United States Office Of Air Quality EPA-454/R-00-026

Environmental Protection Planning And Standards May 2000

Agency Research Triangle Park, NC 27711

Air

HOT MIX ASPHALT PLANTS

TECHNICAL SYSTEMS AUDIT of

TESTING at PLANT C

ASPHALT PLANT C

LOS ANGELES, CALIFORNIA
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EPA-454/R-00-026

HOT MIX ASPHALT PLANTS

TECHNICAL SYSTEMS AUDIT of TESTING at PLANT C

ASPHALT PLANT C

LOS ANGELES, CALIFORNIA

U.S. ENVIRONMENTAL PROTECTION AGENCY

Office of Air and Radiation

Office of Air Quality Planning and Standards

Research Triangle Park, North Carolina 27711

May 2000
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 DISCLAIMER

The information in this document has been funded wholly or in part by the Office of Air

Quality Planning and Standards, U.S. Environmental Protection Agency (EPA) under contract

68-D4-0091 to Research Triangle Institute. It has been reviewed and revised by the Emissions

Measurement Center Quality Assurance Officer. It has been approved for publication as an EPA

document. Mention of trade names or commercial products is not intended to constitute

endorsement or recommendation for use.
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Preface

This report was produced by the Source Measurement Technology Group of EPA’s Emissions

Measurement Center located in Research Triangle Park, NC. It is one of a series of twelve

reports prepared to document an EPA emission test program to characterize emissions to the air

from hot mix asphalt plants. These twelve reports and their associated EPA document numbers

and publication dates are:

Document Title

EPA Document

Number

Publication

Date

Hot Mix Asphalt Plants

Emission Assessment Report EPA 454/R-00-019

Hot Mix Asphalt Plants

Kiln Dryer Stack Instrumental Methods Testing

Asphalt Plant A, Cary, North Carolina EPA 454/R-00-020 April 2000

Hot Mix Asphalt Plants

Kiln Dryer Stack Manual Methods Testing

Asphalt Plant A, Cary, North Carolina

Volume 1 of 2 EPA 454/R-00-021a April 2000

Volume 2 of 2 EPA 454/R-00-021b April 2000

Hot Mix Asphalt Plants

Kiln Dryer Stack Instrumental Methods Testing

Asphalt Plant B, Clayton, North Carolina EPA 454/R-00-022 April 2000

Hot Mix Asphalt Plants

Kiln Dryer Stack Manual Methods Testing

Asphalt Plant B, Clayton, North Carolina

Volume 1 of 2 EPA 454/R-00-023a April 2000

Volume 2 of 2 EPA 454/R-00-023b April 2000

Hot Mix Asphalt Plants

Truck Loading and Silo Filling Instrumental Methods Testing

Asphalt Plant C, Los Angeles, California

EPA 454/R-00-024 May 2000

Hot Mix Asphalt Plants

Truck Loading and Silo Filling Manual Methods Testing

Asphalt Plant C, Los Angeles, California

Volume 1 of 8 EPA 454/R-00-025a May 2000

Volume 2 of 8 EPA 454/R-00-025b May 2000

Volume 3 of 8 EPA 454/R-00-025c May 2000

Volume 4 of 8 EPA 454/R-00-025d May 2000

Volume 5 of 8 EPA 454/R-00-025e May 2000

Volume 6 of 8 EPA 454/R-00-025f May 2000

Volume 7 of 8 EPA 454/R-00-025g May 2000

Volume 8 of 8 EPA 454/R-00-025h May 2000
Document Title

EPA Document

Number

Publication

Date

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Hot Mix Asphalt Plants

Technical Systems Audit of Testing at Asphalt Plant C

Asphalt Plant C, Los Angeles, California EPA 454/R-00-026 May 2000

Hot Mix Asphalt Plants

Truck Loading Instrumental Methods Testing

Asphalt Plant D, Barre, Massachusetts EPA 454/R-00-027 May 2000

Hot Mix Asphalt Plants

Truck Loading Manual Methods Testing

Asphalt Plant D, Barre, Massachusetts EPA 454/R-00-028 May 2000

Hot Mix Asphalt Plants

Response to Comments on Testing Program for Asphalt

Plants C and D EPA 454/R-00-029 May 2000

Hot Mix Asphalt Plants

Stakeholders Opinions Report EPA 454/R-00-030

These documents, including this Response to Comments document, are available for downloading, on

CD-ROM and in paper.

Downloads can be made from:

http//www.epa.gov/ttn/emc/asphalt.html

Copies of the CD ROM can be requested by mail at:

Emission Measurement Center, MD-19

US Environmental Protection Agency

Research Triangle Park, NC 27711

Paper copies of the reports can be obtained from:

National Technical Information Service

5285 Port Royal Road

Springfield, VA 22161

Phone orders 1-800-553-6847 or (703) 605-6000; FAX orders (703) 605-6900

http://www.ntis.gov/products/environment.htm

Acknowledgments

Many individuals contributed to the development of this report. Laura Autry of EPA’s Air Quality

Trends Analysis Group, R.K.M. Jayanty of Research Triangle Institute (RTI) and Robert S. Wright of

RTI are the primary authors of the report. David Mobley, Acting Director of EPA’s Emissions

Monitoring and Analysis Division, Conniesue Oldham of EPA’s Air Quality Trends Analysis Group,

Bill Lamason and Gary McAlister of EPA’s Emission Measurement Center provided advice in

resolving some findings identified by the RTI audit team.
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Glossary

ASTM – American Society for Testing Materials

CO – Carbon Monoxide

CTS – Calibration Transfer Standard

EPA – United States Environmental Protection Agency

FID – Flame Ionization Detector

FTIR – Fourier Transform Infrared Spectroscopy

HAP – Hazardous Air Pollutant

MCEM – Methylene Chloride Extractable Particulate Matter or Organic Extractable Particulate

Matter

MQL – Minimum Quantitation Limit

MRI – Midwest Research Institute

NIST – National Institute of Standards and Technology

NOx – Nitrogen Oxides

OAQPS – Office of Air Quality Planning and Standards

PAH – Polynuclear Aromatic Hydrocarbons

PES – Pacific Environmental Services, Inc.

PM – Particulate Matter

ppb – parts per billion

ppm – parts per million

QAPP – Quality Assurance Project Plan

RAP – Recycled Asphalt Pavement

RSD – Relative Standard Deviations

RTI – Research Triangle Institute

SED – Silo Exhaust Duct

SF6 – Sulfur Hexafluoride

SO2 – Sulfur Dioxide

SSTP – Site Specific Test Plan

SVOHAP – Semi-volatile Organic Hazardous Air Pollutant

THC – Total Hydrocarbons

TSA – Technical Systems Audit

VOHAP – Volatile Organic Hazardous Air Pollutant

VOST – Volatile Organic Sampling Train
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Table of Contents

Disclaimer ........................................................................ . iii

Preface ........................................................................... . v

Acknowledgements ................................................................. . vi

Glossary ......................................................................... . vii

Table of Contents ................................................................... . ix

Chapter 1

1.0 Quality Assurance Audit Results .................................................. . 1.1

1.1 Overview ................................................................ . 1.1

1.2 Process Description ........................................................ . 1.1

1.2.1 Aggregate Processing Operations ....................................... . 1.2

1.2.2 Silo Filling Operations ................................................ . 1.2

1.2.3 Load-Out Operations ................................................. . 1.2

1.3 Emission Testing .......................................................... . 1.2

1.4 Technical Systems Audit ................................................... . 1.3

1.4.1 General Reviews .................................................... . 1.4

1.4.2 Technical Assessment of MRI’s Testing .................................. . 1.4

1.4.3 Technical Assessment of PES’s Testing .................................. . 1.5

Chapter 2

2.0 Technical Systems Audit - Midwest Research Institute ................................. . 2.1

Technical Systems Audit Checklist ............................................... . 2.4

A. Quality System Documentation ........................................... . 2.4

B. Organization and Responsibilities ......................................... . 2.7

C. Training and Safety ................................................... . 2.10

D. Data Quality Indicator Goals and Performance Testing ........................ . 2.10

E. Extractive Sampling System ............................................. . 2.12

F. Extractive Fourier Transform Infrared (FTIR) Instrument ...................... . 2.16

G. Sample Concentrator for Ftir Instrument ................................... . 2.24

H. Total Hydrocarbons (THC) Analyzer ...................................... . 2.32

I. Capture Efficiency Test ................................................. . 2.37

Chapter 3

3.0 Technical Systems Audit - Pacific Environmental Services Inc. .......................... . 3.1

Technical Systems Audit Checklist ............................................... . 3.2

A. General Quality Assurance Information .................................... . 3.2

B. Organization and Responsibilities ......................................... . 3.5

C. Method Specific - EPA Method 1 ......................................... . 3.7
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D. Method Specific - EPA Method 2 ......................................... . 3.8

E. Method Specific - EPA Method 4 ......................................... . 3.9

F. Method Specific - EPA Method 315 ...................................... . 3.10

Laboratory Information Necessary for EPA Method 315 .................... . 3.12

Calibration and General .............................................. . 3.13

G. Method Specific - EPA Method 18 ....................................... . 3.16

Apparatus ......................................................... . 3.17

H. Method Specific - SW-846 Method 0030 (VOST) ........................... . 3.19

I. Method Specific - SW-846-0010 (Modified Method 5) ........................ . 3.21

Train Components .................................................. . 3.22

Preparation of the Train .............................................. . 3.23

Running the Train .................................................. . 3.25

Sample Recovery ................................................... . 3.25

J. Sampling General ..................................................... . 3.27

K. Quality Assurance/quality Control/general ................................. . 3.28

L. Sample Custody and Integrity ........................................... . 3.29

M. Miscellaneous Measurements ........................................... . 3.30

N. Estimation of Particulate Deposition ...................................... . 3.30

P. Estimation of Particulate Deposition on the Inside Walls of the Temporary

Silo Exhaust and Wind Tunnel Exhaust ................................. . 3.31

Q. Direct Interface Portable GC/MS ......................................... . 3.32
Chapter 1

Quality Assurance Audit Results

Hot Mix Asphalt Plant C,

Los Angeles, CA
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Quality Assurance Audit Results 1.1

1.0 QUALITY ASSURANCE AUDIT RESULTS

1.1 Overview

The United States Environmental Protection Agency (EPA) Office of Air Quality Planning and

Standards (OAQPS) is investigating hot mix asphalt plants to characterize emissions during silo filling

and truck loading operations. In support of this investigation, OAQPS issued work assignments to

Pacific Environmental Services, Inc. (PES) and Midwest Research Institute (MRI) to conduct emission

testing of these sources. Additionally, due to the complexity and importance of this testing, OAQPS

issued a work assignment to Research Triangle Institute (RTI) to perform an independent technical audit

of MRI and PES’s emissions testing through a technical review. RTI conducted the audit according to

the principles of the EPA Office of Research and Development’s Quality Assurance Division. These

principles are described in their working draft of EPA Guidance for Technical Assessments for

Environmental Data Operations (EPA QA/G-7).

The primary objective of the emissions testing was to characterize the uncontrolled emissions of

particulate matter (PM), organic extractable particulate matter (methylene chloride extractable particulate

or MCEM) and organic hazardous air pollutants (HAP’s) from silo filling and truck loading operations at

a hot mix asphalt production plant. The organic HAP emissions quantified included polynuclear

aromatic hydrocarbons (PAHs), semi-volatile organic hazardous air pollutants (SVOHAPs), and volatile

organic hazardous air pollutants (VOHAPs). Other emissions that were characterized included methane,

carbon monoxide (CO), sulfur dioxide (SO2), and nitrogen oxides (NOx).

It was concluded from the technical systems audit that the overall quality assurance objectives of

the test were met. Except for some minor deviations, the test team members performed the testing

according to the procedures outlined in the Site Specific Test Plan (SSTP) and Quality Assurance Project

Plan (QAPP). These deviations from the QAPP or SSTP were discussed with and approved by the EPA

Work Assignment Manager. The equipment used was appropriate for the emissions testing and was

operated satisfactorily during the testing.

1.2 Process Description

An asphalt plant located south of Los Angeles, CA, (also called Asphalt Plant C or Plant C), was

selected as the host facility. Testing was performed over five consecutive days beginning on July 24,

1998. Testing of transport truck loading operations was performed under two conditions - normal

operations and a background condition. Additionally, a secondary objective of the emission testing was

to characterize controlled emissions of VOHAPs, CO, SO2 and NOx from the aggregate dryer.

This plant was selected for the emissions testing due to its high production rate, ventilation of the

storage silos and enclosure/ventilation of the load-out bay. The Plant C facility has a rated production

capacity of 650 tons per hour (tph). Daily production varies from approximately 2,000 tons per day (tpd)

to 6,000 tpd depending on demand. The plant produces five different categories of hot mix asphalt: 3/8

in, 1/2 in, 3/4 in, fines, and recycled asphalt (RAP). These categories indicate the average size and type

of aggregate in the mix. In RAP, small amounts of recycled asphalt are added to the mix. The plant also

adds small amounts of rubber to some products as a crack inhibitor. The plant uses two different kinds of

liquid asphalt: AR-4000 and AR-8000. AR-4000 is a softer asphalt and is used approximately 90% of
Quality Assurance Audit Results 1.2

the time. The percent by weight of liquid asphalt in the mix varies from 4.8% to 6.0% depending on the

size of the aggregate (the smaller the aggregate, the higher the liquid asphalt content).

The following paragraphs describe the three operations tested at Plant C.

1.2.1 Aggregate Processing Operations

In this continuous process, cold aggregate is introduced to the rotary drum dryer. As the drum

rotates, the aggregates move toward the other end of the drum. The cold aggregate is first dried and then

is heated as it moves through the drum. After exiting the dryer drum into a mixing drum, the heated and

dried aggregate is mixed with the liquid asphalt cement and recycled asphalt pavement (RAP). A

ventilation system exhausts the gases and condensed particulate from the rotary drum dryer through a

baghouse and exhaust stack.

1.2.2 Silo Filling Operations

Hot mix asphalt produced in the aggregate processing operation is transported by bucket elevator

into temporary storage silos. Plant C has five 200-ton heated silos that sit on top of the load-out tunnel. 

The silos serve as a holding station between production and the loading of the hot mix asphalt into

transport trucks. Depending on customer requirements, a different product can be stored in each silo. 

The hot mix asphalt in storage can have a temperature up to 160E C (320E F). A 10" inside diameter

ventilation duct exhausts the gases and condensed particulate from each of the five silos to an exhaust

duct that ventilates the load-out tunnel.

1.2.3 Load-Out Operations

The hot mix asphalt is dropped from the storage silos into transport trucks within a load-out

tunnel that is approximately 183 ft long with open doorways at both ends. During a full load-out

schedule, trucks enter the tunnel approximately every one to three minutes. Single bed trucks hold

approximately 21 tons of asphalt cement. Dual bed trucks (i.e., a truck and trailer) hold approximately

25 tons. Typically, the temperature of the asphalt cement, after it drops from the silo into the truck, is

approximately 300E F.

The truck is positioned under the silo containing the desired product where it is loaded into the

truck bed. During loading, emissions are captured by activating a double-slotted capture hood at each

silo. With the truck positioned under the silo, one freestanding slot will be at the forward edge and one

at the aft edge of the truck bed. No more than one silo can operate at a given time and only the capture

hood associated with that silo is activated to capture the emissions. It typically takes 15 to 30 seconds to

load a truck. One capture hood is always active, even when no loading is occurring. Each of the capture

hoods connects to the 32 inch inside diameter tunnel exhaust duct. Constant flow is maintained by the

fan setting, thus, a constant airflow is always exhausted from the load-out tunnel to the emission

abatement system. The tunnel, ventilation system, and capture hoods work together to form a near-total

enclosure for the loading operations. The selected test site, however, did not meet all of the criteria for a

permanent total enclosure as defined by EPA Method 204, “Criteria for Verification of a Permanent or

Temporary Total Enclosure,” Federal Register, Vol. 62, No. 115, June 16, 1997.
Quality Assurance Audit Results 1.3

1.3 Emission Testing

The emissions testing consisted of triplicate runs of the silo and load-out ventilation systems. 

Additionally, a fourth test run was performed using two trucks that traversed the load-out area like

normal operations, while no loading was occurring to determine background emissions contributed by

diesel truck exhaust. For all four test runs, capture efficiency testing of the load-out system was

performed. The silo ventilation system was tested intermittently whenever silo loading operations

occurred. Two test runs were performed on the dryer stack using only instrumental test methods. The

three ventilation systems are referred to as the load-out system, the silo storage system, and the hot mix

dryer system. The specific tests performed at each ventilation system are summarized below:

! The Load-out system was tested for HAPs, CO, SO2, and NOx, using extractive Fourier

Transform Infrared Spectroscopy (FTIR) (EPA Method 320) and FTIR with sample

concentration. Total hydrocarbons (THC) were measured using a flame ionization detector (FID)

(Method 25A). A single SW-846 Method 0010 Modified Method 5 (MM5) sampling train was

used to collect both PAHs and SVOHAPs. Three different procedures were used to measure

VOHAPs: 1) sampling procedure SW 846 Method 0030 in combination with analytical

procedure SW 846 Method 8260, 2) EPA Method 18, and 3) on-site GC/MS. During background

testing no measurements were made using the on-site GC/MS.

! The Silo storage system was tested for HAPs, CO, SO2, and NOx, using extractive FTIR (EPA

Method 320) and FTIR with sample concentration. Total hydrocarbons (THC) were measured

using a flame ionization detector (FID) (Method 25A). A single SW-846 Method 0010 Modified

Method 5 (MM5) sampling train was used to collect both PAHs and SVOHAPs. Three different

procedures were used to measure VOHAPs: 1) sampling procedure SW 846 Method 0030 in

combination with analytical procedure SW 846 Method 8260, 2) EPA Method 18, and 3) on-site

GC/MS.

