnel, and resources to complete the project as required and to deliver data of
known and defensible quality. The final review is that of the MRI Division Director, who is
responsible for assuring that the program management systems are established and functioning as
required by division procedures and corporate policy. The Division Director is the final MRI
reviewer and is responsible for assuring that contractual requirements have been met.
In addition to the MRI reviews, RTI APCTVC and EPA also provide reviews.
C1.2 Inspections
Inspections will be conducted by the MRI Test Leader, MRI Project Manager, or MRI Task QA
Officer. Inspections assess activities that are considered important or critical to key activities of
the project. These critical activities may include, but are not limited to, pre- and post-test
calibrations, the data collection equipment, sample equipment preparation, sample analysis, and
data reduction. Inspections are assessed with respect to the test/QA plan, SOPs, or other
established methods, and are documented in the field records. The results of the inspection are
reported to the MRI Test Leader, MRI Project Manager, and MRI Task QA Officer (whomever is
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 36 of 65
not conducting the inspection). Any deficiencies or problems found during the inspections will
be investigated and the results and responses or corrective actions reported in a Corrective Action
Report (CAR). This report is discussed later in this section.
C1.3 Audits
Independent systematic checks to determine the quality of the data will be performed on the
activities of this project. These checks will consist of self-assessments and independent
assessments of technical systems and the quality system and an audit of data quality as described
below. These assessments will be conducted according to the procedures that are described in
EPA guidance documents for assessments of technical systems and quality systems. In addition,
the internal QC measurements will be used to assess the performance of the analytical
methodology. The combination of these assessments and the evaluation of the internal QC data
allow the assessment of the overall quality of the data for this project.
The MRI Task QA Officer is responsible for ensuring that audits are conducted as required by
the test/QA plan. Audit reports that describe problems and deviations from the procedures are
prepared and distributed through management. Any problems or deviations need to be corrected.
The MRI Test Leader is responsible for evaluating CARs, taking appropriate and timely
corrective actions, and informing the MRI Task QA Officer and MRI Project Manager of the
action taken. The CAR is initiated by the person finding the problem or deviation. The MRI Task
QA Officer is then responsible for ensuring that the corrective action was taken. A summary
report of the findings and corrective actions is prepared and distributed to the MRI Project
Manager and the RTI Quality Manager.
Cl.3.1 Technical System Audit
The TSA will be conducted by the RTI Quality Manager prior to the start of the project data
collection. This audit will evaluate all components of the data gathering and management system
to determine if these systems have been properly designed to meet the QA objectives for this
study. The TSA includes a careful review of the experimental design, the test plan, and
procedures. This review includes personnel qualifications, adequacy and safety of the facilities
and equipment, SOPs, and the data management system.
Prior to the TSA, the MRI Task QA Officer may perform a self-assessment of the technical
system, following the same pattern of reviews. Final reports of MRI self-assessments and
independent assessments, including CARs and followup, will be retained by MRI and will be
included in the data packets that are sent to the APCTVC for review.
The TSA begins with the review of study requirements, procedures, and experimental design to
ensure that they can meet the DQO for the study. During the TSA, the RTI Quality Manager or
designee will inspect the analytical activities and determine they adhere to the SOPs and the
test/QA plan. The RTI Quality Manager or a designee reports any area of nonconformance to the
MRI Project Manager and management through an audit report. The audit report may contain
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 37 of 65
corrective action recommendations. If so, follow-up inspections may be required and should be
performed to ensure corrective actions are taken.
Cl.3.2 Performance Evaluation Audit
A PEA is designed to check the operation of a system that has specific operational parameters.
Due to the nature of the task and the type of sampling, the evaluation of performance will be
based on verifying that the sampling equipment is operating within the manufacturer's
parameters.
The performance of the analytical methods will be assessed using the internal QC requirements
as specified in the SOPs for the evaluation.
Cl.3.3 Audit of Data Quality
The ADQ is a critical evaluation of the measurement, processing, and evaluation steps to
determine if systematic errors have been introduced. During the audit, the MRI Task QA
Officer, or a designee, will randomly select at least 10 percent of the data to be followed through
the analysis and processing of the data. The purpose of the audit is to verify that the data-
handling system is correct and to assess the quality of the data generated.
The ADQ is not an evaluation of the reliability of the data presentation. The review of the data
presentation is the responsibility of the MRI Test Leader and the peer reviewer.
CI.4 Quality Systems Assessments
The RTI Quality Manager may conduct an assessment of a quality system, which is a systematic,
independent, and documented examination to determine one or more of the following
characteristics:
1. Does the organization have a documented and fully implemented quality system?
2. Does the quality system comply with external quality requirements?
3. Do the activities that are being performed by the organization comply with its quality system
documentation, particularly in its QMP?
4. Are the quality procedures implemented properly and effectively?
5. Does the quality system support environmental decision making with data that are sufficient
in quantity and quality appropriate for their intended purpose?
An assessment is designed to provide objective feedback about the quality system. It evaluates
and documents the management policies and procedures that are used to plan, implement, assess,
and correct the technical activities that collect or use environmental data. It includes quality
system document review, file examination and review, and interviews of managers and staff
responsible for environmental data operations.
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 38 of 65
C2: Reports to Management
During the different activities on this project, the reporting of information to management is
critical. To insure the complete transfer of information to all parties involved in this project, a
system of reports to management is described below.
C2.1 Status and Activity Reports
The status of the project will be reported to the MRI Test Leader on a regular basis by the project
staff. Project status will be reported by the MRI Test Leader to the MRI Project Manager and
MRI Task QA Officer at regularly scheduled meetings and monthly by the MRI Project Manager
to the RTI Project Manager in the project status report.
Any problems found during the analytical process requiring corrective action will be reported
immediately by the project staff to the MRI Test Leader, MRI Project Manager, and the MRI
Task QA Officer through the investigation and CAR. The results of the inspection by the MRI
Test Leader or Project Manager will be documented in the project files and reported to the MRI
Task QA Officer. Inspections conducted by the MRI Task QA Officer will be reported to the
MRI Test Leader and Project Manager in the same manner as other audits.
The results of TSAs, inspections, PEAs, and data audits conducted by the MRI Task QA Officer
will be written and routed to the MRI Project Manager for review, comments, and corrective
action. The results of PEAs will be documented in the project records. The PEAs, issues, and
corrective action responses covered by the audit reports will be reviewed and approved by the
MRI Test Leader, Project Manager, and Division Director. The results of all assessments, audits,
inspections, and corrective actions for the task will be summarized and included in a quality
assurance/quality assessment section in the final report.
C2.2 Corrective Action Reports
A corrective action is the process that occurs when the result of an audit or QC measurement is
shown to be unsatisfactory or deficient, as defined by the DQO or by the measurement objectives
for each task. The corrective action process involves the MRI Test Leader, the MRI Project
Manager, and the MRI Task QA Officer. In cases involving the analytical process, the corrective
action will also involve the analyst. A written CAR (Figure 8) is required on all corrective
actions.
The MRI Test Leader is responsible for and is authorized to implement any procedures to
prevent the recurrence of problems.
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 39 of 65
Project No.:
Date:
Corrective Action Report
Project Title/Description:
Description of Problem:
Originator: Date:
Investigation and Results:
Investigator: Date:
Corrective Action Taken:
Originator: Date:
Reviewer/Approval: Date:
cc: Project Leader, Program Manager, Division Manager, QA Unit
Figure 8. Corrective action report.
C2.3 Test and Assessment Reports
The MRI Test Leader will notify the RTI Project Manager, RTI Task Leader, and RTI Quality
Manager when the field test is being conducted. MRI will draft the test reports and submit them
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 40 of 65
to RTI. The RTI Project Manager will submit the draft test reports to the RTI Quality Manager.
After technical assessments, the RTI Quality Manager will submit the assessment report to the
RTI Project Manager. The RTI Project Manager will submit test reports to the EPA Project
Manager and will submit assessment reports to the EPA Project Manager for informational
purposes. Final reports of MRI self-assessments and independent assessments will be retained
by MRI and will be included in the data packets that are sent to RTI APCTVC for review.
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 41 of 65
SECTION D: DATA VALIDATION AND USABILITY
Dl: Data Review and Validation Requirements
Data review and validation will primarily occur at the following stages:
1. On site following each test run - by the Test Technician,
2. On site following completion of each series of tests in the field - by the MRI Test Leader,
3. After each series of tests - the mobile sampler quarterly criteria check by the MRI Test
Leader,
4. After each series of tests - by the MRI Data Reviewer and MRI Task QA Officer,
5. Following the completion of all test runs - mobile sampler DQO check by the MRI Test
Leader and MRI Task QA Officer,
6. Before writing the draft test report - by the MRI Data Reviewer, and
7. During QA review of the draft report and ADQ - by the MRI Task QA Officer and MRI
Project Manager.
The criteria used to review and validate the data will be the QA/QC criteria specified in each test
method (see Table 2) and the DQO analysis of the dust suppression test data (see Section A4.1).
Those individuals responsible for on-site data review and validation are noted in Figure 7,
Section BIO, and above. The MRI Test Leader is responsible for verification of data with all
written procedures. Finally the MRI Task QA Officer reviews and validates the data and the
draft report using the test/QA plan, test methods, general SOPs, and project-specific SOPs.
The data review and data audit will be conducted in accordance with MRI's SOP 0208 -
"Review and Audit of Data and Study Reports." The procedures that will be followed are
summarized in Sections CI.3.3 and C2 of this test/QA plan. Form MRI-86 ("blue sheet") will be
used for Report review/approval/distribution within MRI. A copy of Form MRI-86 is included
as Appendix B.
Dl.l Mobile Sampler QC Criteria for Quarterly Test Runs
A preliminary study was conducted at Fort Leonard Wood (FLW), MO from October 2001 to
January 2002 using the mobile sampler to measure the CE of dust suppressants.22 The variance
of CE was approximated in terms of the component means, variances, and sample sizes. The
means and standard deviations of the replicate measurements were then computed and plotted.