! The Hot mix dryer system was tested for HAPs, CO, SO2, and NOx, using extractive FTIR (EPA

Method 320) and FTIR with sample concentration. Total hydrocarbons (THC) were measured

using a flame ionization detector (FID) (Method 25A). 

! Capture efficiency tests of the load-out system were also performed simultaneously with the

load-out system tests. Tracer gas was released from a manifold in the load-out bay, was collected

by the ventilation system, and air concentrations were measured, allowing capture efficiency to

be calculated.

The responsibilities for this testing were divided between PES and MRI. The instrumental test

methods were performed by MRI under the direction of Scott Klamm. The manual test methods were

performed by PES under the direction of Frank Phoenix. Mike Toney of EPA was on site and overall

responsibile for the testing.

1.4 Technical Systems Audit

The technical systems audit (TSA) was performed by R.K.M. Jayanty and Robert S. Wright of

Research Triangle Institute (RTI) under EPA Contract 68-D4-0091, work assignment 99-03, from July
Quality Assurance Audit Results 1.4

20, through July 26, 1998. The purpose of the audit was to conduct an independent technical assessment

of MRI and PES’s emissions testing through a technical review. The review included an in-depth

evaluation of documents, on-site activities, equipment, procedures, record keeping, data validation, data

management, and reporting to ensure that established requirements are satisfied. The TSA was

conducted following principles described in a working draft version of EPA Guidance for Technical

Assessments for Environmental Data Operations (EPA QA/G-7), which was being developed by EPA’s

Quality Assurance Division at the time. Detailed findings and Technical Systems Audit Checklists as

revised by EPA for the tests performed by MRI and PES are presented in Chapters 2 and 3 respectively. 

Summaries of the findings and descriptions of the EPA revisions are presented below.

1.4.1 General Reviews

In general, RTI found that the PES and MRI team members performed the testing according to

the procedures outlined in the Site Specific Test Plan (SSTP) and Quality Assurance Project Plan

(QAPP). Deviations from the QAPP or SSTP were discussed with the EPA Work Assignment Manager. 

RTI’s assessment proceeded after approval of the deviations. The equipment used was found by RTI to

be appropriate for the planned emissions testing and generally operated satisfactorily during the testing. 

RTI found that the PES and MRI team members, who were present at the site, to be well qualified and

experienced to perform the emissions testing and conducted themselves in a professional manner.

Although RTI’s assessment of the performance of the testing by MRI and PES is valid, a few

revisions of their findings were made. While most of the revisions were made to clarify the finding or

eliminate unnecessary comments, one revision was made that altered the determination of the potential

effect on Data Quality. Some of the items in the TSA checklist for PES were not completed by RTI due

to lack of information available at the on-site operations. After the field test, RTI requested this

information from PES, but it was not received by RTI by the date of their report to EPA. The checklist

was completed based on the RTI auditors’ observations during sampling and their discussions with the

PES task manager, sampling train operators, custodians, and PES quality assurance (QA) coordinator at

the site. Additional information on the calibration of the equipment in the laboratory prior to the on-site

testing was requested, but had not been received by RTI. Examples of blank data sheets, custody forms,

and labels have been supplied to the auditors and were included with the draft version of the checklist.

The following paragraphs describe the revisions that EPA made to the findings and technical

system audit checklists RTI submitted to EPA on September 29, 1998.

1.4.2 Technical Assessment of MRI’s Testing

RTI identified as a finding, which may have a potential effect on data, that besides all reports

generated by this project being reviewed formally by senior project personnel, quality control data should

be audited by the project’s quality assurance officer. While the letter RTI received from MRI did not

address the auditing of quality control data, MRI’s standard procedures require a senior project person to

review raw test data and to randomly select data to be followed through the analysis and data processing. 

In addition, EPA performed a quality control audit of the data and reproduced the calculations from raw

data to final results. As a result, the clarifying statements by RTI were removed and this finding was

changed to one that is unlikely to have a effect on data quality. 
Quality Assurance Audit Results 1.5

In the findings which are unlikely to have an effect on data quality table, wording of the third

finding was changed to better characterize the level of detail used to describe the FTIR procedures

without indicating the adequacy of the procedures. The complexity of the FTIR procedures precludes a

description as detailed and thorough as most other methods. In the Technical Systems Audit Checklist,

sentences were removed from items 3 and 10 of the Quality System Documentation. In Item 3, the

sentence indicating the QAPP and SSTP were not revised has been deleted. In Item 10, the sentence was

completed by stating that the THC calibration data was recorded on a legal pad.

1.4.3 Technical Assessment of PES’s Testing

In the findings that may have a potential effect on data quality, items 1 and 2 were revised. A

sentence was added to Item 1 explaining that this was a research study and that testing was not meant to

have validation. This was the first attempt to measure many of the pollutants at these sources. It would

be highly unusual and expensive to also attempt to validate the test methods at these sources without

some prior knowledge of the performance of some initial testing. The paragraph for Item 2 discussing

the spiking of surrogate compounds for the VOST cartridges has been completely revised to properly

reflect that the analytical laboratory spiked compounds before transport to the field-testing location. The

sentence identifying a better spiking methodology was removed.

In the findings that are unlikely to have an effect on data quality, Items 1 and 2 have been

revised. In Item 1, the sentence identifying a better spiking methodology was removed. In Item 2 one

sentence was revised and one was removed. This corrects an incorrect and contradictory statement in

one sentence that a dedicated notebook was not maintained to record any problems or process changes.

In the Technical Systems Audit Checklist, a clarifying statement was added to the comment for

Item 2 under General Quality Assurance Information indicating that key personnel provided sample train

operators with information from the QAPP and SSTP as needed for their tasks.
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Chapter 2

Technical Systems Audit

Instrumental Test Methods Performed by

Midwest Research Institute at

Hot Mix Asphalt Plant C,

Los Angeles, CA
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Technical Systems Audit of Test Methods Performed by MRI 2.1

2.0 TECHNICAL SYSTEMS AUDIT - MIDWEST RESEARCH INSTITUTE

This chapter is the final technical systems audit (TSA) of the emissions testing performed by

Midwest Research Institute (MRI) at Hot Mix Asphalt Plant C in the Los Angeles, California area. As

explained in detail in Chapter 1, the final TSA includes revisions by the EPA Quality Assurance Officer. 

The draft TSA report from Research Triangle Institute (RTI) was delivered to the EPA Quality

Assurance Officer on September 29, 1998. The TSA was performed by R.K.M. Jayanty and Robert S.

Wright of RTI under EPA Contract 68-D4-0091, work assignment 99-03, from July 20, through July 26,

1998. The purpose of the TSA was to conduct an independent technical assessment of MRI's emissions

testing through a technical review, which included an in-depth evaluation of documents, on-site

activities, equipment, procedures, and record keeping to assure that quality assurance requirements were

satisfied. The TSA was conducted in accordance with principles described in the EPA Quality

Assurance Division’s working draft version of EPA Guidance for Technical Assessments for

Environmental Data Operations (EPA QA/G-7).

In general, MRI did a very good job during the emissions testing at the hot mix asphalt plant. 

The emissions testing was executed according to the quality assurance project plan (QAPP) and the sitespecific test plan (SSTP) to a large degree. The equipment that was used is appropriate for the planned

emissions testing and it generally operated satisfactorily. The on-site project personnel were wellqualified to perform the emissions testing and conducted themselves in a professional manner.

Checklist

Section

Findings which may have a Potential Effect on Data Quality

G3, G31 The sample concentrator method for the FTIR instrument does not appear to have

been throughly validated or throughly documented. In 1993, Entropy

Environmentalists conducted a method validation at a coal-fired boiler, which was

published as EPA Report No. EPA/454/R-95/004, July 1993 (NTIS Order No. PB95-

193199INZ). This method validation found that EPA Method 301 validation criteria

were met for toluene and xylenes in concentrated samples. Pacific Environmental

Services found these compounds during its preliminary measurements at the hot-mix

asphalt plant. If MRI discovers significant concentrations of other chemical

compounds in the asphalt plant emissions, then the report of MRI's emissions testing

should note that the FTIR sample concentrator method has not been validated for

these additional compounds, which it does.

Checklist

Section

Findings which are Unlikely to have an Effect on Data Quality

A3 Some equipment and procedures that were used during the emissions testing in July

differ from those documented in the QAPP, which was submitted to EPA in March. 

In many cases, these changes are documented in the SSTP. Some changes were

made as recently as 3 weeks before the testing and are not documented in either

document. Revisions and/or amendments to both documents should have occurred,

according to procedures outlined within the QAPP.
Checklist

Section

Findings which are Unlikely to have an Effect on Data Quality

Technical Systems Audit of Test Methods Performed by MRI 2.2

A8 The total hydrocarbon (THC) analyzer's calibration data were recorded on a legal

pad, rather that on a formal data sheet as was used for other measurements. Section

5.1 of the QAPP states that information will be entered in standard data forms. 

A14 A letter from MRI to RTI indicates that all reports that are generated by this project

will be reviewed formally by senior project personnel. It is assumed these reports did

receive review by senior personnel.

A-Comments The QAPP does not describe the FTIR procedures in a lot of detail. It cites EPA Test

Method 320 and the FTIR Protocol, which are pretty general to describe the specifics

of the data collection effort at the hot-mix asphalt plant.

F31 Test Method 320 specifies an accuracy of ±2% for the CTS. The CTS used for this

study had an accuracy of ±5%. The concentration of the CTS was not independently

verified by MRI.

F-Comments QAPP Section 3.1.1 states that the time for 5 cell volumes to pass through the cell is

considered the minimum interval separating independent samples. If the cell volume

is 8.5 L, then 5 cell volumes corresponds to 42.5 L. If the FTIR sample gas flow rate

is 5 L/min and the FTIR sample interval is 2.5 minutes, only 12.5 L (or 1.5 cell

volumes) of sample gas passes through the cell between measurements. Therefore,

an individual FTIR measurement cannot be considered to be completely independent

of the measurements that immediately precede it. Scott Klamm confirms that it takes

3 to 4 samples to flush the cell for CTS measurements.

F-Comments During the emissions testing, MRI analyzed a nine-component hydrocarbon

calibration standard (Spectra Gases cylinder number CC91245) that had been

brought to the hot mix asphalt plant by Emissions Monitoring, Inc. The analysis of

this calibration standard does not constitute a performance evaluation of the

extractive FTIR method because MRI was not informed of the analysis prior to the

emissions testing nor during our initial on-site meeting on 20 July 1998. The results

of the analysis were not available during the RTI assessor's conversation with MRI's

Thomas Geyer on August 27, 1998. RTI suggests that the results of the MRI's

analysis of this calibration standard be included in MRI's emissions testing report,

which will allow EPA to compare the MRI analytical results with the attached

certificate of analysis for the calibration standard.

G21 The SSTP indicates that a preheated vapor-phase surrogate spike will be loaded onto

the Tenax cartridge via the sampling probe. The surrogate spike was actually loaded

in the monitoring trailer at room temperature.

G25 A duplicate train sample was collected on 25 July 1998, but the FTIR sample

spectrum was not saved. A second attempt to collect a duplicate train sample was

scheduled for 27 July 1998 after the assessors departure. The results of the post

sampling analysis of this sample were not available for review as of 27 August 1998.
Checklist

Section

Findings which are Unlikely to have an Effect on Data Quality

Technical Systems Audit of Test Methods Performed by MRI 2.3

H-Comments There appear to be some errors in the draft THC calibration data the MRI submitted

for review. The span drift data for stack dryer Runs 1 and 2 are identical, which is an

unlikely occurrence. There appear to be errors in the calculated span drifts for Dryer

Stack Run 1 and Load-out Run 1. These errors do not appear to be major problems.
Technical Systems Audit of Test Methods Performed by MRI 2.4

Technical Systems Audit Checklist

Project: Emissions Testing at a Hot Mix Asphalt Plant

Organization: Midwest Research Institute (Kansas City, Missouri)

Assessment Location: Asphalt Plant C, Los Angeles, California

Assessors: Robert S. Wright and R.K.M. Jayanty, Research Triangle Institute (Research

Triangle Park, North Carolina)

Assessment Dates: July 20 through July 26, 1998

Brief Project Description: EPA is investigating hot mix asphalt plants to identify and quantify particulate

matter and hazardous air pollutants (HAPs) emitted from asphalt cement load-out operations. EPA has

issued a work assignment to MRI to conduct an air emissions test program to collect data in support of

the investigation. Asphalt Plant C in Los Angeles, California was chosen primarily because load-out

emissions are controlled by a silo exhaust system and a load-out tunnel. The plant has a production

capacity of more 650 tons per day. Approximately 2,000 tons per 4 hour period were produced, during

the test. The primary objective of the project was to characterize air emissions of organic HAPs from the

storage silos, the load-out tunnel, and the hot mix dryer.

AUDIT QUESTIONS

RESPONSE

COMMENT

Y N

N

A

A. QUALITY SYSTEM DOCUMENTATION

 1. Is there an approved quality

assurance project plan (QAPP) for

the project and has it been

reviewed by all appropriate

personnel?

T A QAPP was submitted to EPA on

March 27, 1998. Additionally, MRI

submitted a site-specific test plan

(SSTP) on June 22, 1998. Both

documents have been approved by EPA.

 2. Is a copy of the QAPP maintained

at the field site? If not, briefly

describe how and where QA and

quality control (QC) requirements

and procedures are documented.

T Copies of the QAPP and SSTP are

available in plain sight in the monitoring

trailer. No one has been observed

consulting these documents.
AUDIT QUESTIONS

RESPONSE

COMMENT

Y N

N

A

Technical Systems Audit of Test Methods Performed by MRI 2.5

 3. Is the design and conduct of the

project as is specified in the

QAPP? 

T In general, the project is being

implemented as was specified in the

QAPP. However, some equipment and

procedures have changed since the

QAPP was submitted to EPA. In many

cases, these changes are documented in

the SSTP. Some changes were made as

recently as 3 weeks before the testing

and are not documented. Revisions

and/or amendments to both documents

should have occurred, according to

procedures outlined within the QAPP.

4. Are there deviations from the

QAPP?

T There are some noticeable deviations,

which do not appear to affect the quality

of the data being collected. For

example, QAPP Section 3.1.2 states that

Tenax will be spiked with an analyte or

surrogate compound during sample

collection if practical. The sample

concentration description in the QAPP

also mentions a post-test, laboratory

gaseous spiking procedure and other

procedures. SSTP Section 5.1.3 states

that a vapor phase spike will be

preheated and injected into the back of

the sampling probe. However, the

surrogate spike gas was loaded onto the

Tenax trap in the trailer prior to

sampling using the cool thermal

desorption system for the traps.
AUDIT QUESTIONS

RESPONSE

COMMENT

Y N

N

A

Technical Systems Audit of Test Methods Performed by MRI 2.6

5. How are any deviations from the

QAPP noted?

T QAPP Section 6.3 indicates that the

QAPP will be amended to correct minor

discrepancies that have no effect on the

overall conduct of the study. The QAPP

presents a form for documenting such

amendments. An entire chapter of the

QAPP will be revised if major changes

in the conduct of the study occur. 

However, no amendments or revisions

have been submitted to EPA. Any

deviations that arise before or during the

testing should be documented.

6. For each measured parameter, does

the QAPP list the frequency of

calibration, acceptance criteria for

the calibration, and the process for

calibration data reduction and

review?

T QAPP Table 2-1 and SSTP Table 5-2

give the calibration frequencies and

accuracy and precision objectives for

some field test methods. SSTP Table 5-

1 lists the calibration frequencies,

acceptance limits, reference standards,

and calibration techniques for other

methods. 

7. Are written and approved standard

operating procedures (SOPs) used

in the project? If so, list them and

note whether they are available at

the field site. If not, briefly

describe how and where the project

procedures are documented.

T No SOPs were observed at the testing

site. The Fourier transform infrared

(FTIR) sample concentration procedure

is attached to the QAPP. EPA test

methods are cited and, in some cases,

attached to the QAPP and SSTP (i.e.,

Methods 25A and 320 and the FTIR

Protocol). 

8. Briefly describe how calibration

and other QC data are documented.

T Operational parameters and calibration

data were recorded on paper data sheets

and Excel spreadsheets except for total

hydrocarbon (THC) analyzer's

operational parameters and calibration

data, which were recorded on a legal

pad.

9. Does the calibration

documentation show that

calibrations are being performed at

the required frequency and in the

required manner??

T MRI calibration data indicates that the

extractive FTIR instrument and the THC

analyzer were calibrated at the required

frequency and in the required manner.
AUDIT QUESTIONS

RESPONSE

COMMENT

Y N

N

A

Technical Systems Audit of Test Methods Performed by MRI 2.7

10. Are there standard paper or

electronic forms to record

calibration data and operational

parameters?

T Standard paper data sheets and Excel

spreadsheets were used for all

measurements except the THC

measurements, which was recorded on a

legal pad.

11. Are the standard data forms dated? T The forms have a line for the entry of

the date.

12. Is the person who recorded the data

identified on the form?

T The forms have a line for the entry of

the operator's name.

13. Are any paper records written in

indelible ink?

T All reviewed data forms were filled out

in ink.

14. Are the QC data reviewed by

another qualified person such as

the QA officer or the project

leader? Who is this individual?

T A letter from MRI to RTI indicates that

Scott Klamm, Thomas Geyer, John

Hosenfeld, Bruce Diel, and Jack

Balsinger will review formally all

reports generated by this project. 

However, there is no indication whether

the raw QC data are reviewed directly

by any MRI personnel.

15. Is the project team adhering to the

planned schedule? If not, explain

the new schedule. Verify that all

schedule changes have been

authorized.

T The schedule is being followed to the

extent allowed by unexpected

equipment breakdowns in the asphalt

plant and FTIR instrumentation

problems. All schedule modifications

were authorized by the EPA Work

Assignment Manager.

Additional Questions or Comments: The QAPP does not describe the FTIR procedures in enough

detail. It cites EPA Test Method 320 and the FTIR Protocol, which are too general to describe the

specifics of the data collection effort at the test site. For example, QAPP Section 2.2.1.1 states that

ethylene in nitrogen will be used as the FTIR calibration transfer standard (CTS) and FTIR Protocol

Section 4.5 gives selection criteria for the CTS. However, nowhere is it stated why ethylene in

nitrogen was selected as the CTS for this project. A similar problem exists for selection of the Tenax

trap surrogate spike gas.
AUDIT QUESTIONS

RESPONSE

COMMENT

Y N

N

A

Technical Systems Audit of Test Methods Performed by MRI 2.8

B. ORGANIZATION AND RESPONSIBILITIES

Identify the following personnel and determine whether they have the listed responsibilities:

1. MRI Work Assignment Leader:

John Hosenfeld (Kansas City, MO)

• responsible for overall

performance of the project, and

• communications with EPA

T Mr. Hosenfeld was not present at the

emissions testing.

2. MRI Quality Assurance Officer:

 Jack Balsinger (Kansas City, MO)

• prepare QAPP

C review and monitor QA activities

T Mr. Balsinger was not present at the

emissions testing.

3. MRI Project Task Leader:

Scott Klamm (Kansas City, MO)

C responsible for the on-site

emissions testing effort

C supervision of all MRI on-site

and off-site staff 

• communication with other onsite personnel.

T Mr. Klamm is also responsible for the

FTIR instrument.

4. MRI FTIR Oversight:

Thomas Geyer (RTP)

C guidance for FTIR field data

collection

• direct spectral analysis effort

T Mr. Geyer was not present at the

emissions testing, but was available for

consultation by telephone. After testing

was completed, he analyzed the FTIR

spectra to identify compounds and

quantify concentrations.

5. MRI FTIR Operators:

Scott Klamm and Andy Page

• operation of FTIR instrument

and sample concentrator,

• calibration of FTIR instrument

and sample concentrator, and

• recording operational parameters

T Mr. Klamm has primary responsibility

for operating the FTIR instrument

during the emissions testing.

6. THC Analyzer Operators:

Bob Gulick and Bobby Edwards

• operation of THC analyzer,

• calibration of THC analyzer, and

• recording operational parameters

T Mr. Edwards is also a gas sampling train

operator.
AUDIT QUESTIONS

RESPONSE

COMMENT

Y N

N

A

Technical Systems Audit of Test Methods Performed by MRI 2.9

7. MRI SF6 Tracer Gas Operator:

Dan Neal

• operation of SF6 tracer gas

release manifold

T Mr. Neal is also a gas sampling train

operator.

8. Other MRI Testing Staff:

Jim Surman and Pam Murowchick

T Mr. Surman is a gas sampling train

operator. Ms. Murowchick collects

process monitor data in the asphalt plant

control room and alerts the SF6 tracer

gas operator of load-out tunnel

activities.

9. EPA Work Assignment Manager:

Michael L. Toney

C oversight of emissions testing

and problem solving

• communication with all on-site

personnel

T Mr. Toney was present throughout the

entire testing program and coordinated

the efforts of the emissions testing

teams. He authorized all changes in

testing schedule and procedures.

10. EPA QA Officer:

Lara P. Autry

• review and approve QAPP

• review and approve QA activities

T Ms. Autry was not present at the

emissions testing.

Additional Questions or Comments:
AUDIT QUESTIONS

RESPONSE

COMMENT

Y N

N

A

Technical Systems Audit of Test Methods Performed by MRI 2.10

C. TRAINING AND SAFETY

1. Does the FTIR instrument operator

have special training or experience

for the operation of the instrument?

T Mr. Klamm has 8 years experience with

extractive FTIR and open-path FTIR in

laboratory and field applications.

2. Does the THC analyzer operator

have special training or experience

for the operation of the instrument?

T Mr. Gulick has 10 years experience with

emissions testing and 5 additional years

of experience with analytical

instrumentation.

3. Does the project maintain current

summaries of the training and

qualifications of project personnel?

T A letter from MRI to RTI includes brief

resumes for project personnel.

4. Does the project maintain

descriptions of assignment

responsibilities?

T The QAPP contains descriptions of

senior project personnel. A letter from

MRI to RTI states that the

responsibilities for other personnel were

assigned in meetings before and during

the project.

5. Is there special safety equipment

required to ensure the health and

safety of project personnel?

T The asphalt plant required personnel to

wear hard hats while walking under

conveyor belts.

6. Is each project team member

appropriately outfitted with safety

gear?

T Each team member wore safety shoes

and a hard hat when outside of the

trailer. Eye and ear protection were

worn on an as-needed basis.

7. Are project personnel adequately

trained for their safety during the

performance of the project?

T Question not asked, but observation of

the team members demonstrates that

they were adequately trained about

safety.

8. Who is authorized to halt

emissions testing in the event of a

health or safety hazard?

T The EPA Work Assignment Manager

retained authority to halt emissions

testing as necessary to protect health

and safety.

Additional Questions or Comments:
AUDIT QUESTIONS

RESPONSE

COMMENT

Y N

N

A

Technical Systems Audit of Test Methods Performed by MRI 2.11

D. DATA QUALITY INDICATOR GOALS AND PERFORMANCE TESTING

1. Is the anticipated use of the data

known and documented in the

QAPP?

T The study objectives are briefly

described in the QAPP.

2. What are the critical

measurements?

T The QAPP describes extractive Fourier

transform infrared (FTIR) spectroscopy,

FTIR by sample concentration, and total

hydrocarbons (THC).

3. Have data quality indicator goals

for each critical measurement been

documented in the QAPP?

T QAPP Table 2-1 presents accuracy and

precision goals for direct and indirect

FTIR, THC, moisture, temperature,

velocity, oxygen, and carbon dioxide.

4. Do the above data quality indicator

goals appear to be based on

documented performance criteria

for the measured parameter or on

actual QC data compiled for the

particular measured parameter?

T The accuracy and precision goals for

extractive FTIR and THC are based on

EPA Test Methods 320 and 25A. The

accuracy and precision goals for FTIR

by sample concentration are based on

EPA Method 301 validation criteria

from Entropy Environmentalists' 1993

method validation at a coal-fired boiler.

5. Has the performance of each of the

critical measurements been

assessed and documented?

T Calibration data for direct and indirect

FTIR and THC were obtained and

recorded on a daily basis.

 6. Are there established procedures

for corrective or response actions

when measurement performance

criteria or the data quality indicator

goals (e.g. out-of-control

calibration data) are not met? If

yes, briefly describe them. 

T The corrective action procedures are

informal and are implemented on an asneeded basis. For example, problems

with the FTIR instrument prompted a

call to a FTIR consultant, who was able

to provide suggestions for corrective

actions.

7. Are the corrective action

procedures consistent with the

QAPP?

T QAPP Section 4.6 describes general

corrective action procedures that are

followed when problems occur.
AUDIT QUESTIONS

RESPONSE

COMMENT

Y N

N

A

Technical Systems Audit of Test Methods Performed by MRI 2.12

8. Have any such corrective actions

been taken?

T A few minor corrective actions have

been taken, but none were significant

enough to halt work on the project or to

involve the MRI work assignment leader

or the MRI quality assurance officer.

Additional Questions or Comments:

E. EXTRACTIVE SAMPLING SYSTEM

1. Describe locations of the sampling

ports.

T During the testing of the hot mix drying

exhaust, the sampling ports were located

at the baghouse exhaust stack

approximately 10 feet below the outlet. 

The sample ports for the testing of the

load-out tunnel were located in the

exhaust ducting between Silos 1 and 2. 

The sampling ports for the testing of the

silos were located in the exhaust ducting

of Silo 2 between the silo vent and the

damper.

2. Describe the sampling probes. T The sampling probes were short,

straight lengths (i.e., 1 to 2 feet) of

stainless steel tubing that were

connected to the particulate filters.

3. Are the sampling probes heated to

prevent condensation?

T The sampling probes were located

inside the sampling ports and remained

at that those temperatures. The dryer

baghouse exhaust temperature was

approximately 260E C, the silo duct

temperature was approximately 240E C, 

and the load-out tunnel exhaust was

near ambient air temperatures.

4. Does each of the sample probes

have a calibration valve assembly

for sampling system bias tests?

T The sample probes have calibration

valve assemblies for delivering

calibration gas to the FTIR and THC

instruments via the sampling lines.
AUDIT QUESTIONS

RESPONSE

COMMENT

Y N

N

A

Technical Systems Audit of Test Methods Performed by MRI 2.13

5. Describe the sampling lines. T Two 100-foot lengths of Technical

Heaters Model 22129-02-01-01

sampling line containing three Teflon®

tubes were used between the dryer

baghouse exhaust sampling port and the

sampling pumps outside of the trailer. 

One tube conveyed sample gas, another

tube conveyed calibration gas, and the

third tube was not used. For the loadout tunnel and silo testing, one length of

sampling line was used between the silo

and load-out sampling ports and another

was used between the load-out tunnel

sampling ports and the sampling pumps. 

Two Teflon® tubes conveyed sample

gas and the third tube conveyed

calibration gas. A Furon Unitherm

Model 220-666 sampling line containing

three Teflon® tubes was used between

the sampling pumps and the sample

distribution manifold inside the trailer.

6. Are the sampling lines heated to

prevent condensation?

T The sampling line is heated to 300E C

using a control and display box in the

trailer.

7. Describe any sample

conditioning/moisture

removal/dilution air system. 

T There was no sample conditioning or

dilution system.

8. Describe how the instrument

operators switch from sampling

from one location to sampling to

another location.

T FTIR and THC instrument operators

switch between sampling lines using

valves in the sample distribution

manifold.

9. Is any sample conditioning system

maintained according to schedule?

T Not applicable.

10. Describe the particulate filter. T A Balston particulate filter is contained

in a stainless steel housing.
AUDIT QUESTIONS

RESPONSE

COMMENT

Y N

N

A

Technical Systems Audit of Test Methods Performed by MRI 2.14

11. Is the filter changed according to

schedule?

T Question not asked. There did not

appear to be enough particulate matter

in the sample streams to require

changing the filter. 

12. Describe the sample pump. T Two KNF Model UN035ST.11I

diaphragm pumps with stainless steel

heads.

13. Describe the sample flow control

apparatus.

T The sample flow rate was controlled by

a shutoff valve in the sample

distribution manifold and it was 12

L/min. The FTIR instrument required a

sample flow rate of 5 L/min and the

THC analyzer required a flow rate of

2.5 L/min. All three flow rates were

indicated by a flow meter in the

manifold. These flow rates were not

critical measurements and were not

recorded on data sheets. A backpressure regulator maintained the

manifold pressure at 4 to 5 psig. Excess

sample not used by the two instruments

was discarded through the sample

distribution manifold vent.

14. Describe how the total sample

volume is measured.

T Not applicable.

15. Describe how the sample volume

meter is calibrated.

T Not applicable.

16. When was the last time that the

sample volume meter was

calibrated?

T Not applicable.

17. Is the volumetric calibration

traceable to NIST standards?

T Not applicable.

18. How is the gas meter temperature

measured?

T Not applicable.

19. How is the gas meter thermometer

calibrated?

T Not applicable.
AUDIT QUESTIONS

RESPONSE

COMMENT

Y N

N

A

Technical Systems Audit of Test Methods Performed by MRI 2.15

20. When was the last time that the gas

meter thermometer was calibrated?

T Not applicable.

21. Is the thermometer calibration

traceable to NIST standards?

T Not applicable.

22. How is the stack gas stream

temperature measured?

T A Type-K thermocouple was mounted

on the Pitot tube and was measured with

an Omega Model HH81 digital

thermometer.

23. How is the temperature sensor

calibrated?

T The thermocouple was calibrated in a

boiling water bath, an ice water bath, or

a newly-acquired dry well and the

calibration temperature was measured

with an ASTM mercury-in-glass

thermometer.

24. When was the last time that the

temperature sensor was calibrated?

T 24 March 1998

25. Is the thermometer calibration

traceable to NIST standards?

T ASTM thermometers are traceable to

NIST standards.

26. How is barometric pressure

measured?

T Taylor aneroid barometer (Asheville,

NC) with a 600-foot altitude correction. 

The asphalt plant is 540 feet above

mean sea level.

27. How is the barometer calibrated? T The aneroid barometer is compared to a

Sargent-Welch Model S-4519 mercury

column barometer.

28. When was the last time that the

barometer was calibrated?

T 14 July 1998

29. Is the barometric pressure

calibration traceable to NIST

standards?

T The mercury column barometer is

generally considered to be a primary

standard.
AUDIT QUESTIONS

RESPONSE

COMMENT

Y N

N

A

Technical Systems Audit of Test Methods Performed by MRI 2.16

30. Describe the sample manifold. T Sample gas enters the sample

distribution manifold where it is

distributed by switching valves, shutoff

valves, and flow meters to the FTIR and

THC instruments. A back-pressure

regulator maintains the pressure in the

manifold. Excess flow is vented outside

the trailer. 

31. Describe the calibration gas

manifold and associated calibration

gas lines to the sample probe and

sample manifold.

T Calibration gas enters the sample

distribution manifold where it is

distributed by switching valves, needle

valves and flow meters either directly to

the FTIR and THC instruments or

indirectly to them via the sampling lines

and the calibration valves on the

sampling probes.

Additional Questions or Comments:

F. EXTRACTIVE FOURIER TRANSFORM INFRARED (FTIR) INSTRUMENT

 1. Describe the extractive FTIR

instrument. List the brand, model

number, and serial number.

T KVB Analect (Irvine, CA) Model RFX40 FTIR instrument with a glow-bar

light source and a liquid-nitrogencooled mercury-cadmium-telluride

(MCT) detector. The FTIR instrument

has a 1 cm-1 resolution, 400 to 4400 cm1

 spectral range.

2. Does the instrument operate

according to an EPA method?

T EPA Test Method 320
AUDIT QUESTIONS

RESPONSE

COMMENT

Y N

N

A

Technical Systems Audit of Test Methods Performed by MRI 2.17

3. Describe the gas containment cell. T Infrared Analysis Model D-22H variable

pathlength White cell inside an Infrared

Analysis G-5-22-V-BA-AU heated gas

cell oven that was maintained at a

temperature of 250E C. The light path

was aligned with a laser. The

pathlength was approximately 9 to 10

meters and was determined on a daily

basis by measurement of the calibration

transfer standard (CTS).

4. Is the pressure in the gas

containment cell monitored?

T The cell pressure was monitored with an

Edwards Model W60041111 Barocel

pressure sensor with a 0 to 1000 mm Hg

range. This sensor is calibrated

annually at the factory and its readings

were verified using the barometer.

5. Describe the sample lines between

the sample distribution manifold

and the gas cell.

T A 20-foot length of Technical Heaters

sampling line connected the FTIR

instrument to the sample distribution

manifold. The sampling line was

maintained at a temperature of 300E F.

6. How are FTIR data recorded (e.g.,

data acquisition system)? Briefly

describe the system, giving its

brand, model, and serial number.

T Interferograms and sample spectra were

recorded on the hard drive of the

personal computer running the FTIR

software and on an external Iomega Jaz

drive.

7. Does the data recording system

have a provision for documenting

operating parameters (e.g.,

resolution, pathlength, scan

number, sampling time, etc.) for

individual spectra? If not, are

these parameters documented in

some other manner?

T The data recording system recorded

parameters (e.g., resolution) that were

directly related to the operation of the

FTIR instrument. Parameters (e.g.,

pathlength) that were not related to the

operation of the FTIR instrument were

recorded on a paper data sheet.

8. Is there a back-up for the data

recording system?

T The external Iomega Jaz drive was the

back-up data recording system.
AUDIT QUESTIONS

RESPONSE

COMMENT

Y N

N

A

Technical Systems Audit of Test Methods Performed by MRI 2.18

9. Can raw FTIR spectra be recovered

from the backup?

T Interferograms and sample spectra could

be recovered from the back-up data

recording system.

10. Describe the routine sampling and

analysis procedure for the

instrument.

T Sample gas flowed through the gas

containment cell on a continuous basis. 

The sample flow rate was 5 liters per

minute. Over a 2- to 2.5-minute

sampling interval, 100 interferometer

scans were coadded. The FTIR

instrument converted the coadded

Interferograms into sample spectra.

11. What is the leak volume for the gas

containment cell?

T Daily leak checks indicate that the cell

leak rate meets the acceptance criterion

of less than 4 %/minute.

12. What is the noise level in each

analytical region?

T Typical noise levels range between 10-3

and 10-4. On the morning of 22 July 98,

the noise level was 10-4 in the 1000 to

1300 cm-1 spectral region in which

volatile organic compounds (VOC)

absorb light. In general, noise levels are

dependent on sample moisture levels,

which will vary from source to source.

13. What is the sample absorption

pathlength for each analytical

region?

The nominal pathlength is 10.5 meters. 

The actual pathlength was determined

from measurements of the CTS. See

Item G35 below.

14. What is the fractional analysis

uncertainty for each analytical

region?

The calculated uncertainty in the

measured concentration of the CTS 

because of errors in the mathematical

comparison of reference and sample

spectra will be determined during the

post sampling analysis phase of the

project .

15. What is the calibration frequency? T The CTS was measured at the beginning

and end of each test. The sulfur

hexafluoride (SF6) calibration gas and

the SF6/toluene sampling bias check gas

were measured daily.
AUDIT QUESTIONS

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Technical Systems Audit of Test Methods Performed by MRI 2.19

16. Describe the routine calibration

procedure for the instrument.

T The gas containment cell was evacuated

to a pressure of 10 mm Hg and then was

filled to atmospheric pressure with the

CTS. The mean CTS concentration

across the entire project was compared

with the certified value to determine the

pathlength of the cell. The SF6 standard

was used for the capture efficiency tests. 

The SF6/toluene sampling bias check

was used to determine sampling line

losses by comparing the ratio of direct 

FTIR measurements of the two

compounds in the gas mixture with the

corresponding ratio for measurements of

the same gas mixture after it passed

through the sample probe calibration

valve and the sampling line.