These plots clearly showed that standard deviations increased as the (mean) levels increased. It
appeared that a relationship of the form s=Bx between the standard deviation (s) and the mean
(x) would adequately approximate the variance of the measurements [i.e., a model that assumes
that the relative standard deviation (RSD)=s/x is constant, and equal to B], The geometric mean
of the RSDs was used to estimate B. Estimates of B from the preliminary study were 0.163 for
PM10, 0.176 for PM2 5, and 0.150 for TP.
If the estimated B is taken to be the true RSD value for the planned study and if a sample size of
5 is used, then the observed RSDs would be expected, with approximately 95 percent confidence,
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 42 of 65
to fall between 0.35B and 1.67B. (This is based on a chi-square distribution with four degrees of
freedom.) This analysis provides an estimate for a quantitative QC criterion for the five replicate
measurements that comprise a test run during the quarterly tests. The estimated criterion is to
achieve a RSD for a test run of 0.334 or less. This is based on a value of B = 0.2. This value
was chosen a little above the values of B obtained in the preliminary study because there are no
data to assess how test site conditions from test to test may affect the value of B. The above
analysis shows that, with 95 percent confidence, actual RSDs are estimated to be between 0.35B
and 1.67B; thus, the criterion is set at less than the upper end (RSD of 0.334). The RSD is
calculated using Equation 7 as given in Section B5.
RSD
1
Xx,2 -5X:
7=1
'X
Eq. 7
where:
X; = ith measurement, and
X = mean of 5 measurements.
This value will be calculated by the MRI Test Leader after each quarterly series of tests.
Derivation of this quarterly QC criterion is described in Appendix C.
D1.2 DQO for CE for 6-month Test
Consistent with the approach and assumptions described in Section D1.1, half widths of
confidence intervals for 6-month CEs should be approximately 0.707 (or V1/2 ) times as long as
those expected for quarterly CEs. This results from assuming that the quarterly CEs are the same
for all quarters (simplification of Equation 8 in the GVP). This rationale provides an appropriate
approach to defining a DQO for a 6-month CE, since no prior data exist as a basis for such a
DQO.
Using the above assumptions, and assuming that the quarterly RSD criteria are met for each set
of 5 replicate measurements, that B = 0.2, and that RSD/B = 1.67, a DQO for the 6-month CE
measurement was set consistent with the quarterly criteria. The DQO is expressed in percent as
the half-width interval for the 90 percent confidence limits. The values vary with CE and are set
at (100-CE)/5. For example, as shown in Table 6, the DQO is 1 percent when the CE is 95
percent or 12 percent when the CE is 40 percent.
Table 6. Half-Widths of 90 Percent Confidence Intervals for 6-month CEs
CE = 95%
CE = 90%
CE = 80%
CE = 70%
CE = 60%
CE = 50%
CE = 40%
1.4
2.8
5.6
7.8
11
14
17
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 43 of 65
D2: Validation Methods
The process for validating and verifying data has been described in Sections B10.1 and D1. If
the test is found to not meet the DQO, the process described in Section A4.1 will be followed.
Derivation of the DQO is described in Appendix C.
D3: Reconciliation with Data Quality Objectives
The DQO was defined in the GVP, as is the mobile sampler quarterly criteria check. After each
test campaign, the MRI Task Leader and the MRI Task QA Officer will determine if the tests are
on track to attain the DQO, and if not, what corrective actions are needed. They will report this to
the APCTVC.
The DQO reconciliation step is an integral part of the test program and will be done after the
field tests. Attainment of the DQO is confirmed by statistically analyzing the test data as
described in the GVP. The statistical analysis to determine the DQO will be done by a
statistician after the conclusion of all scheduled test runs. The statistical analysis will be done
using a statistical analysis tool. The MRI Task QA Officer will reconcile the results of this
analysis with the DQO.
The reconciliation process starts with the review of the DQO and the sampling design to assure
that the sampling design and data collection documentation are consistent with those needed for
the DQO. When the preliminary data are collected, the data will be reviewed to ensure that the
data are consistent with what was expected and to identify patterns, relationships, and potential
anomalies. The data will be summarized and analyzed using appropriate statistical procedures to
identify the key assumptions. The assumptions will be evaluated and verified with all deviations
from procedures assessed as to their impact on the data quality and the DQO. Finally, the quality
of the data will be assessed in terms as they relate to the measurement objectives and the DQO.
Should the test be conducted and the DQO not be met due to excessive data variability, RTI and
MRI will present the data to the product manufacturer/distributor after the last field test day and
discuss the relative merit of various options. The two primary options will be either to continue
the test to obtain additional data, with resulting increases in cost to all parties, or to terminate the
test and report the data obtained. The RTI Project Manager will make the final decision after
consultation with MRI and the product manufacturer/distributor.
Results from testing of the dust suppression products will be presented in a report as described in
Section BIO. 1.3.