17. Does the calibration

documentation show that the

calibration procedures are being

followed?

A letter from MRI to RTI presents CTS

calibration data which were collected

several times each day. No SF6 or

SF6/toluene calibration data were

presented in the letter because they will

be determined during the post sampling

analysis phase of the project.

18. What is the sampling system bias

according to the calibration

documentation?

The SF6/toluene calibration mixture is

delivered to the calibration valve on the

sample probe and directly to the FTIR

instrument. The bias will be determined

during the post sampling analysis phase

of the project by comparison of the two

sets of SF6/toluene data.

19. How frequently are background

spectra collected?

T Background spectra using pure nitrogen

were collected at the beginning and end

of the day. The first spectrum was used

routinely for the entire day unless the

second spectrum seemed to be more

representative.
AUDIT QUESTIONS

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Y N

N

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Technical Systems Audit of Test Methods Performed by MRI 2.20

20. Are emissions measurements

corrected for background

interference?

T Sample spectra were corrected for

background interferences associated

with the light source, the gas cell, and

the detector.

21. How are compounds in the sample

identified?

T Thomas Geyer will analyze sample

spectra and will identify detected

compounds after the completion of the

testing using reference spectra or other

spectroscopic analysis techniques.

22. What is the source of reference

spectra and absorption coefficients

for identified compounds?

T The EPA reference spectra database will

be the primary source of reference

spectra. Other spectral databases will

be used if necessary.

23. What will be done for compounds

without reference spectra?

T If MRI discovers significant,

unidentified spectral features in the

sample spectra, the EPA Work

Assignment Manager will be consulted

regarding whether these features are to

be identified by laboratory

measurements.

24. How will unidentified peaks be

reported?

T The primary goal of the testing was not

to identify all compounds in the sample

spectra, but to determine the

concentrations in the emissions of a

specific list of hazardous air pollutants

(HAPs) and other compounds.

25. How are concentrations

calculated?

T QAPP Section 4.4 states that a K-matrix

analytical procedure used uses sample

spectra collected during the emissions

testing and reference spectra for

identified compounds from the EPA

library to calculate a least-squares fit of

the spectral features and to determine a

concentration for each identified

compound.
AUDIT QUESTIONS

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N

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Technical Systems Audit of Test Methods Performed by MRI 2.21

26. What are the minimum detectable

concentration for the compounds

of interest?

T Scott Klamm estimated that the

minimum detectable concentration

ranges between 0.5 and 5 ppm

depending on the compound. Thomas

Geyer noted that the sensitivity limit is

at low ppb-levels and the minimum

quantitation limit (MQL) is in low ppmlevels for samples containing

considerable amounts of water and

carbon dioxide. For toluene and the

xylenes, the MQL is estimated to be

greater than the 100 ppb that was

measured during preliminary testing.

27. Does the FTIR instrument have

any spectral interferants for the

compounds of interest?

T Water vapor and carbon dioxide are

common analytical interferants in

sample spectra.

28. How are the FTIR data corrected

for analytical interferants?

T An integrated bag sample of the

emissions was collected for each test

run. The bag's moisture and carbon

dioxide levels were determined with an

Orsat analyzer. The measured levels

were used to select appropriate water

vapor and carbon dioxide reference

spectra for use in sample spectra

analysis by Thomas Geyer after

completion of the field portion of the

project.
AUDIT QUESTIONS

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Technical Systems Audit of Test Methods Performed by MRI 2.22

29. List the calibration transfer

standards (CTSs) for the FTIR

instrument

T The CTS was Scott Specialty Gases

cylinder number ALM005893

containing 99.9 parts per million (ppm)

ethylene in nitrogen. This gas mixture

was analyzed on 31 March 1998.

The SF6 tracer calibration gas was Scott

Specialty Gases cylinder number

ALM033887 containing 0.205 ppm SF6

in nitrogen. It was analyzed 7 April

1998.

The sampling bias check gas was Scott

Specialty Gases cylinder number

AAL17264 containing 3.83 ppm SF6

and 105 ppm toluene in nitrogen. It was

analyzed on 7 April 1998.

30. Do the CTSs have appropriate gas

mixtures and concentrations for the

sample gas mixtures and

concentrations? 

FTIR Protocol Section 4.5.1 specifies

that each analytical region lie within

25% of the CTS position. The CTS for

this testing is a compressed gas

calibration standard containing 100 ppm

(±2 %) ethylene in nitrogen. This gas

mixture was selected as the CTS

because it has an light absorption line at

949 cm-1, which meets the specification

for SF6 (942 cm-1), toluene (727 cm-1),

and xylenes (740 to 797 cm-1).

31. What is the analytical uncertainty

of the CTSs?

T A letter from MRI to RTI presents

certificates of analysis for CTS, SF6,

and SF6/toluene calibration standards. 

All three standards have an analytical

uncertainty of ±5%. Section 7.2 of Test

Method 320 directs the analyst to

"obtain a NIST-traceable, gravimetric

standard of the CTS (±2 percent)".
AUDIT QUESTIONS

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Technical Systems Audit of Test Methods Performed by MRI 2.23

32. Are the CTSs traceable to NIST

SRMs or otherwise traceable to

NIST? EPA Test Method 320

specifies that the CTS be a NISTtraceable gravimetric standard (±

2%).

T A letter from MRI to RTI states that the

calibration standards are traceable to the

specialty gas producer's primary

reference standards, which are prepared

using gravimetric procedures. These

calibration standards are not traceable to

NIST as NIST defines traceability for

compressed gas standards. NIST does

not have SRMs for this gas mixture. 

33. Have the CTSs been independently

verified by MRI?

T The calibration standards were not

independently verified by MRI.

34. Are the CTS regulators and

delivery system properly

maintained?

T The pressure regulators and the

associated gas handling equipment

appear to be well-maintained.

35. What is the variation of successive

CTS absorbency measurements

relative to their mean value?

T A letter from MRI to RTI presents the

CTS calibration data, which yielded a

mean pathlength of 10.475 meters and a

maximum deviation from the mean of

0.337 meters or 3.2% of the mean. 

These data meet the QAPP's precision

specification of agreement to within

±%5 of the mean.

36. Is there a schedule of preventive

maintenance for the FTIR

instrument?

T The instrument is three years old and

Scott Klamm indicated that it had not

been serviced by a factory

representative during that period. All

maintenance is done on an as-needed

basis.

37. Are calibration and maintenance

logs kept for the FTIR instrument?

T Calibration data are recorded on data

sheets, rather than in logbooks. There

are no maintenance logs.
AUDIT QUESTIONS

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Technical Systems Audit of Test Methods Performed by MRI 2.24

38. Review any maintenance and

operational records for the FTIR

instrument. Based on these

records, does the instrument appear

to be in good operating condition?

T The FTIR instrument was manufactured

by KVB Analect, which is located in

Irvine, California. A factory service

representative optimized the

interferometer on 20 July 1998 in the

presence of the assessors. The FTIR

instrument appeared to be in good

operating condition after it was

optimized.

39. Are the manufacturer’s operating

manuals readily available to the

FTIR instrument operators?

T Neither MRI's FTIR operator nor the

KVB Analect factory service

representative had a copy of the

operating manual.

Additional Questions or Comments: QAPP Section 3.1.1 states that the time for 5 cell volumes to

pass through the cell is considered the minimum interval separating independent samples. If the cell

volume is 8.5 L, then 5 cell volumes corresponds to 42.5 L. If the FTIR sample gas flow rate is 5

L/min and the FTIR sample interval is 2.5 minutes, only 12.5 L (or 1.5 cell volumes) of sample gas

passes through the cell between measurements. Therefore, a individual FTIR measurement cannot be

considered to be completely independent of the measurements that immediately precede it. Scott

Klamm confirms that it takes 3 to 4 samples to flush the cell for CTS measurements.

During the emissions testing, MRI analyzed a nine-component hydrocarbon calibration standard

(Spectra Gases cylinder number CC91245) that had been brought to the hot mix asphalt plant by

Emissions Monitoring, Inc. The analysis of this calibration standard does not constitute a

performance evaluation of the extractive FTIR method because MRI was not informed of the analysis

prior to the emissions testing nor during our initial on-site meeting on 20 July 1998. The results of

the analysis were not available during the RTI assessor's conversation with MRI's Thomas Geyer on

August 27, 1998. RTI suggests that the results of the MRI's analysis of this calibration standard be

included in MRI's emissions testing report, which will allow EPA to compare the MRI analytical

results with the attached certificate of analysis for the calibration standard.
AUDIT QUESTIONS

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Technical Systems Audit of Test Methods Performed by MRI 2.25

G. SAMPLE CONCENTRATOR FOR FTIR INSTRUMENT

1. Describe the sample concentrator. T Samples were concentrated for FTIR

analysis by pulling source gas through

two traps containing 20 grams of Tenax

adsorbent. VOCs that were collected on

the Tenax were desorbed by heating the

trap to 220E C. Nitrogen flowing

through the heated trap transferred the

VOCs to an evacuated gas containment

cell, which has a volume of 8.5 L. If the

source gas flowed through the Tenax

trap for 4 hours at a flow rate of 1.5

L/min, source gas samples were

concentrated by a factor of about 42.

2. Does the concentrator operate

according to an EPA method?

T The method is still experimental and has

not been standardized as an EPA test

method.

3. If it is not an EPA method, what

documentation exists concerning

laboratory and field validations of

the concentrator?

See comment below Item G32.
AUDIT QUESTIONS

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Technical Systems Audit of Test Methods Performed by MRI 2.26

4. Have the validations involved the

compounds of interest to this

study?

T SSTP Section 4.1.2 states that 

preliminary measurements by Pacific

Environmental Services (PES) at the

asphalt plant indicated the presence of

toluene and xylenes at concentrations

below 100 ppb.

The 1993 FTIR method validation

report by Entropy Environmentalists

included the following correction

factors and relative standard deviations

(RSDs) in concentrated samples:

 Correction

Compound Factor RSD(%) 

 toluene 0.83 10.31

 m-xylene 0.78 4.85

 p-xylene 1.16 14.25

For the method to be acceptable, the

correction factor must be between 0.70

and 1.30 and the RSD must be < 50%.

MRI does not plan to correct the

indirect FTIR data for the surrogate

spike gas collection efficiency.

5. Describe the sample lines between

the sample distribution manifold

and the concentrator.

T The sample concentrator was not

connected to the sample distribution

manifold. It was mounted on a separate

VOST sampling train at the sampling

port.

6. Describe how sample is drawn

through the Tenax adsorbent trap.

T Source gas is pulled through the

sampling probe, a 5-foot run of heated

sampling line, an intake manifold, a

condenser, one Tenax trap, a water

drop-out trap, a second condenser, a

second Tenax trap, and a Nutech Model

280/01BVOST pump box.
AUDIT QUESTIONS

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Technical Systems Audit of Test Methods Performed by MRI 2.27

7. What are the sample flow rate,

sample duration, and sample

volume?

T The sample flow rate was 1.5 L/min, the

sample duration was 4 hours, and the

sample volume was 360 L.

8. Describe how the flow rate is

measured and controlled.

T A Matheson rotameter measured the

sample flow rate and a needle valve

controlled the flow rate.

9. Describe how the total sample

volume is measured.

T A Single Model 802 dry gas meter in the

VOST pump box measured the sample

volume. 

10. Describe how the sample volume

meter is calibrated.

T The dry gas meter and the rotameter

were calibrated by a wet test meter in

three separate runs of 14 to 21 L each 

11. When was the last time that the

sample volume meter was

calibrated?

T 13 July 1998

12. Is the volumetric calibration

traceable to NIST standards?

The wet test meter was calibrated on an

annual basis with a calibrated water

volume, which MRI considers to be a

primary standard. A wet test meter

calibration data sheet dated 2 May 1997

shows that it was calibrated according to

ASTM Method D1071-83.

13. How is the first condenser's

temperature measured?

T The temperature was measured with a

Type-K thermocouple and a Omega

Model HH81 digital thermometer.

14. How is the first condenser's

thermometer calibrated?

T The thermocouple was calibrated with a

boiling water bath, an ice water bath, or

a recently-acquired dry well as

appropriate. An ASTM mercury-inglass thermometer was the reference

standard.

15. When was the last time that the

first condenser's thermometer was

calibrated?

T 24 March 1998

16. Is the thermometer calibration

traceable to NIST standards?

T ASTM thermometers are traceable to

NIST.
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Technical Systems Audit of Test Methods Performed by MRI 2.28

17. How is Tenax cleaned prior to

sampling?

T Precleaned Tenax was purchased for the

emissions testing. Before a Tenax trap

was used, it was further cleaned by

being heated in the thermal desorber to

180E C for 1 hour while nitrogen

removed any residual VOCs. The

Tenax trap was then desorbed into the

FTIR instrument and a blank spectrum

for the cleaned trap was recorded. 

18. Has the Tenax used in this project

passed the 5-ppb THC pass/fail

criterion for cleanliness?

T Cleanliness for cleaned Tenax traps was

verified by field FTIR checks, rather

than by laboratory FID checks, which

are associated with the 5 ppb cleanliness

criterion.

19. What is the surrogate spike gas? T Scott Specialty Gases cylinder number

ALM031809, 10.6 ppm toluene-d8 in

nitrogen, analyzed 2 April 1998. The

attached certificate of analysis lists the

analytical accuracy of ±5%. Section 9.1

of Test Method 320 specifies the use of

"a certified standard (accurate to ±2

percent) of the target analyte, if one can

be obtained".
AUDIT QUESTIONS

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Technical Systems Audit of Test Methods Performed by MRI 2.29

20. Does the surrogate spike gas have

an appropriate gas mixture and

concentration for the sample gas

mixture and concentration? 

T SSTP Section 5.2 states that toluene was

chosen as the surrogate spiking gas

based on results reported by PES from

preliminary sampling conducted during

their pretest site survey. These

measurements indicated the presence of

toluene and xylenes at concentrations

below 100 ppb. Item G1 above

determines the Tenax concentration

factor to be 42. If the sample

concentration method had been used

during PES' preliminary measurements,

the toluene concentration in the gas cell

would have been less than 4.2 ppm. 

This calculated concentration differs

from the surrogate spiking gas

concentration by a factor of 2.5. 

Appendix D in the QAPP states that

surrogate spiking gas concentrations

should approximate the levels expected

in the trap after sample collection.

21. How is the surrogate spike gas

added to the sample?

T Approximately 1 gas cell volume of the

surrogate spike gas was loaded onto the

Tenax trap before sampling using the

thermal desorber at ambient

temperature. Note that this spiking

procedure deviated from QAPP Section

5.1.3, which states that the vapor-phase

spike will be heated and injected into

the back of the sampling probe, similar

to the Method 320 analyte spike

procedure. This deviation was

necessary because a VOST train was

used to pull source gas directly from the

source through about 5 feet of heated

sample line into the Tenax trap.
AUDIT QUESTIONS

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Technical Systems Audit of Test Methods Performed by MRI 2.30

22. Describe any ambient air samples

that are collected.

T An ambient air sample was collected on

the morning of Wednesday, 22 July

1998 using VOST Control Box #3. The

sample was collected at the load-out

tunnel entrance where diesel trucks wait

to be loaded.

23. Describe any train blanks that are

collected.

T A train blank was collected in the trailer

at the beginning of the emissions testing

by passing 90 L (1.5 L/min for 1 hour)

of nitrogen through the Tenax train

24. Describe any preliminary sampling

that occurs.

T No preliminary sampling was conducted

due to time delays at the beginning of

the emissions testing due to asphalt

plant equipment breakdowns.

25. Describe any duplicate train

samples that are collected.

T A duplicate train sample was collected

on 25 July 1998, but the FTIR sample

spectrum was not saved. A second

attempt to collect a duplicate train

sample was scheduled for 27 July 1998

after the assessors departure. The

results of the post sampling analysis of

this sample were not available for

review as of 27 August 1998.

26. Describe any breakthrough traps

that are used in the sample train.

T A second Tenax trap was mounted

downstream of the first trap to collect

any VOCs that might break through.

27. Describe how Tenax samples are

stored prior to analysis.

T Tenax traps were capped after sampling

and then were stored on ice until they

were analyzed.

28. How much time elapses between

sampling and analysis of Tenax

samples?

T In general, the Tenax traps are analyzed

within an hour or two of the end of a

test run. However, the traps of 24 July

1998 were not analyzed until 25 July

1998 due to the need to produce cleaned

traps for the next day.
AUDIT QUESTIONS

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Technical Systems Audit of Test Methods Performed by MRI 2.31

29. How are Tenax samples identified? T All Tenax traps had an engraved

number on their bodies. Additionally,

green sticky tape with the intended

usage was attached to the traps after

cleaning.

30. How is the sample desorbed from

the Tenax and transferred to the

gas containment cell?

T The FTIR gas containment cell was

evacuated to a pressure of 10 mm Hg. 

The Tenax trap was heated to 220E C in

the thermal desorber. A heated transfer

line at 250E C was opened between the

thermal desorber. Nitrogen carried the

VOCs into the 8.5-L gas cell at a flow

rate of 1 L/min until the cell returned to

atmospheric pressure.

31. What current or previous data are

available concerning the

desorption efficiencies for the

compounds of interest and the

surrogate gas?

T The 1993 FTIR method validation

report by Entropy Environmentalists

included the following correction

factors:

 toluene 0.83

 m-xylene 0.78

 p-xylene 1.16

For the method to be acceptable, the

correction factor must be between 0.70

and 1.30 as per EPA Method 301. No

information is available for the

desorption efficiencies for other

compounds that might be found in the

asphalt plant.

32. What is the detection limit for the

compounds of interest using the

sample concentrator?

T The attached letter from MRI implies

that sampling parameters were chosen to

obtain minimum detectable

concentrations of 100 ppb for toluene

and xylene, which were identified by

PES' preliminary measurements.
AUDIT QUESTIONS

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Technical Systems Audit of Test Methods Performed by MRI 2.32

Additional Questions or Comments: The sample for the morning of 22 July 1998 had an ambient

air leak for an unknown period of time (10 minutes?) due to the first condenser separating from the

inlet manifold.