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 44 of 65
Review/Revision History
Date
Pages
Revision
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 45 of 65
Appendix A.
Mobile Sampler Operating Procedures
-------
ETV/APCTVC/Maricopa Test/QA Plan Rev 3 (7/24/2003) - Page 46 of 65
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 47 of 65
Appendix A. Mobile Sampler Operating Procedures
1. Before the initial use of a truck with the mobile sampler, check the vehicle's speedometer in
the following manner
a. Lay out a test section at least 150 ft long along a straight, flat section of road.
b. Drive the truck over the test section, maintaining a steady "target" speed (25 or 35 mph as
indicated by the speedometer) over the test section.
c. Make at least 20 passes (10 in each direction).
d. Have a second person use a stopwatch to accumulate the total time on the test section for
the 20 (or more) passes.
e. Calculate the mean measured speed in mph as follows.
(No. of passes * Test section length) / (Total time)
f. Calculate the ratio of the indicated speed / measured speed. This ratio, when multiplied
by a "target speed" provides the speedometer indicated speed for test runs using the
subject truck.
Based on the ability to read a speedometer and hold a truck speed steady, this procedure is
expected to provide an accuracy for truck speed within ±10 percent.
2. With the vehicle parked, load the 8- by 10-in. filter cartridge and 47-mm filter holder onto the
mobile sampler.
3. Fit the high-volume cyclone intake with the appropriate nozzlea, matched to the target travel
speed (25 or 35 mph).
4. Start the vacuum pump and allow it run for at least 1 minute. Record the start time (to the
nearest minute, using local time).
5. Set the flow through the URG at 16.7 Lpm using a rotameter. Record the time that the flow
rate is set.
6. Start the high-volume sampler and allow it to run at least 1 minute. Record the start time and
note the back-plate pressure.
7. Use the on-site calibration results to determine the back-plate pressure that corresponds to 40
cfm.
8. Set the flow through the high-volume sampler by adjusting the autotransformer ("variac")
until the back-plate pressure reading is slightly above the pressure determined in Step 6.
Recheck the rotameter and reset to 16.7 Lpm, if necessary.
9. Record the pressure reading and turn off the high-volume sampler. Record the stop time.
10. Check all hoses, electrical cords, and mechanical fastenings for the measurement devices
prior to starting the vehicle.
11. Driving slowly, position the truck test approximately 150 ft away from the test section.
Slowly accelerate to the target travel speed using the speedometer indicated speed calculated
in Step 1.
a Four sizes of nozzles ("A" through "D" ) are available to maintain isokinecity within ± 20%. The "C'and "D"
nozzles provide intake speeds of 26.3 and 35.1 mph, respectively, when the sampler is operated at 40 cfm. Thus,
use the "C" nozzle for a target speed of 25 mph and the "D" nozzle for a target of 35 mph.
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 48 of 65
12. As the truck passes the start of the 500-ft test section, activate the high-volume sampler using
the autotransformer (check the red light to ensure that generator circuit breaker has not
tripped).
13. As the truck passes the end of the 500-ft test section, deactivate the high-volume sampler
using the autotransformer.
14. Slow the truck gently and reposition for another trip over test section (in opposite direction).
15. Repeat Steps 11 through 14 until 6 to 24 passes (depending upon the level of control) have
been completed.
16. Stop the truck and briefly reactivate the high-volume sampler to read the back-plate pressure
and rotameter reading. Record values and time of readings.
17. Recover the filter cartridge and holder.
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 49 of 65
Appendix B
Form MRI-86. Report Review/Approval/Distribution
-------
ETV/APCTVC/Maricopa Test/QA Plan Rev 3 (7/24/2003) - Page 50 of 65
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 51 of 65
Report review/approval/distribution
Project No. (task and subtasks):
Form MRI-86 starts in the technical department office and is circulated with the document through production and review. The
completed original form is attached to the Archives copy and sent to the Records Center by the Word Processing Center. The
Records Center sends a copy of the completed form to Contracts for deliverable tracking. Form MRI-86 is used for letter
reports, monthly reports, interim reports, QA plans, test plans, draft and final reports, and other internally generated project
documents. All portions must be filled in. If an information item is not needed, cross it out, initial, and date it. Documents will
not be mailed until this form is properly completed. THIS FORM SHOULD BE PRINTED ON BLUE PAPER.
Date: Client due date: MRI shipping date:
Charge work to (if different from project number above):
Author: Dept: Client name:
Report title:
Number of client copies (specify if different for each volume):
Shipping via: ~ FedEx ~ UPS ~ First-class mail D Express mail D Courier ~ Fax
Security: ~ None
Notes:
~ Neither/Nor ~ Nongovt Confidential ~ Classified ~ CBI
D Electronically
~ Controlled Document
Review routing
Printed name
Review due date | Signature
Date reviewed
Technical reviewers
Project Leader/Program Manager
Section Manager
Quality Assurance/Editorial
Approval routing
Department Director
Other
Internal distribution of document No. of internal copies (specify if different for each volume): :
1 Department Director, 1 Records Center (unbound), and those shown below. (Include, as needed, authors
and appropriate QA staff.)
Name No. of copies
Name No. of copies
Job processed by: ~ Word Processing Center ~ Other (name): Date shipped:
-------
ETV/APCTVC/Maricopa Test/QA Plan Rev 3 (7/24/2003) - Page 52 of 65
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 53 of 65
Appendix C
Mobile Sampler QC Criteria and DQO Derivation
-------
ETV/APCTVC/Maricopa Test/QA Plan Rev 3 (7/24/2003) - Page 54 of 65
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 55 of 65
Appendix C. Mobile Sampler QC Criteria and DQO Derivation
Calculation of Confidence Intervals for Quarterly Control Efficiencies
A preliminary study was conducted at FLW from October 2001 to January 2002 using the
mobile sampler to measure the control efficiency of dust suppressants22. The calculation of
confidence intervals for an efficiency, CEt, was accomplished by first deriving an algebraic
expression that approximates the variance of CEt in terms of the component means, variances,
and sample sizes:
Var[CEt ]=Var[l-Xt/X0 ]=Var[Xt/X0 ]
1 Var[Xt]+^kVar[X0\
*1
(CI)
=(1 -CEtf [(RSJ); !nt )+(RSD2 In0)]
=^k[(RSD?/nt)+(RSD20/n0)]
^0
where:
Xt denotes the mean of //, post-treatment observations,
-^o denotes the mean of n0 pre-treatment (baseline) observations, and
RSDt and RSD0 denote the relative standard deviations for the post-treatment and baseline
observations, respectively.
In the preliminary study, the sample sizes were 2 for the post-treatment observations and 3 for
the baseline observations. The above derivation makes use of a Taylor series approximation.
The means and standard deviations of the duplicate measurements (and the time 0 triplicates)
were then computed and plotted. These plots clearly showed that standard deviations increased
as the (mean) levels increased. It appeared that a relationship of the form s=Bx between the
standard deviation (s) and the mean x would adequately approximate the variance of the
measurements (i.e., a model that assumes that the RSD=s/x is constant and equal to B).
Substitution of this model into the above variance expression for CEt leads to
Var[CEt]~(l-CEt)2 B7
nt n0
(C2)
where B is the estimate of B.
In the previous study, three different estimates of B were considered: the geometric mean of
the relative standard deviations (RSDs), the median of the RSDs, and the mean of the RSDs. For
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 56 of 65
estimating B, cases in which a duplicate had a zero measurement (either one or both) were not
used. The estimate based on the geometric mean was recommended. (It is less sensitive to large
RSDs than the third method and can be derived from the least squares estimate for log(B) in the
model log(s)= log(Bx); this log-scale model has appeal because it should have fairly
homogeneous error structure - since standard deviations of standard deviations tend to increase
proportionally with their magnitude.) Estimates of B from the prior study at FLW were 0.163 for
PM10, 0.176 for PM2 5, and 0.150 for TP.
Forming a confidence interval for a quarterly CE in future verification tests can be
accomplished in two ways. The first way assumes:
1. a model like that used in the prior study (i.e., s=Bx) will be used to produce an estimate of B,
and
2. the estimate of B is used, along with the CEt value, to produce the estimated variance of CEt
via equation C2.
Then a 90% confidence interval would be formed via
where tk 0 95 is the upper 95th percentile of the t distribution with k degrees of freedom. The
degrees of freedom, k, can be taken to be equal to the number of RSDs upon which the estimated
B is based. Hence, this first approach will be useful only after a substantial amount of testing has
been performed. In this context, the subscripts t and 0 in the above equations now represent
something different than they did in the preliminary study. In that study, as noted above, the 0
subscript represented a baseline, pre-treatment condition for a given road segment and t
represented that same segment after treatment (of a given type); in the planned study, the 0
subscript identifies measurements for an untreated segment at a given time and the t subscript
identifies measurements on a similar segment at that same time that was treated with product t.
The second way of forming a confidence interval for a CE does not rely on the variance
versus mean model; rather it uses only the data from nt + n() observations used in calculating the
CEt. In this case, Equation CI [last part] is used to compute the variance of the control efficiency
and the 90% confidence interval is determined as:
where tK 0 95 is the upper 95th percentile of the t distribution with K degrees of freedom. The
degrees of freedom, K, in this case, is determined (after rounding the result down to the nearest
integer) by Satterthwaite's formula:
CEt±tk 0 95 ^Var[CEt]
(C3)
CEt±tK 0 95^Var[CEt]
(C4)
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 57 of 65
\ ii \j \j /
{RSDf lntf | (.RSDp/n0f
(RSI)1; / n, + RSl)l / n(] f
(C5)
n— 1
This approach for forming confidence intervals can be implemented early in the testing. The
value of K will tend to be maximized if the RSDs and the ns are the same; in that case,
K = nt +n0 - 2 .