There is little documentation for the FTIR sample concentration method. The QAPP contains a fairly

general discussion of the method that only briefly mentions the validations of the method. The

validations were reported to EPA in project reports by Entropy Environmentalists and MRI. In 1993,

Entropy performed a FTIR method validation at a coal-fired boiler. Multi component gas mixtures

were spiked into boiler emissions, which were sampled by four parallel sample concentrators similar

to the one used in this emissions testing.

This method validation found that EPA Method 301 validation criteria were met for toluene and

xylenes in concentrated samples. Pacific Environmental Services found these compounds during its

preliminary measurements at the hot-mix asphalt plant. If MRI discovers significant concentrations

of other chemical compounds in the asphalt plant emissions, then the report of MRI's emissions

testing should note that the FTIR sample concentrator method has not been validated for these

additional compounds.

The 1993 tests used a KVB Analect Model RFX-40 FTIR instrument with a MCT detector and an

Infrared Analysis Model 5-22H gas containment cell with a pathlength of 22 m. The sample volume

was 280 L. The target gas mixture concentrations in the FTIR gas cell were 20 ppm. The CTS was

100 ppm ethylene in nitrogen.

H. TOTAL HYDROCARBONS (THC) ANALYZER

1. Describe the THC analyzer. List

the brand, model number, and

serial number.

T Two J.U.M. Engineering Model VE7

total hydrocarbon analyzers were used

for the emissions testing. A third

analyzer was rented when one of the

original analyzers failed.

2. Does the THC analyzer operate

according to an EPA method?

T EPA Test Method 25A

3. How are THC data recorded (e.g.,

data acquisition system)? Briefly

describe the system, giving its

brand, model, and serial number.

T THC data were recorded with a

Winbook XP laptop computer with a

data acquisition system docking station

and Labtech Notebook software. Data

were collected at 1-second intervals and

1-minute mean concentrations were

stored on the computers hard drive.
AUDIT QUESTIONS

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Technical Systems Audit of Test Methods Performed by MRI 2.33

4. Does the THC data recording

system have a provision for

documenting changes in operating

parameters? If not, are changes in

operating parameters documented

in some other manner?

T The data recording system collected the

date and time, but not other operational

parameters. Other parameters,

including calibration data, were

recorded on a legal pad.

5. Is there a hard copy back-up for the

THC data recording system?

T A paper copy of data from the computer

is printed by a Panasonic KX-P1180i

printer.

6. Can THC data be recovered from

the hard copy backup?

T Data would have to be reduced by hand

from the paper copy.

7. Describe the sample lines between

the sample distribution manifold

and the THC analyzer.

T Approximately 6 feet of heated

sampling line connect the sample

distribution manifold to the THC

analyzer. The sampling line was

maintained at 300E C.

8. Describe how sample is drawn

through the THC analyzer.

T A pump pulled sample into an oven

heated to 300E C and through a sample

filter at a flow rate of approximately 2.5

L/min. The pump pushed sample

through a sample capillary into the

flame ionization detector (FID). The

excess sample was vented through a

bypass capillary. A back-pressure

regulator and a pressure gauge controls

the sample pressure to approximately

200 millibar (or 3 psig) inside the

instrument.

9. What is the sample flow rate and

the bypass flow rate?

T The total sample flow rate was

approximately 2.5 L/min and the flow

rate into the FID was approximately 20

mL/min.

10. Describe how the flow rates are

measured and controlled.

T The flow rates are controlled by the

capillaries and the back-pressure

regulator. The flow rates are not

measured.

11. Describe how the flow rate meters

is calibrated.

T Not applicable.
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Technical Systems Audit of Test Methods Performed by MRI 2.34

12. When was the last time that the

flow rate meters were calibrated?

T Not applicable.

13. List the flame ionization detector

hydrogen (vendor, grade, etc.).

T Air Products cylinder number

SGKK064 (40%hydrogen, 60% helium,

analyzed on 11 June 1998).

14. List the flame ionization detector

burner air (vendor, grade, etc.).

T Ambient air is drawn through a charcoal

scrubber by an internal pump and

hydrocarbons in the air are removed. 

Bob Gulick indicated that methane

passes through the scrubber.

15. What is the THC analyzer

calibration frequency?

T As per Method 25A, the THC analyzer

is calibrated at the beginning of the test

run and a drift check is done at the end

of the run. Bob Gulick will do more

frequent drift checks if he is concerned

about possible drift during a test run.

16. Describe the routine THC analyzer

calibration procedure.

T Calibration gas mixtures of varying

concentrations (e.g., 0, 25, 50, and 90

ppm) are prepared in the Environics

Model 2020 gas dilution system from a

propane calibration standard and

nitrogen. The calibration gas mixtures

flow through the sample line to the

calibration valve in the sample probe.

17. Does the THC analyzer calibration

documentation show that the

calibration procedures are being

followed?

T The attached letter from MRI presents

draft calibration data for the THC

analyzer, which indicate that the

calibration procedures were followed.

18. List the THC calibration gases

(including zero gas).

T Air Products and Chemicals cylinder

number SG9168085, 3690 ± 23 ppm

propane in nitrogen (EPA Protocol

Gas), analyzed by gas chromatographyFID on 5 August 1996.
AUDIT QUESTIONS

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Technical Systems Audit of Test Methods Performed by MRI 2.35

19. Do the THC calibration gases have

appropriate gas mixtures and

concentrations for the sample gas

mixtures and concentrations? 

T The THC calibration gas mixture is

appropriate. The concentration is

appropriate because the gas mixture is

diluted by an Environics Model 2020

gas dilution system, whose flow meters

were calibrated at the factory using a

Sierra Cal Bench on 23 April 1998.

20. What is the analytical uncertainty

of the THC calibration gases?

T The analytical uncertainty of the THC

calibration gas is 23 ppm or 0.6 percent

of the certified concentration. The

specified uncertainty of the gas dilution

system's flow rates is 0.5 percent.

21. Are the THC calibration gases

traceable to NIST SRMs or

otherwise traceable to NIST?

T The THC calibration gas is traceable via

a 4723 ppm propane gas manufacturer's

internal standard (GMIS), which is

directly traceable to a NIST SRM.

22. Have the THC calibration gases

been independently verified by

MRI?

T An independent verification is not

necessary because the THC calibration

gas is an EPA Protocol Gas.

23. Are the THC calibration gas

regulators and delivery system

properly maintained?

T No problems were observed.

24. What is the THC analyzer

calibration error according to the

calibration documentation?

T The attached letter from MRI presents

draft calibration data for the THC

analyzer, which indicate that the

calibration error ranged between 0.0%

and 4.8%, which is less than the ±5%

criterion specified in Test Method 25A.

25. What is the THC analyzer linear

error according to the calibration

documentation?

T Section 2.2.1.2 of the QAPP specifies a

±2% accuracy criterion for linear. 

However, this criterion does not appear

in Test Method 25A and appears to be

an error in the QAPP.
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Technical Systems Audit of Test Methods Performed by MRI 2.36

26. What are the THC analyzer zero

and calibration drifts according to

the calibration documentation?

T The attached letter from MRI presents

draft calibration data for the THC

analyzer, which indicate that zero drift

ranged between 0.0% and 1.0%, which

is less than the ±3% criterion specified

in Test Method 25A. Span drift ranged

between 0.0% and 1.4%, which is less

than the ±3% criterion.

27. What is the sampling system bias

according to the THC analyzer

calibration documentation?

T Section 2.2.1.2 of the QAPP specifies a

±5% accuracy criterion for systems bias. 

However this criterion does not appear

in Test Method 25A and appears to be

an error in the QAPP.

28. Is there a schedule of preventive

maintenance for the THC

analyzer?

T Maintenance is performed on an asneeded basis in MRI's laboratories and

in the field.

29. Are calibration and maintenance

logs kept for the THC analyzer?

T No logs are available.

30. Review maintenance and

operational records for the THC

analyzer. Based on your findings,

does it appear to be in good

operating condition?

T Visual Inspection of the two THC

analyzers indicates that they were in

good operating condition at the

beginning of the project. See additional

comment below.

31. Are the manufacturer’s operating

manuals readily available to the

THC analyzer operator?

T The operator has a manual for the THC

analyzer.
AUDIT QUESTIONS

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Technical Systems Audit of Test Methods Performed by MRI 2.37

Additional Questions or Comments: Something associated with emissions from the silo seemed to

be damaging THC analyzers. Beginning on 23 July 1998, one THC analyzer sampled the load-out

tunnel and another THC analyzer sampler the silo. On 24 July 1998, the silo THC analyzer's FID

flamed out and could not be relighted. The remaining THC analyzer sampled both locations until

early afternoon on 25 July 1998 when it also flamed out. A rental THC analyzer arrived at noon on

25 July 1998 and was used for the remainder of the day. The second THC analyzer's FID was baked 

at high temperature and appeared to be operational on 26 July 1998, although it was not used for that

day's sampling. One hypothesis is that heavy hydrocarbons from the silo or their oxidation products

may be clogging the FID burner tip. However, a 20 August 1996 e-mail message from a JUM

Engineering representative to RTI indicates that a number of their THC instruments are operating at

asphalt plants for raw emissions as well as for emissions after treatment.

There appear to be some errors in the draft THC calibration data the MRI submitted for review. The

span drift data for stack dryer Runs 1 and 2 are identical, which is an unlikely occurrence. There

appear to be errors in the calculated span drifts for Dryer Stack Run 1 and Load-out Run1. These

errors do not appear to be major problems.

I. CAPTURE EFFICIENCY TEST

1. Describe the apparatus for

releasing the tracer gas.

T Tracer gas passes from a compressed

gas cylinder through a pressure gauge

and a mass flow meter to four sets of

toggle valves and needle valves, which

are set to deliver 4 L/min. Teflon®

tubing goes from each needle valve to

six critical orifices that are set at the

base of one asphalt silo. Each critical

orifice has a maximum flow rate of 0.8

L/min.

2. How is the tracer gas measured? T Tracer gas is measured by the extractive

FTIR instrument .

3. How does the tracer gas operator

switch from one release point to

another release point?

T The tracer gas operator uses the toggle

valves to control silo at which tracer gas

is being released. Information about

which silo is being used is radioed to the

operator from an observer in the asphalt

plant's control room.
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A

Technical Systems Audit of Test Methods Performed by MRI 2.38

4. Describe the tracer gas. T Scott Specialty Gases cylinder number

ALM013870, 1.99 percent sulfur

hexafluoride (SF6) in nitrogen (certified

working standard), analyzed on 2 April

1998.

5. Does the tracer gas have an

appropriate gas mixture and

concentration for the capture

efficiency test? 

T If the load-out tunnel emissions control

system has a flow rate of 15,000 dscm,

the FTIR instrument will sample a SF6

concentration of 0.19 ppm, which is

easily detected by the extractive FTIR

instrument with a 10-meter pathlength.

The SF6 calibration gas has a

concentration of 0.205 ppm , which

closely matches the sample's SF6

concentration

6. What is the analytical uncertainty

of the tracer gas?

T ±5 percent

7. Is the tracer gas traceable to NIST

SRMs or otherwise traceable to

NIST?

T The tracer gas is traceable to the

specialty gas producer's primary

standards.

8. Has the tracer gas been

independently verified by MRI?

T

9. Is the tracer gas regulator and

delivery system properly

maintained?

T The equipment appears to have been

properly maintained.

10. What is the tracer gas flow rate? T 4 L/min

11. Describe how the tracer gas flow

rate is measured and controlled.

T The flow rate is measured by a mass

flow meter and is controlled by a needle

valve.

12. Describe how the tracer gas flow

rate meter is calibrated.

T The flow meter was calibrated with a

Sierra Instruments Cal-BenchTM (serial

number AN0125), which has a 1%

accuracy.

13. When was the last time that the

tracer gas flow rate meter was

calibrated?

T 30 April 1998
AUDIT QUESTIONS

RESPONSE

COMMENT

Y N

N

A

Technical Systems Audit of Test Methods Performed by MRI 2.39

14. Is the tracer gas flow rate

calibration traceable to NIST

standards?

T The Sierra Instruments Cal-BenchTM

automated primary gas flow calibration

system is traceable to NIST length and

time standards.

Additional Questions or Comments:
Technical Systems Audit of Test Methods Performed by MRI 2.40

Midwest Research Institute Standard Data Forms for

Emissions Testing at a Hot Mix Asphalt Plant
Mr. Robert Wright

Research Triangle Institute

3040 Comwallis Road

Post Office Box 12 194

SUBJECT TO C/3 ZGiGFIDENTIAL

BWNESS !NFOHk%TICN CLAIM

Does Not CanfainNafional Security lnfomdion

Research Triangle Park, NC 27709

Dear Mr. Wright,

Enclosed are responses to your request for technical information related to the

technical system audit of the recent emissions testing at a hot-mix asphalt plant

performed by Midwest Research Institute @4RI). In attempting to respond to your need

for timeliness of a draft report (August 21) all issues easily completed have been

included in this response. Several issues, however, cannot be completed at this time, and

are expected to be available through our report to EPA which is due by September 30,

1998. These issues have been appropriately marked in the following list. I have also

included your original references to “checklist section” for clarity.

1 . (A9) Raw quality control/calibration data sheets and/or calculated calibration data for

the FTlR instrument (e.g. CTS, SF6, or SF61toluene measurements) and the total

hydrocarbon instrument (e.g. calibration error, linearity error, zero and calibration

drift, sampling system bias.

Both the FTIR and THC met all calibration requirements during the test program,

FTIR pathlength determination and CTS calculations are attached. Criteria for

pass/fail for the CTS spectra are +/- 5%, which all ofthe CTS spectra met.

SF61toluene determinations are not yet complete, but will be included in the final

report.

THC calibration error, zero drill and calibration drift calculations are also attached.

The THC analyzer met all criteria, which include +/- 5% for calibration error, and +/-

3% for zero drift and calibration drift. Procedures followed EPA Method 25A, which

requires calibrations through the sample line. Thus, there are no other linearity or

system bias checks associated with this method.

Note that the attached data have not been finalized and approved by MRl’s QA

procedures and have been stamped as “Drafi.”
24. (H18) A copy ofthe certificate of analysis for the THC analyzer’s calibration gas and

information about its analytical uncertainty, traceability, and any independent

concentration verifications.

The THC calibration gas certificate of analysis is attached. The gas is an EPA

Protocol gas, and meets all requirements of that certification.

25. (Hl8) Information about the annual factory calibration of the Environics Model 2020

gas dilution system and any field evaluations according to EPA Test Method 205.

Calibration records for the Environics gas dilution system are attached

26. (H30) Information about any maintenance logs for the THC analyzer

THC maintenance is performed on an as needed basis in MRI’s laboratories and in

the field. No other maintenance logs are available.

I hope you find the attached information helpful and allow you to complete those

sections of your audit. If you have additional questions, please feel free to call me at

816-753-7600, ext. 1228.

Sincerely,

Scott W. Klamm

Environmental Engineer

cc: J. Hosenfeld

J. Balsinger

T. Geyer

M. Toney
2 . (AIO) Blank copies of data sheets used for recording load-out operations data and

tracer gas release data.

Blank copies of data sheets used for recording load-out operations data and tracer gas

release data are attached.

3 . (A14) Identification ofany MRI personnel performing reviews of QC data from the

emissions testing.

MRI has a formal review process for all reports generated under this contract. The

review process includes a review and signature requirement by the Work Assignment

Leader, Program Manager, and Senior Quality Assurance Officer. Specific to this

project, these individuals would be Mr. Scott Klamm (Field Team Leader), Dr. Tom

Geyer (FTIR Oversight), Mr. John Hosenfeld (Work Assignment Leader), Dr. Bruce

Diel (OPPT Program Manager), and Mr. Jack Balsinger (Senior Quality Assurance

Oflicer). These individuals are in accordance with the organizational chart (Figure

l-l) ofthe QAPP.

4 . (C3) Information about any current summaries (e.g. training files) of the training and

qualifications of each project team member.

MRI maintains a file of personnel resumes and curriculum vitae for each project team

member detailing their experience and qualifications. Single page summaries for

each team member are attached.

5. (C4) Information about any descriptions of individual project team member

responsibilities.

Individual project team member responsibilities are briefly summarized in the QAPP,

Section 1.4. Specific responsibilities not described in the QAPP were assigned at

MRI project coordination meetings prior to the field phase, and were updated on a

daily basis during the field effort

6 . (D4) Information about the source (e.g. documented performance criteria or actual

QC data) for the data quality indicator goals for the sample concentration FTIR

method.

This comment will be addressed in the report
7 . (F12) Information about noise levels for each FTIR analytical region

As demonstrated to RTI in the field, RMSD noise levels in the sample spectra were

on the order ofO.OOO1 absorbance units in the 1000-1300 wavenumber region, In the

report, RMSD in the residual (subtracted) spectra will also be calculated (i.e. after

analysis).

8 . (F13) Information about sample absorption pathlengths for each FTIR analytical

region.

The average pathlength for the test program was determined from the daily CTS

spectra, and is included in the CTS stability calculations described earlier in Item 1,

and contained in the attachment for Item 1. These preliminary pathlengths were

calculated from raw field parameters and are subject to revision in the report,

9 . (F14) Information about fractional analysis uncertainties for each FTIR analytical

region.

This comment will be addressed in the report.

10. (F25) A description about how analyte concentrations are quantitated from FTIR

absorption spectra.

These procedures are outlined in EPA Method 320 and the FTIR Protocol included in

the QAPP. Specific aspects of the analyses and deviations from the methods will be

included in the report.

11. (F26) Information about minimum detectable concentrations for the compounds

found during the emissions testing by the extractive FTIR method.

A summary of minimum detectable concentrations for non-detects will be included in

the report

12. (F29) A copy of the certificates of analysis for the CTS, the SF6, and the SF6/toluene

standards.

Copies of certificates of analysis for the CTS, SF6, and SF6itoiuene sases have been

attached.
13. (F30) Information relating to the basis for selection ofthe CTS gas mixture and

concentration relative to the selection criteria given in Section 4.5 ofthe FTIR

Protocol.

Ethylene has been used as a CTS gas on numerous EPA test programs, and meets the

criteria given by the FTIR Protocol.

14. (F3 1) Information about the uncertainty of the analysis of the CTS, the SF6, and the

SF6/toluene standards.

Analytical accuracy for each of these gas standards is contained on their respective

certificates of analyses. All are listed as +/- 5%.

15. (F32) Information about the traceability ofthe analysis ofthe CTS, the SF6, and the

SF6Itoluene standards to NIST.

Scott Specialty Gases uses gravimetric procedures to generate their gas standards.

They do not claim NIST traceability, but, rather, are certified by their own internal

calibrations and standard procedures.

16. (F33) Information about any independent concentration verifications of the CTS, the

SF6, and the SF6koluene standards by h4RI.

See Items 14 and 15, above

17. (F34) Information about the variability of successive CTS measurements.

Variability of successive CTS measurements will be included in the report, and can

be seen from the calculations presented earlier in Item 1. The CTS measurements

met the Protocol requirements of +/- 5% precision.

18. (F37) Information about any maintenance logs for the FTIP. instrument

CTS stability is the primary indicator of instrument operations. When necessary,

FTIR maintenance is performed on an as needed basis in MRI’s laboratories and in

the field. For this particular test program, the instrument was serviced by an Analect

representative on July 20, was found to be in good working order, and did not require

any corrective actions.
19. (G3) Information about any Entropy Environmentalists or MRI laboratory or field

validations of the sample concentration FTIR method for the compounds found

during the emissions testing.

This information was provided to RTI while in the field (Fourier Transform Infrared

Method Validation at a Coal-tired Boiler, Entropy Environmentalists, July 1993,

published by EPA in 1994).

20. (G12) Information about the calibration traceability of the wet test meter used to

calibrate dry gas meters in the VOST sampling trains associated with the sample

concentration FTIR method.

MRI calibrates the dry gas meters versus a wet test meter located at our Kansas City

laboratories, The wet test meter is calibrated according to the displacement method

and is, therefore, considered a primary standard. Calibration records for the wet test

meter and the VOST consoles are kept on tile and are available upon request.

21. (G19) A copy of the certificate of analysis for the toluene-d8 surrogate spiking gas

and information about its analytical uncertainty, traceability, and any independent

concentration verifications.

A copy of the toluene-d8 certificate of analysis is attached.

5%.

The gas is certified to +/-

22. (G3 1) Information about any Entropy Environmentalists or MRI laboratory and/or

field determinations of the collection and desorption efliciencies of the sample

concentration FTIR method for the compounds found during the emissions testing.

See Item 19. above.

23. (G32) Information about minimum detectable concentrations for the compounds

found during the emissions testing by the sample concentration FTIR method.

Minimum detectable concentrations for this method are, by nature, dependent upon

the compound and sampling parameters, and will be estimated in the report. For this

test, sampling parameters were chosen to obtain 100 ppb of toluene and xylene,

which were identified by PES in a preliminary screening.

c
Attachment 1

Item 1 (A9)
Filename ctspath Temp. (C) Pathlength (m) % Diff.

co721 b 2.7207 124 10.812 3.22

~0721~ 2.6321 124 10.460 -0.14

c072Id 2.6718 124 10.618 1.37

c072Ie 2.6181 124 10.404 -0.67

c0722a 2.6234 124 10.425 -0.47

c0722b 2.6280 124 10.444 -0.30

c0723.a 2.6131 124 10.364 -0.86

c0723b 2.6162 124 10.397 -0.74

~0723~ 2.6420 124 10.499 0.24

c0724a 2.6242 124 10.429 -0.44

c0724b 2.6536 124 10.545 0.68

~0725~1 2.6122 124 10.381 -0.89

c0725b 2.6247 124 10.430 -0.42

~0725~ 2.6582 124 10.564 0.85

c0726a 2.6390 124 IO.487 0.12

c0726b 2.6378 124 10.483 0.08

cO727a 2.6220 124 10.420 -0.52

c0727b 2.6268 124 10.439 -0.34

~0727~ 2.6283 124 10.445 -0.28

c0727d 2.6234 124 10.425 -0.47

CTS Pathlength and % Difference Calculations

Average = 10.475

DRAFT

Pathlength is based on use of a 99.9 ppm ethylene standard.

% Difference is based on the average calculated pathlength.
THC

Cal Gas Measured Difference

Value Value As % Error

0.0 0.0 0.0 Pass

90.3 90.2 0.1 Pass

50.2 50.9 1.4 Pass

25.0 25.0 0.0 Pass

Run 1 - Dryer Stack - 7121198

Calibration Error Determination

Pass/ Fail

Instrument Span for THC is 100 ppm

Pass/Fail Criteria is +I- 5% of Cal Gas for THC

Zero Drift

Initial 1 st Drift Check Difference

Value Value As % Error

0.0

1 st Drift Check Final Difference

Value Value As % Error

0.3

Initial 1 st Drift Check Difference

Value Value As % Error

90.2

1 st Drift Check Final Difference

Value Value As % Error

0.3 0.3

0.3 0.0

Span Drift

89.9 0.7 Pass

Pass/Fail

Pass

Pass/Fail

Pass

Pass/Fail

Pass/Fail

89.9 89.5 0.4 Pass
Run 2 -Dryer Stack - 7122198 DRAFT

Calibration Error Determination

Cal Gas

Value

Measured

Value

Difference

As % Error

Pass/ Fail

0.0

90.3

50.2

25.0

0.2 0.2 Pass

90.1 0.2 Pass

50.6 0.8 Pass

25.6 2.4 Pass

THC

Instrument Span for THC is 100 ppm

Pass/Fail Criteria is +/- 5% of Cal Gas for THC

Zero Drift

1 st Drift Check

Value

Difference

As % Error

Pass/Fail

Value

0.2 -0.1 0.3 Pass

1 st Drift Check Pass/Fail

Value

-0.1

Final

Value

Difference

As % Error

0.3 0.4 Pass

Span Drift

initial

Value

1 st Drift Check

Value

Difference

As % Error

Pass/Fail

90.2 89.9 0.7 Pass

1 st Drift Check Final Pass/Fail

Value Value

Difference

As % Error

89.9 89.5 0.4 Pass
. .

Run 1 - Load Out - 7/23/98 (aborted)

Calibration Error Determination

Cal Gas

Value

Measured

Value

Difference

As % Error

Pass/ Fail

THC Silo 0.0 3.6

899.0 900.0

498.0 504.0

249.0 256.0

Instrument Span for THC Silo is 1000 ppm

Pass/Fail Criteria is +/- 5% of Cal Gas for THC

0.4

0.0

1.2

2.8

Pass

Pass

Pass

Pass

Cal Gas Measured Difference

Value Value As % Error

Pass/ Fail

THC Tunnel 0.0 0.2

90.4 90.2

50.2 49.8

25.0 27.7

Instrument Span forTHC Tunnel is 100 ppm

Pass/Fail Criteria is +/- 5% of Cal Gas for THC

0.2 Pass

0.2 Pass

0.8 Pass

1.2 Pass

Zero Drift

Initial Final Difference

Value Value As % Error

THC Silo 0.0 9.8 1.0

Initial Final Difference

Value Value As % Error

THC Tunnel 0.0 0.5

Initial Final

Value Value

0.5

Span Drift

Difference

As % Error

THC Silo 900.0 914.0 1.4

Initial Final Difference

Value Value As % Error

THC Tunnel 90.2 89.7 0.5

Pas&Fail

Pass

Pass/Fail

Pass

Pass/Fail

Pass

Pass/Fail

Pass

Pass/Fail Crtteria for Drift is +I-3% of THC Span
. Run 1 - Load Out - 7124198

Calibration Error Determination

Cal Gas Measured

Value Value

THC 0.0 1.2

899.0 905.0

498.0 508.0

249.0 246.0

instrument Span for THC Silo is 1000 ppm

Pass/Fail Criteria is +/- 5% of Cal Gas for THC

THC

Initial Final

Value Value

1.2 -0.2

Initial Final

Value Value

THC Silo 905.0 907.0

Pass/Fail Criteria for Drift is +/-3% of THC Soan

Difference

As % Error

Pass/ Fail

0.1

0.7

2.0

1.2

Pass

Pass

Pass

Pass

Zero Drift

Difference

As % Error

0.1

Span Drift

Difference

As % Error

0.0

Pass/Fail

Pass

Pass/Fail

Pass
. .

Run 2 - Load Out - 7/25/98

Calibration Error Determination

Cal Gas

Value

Measured Difference

Value As % Error

THC 0.0 1.7

899.0 902.0

498.0 506.0

249.0 254.0

Instrument Span for THC is 1000 ppm

Pass/Fail Criteria is +I- 5% of Cal Gas for THC

0.2 Pass

0.3 Pass

1.6 Pass

2.0 Pass

I-HC

Initial

Value

1.7

Final

Value

2.0

Initial Final

Value Value

THC Silo 902.0 900.0

Pass/Fail Criteria for Drift is +/-3% of THC Span

Zero Drift

Difference

As % Error

0.0

Span Drift

Difference

As % Error

0.0

Pass/ Fail

Pass/Fail

Pass

Pass/Fail

Pass
.

lntermittant Load Dump - 7125198

Calibration Error Determination

Calm Gas Measured Difference

Value Value As % Error

THC 0.0 0.2

90.4 90.7

50.2 50.9

25.0 25.7

Instrument Span for THC is 100 ppm

Pass/Fail Criteria is +/- 5% of Cal Gas for THC

0.2

0.3

1.4

2.8

THC

Initial Final

Value Value

0.2 0.4

Initial Final

Value Value

THC Silo 90.7 90.4

Pass/Fail Criteria for Drift is +/-3% of THC Soan

Zero Drift

Difference

As % Error

0.2

Span Drift

Difference

As % Error

0.3

Pass/ Fail

Pass

Pass

Pass

Pass

Pass/Fail

Pass

Pass/Fail

Pass
Run 4 - Baseline - 7126198

Calibration Error Determination

Cal Gas

Value

Measured Difference

Value As % Error

Pass/ Fail

THC 0.0 0.2 0.2 Pass

90.3 90.5 0.2 Pass

50.2 51.1 1.8 Pass

25.0 25.5 2.0 Pass

Instrument Span for THC is 100 ppm

Pass/Fail Criteria is +/- 5% of Cal Gas for THC

Zero Drift

Initial

Value

1 st Drift Check

Value

Difference

As % Error

Pass/Fail

0.2 0.1 0.1 Pass

1st Drift Check Final Pass/Fail

Value Value

Difference

As % Error

0.1 0.1 0.0 Pass

Span Drift

Initial

Value

1st Drift Check

Value

Difference

As % Error

Pass/Fail

90.5 90.4 0.3 Pass

1st Drift Check Final Pass/Fail

Value Value

Difference

As % Error

90.4 90.8 0.4 Pass
I .

Run 3 - Load Out - 7123198

Calibration Error Determination

Cal Gas Measured Difference

Value Value As % Error

THC Silo 0.0 1.1

899.0 907.0

498.0 504.0

249.0 260.0

Instrument Span for THC Silo is 1000 ppm

Pass/Fail Criteria is +/- 5% of Cal Gas for THC

0.1

0.9

1.2

4.0

Cal Gas Measured Difference

Value Value As % Error

THC Tunnel 0.0 0.2

90.4 90.4

50.2 50.9

25.0 25.5

Instrument Span for THC Tunnel is 100 ppm

Pass/Fail Criteria is +/- 5% of Cal Gas for THC

0.2

0.0

1.3

2.0

Initial Final

Value Value

THC Silo 1.1 -0.1

Initial Final

Value Value

THC Tunnel 0.2 0.1

Initial Final

Value Value

THC Silo 907.0 903.0

Initial Final

Value Value

THC Tunnel 90.4 90.6

Pass/Fail Criteria for Drift is +/-34/o of ~7tiC Span

Pass/ Fail

Pass

Pass

Pass

Pass

Zero Drift

Difference

As % Error

0.1

Difference

As % Error

0.1

Span Drift

Difference

As % Error

0.0

Difference

As % Error

0.2

Pass/ Fail

Pass

Pass

Pass

Pass

Pass/Fail

Pass

Pass/Fail

Pass

Pass/Fail

Pass

Pass/Fail

Pass
. .

Analyzer

THC Silo

THC Tunnel

THC Dryer Stack

Response Times DRAFT

Response Time

1 min. 25 sec.

35 sec.

1 min. 30 sec.
Attachment 2

Item 2 (AlO)
.

Load-Out Log Spreadsheet Sheet __ of
. .

SF6 Gas Delivery data Spreadsheet Sheet-of-
Attachment 3

Item 4 (C3)
Thomas J. Geyer

Principal Chemist

Dr. Geyer specializes in molecular spectroscopy, FTIR test method development and

validation, EPA protocol development, FTIR data analysis, analytical software

development, and project management. Dr. Geyer has developed EPA FTIR applications

for emissions testing in the field and managed the first field evaluation of an FTIR

continuous emission monitoring system for measuring HAPS. He has led many field test

programs and developed analyte spiking procedures for hazardous air pollutants (HAPS).

Dr. Geyer helped develop the EPA FTIR analytical protocol to measure reference spectra

and to apply spectra for field measurements.

Recently, Dr. Geyer developed FTIR test Methods 3 18 for wool fiberglass, 320 for

hazardous air pollutants and Performance Specification 15 for FTTR continuous emissions

monitoring applications. He also does analytical programming for instrumental methods.

Based at MRI’s North Carolina Office, Dr. Geyer develops hardware, software, and

measurement techniques using FTIR spectrometry for the analysis of pollutant emissions.

His project assignments have included a number of FTIR method development and test

programs.

Before joining MRI in 1995, Dr. Geyer was a Senior Chemist and Group Leader in the

Research Division of Entropy, Inc. He directed an EPA FTIR emission test project at five

electric utilities, conducted field studies with FTlR emissions tests, and managed in-house

laboratory projects. He helped develop procedures to analyze FTIR validation data and

helped develop FTIR validation sampling procedures. He directed laboratory and field

evaluations to exp,and the capabilities ofFTlR emissions testing.

From 1989 to 1991, Dr. Geyer was Assistant Professor of Chemistry at the U.S. Naval

Academy. Previously, he spent a year as an Offme of Naval Technology Postdoctoral

Felllow at China Lake, California, He performed studies to characterize material ejected by

laser ablation from the surface of YBa,Cu,O, high-temperature superconductor. As a

Research Assistant at the University of South Carolina from 1984 to 1988, he conducted

original research in molecular spectroscopy to determine structures and conformational

equilibria of substituted cyclobutane and cyclopentane molecules.

Dr. Geyer has a Ph.D. in Physical Chemistry from the University of South Carolina

(1988). He is a member of the American Chemical Society, American Physical Society, Air

and Waste Management Association, and Sigma Xi (Scientific Research Society of North

America). Entropy honored him with an Outstanding Contribution Award in 1992. He is

the coauthor of more than 20 technical publications and presentations. l~)Wr
Scott W. Klamm

Senior Environmental Engineer

Mr. Klamm specializes in air toxics, combustion processes, emission control

technologies, and related environmental engineering programs. He has worked extensively

on the development and operation of laboratory and field equipment for point source and

ambient testing. His recent activities at MRI include leading an EPA field method

comparison project on acetaldehyde, performing data analysis for a comparison of three

methods for HI?, and leading the data analysis and reporting activities for an EPA

incineration project to identify and measure products of incomplete combustion using a

wide range of field and analytical methods. Mr. Klamm has also recently led field studies

for two industrial clients to demonstrate collection efficiency on a control device in one, and

to determine measurement errors of an on-line mass spectrometer for emission monitoring

in the other.

Mr. Klamm developed an experimental extended-period ambient organic sampler and

carried out IaboratoIy testing of the system. For the electronics industry, he examined the

use of CFC solvents and alternative technologies for emission control. Mr. Klamm

prepared the test plan and matrix design as well as special sampling equipment for a field

study of organic compound adsorption in boiler soot for EPA. On several occasions, he has

served as an EPA field auditor for the disposal of chemical agents and munitions at an Army

facility. He ran tests on stack sampling equipment and emissions monitors and made

recommendations on the equipment and monitors. Mr. Klamm has also been field auditor

and reviewer of trial bum data as part of permit review assistance to the states of Utah and

Kansas, EPA Headquarters, and EPA Region VII.

As part of an evaluation of the Alaska CO inventory, Mr. Klamm tested various

locations in an urban area for mobile-source CO emissions, applied meteorological

information, assisted in modeling, determined accuracy of existing monitors compared to

MRI-gathered data, and helped prepare recommendations to the State of Alaska. For the

U.S. Air Force, Mr. Klamm designed a test matrix to study airborne pollutants and toxic

gases formed during extinguishment of jet fuel fires with Halon agents at firefighter training

exercises. He assisted in operation of SuMMq ambient VOST, open-path FTIR, PUF,

particulate, and CO monitors. He also performed data reduction, coauthored reports and

papers, and assisted in risk assessment and dispersion modeling,

Regulatory work has involved coauthoring EPA guidance documents on setting permit

conditions, reporting trial bum results, and related incineration topics, such as combustion

gas velocity, treatment of gasoline-contaminated soils, and solid waste feed systems.

Mr. Klamm graduated magna cum laude from the University of Missouri-Rolla with a

B.S. in Chemical Engineering in 1985. He has taken additional courses in solid and

hazardous waste management, human environmental biology, and dispersion modeling. He

is a member of the Air and Waste Management Association. He received the 1990 Bidstrup

Award from MRI for outstanding technical contribution and the I997 Achievement Award

from MRl’s Council of Principal Scientists. 1~0j2r j1’>8
. .