The formation of confidence intervals in either of the above two ways assumes that the
estimated quarterly efficiencies are approximately normally distributed. The former way
(Equation C3) also relies on the accuracy of the variance-versus-mean relationship. The former
way also has the advantage that the estimation of the B can make use of data from all of the
different treatments used in a study. For example, if five products are tested at each of two
quarters, there will be 6x2 standard deviations that can be used in the modeling.
Anticipated Half-Widths of Confidence Intervals for Quarterly Control Efficiencies
The values of B obtained in the prior study can be used to provide some insight into the
expected widths of the confidence intervals. If the estimated B is taken to be the true RSD value
for the planned study and if a sample size of five is used, then the observed RSDs would be
expected, with approximately 95% confidence, to fall between 0.35B and 1.67B. (This is based
on a chi-square distribution with four degrees of freedom.)
Table CI provides half-widths of 90% confidence intervals for CE generated for four
different B values ranging from 0.15 to 0.30 and for seven different efficiencies ranging from
40% to 95%. Values of the RSDs appearing in Equation CI were allowed to take on various
multiples of B - namely, as shown in Table C2.
These were combined with the four choices for B and the seven efficiency values to produce the
estimated half-widths. Equation CI was used to produce the variance estimate, Equation C5 was
used to determine K, and the half-width was determined as indicated in Equation C4.
QC Criteria for Quarterly Test Runs
The analysis above provides an estimate for a quantitative QC criteria for the five replicate
measurements that comprise a test run during the quarterly tests. The estimated criterion is to
achieve a RSD for a test run of 0.334 or less. This is based on a value of B = 0.2. This value
was chosen a little above the values of B obtained in the preliminary study because there are no
data to assess how test site conditions from test to test may affect the value of B. The above
analysis shows that, with 95% confidence, actual RSDs are estimated to be between 0.35B and
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 58 of 65
Table CI. Half Widths of Confidence Intervals for CE for
Selected Combinations of RSDs and Estimated Efficiencies (%)
Ratio
Half-Widths of 90°/
7o Confidence Intervals for CEs
Smaller
Larger
of
Smaller
Larger
CEt=
CEt=
CEt=
CEt=
CEt=
CEt=
CEt=
B
RSD/B
RSD/B
RSDs
RSD
RSD
95%
90%
80%
70%
60%
50%
40%
0.15
0.35
0.35
1.000
0.053
0.053
0.3
0.6
1.2
1.9
2.5
3.1
3.7
1.00
1.00
1.000
0.150
0.150
0.9
1.8
3.5
5.3
7.1
8.8
10.6
1.67
1.67
1.000
0.251
0.251
1.5
2.9
5.9
8.8
11.8
14.7
17.7
1.00
1.67
1.670
0.150
0.251
1.3
2.5
5.1
7.6
10.1
12.7
15.2
0.35
1.00
2.857
0.053
0.150
0.8
1.5
3.0
4.5
6.1
7.6
9.1
0.35
1.67
4.771
0.053
0.251
1.2
2.4
4.9
7.3
9.8
12.2
14.6
0.20
0.35
0.35
1.000
0.070
0.070
0.4
0.8
1.6
2.5
3.3
4.1
4.9
1.00
1.00
1.000
0.200
0.200
1.2
2.4
4.7
7.1
9.4
11.8
14.1
1.67
1.67
1.000
0.334
0.334
2.0
3.9
7.9
11.8
15.7
19.6
23.6
1.00
1.67
1.670
0.200
0.334
1.7
3.4
6.8
10.1
13.5
16.9
20.3
0.35
1.00
2.857
0.070
0.200
1.0
2.0
4.0
6.1
8.1
10.1
12.1
0.35
1.67
4.771
0.070
0.334
1.6
3.3
6.5
9.8
13.0
16.3
19.5
0.25
0.35
0.35
1.000
0.088
0.088
0.5
1.0
2.1
3.1
4.1
5.1
6.2
1.00
1.00
1.000
0.250
0.250
1.5
2.9
5.9
8.8
11.8
14.7
17.6
1.67
1.67
1.000
0.418
0.418
2.5
4.9
9.8
14.7
19.6
24.6
29.5
1.00
1.67
1.670
0.250
0.418
2.1
4.2
8.5
12.7
16.9
21.1
25.4
0.35
1.00
2.857
0.088
0.250
1.3
2.5
5.1
7.6
10.1
12.6
15.2
0.35
1.67
4.771
0.088
0.418
2.0
4.1
8.1
12.2
16.3
20.3
24.4
0.30
0.35
0.35
1.000
0.105
0.105
0.6
1.2
2.5
3.7
4.9
6.2
7.4
1.00
1.00
1.000
0.300
0.300
1.8
3.5
7.1
10.6
14.1
17.6
21.2
1.67
1.67
1.000
0.501
0.501
2.9
5.9
11.8
17.7
23.6
29.5
35.4
1.00
1.67
1.670
0.300
0.501
2.5
5.1
10.1
15.2
20.3
25.4
30.4
0.35
1.00
2.857
0.105
0.300
1.5
3.0
6.1
9.1
12.1
15.2
18.2
0.35
1.67
4.771
0.105
0.501
2.4
4.9
9.8
14.6
19.5
24.4
29.3
Table C2. RSD Values for Multiples of B
Selected values
of RSDs
Description of RSD Values
Ratio of
RSDs
K, determined
from eq. C5
^K, 0.95
0.35B and 0.35B
Both values near lower end of expected range
1.00
8
1.86
0.35B and 1.00B
One value near lower end, one near expected
value
2.86
4
2.13
0.35B and 1.67B
One value near lower end, one near upper end
of expected range
4.77
4
2.13
1.00B and 1.00B
Both values near expected value
1.00
8
1.86
1.00B and 1.67B
One value near expected value, one near upper
end of expected range
1.67
6
1.94
1.67B and 1.67B
Both values near upper end of expected range.