Robert G. Gulick

Supervisor of Field Programs

Mr. Gulick specializes in the operation and maintenance of continuous emission

monitors in compliance with appropriate EPA methods. As Supervisor of Field

Programs, Mr. Gulick is responsible for assuring that all equipment for source sampling

is available, calibrated, and in working condition. In addition, he has responsibility for

operating and maintaining continuous emission monitors during field sampling at

indusnial facilities. Recent programs include:

l Performed continuous emission monitoring of carbon monoxide, carbon dioxide,

sulfur dioxide, nitrogen oxides, total hydrocarbons, and hydrogen chloride on

source sampling projects. These have included a hysteresis boiler study in

Pennsylvania and a kiln study in Nebraska.

l Evahated 24-hour sampling for total hydrocarbons to determine capture

efficiency in the development of total temporary enclosure model.

l Project Leader on a shldy that assessed and recommended a full complement of

continuous emission monitors for a hazardous waste facility’s continuous

emission monitor replacements.

In 1988 and 1989, Mr. &lick was a Technical Sales Engineer with Torotel

Products of Grandview, Missouri. He negotiated price and delivery of electronic

components, expedited production to meet delivery schedules, and monitored

engineering changes to meet customer specifications. During 1986 and 1987,

Mr. Gulick was the owner and manager of a home electronics retail sales and service

business. He was responsible for retail sales, inventory purchase and control, service

and repair of audiovisual and computer products, advertising, and personnel

management.

Mr. Gulick’s background includes rive years as a Field Service Engineer with

Perkin-Elmer. He installed and repaired analog and digital test instrumentation,

computers, and peripherals. He handled inventory control, trained junior engineers, and

sold service contracts.

In 1981, Mr. Gulick received an A.A.S. in Electronic Engineering Technology from

Western Iowa Technical College. In 1990, he completed special training in hazardous

waste operations. He has certification of OSHA safety and health training.

A-16
,

Andrew E. Page

Assistant Environmental Scientist

Mr. Page performs work in the Air Quality Engineering Section of the Applied

Engineering Department. His experience includes field and laboratory testing for fugitive

dust sources as well as ducted emission sources using various types of sampling equipment.

He performs laboratory analysis on emission sources; Method 18 analysis on ducted

emission sources by gas chromatography, including data reduction for these analyses; and

assists in operation and maintenance of mobile laboratory and field sampling equipment and

analytical instrumentation (JR and GC with FID, PID, and ECD).

From 1994 to March of 1997, Mr. Page worked for Ken Wilcox Associates where he

tested leak detection systems and prepared certification reports according to EPA

protocols. While at KWA he gamed extensive experience in working with and testing leak

detection equipment for aboveground and underground storage tanks and pipeline systems.

His other responsibilities included assistance in development of a fuels management research

center; product development testing for clients; data reduction and analysis for various

types of testing; preparation of estimates for analysis on environmental cleanup projects;

soil and water analysis using gas chromatography (GC) and infrared spectrometry (IR); and

maintenance of GC and & calibration, troubleshooting, and repair.

As a research and teaching assistant at the University of Missouri, from 1992 to 1994,

he worked on various research projects, namely development of reverse-bum gasification as

a thermal treatment process for petroleum sludge, sewage sludge, and other wastes.

Presented research at various conferences. As a teaching assistant, he taught help sessions

and laboratory sessions for general chemistry courses.

Mr. Page received a B.A. in Chemistry from Central Methodist College in 1993
.

Pamela S. Murowchick

Associate Environmental Engineer

Ms. Murowchick provides engineering support on environmental contracts ranging

from incinerator trial bums to protocol development to test monitoring systems. The

diversity of her assignments has required versatility in applying her engineering knowledge

and the ability to work effectively with project management, project team members, and

client personnel. Her experience at MN has included:

* Prepared trial bum plans and associated QA plans.

* Operated the sampling console for Modified Method 5 testing during RCRA and

TSCA trial bums of hazardous waste incinerators.

* Performed laboratory preparation and recovery tasks for incinerator sampling and

analysis projects.

* Performed test data reduction and reporting.

* Assisted on EPA regulatory support assignments involving waste management.

* Coauthored a conference presentation on incineration options for waste

management.

* Coauthored a conference presentation on emissions of organic compounds and

combustion gases from an industrial boiler during hazardous waste cofiring.

* Assisted with EPA protocol development work for underground storage tanks at

MRI’s Experimental Tank Facility.

* Assisted with evaluations of commercial equipment for tank tightness testing.

* Assisted on a study of solar energy for waste disposal.

From 1988 to 1989, Ms. Murowchick was a Plant Chemist with Lubripac in Kansas

City, Kansas. She performed routine physical and chemical testing of oil in the Quality

Control Laboratory. Ms. Murowchick monitored the progress of special projects involving

cleanup in the tank farm, and she tested and adjusted new oil formulations in the laboratory

before full-scale production was begun.

Ms. Murowchick received a B.S. (with honors and distinction) in Chemical Engineering

from Pennsylvania State University in 1985. In 1987 and 1988 she did course work in

Secondary Education and Chemistry at Mercyhurst College. She is certified in CPR and

completed OSHA’s RCRA safety training. Her computer skills include Fortran

programming and WordPerfect, Quattro, and Lotus applications.
.

James S. Surman, Jr.

Senior Environmental Scientist

Mr. Surman has over 28 years of direct experience in stationary source air emissions

testing, continuous emission monitoring, and related QA/QC procedures. His work at MRI

focuses on the evaluation of hazardous waste incinerators, municipal waste combustors,

boilers and industrial furnaces, and other sources of air pollution. He has been Field

Sampling Task Leader on 63 projects and Project Leader on 8 emission studies of

incinerators, boilers, and kilns, Mr. Surman has also participated as an operator and

sampler on numerous field programs and has audited RCRA trial bums of hazardous waste

incinerators and emissions tests at power plants for regulatory agencies. In addition to field

assignments, he participates in EPA-sponsored work assignments relevant to quality

assurance and emissions standards development.

Field assignments have involved sampling for volatile and semivolatile organic

compounds; particulate matter, including PM,, by the EGR method; particle size distribution; multiple metals, including hexavalent chromium, acid gases, and other emissions.

Mr. Surman has prepared and assisted engineers in preparing proposals, test plans, work

plans, QA plans, and project final reports. He also has been responsible for the hands-on

preparation and execution of field sampling projects involving as many as 15 field personnel

for periods up to one month at a test site.

From 1978 to 1987, Mr. Surman was Quality Assurance Manager and Project

Supervisor with Mostardi-Platt Associates of Bensenville, Illinois. He evaluated all testing

procedures, equipment maintenance and calibrations, and techniques in the performance of

new or innovative test methods. He helped implement EPA reference methods as they

became available and supervised air pollution source testing and air pollution control

evaluation for various industries. He also conducted ambient air monitoring studies and

audits and developed a QA plan for testing activities.

Earlier experience with air pollution source testing was with Kin Associates at Chicago

Heights, Illinois (1977) and Commercial Testing and Engineering Company in South

Holland, Illinois (1973-1977). Mr. Surman initially worked in Commercial Testing and

Engineering Company’s services for the sampling and analysis of coal, iron ore, water, soils,

and other materials for chemical and physical characteristics (1970-1973). With Rand

Development Corporation in Cleveland, Ohio (1966- 1970) he aided in field investigations

related to water pollution control, groundwater contamination, and strip mine reclamation.

Mr. Surman received the B.S. in Biology with a minor in Chemistry horn Cleveland

State University (1966). He is a member ofthe Source Evaluation Society and coauthor of

a municipal waste combustion multipollutant study (EPA-600/8-89.064).
Bob J. Edwards

Senior Technician

Mr. Edwards joined MRI’s Field Measurements Section in 1992. He has participated in

a number of industrial projects around the country for hazardous waste incinerator testing

and analysis services. He also has worked on assignments under MRI’s subcontract for

technical assistance to EPA for the implementation of RCRA regulations for hazardous

waste management facilities.

In support of various field sampling and analysis programs, Mr. Edwards calibrates

equipment, performs routine and corrective maintenance on equipment, operates an EPA

Method S console during stack sampling, performs Orsat analysis on gas streams, and

titrates EPA Method 6 samples. He stages and destages equipment for field sampling and

sets up the equipment on-site. In addition, he performs data entry for reports, investigates

equipment and vendors to assist with equipment purchasing decisions, and orders materials.

His background includes six years in the U.S. Navy, followed by three years in

manufacturing and industrial facilities. He has worked extensively in environmental

maintenance, pneumatics, hydraulics, and electrical and mechanical equipment and systems.

Mr. Edwards also has experience with quality assurance, radiological controls, gauge

calibration, hazardous materials, and security and safety issues.

In the Navy, Mr. Edwards was a missile technician. He operated and maintained the

Poseidon Ballistic Missile System as launcher operations supervisor. He performed

colateral duties, such as nuclear weapons handling supervisor, departmental coordinator for

maintenance and material management, nuclear weapons radiological controls assistant,

missile and readiness equipment expert, departmental publications coordinator, quality

assurance inspector, field metrology technician, and nuclear weapons security guard. He

completed several training programs in the Navy that covered electricity, electronics,

hydraulics, pneumatics, digital computers, radiological controls, QA, gauge calibration,

theory and practice of equipment maintenance, and related specific disciplines. He has also

taken courses in electronic engineering at Maple Woods Community College in Kansas

City.

With a division of Kraft-General Foods, Mr. Edwards worked as plant maintenance

supervisor/trainee. He oversaw maintenance aspects of production and packaging,

interacted with contractors and the company upgrade team in monitoring progress during

equipment improvement and expansion, and served on the plant’s hazardous materials

response team after required OSHA training.

2%
Daniel 0. Neal

Senior Technician

Mr. Neal provides technical support on programs for environmental monitoring,

sampling, and analysis in the Field Measurements Section of MRPs Environmental

Technology and Engineering Department. His responsibilities include staging and destaging

equipment for field tests, setup and operation of equipment, and calibration and

maintenance of test equipment.

Since joining MRI in 1993, Mr. Neal has accompanied field measurement teams on

several projects for clients in government and industry. In addition to equipment setup, he

performs various tasks, including nmning the Method 5 console and operating the stack

probe. Project work has included an emissions test of a kiln at a brick manufacturing plant

for EPA, compliance. and performance tests of cooling towers, and various trial bum,

minibum, and performance tests for industrial clients.

Prior to joining MET, Mr. Neal worked as a sales representative for a publishing

company and an appliance company. From 1976 to 1984, he worked for the Power

Division ofBums and McDonneh Engineers in Kansas City, Missouri. As a Design Detailer

and Electrical Substation Drafting Supervisor, Mr. Neal assisted with design and layout of

power substations, Mr. Neal has completed undergraduate courses at Kansas State

University, Johnson County Community College, and Longview College.
Attachment 4

Items 12,21, and 24 (F29, G19, and H18)
~scott Specialty Gases

,.,-.&wed

6141 EASTON ROAD PO BOX 310

PLUMSTE~VILLE ? A 1E949-0310

BFrOm : Phone: 215-766-8861 -Fax: 215-766-2070

CERTIFICATE OF ANALYSIS

-------------______------------------------------------------------------

MIDWEST RESEARCH PROJECT #: 01-01788-004

SCOTT KLAMM PO#: 033452

425 VOLKER BLVD ITEM #: 01023822 5AL

DATE: 4/07/98

KANSAS CITY MO 64110

-----_-_--_--__----------------------------------------------------------

CYLINDER #: ALM033887 ANALYTICAL ACCURACY: +/-5%

FILL PRESSURE: 2000 PSIG

BLEND TYPE : CERTIFIED WORKING STD

REOUESTED GAS

COMPONENT

SULFUR HEXAFLUORIDE

NITROGEN

- ~~.~ mmLYSIS

CONC MOLES (MOLES)

.2 PPM 0.205 PPM

BALANCE BALANCE
Scott Specialty Gases

6141 EASTON ROAD PO BOX 310

a

Shipped PLUMSTEADVILLE P A 18949-0310

From: Phone: 215-766-8861 Fax: 215-766-2070

CERTIFICATE OF ANALYSIS

----------------_---____________________--~----------~-------------------

MIDWEST RESEARCH

SCOTT KLAMM

425 VOLKER BLVD

KANSAS CITY

PROJECT #: 01-01788-001

PO#: 033452

ITEM #: 0102S3000815AL

DATE: 4/07/98

MO 64110

---_------_-____--_-____________________---------------------------------

CYLINDER #: AAL

FILL PRESSURE:

ANALYTICAL ACCURACY: +/-5%

1280 PSIG

BLEND TYPE : CERTIFIED WORKING STD

REQUESTED GAS ANALYSIS

COMPONENT CONC MOLES

SULFUR HEXAFLUORIDE

(MOLES)

4 . PI-9 3.83 PPM

TOLUENE 100. PEW 105. PPM

NITROGEN BALANCE BALANCE
.

i0 No Xl3452
___--..__ <IL- _-____ -______ _-- _____________________________

Reordcr/Serv,ce Contact ~21517s6-8a61 FttNSTER!xlLLE PR ISrn

CEFtTlFlCATE OF ANALYSIS
06/10/96 15:29 axz5 766 2070 3b"ll Jlz.cAnr--

. . _

-

i

-:

@

Scott Specialty Gases

6141 BASTON ROAD PO BOX 310

Shipped PLUMSTEADVILLE PA 18949-0310

From: Phone: 215-766-8861 Fw: 215-766-2070

CERTIFICA.TE O F ANALYSIS

_____-_________--_------------------------------------------------..------

MIDWEST RESEARCH PROJECT #: 01-017118-005

SCOTT IcLAm PO#: 033452

425 VOLKER BLVD ITEM #: 01021951 5AL

DATE: 3/31/98

KANSAS CITY M O 64110

----____-_--__-_____----------------------------------------------.------

CYLINDER #: AU4005893 ANALYTICAL ACCURACY: +/-St

FILL PRESSURE: 2000 PSIG

BLEND TYPE : CERTIFIED WORKING STD

REQUESTED GAS ANALYSIS

COMTONENT CONC NOLES (MOLES)

100. PPM 99.9 PPM

NITROGEZN E3sANcE BAL:.NcE
~I'i.RFi~ili~lE!) I~CCOROIIIC 'I'0 EPA 'TRACEABILITY I'IOTOCOL FOR ASSAY AND CERTIFICATION OF GASEOUS CALIBRATION STANDARDS (PRoCED""E #till

<Al stomer : Order No:

! itrn PRODUCTS A,,,> CfIL:,,ICALS, 1,rc.

312-020638-01

Batch No:

i 1 R CAI.!DE,I STREE:T

861-33582

Notes:
Attachment 5

Item 25 (H18)
Daniel A. Kaplinski

Sales Engineer I I

vironics Inc. uo,,,d. CT ‘3608-l tij Industrial Park Road 6%

(660) 8,2 -111, . FAX: (860) 8i’o-9333

World Wide Web: http:llwwW.OnVirOniCs.corn

E-mail: dktaplinski8environics.com

COmpU,,nl~ Ga, ~i,;~p~oi~ytion~c~~~~~~~~ sw*m*

Mf #: I<

ENVIK@NICS FLOW CONTRCLLEF: C&LIERATION SHEET

Description: AIR ? Sire: 1 rw @iB . SCCM. tr:-f actor: 1.!3

This flaw enntroller was calibrated clsing a Sierra Cal Eench(TM)I a traceable

Primary Flow Standard Calibration System. This calibration is referenced to

dry air at. a temperaturr af LF ( -C) and a pressure nf 29.92 in.Hg (76BTorr).

Mf #: 3, Description: AII? 5i-E. : -.

1 gg [.:I . !!I Sl3Ctq ~ K-factor: 1. i?i

SERIAL # nw 9572K1

This flow controller was calibrated using a SiF-t-r.5 Cal i&-,~;?<Tt'l! ~ a traceable

Primary Flow Stcindard Ca!ibration~Systc,n. This calibration is referenced to

dry air a t S tetTPC+-ature nf u I-C) and a pressure zf :?.'?I1 in.Hg [76WTo~r).
This flow cantrnller was calibrated using a Sierra Cal F.enrI-, (TM) ~ a trace&SE

Primary Flow Standard Calibration System. This calihratinn is refcrencd to

dry sir at s temperature of RF (-C! and a pr~?~surp nf 27.?2 in.Hq (760Tar.ri.
This

is

a

Blank

Page
Chapter 3

Technical Systems Audit

Manual Emissions Test Methods Performed by

Pacific Environmental Services Inc.

at Hot Mix Asphalt Plant C,

Los Angeles, CA
This

is

a

Blank

Page
Technical Systms Audit of Test Methods Performed by PES 3.1

3.0 TECHNICAL SYSTEMS AUDIT - PACIFIC ENVIRONMENTAL SERVICES INC.

This Chapter is the final technical systems audit (TSA) of the manual emissions testing at Hot

Mix Asphalt Plant C in the Los Angeles, California area performed by Pacific Environmental Services,

Inc. (PES). As explained in detail in Chapter 1, the final TSA includes revisions by the EPA Quality

Assurance Officer. The draft TSA report from Research Triangle Institute (RTI) was delivered to the

EPA Quality Assurance Officer on September 29, 1998. The TSA was performed by R.K.M. Jayanty

and Robert S. Wright of Research Triangle Institute (RTI) under EPA Contract 68-D4-0091, work

assignment 99-03, from July 20, through July 26, 1998. The TSA was conducted in accordance with

principles described in the EPA Quality Assurance Division’s working draft version of EPA Guidance

for Technical Assessments for Environmental Data Operations (EPA QA/G-7).

In general, PES and its team members have performed the testing according to the procedures

outlined in the Site Specific Test Plan (SSTP) and Quality Assurance Project Plan (QAPP). Any

deviations from the QAPP or SSTP have been discussed with the EPA Work Assignment Manager. PES

and its team members who are present at the site are well qualified and experienced in the work to which

they are assigned.