1.00
8
1.86
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 59 of 65
1.67B; thus, the criterion is set at less than the upper end (RSD of 0.334). The RSD is calculated
(for a given product or uncontrolled segment at a given time) as:
Xj = ith measurement (i=l,2,...,5) for the given product (or uncontrolled segment), and
X = mean of five measurements.
Calculation of Confidence Intervals for 6-Month Control Efficiencies
Assume that the 6-month control efficiency for a given product is estimated as:
where:
the index q denotes quarters (q= 1,2),
CEtq is the estimated control efficiency for quarter q and treatment t,
Xtn denotes the quarterly mean of observations for quarter q and treatment t, and
iq
denotes the quarterly mean of observations for quarter g and the untreated segment.
If Equation (C2) is used to estimate the variance of the quarterly control efficiencies, then the
variance of the 6-month estimate is given approximately as
Equation (C8) assumes the sample size is n for each quarter and treatment (n is expected to be
five). The degrees of freedom, k, associated with Equation C8 can be taken to be equal to the
number of RSDs upon which the estimated B is based. Then a 90% confidence interval for a 6-
month control efficiency for product t would be formed as
(C6)
where:
(C7)
Var[At]~— 2(1 -CEtqf
(C8)
At±hfi35^Var\-AA
(C9)
where tkog5 is the upper 95th percentile of the t distribution with k degrees of freedom.
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 60 of 65
DQO for 6-Month CE
Half widths of confidence intervals for 6-month CEs, as determined via equation (C9),
should be approximately 70 percent as long as those expected for quarterly CEs (see Table CI).
This can be seen by assuming that the CE values that appear in equation C8 are the same for both
quarters; simplification of Equation C8 then results in a variance that is '/2 as big as that given by
Equation C2; that is, the resultant confidence intervals will be as long. This rationale
provides an appropriate approach for defining a DQO, since no prior annual data exists as a basis
for such a DQO.
Using the above assumptions and assuming that the quarterly RSD criteria are met for each
set of five replicate measurements, a DQO for the 6-month CE measurement can be set
consistent with the quarterly criteria. The DQO is expressed as the half-width interval for the
90percent confidence limits and is set at y^ the value in Table CI for a B of 0.2 and RSD/B of
1.67. For example, the DQO is 1.4 percent when the CE is 95 percent or 17 percent when the CE
is 40 percent.
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 61 of 65
Appendix D
References
-------
ETV/APCTVC/Maricopa Test/QA Plan Rev 3 (7/24/2003) - Page 62 of 65
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 63 of 65
References
1. Policy and Program Requirements for the Mandatory Agency-wide Quality System. U.S.
Environmental Protection Agency, Washington, DC. EPA Order 5360.1 A2. May 2000.
2. EPA Requirements for Quality Management Plans, EPA QA/R-2. U.S. Environmental
Protection Agency, Office of Environmental Information, Washington, DC. EPA
Publication No. EPA/240/B-01/002. March 2001.
3 • EPA. Environmental Technology Verification Program; Quality Management Plan;
EPA/600/R-03/021; Office of Research and Development: Cincinnati, OH, December
2002.
4. MRI. Applied Engineering Division Quality System Manual for Environmental Programs.
Quality Management Systems, January 24, 2000, Revision 0, Midwest Research Institute,
Kansas City, MO, and Quality Systems for the Collection and Evaluation of Environmental
Data, August 1, 2000, Revision 0, Midwest Research Institute, Kansas City, MO.
5. RTI. Verification Testing of Air Pollution Control Technology - Quality Management
Plan. Air Pollution Control Technology Program. J. R. Farmer, Program Director,
Research Triangle Institute, Research Triangle Park, NC. 1998.
6. MRI, Cary, NC, RTI, Research Triangle Park, NC, CERF, Washington DC, and EPA,
Research Triangle Park, NC. Generic Verification Protocol (GVP) for Dust Suppression
and Soil Stabilization Products. November 2002 draft.
7. EPA Requirements for Quality Assurance Project Plans, EPA QA/R-5. U. S.
Environmental Protection Agency, Office of Environmental Information, Washington, DC.
EPA Publication No. EPA/240/B-01/003. March 2001.
8. ANSI/ASQC E4-1994 Standard, Specifications and Guidelines for Quality Systems for
Environmental Data Collections and Environmental Technology Programs, American
Society for Quality Control, Milwaukee, WI, 1994.
9. MRI, Evaluation of a Mobile Sampler to Characterize Unpaved Road Dust Palliatives, for
U.S. Army Construction Engineering Research Laboratory, Champaign, IL,
August 5, 2002.
10. Sanders, T.G., Addo, J.Q., Ariniello, A., and Heiden, W.F., "Relative Effectiveness of
Road Dust Suppressants," ASCE Journal of Transportation Engineering, Vol. 123, No. 5,
pp 393-397, 1997.
11. EPA, Methods for Measuring the Acute Toxicity of Effluents and Receiving Waters to
Freshwater and Marine Organisms (Fourth edition). EPA/600/4-90/027F. U. S.
Environmental Protection Agency, Cincinnati, OH. 1993.
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 64 of 65
12. EPA, Short-Term Methods for Estimating the Chronic Toxicity of Effluents and Receiving
Waters to Freshwater Organisms, Third Edition. EPA/600/4-91/002. U. S. Environmental
Protection Agency, Cincinnati, OH. 1994. This document includes:
a. EPA Test Method 1003.0, Green Alga, Selenastrum Capricornutum, Growth Test.
Section 14, pp 181-211.
b. EPA Test Method 1000.0, Fathead Minnow, Pimephales Promelas, Larval
Survival and Growth Test. Section 11, pp 48-99.
c. EPA Test Method 1002.0, Daphnid, Ceriodaphnia Dubia, Survival and
Reproduction Test. Section 13, pp 128-180.
d. EPA Test Method 1001.0, Fathead Minnow, Pimephales Promelas, Embryo-
Larval Survival and Teratogenicity Test. Section 12, pp 100-127.
13. EPA, Test Method 405.1, Standard Operating Procedure for the Analysis of Biochemical
Oxygen Demand in Water. U. S. Environmental Protection Agency, Region 5, Chicago,
IL. 2000.
14. EPA, Methods for Chemical Analysis of Water and Wastes. EPA/600/4-79/020. U.S.
Environmental Protection Agency, Cincinnati, OH. 1993. This includes EPA
Method 410.4, Chemical Oxygen Demand.
15. EPA, Test Method 24, Determination of Volatile Matter Content, Water Content, Density,
Volume Solids, and Weight Solids of Surface Coatings. U.S. Environmental Protection
Agency, Office of Solid Waste. Washington, DC, 2000.
16. EPA, SW-846, Test Methods for Evaluating Solid Waste, Physical/Chemical Methods.
U.S. Environmental Protection Agency, Office of Solid Waste, Washington DC. 1998.
This includes the following tests:
Method 1311, TCLP - Toxicity Characteristics Leaching Procedure
Method 6010 - Inorganics by ICP
Method 8260 - VOCs by GC/MS
Method 8270 - SVOCs by GC/MS
17. Unified Soil Classification System, Technical Memorandum 3-357, US Waterways
Experiment Station, Vicksburg, MS 1953.
18. EPA, Compilation of Air Pollutant Emission Factors, AP-42, Volume I, Fifth Edition.
Office of Air Quality Planning and Standards, U.S. Environmental Protection Agency,
Research Triangle Park, NC. July 1993. This document includes the following:
Appendix C. 1, Procedures for Sampling Surface/Bulk Dust Loading.
http://www.epa.gov/ttn/chief/ap42/appendix/app-cl.pdf.
Appendix C.2, Procedures for Laboratory Analysis of Sampling Surface/Bulk Dust
Loading Samples.
http://www.epa.gov/ttn/chief/ap42/appendix/app-c2.pdf.
Section 13.2.2, Unpaved Roads.
http://www.epa.gov/ttn/chief/ap42/chl3/final/cl3s02-2.pdf.
-------
ETV/APCTVC/Maricopa Test/QA Plan
Rev 3 (7/24/2003) - Page 65 of 65
19. EPA, On-site Meteorological Program Guidance for Regulatory and Modeling
Applications. EPA-450/4-87-013. Office of Air Quality Planning and Standards. U.S.
Environmental Protection Agency, Research Triangle Park, NC. 1987.
20. EPA, Quality Assurance Guidance Document 2.11 Monitoring PM10 in Ambient Air Using
a High-Volume Sampler Method. EPA-600/4-77-027a. U. S. Environmental Protection
Agency, Research Triangle Park, NC. 1977.
21. ASTM, E617, Standard Specification for Laboratory Weights And Precision Mass
Standards. American Society for Testing and Materials. West Conshohocken, PA. 1997.
22. RTI, MRI. Test/QA Plan for Testing of Dust Suppressant Products and Comparison of
Dust Emissions Monitoring Methods at Fort Leonard Wood. RTI, Research Triangle Park,
NC, and MRI, Kansas City, MO. 2001.
------- |