Item Findings that may have a potential effect on data quality

1 The EPA Methods, VOST and Modified Method 5 (MM5), have not been validated

for all the chemical compounds of interest in the asphalt plant emissions. Some of

the compounds may have been recovered during the laboratory testing in other

programs, but none have been validated in the asphalt plant emissions matrices. 

This was a research study, however, and not meant to have validation.

2 The VOST cartridges were spiked with surrogate compound(s) before field

sampling at Triangle Labs.

3 The precision and accuracy goals indicated in the QAPP are based on estimates

from the VOST and semi-VOST methods, but they are not established values for

many of the compounds of interest in this program.

Item Findings that are unlikely to have an effect on data quality

1 The spikes into the XAD-2 resin (MM5) and Anasorb 747 (M-18) were loaded

directly onto the cartridges in the field.

2 The train operators have noted the readings on the data sheets. The data sheets do

not have any column to note any comments during sampling. Similarly, a notebook

was maintained at the site to record any problems or process changes, etc., during

sampling.

3 The flow rates used for VOST at the tunnel exhaust were too low to maintain

constant on the rotameter or VOST console, which may cause some error in the total

volume collected.
Technical Systms Audit of Test Methods Performed by PES 3.2

Technical Systems Audit Checklist

Project: Emissions Testing at a Hot Mix Asphalt Plant 

Organization: Pacific Environmental Services 

Location: Asphalt Plant C - Los Angeles, CA 

Assessors: R.K.M. Jayanty and R.S. Wright (Research Triangle Institute; Research Triangle Park,

North Carolina) 

Audit Dates: July 20 through July 26, 1998 

 

Brief Project Description: EPA is investigating hot mix asphalt plants to identify and quantify

particulate matter and hazardous air pollutants (HAPs) emitted from asphalt cement load-out operations. 

EPA has issued a work assignment to PES to conduct an air emissions test program to collect data in

support of the investigation. Asphalt Plant C in Los Angeles, California was chosen primarily because

load-out emissions are controlled by a silo exhaust system and a load-out tunnel. The plant has a

production capacity of more 650 tons per day. Approximately 2,000 tons per 4 hour period were

produced, during the test. The primary objective of the project will be to characterize air emissions of

organic HAPs from asphalt cement load-out operations and operation of the hot mix dryer; however, PES

is not responsible for the testing of the hot mix dryer stack. Testing will be performed to characterize

emissions from the storage silos, the load-out tunnel, and the hot mix dryer.

AUDIT QUESTIONS

RESPONSE

COMMENT

Y N

N

A

A. GENERAL QUALITY ASSURANCE INFORMATION

 1. Is there an approved quality

assurance (QA) plan for the overall

project and has it been reviewed by

all appropriate personnel?

T A QAPP was submitted to EPA in

January 1998. Subsequently, two

revisions have been made and a final

QAPP was submitted on July 14, 1998.

Additionally, PES submitted a SSTP in

June 1998. Both documents have been

approved by EPA.

 2. Is a copy of the approved QA plan

maintained at the field site? If not,

briefly describe how and where

QA and quality control (QC)

requirements and procedures are

documented at the field site.

T Copies of the QAPP and SSTP are

available in the trailer. Few operators of

the trains have used these documents;

however, key personnel provided them

with information from these documents

as needed for their tasks.
AUDIT QUESTIONS

RESPONSE

COMMENT

Y N

N

A

Technical Systms Audit of Test Methods Performed by PES 3.3

 3. Is the design and conduct of the

project as specified in the QA

plan? Are there deviations from

the QA plan? How are any

deviations from the QA plan

noted?

T In general, the project is being

implemented as was specified in the

QAPP. However, some procedures have

changed since the revised QAPP was

submitted to EPA. This was

communicated to EPA WAM in a letter

form on July 8, 1998. The proposed

deviations do not appear to affect the

quality of the data being generated.

 4. Are written and approved standard

operating procedures (SOPs) used

in the project? If so, list them and

note whether they are available at

the field site. If not, briefly

describe how and where the project

procedures are documented.

T No SOPs were observed at the testing

site. EPA test methods are used as they

are and those methods are attached to

the QAPP.

 5. For each measured parameter, do

any SOPs clearly define the data

quality indicator goals for

precision and accuracy?

T Data quality indicator goals defined in

the EPA methods were used.

 6. Do the above data quality indicator

goals appear to be based on

documented performance criteria

for the measured parameter or on

actual QC data compiled for the

particular measured parameter?

T Data quality indicator goals appear to be

based on EPA methods.

 7. Are there established procedures

for corrective or response actions

when measurement performance

criteria or the data quality indicator

goals (e.g. out-of-control

calibration data) are not met? If

yes, briefly describe them. Are

they consistent with the QA plan?

T Whenever there are deviations from the

QAPP or established procedures in EPA

methods, the EPA Work Assignment

Manager was informed by the PES Task

Manager.
AUDIT QUESTIONS

RESPONSE

COMMENT

Y N

N

A

Technical Systms Audit of Test Methods Performed by PES 3.4

 8. For each measured parameter, do

the SOPs specify the frequency of

calibration, acceptance criteria for

the calibration, and the process for

calibration data reduction and

review?

T PES used the specifications established

in the EPA methods. All calibration data

sheets will be given to RTI at a later

date. Mr. Dennis Holzschuh, Sr., will be

responsible for QA coordination and

review of the calibration data.

 9. Briefly describe how calibration

and other QC data are documented.

T Operational parameters and calibration

data were recorded on paper data sheets.

10. Does the calibration

documentation show that

calibrations are being performed at

the required frequency and in the

required manner?

11. Are there standard paper or

electronic forms to record QC data

and operational data? Are the

records dated? Is the person who

completed the record identified? 

Are paper records written in

indelible ink? 

T Standard paper data sheets were used

for all measurements and blank data

sheets were supplied to RTI. The data

sheets are dated and the operator name

was noted. All data forms were filled

out in ink.

12. Are the QC data reviewed by

another qualified person such as

the QA officer or the plant

manager? Who is this individual?

T Mr. Dennis P. Holzschuh, Sr., PES QA

Coordinator, will review all QA data

sheets. He performed internal QA at the

field site.

13. Is the project team adhering to the

planned schedule? If not, explain

the new schedule. Verify that all

schedule changes have been

authorized.

T The schedule is being followed to the

extent allowed by unexpected

equipment breakdown and process

changes in the asphalt plant. All

schedule modifications were authorized

by the EPA Work Assignment Manager.

14. Are there written plans to report

changes in the QAPP during datagathering activities?

T There are no written plans to report

changes in the QAPP during sampling.

However, the PES Task Manager

informed EPA WAM and other staff

verbally concerning schedule modifications and any deviations from the

QAPP.
AUDIT QUESTIONS

RESPONSE

COMMENT

Y N

N

A

Technical Systms Audit of Test Methods Performed by PES 3.5

Additional Questions or Comments:

B. ORGANIZATION AND RESPONSIBILITIES

1. Identify the following personnel

and determine whether they have

the listed responsibilities:

PES Principal Investigator:

 C. Wayne Westbrook 

• responsible for overall

performance of the project, and

• communications with EPA

T Wayne Westbrook was identified as

Program Manager for PES in the QAPP,

whereas the SSTP identified John

Chehaske as the Program Manager for

PES. In either case, it will not affect the

data quality or scope of the project.

2. PES QA Officer:

 Dennis Falgout 

• assist with and will be

responsible for review and

monitoring of all QA/QC

activities

T Dennis Falgout was not present at the

emissions testing.

3. PES Project On-Site Manager:

 Frank Phoenix 

C coordination with PES principal

investigator,

• Planning and scheduling the

demonstration project

T Frank Phoenix is the Task Manager and

is responsible for all the project

activities at the emissions testing site.

4. PES On-Site Quality Assurance

Coordinator:

 Dennis P. Holzschuh, Sr. 

C QC activities

T Mr. Holzschuh is responsible for the onsite QA/QC activities and was present.
AUDIT QUESTIONS

RESPONSE

COMMENT

Y N

N

A

Technical Systms Audit of Test Methods Performed by PES 3.6

5. Have there been any changes in the

project organization and the

personnel as outlined in the

QAPP?

T In general, there are no significant

changes except staff from Atlantic

Technical Services, Inc., were not

present. MM5 train samples for the

Analysis of PAHs will be analyzed by

Quanterra laboratories instead of

Triangle Labs. This was approved by

EPA WAM prior to the field testing.

Quanterra labs have high resolution

GC/MS analysis capability for PAHs.

6. Manual Test Methods

Operators:

 Mike Maret, VOST at TED 

 Troy Abernathy, VOST M18 at 

 SED 

 Dennis Holzschuh, Jr., MM5 at 

 SED 

 Joe Rubio, MM5& M315 at SED 

 Brian Purser, M18 at TED 

 Nick Neilson, M315 at TED 

 Jessica Swift, MetStation 

 Jairo Barreda, Shipping & Sample 

 Custodian 

T Laura Kinner, GC/MS Operator

Jim Peeler, GC/MS Operator

Josh Letomeau, Process Monitor

Each identified operator was

responsible for sample collection and

sample recovery for that method.

7. EPA Work Assignment -

Manager

Michael L. Toney

T Mr. Toney was present throughout the

entire testing program and coordinated

the efforts of the emissions testing

teams. He authorized all changes in

testing schedule and procedures.
AUDIT QUESTIONS

RESPONSE

COMMENT

Y N

N

A

Technical Systms Audit of Test Methods Performed by PES 3.7

8. EPA QA Officer:

Lara P. Autry

C review and approve QAPP

C review and approve QA activities

T Ms. Autry was not present at the

emissions testing.

9. Does the project maintain a current

summary of the training and

experience of each individual

engaged in the project?

T Training and experience of each

assigned person were maintained at the

office.

10. Does the project maintain

descriptions of assignment

responsibilities and required

proficiency levels?

T Responsibilities are assigned for each

person and it appears that they are all

well qualified. Only two persons,

Jessica Swift and Jairo Barreda, are

summer interns and they have been

given sufficient training for the work

assigned to them.

Additional Questions or Comments:

C. METHOD SPECIFIC - EPA Method 1

1. Is stack diameter properly

determined?

T The tunnel exhaust is a horizontal 32

inch diameter duct which leads from the

load-out tunnel to the Smog Hog.

2. Is distance to nearest upstream

disturbance properly determined?

T

3. Is distance to nearest downstream

disturbance properly determined?

T

4. Is number of sampling points

properly selected?

T For isokinetic testing, a 24-point

traverse matrix consisting of 12 traverse

points on each of two perpendicular

traverse lines was used.

5. Is points properly marked on pitot

tube?

T Points are noted on the tape which is

attached to the pitot tube and probe.

6. Verification of cyclonic flow is

acceptable?

T
AUDIT QUESTIONS

RESPONSE

COMMENT

Y N

N

A

Technical Systms Audit of Test Methods Performed by PES 3.8

7. Prior to sampling, all duct

dimensions are checked against

preliminary information to verify

measurement at locations, location

of test ports, and stack inside

dimensions?

T The stack dimensions and locations of

the traverse points were verified prior to

sampling.

8. Are the stack inside dimensions,

wall thickness, and sample post

depths measured to the nearest

1/16 inch?

T Performed prior to the testing.

Additional Questions or Comments:

The new silo exhaust duct was installed at Silo 2 instead of Silo 3. Since the new SED is 10 inches in

diameter, Method 1A was used instead of Method 1. This change was approved by EPA WAM.

Some of the work was performed prior to the auditor’s arrival to the site.

The silo exhaust and tunnel exhaust duct dimensions and locations of the traverse points were

verified prior to testing. Prior to testing, the silo exhaust and tunnel exhaust ducts were checked for

the presence of nonparallel flow by recording yaw angle misalignment at each isokinetic sampling

point. The details are in the PES site-specific Test Plan.

D. METHOD SPECIFIC - EPA Method 2

1. Is pitot tube, lines and manometer

assembled correctly?

T A type S pitot tube is connected to an

inclined-vertical manometer.

2. Is manometer leveled and zeroed

before and after each test?

T The box containing the manometers is

kept on a bench. Noticed zero before

and after each run.

3. Is pitot tube checked for chips? 

Performed leak checks before and

after each test run?

T Leak checks were performed before and

after each test run. Leak rates are noted

in data sheets.

4. Is cyclonic flow checked properly? T

5. Is orientation of pitot tube correct

during traverse?

T Noticed the orientation of pitot tube and

found to be acceptable during traverse.

6. Is sampling port adequately sealed

around pitot tube?

T It is sealed either with gloves or a cloth.
AUDIT QUESTIONS

RESPONSE

COMMENT

Y N

N

A

Technical Systms Audit of Test Methods Performed by PES 3.9

7. Is process operating at correct

conditions?

T Sampling was done whenever the

process was operating properly and at

correct conditions (determined prior to

the sampling).

8. Is stable reading taken at each

traverse point?

T Readings are noted in the data sheets.

9. Is static pressure measured? T

10. Is temperature measured? T The effluent gas temperature is recorded

at each traverse point using type-K

thermocouple.

11. Is moisture content determined? If

so, what method used?

T Moisture content was measured by EPA

Method 315.

12. Is data recorded properly? T Data are recorded in data sheets.

13. Are calculations correct? T Calculations will be performed in the

office and not at the site.

Additional Questions and Comments:

E. METHOD SPECIFIC - EPA Method 4

1. Is method conducted in

conjunction with pollutant test

methods 315 and MM-5?

T Method 315 and MM-5 trains were run

simultaneously both at the silo tunnel

and silo exhaust.

2. Are impingers properly placed? 

Impinger contents - 1, 2, 3, 4, 5.

T For Method 315, the first and second

impingers contained 100 mL of DI

water each, the third impinger is empty,

and the fourth and fifth impingers

contained 200 g of silica gel.

3. Sampling time per point? 10 min at the silo tunnel

5 min at the silo exhaust

4. Number of points? T 24 points

5. Is probe heater on? What

temperature? Is it stable?

T Probe is heated at 250 EF. Temperature

readings are noted in the data sheets.
AUDIT QUESTIONS

RESPONSE

COMMENT

Y N

N

A

Technical Systms Audit of Test Methods Performed by PES 3.10

6. Is filter heater on? What

temperature? Is it stable?

T Filter is heated at 250 EF. Temperature

readings are noted every 10 min in the

data sheets.

7. Is crushed ice in ice bath around

impingers?

T Crushed ice added periodically to

maintain the impingers at 0 EC.

8. Is the exit temperature being kept

below 68EF?

T Temperatures are periodically recorded

in the data sheets (every 5 min).

9. Is pretest leak check conducted? 

Leakage rate?

T Data sheets will be provided. Leakage

rate was within the acceptable limits.

10. Is sampling rate constant? Is it

isokinetic sampling?

T Sampling rate is 1.5 ft3/min and found

to be within the specifications.

Isokinetic sampling was followed.

11. Is port leak check performed? 

Leakage rate?

T Data sheets will be provided. Leakage

rate was within the acceptable limits.

12. Is electronic balance calibrated

with reading within 0.1 grams of

known reference standard?

T Calibration was performed in the

laboratory but not at the site. Calibration

data will be provided.

13. All data are recorded properly? T Noted in data sheets.

Additional Questions and Comments:

Moisture was determined from EPA Method 315 instead of EPA Method 5. Audit questions were

completed based on EPA Method 315 sampling procedures. Method 4 was performed in conjunction

with each EPA Method 315 test run.

F. METHOD SPECIFIC - EPA Method 315

Apparatus

1. Is the probe nozzle made of glass

or glass lined? What is its design? 

Is it clean?

T Probe nozzle was made of glass.

Cleaned with methylene chloride and

methanol (50:50 mixture). It appears to

be clean.

2. Is the probe liner made of

borosilicate or quartz and is it

clean?

T Probe liner is made of borosilicate.

Cleaned with methylene chloride and

methanol mixture (50:50). It appears to

be clean. 
AUDIT QUESTIONS

RESPONSE

COMMENT

Y N

N

A

Technical Systms Audit of Test Methods Performed by PES 3.11

3. Is it type S pitot tube and is it

properly attached?

T S-type pitot tube was used and it is

properly attached.

4. Is the differential pressure gauge as

two inclined manometers?

T The meter box contained two inclined

manometers.

5. Is the filter holder borosilicate

glass; glass frit-support; or silicone

rubber gasket?

T The filter holder is a borosilicate glass.

6. Describe number of impingers in

the condenser and its contents?

T The first and second impingers

contained 200 mL of DI water, the third

impinger is empty, and the fourth

impinger contained 200 g of silica gel.

7. What type of barometer? Mercury

or Aneroid?

T Aneroid barometer was used. It was

calibrated against mercury manometer.

8. What type of gas density

determination equipment used?

- sensor type _____

- pressure gauge ______

Temperature sensor attached to

probe?

T

9. Has filters checked visually for

inequalities?

T Glass fiber filter appears to be good.

10. Has filters properly labeled? T Filters after collection were kept in an

amber glass bottle and labeled.

11. Has pretest and post-test leak

check performed properly?

T Leak checks performed properly before

and after each run and noted in the data

sheets.

12. Has impingers properly

assembled?

T Impingers were assembled according to

the Method 315 specifications.

13. Has pitot tube lines checked for

plugging or leaks?

T Leak-checked before and after each run.

14. Has meter box leveled

periodically?

T Meter box was kept on a horizontal

surface.

15. Have manometers zeroed? T
AUDIT QUESTIONS

RESPONSE

COMMENT

Y N

N

A

Technical Systms Audit of Test Methods Performed by PES 3.12

16. Has acetone-insoluble head-stable

silicone grease added to all ground

glass joints?

T No silicone grease was used to the

ground glass joints. They are used only

when it leaks.

17. Is probe heat uniform along length

of probe?

T Probe is kept at 250 EF and the

temperatures are noted in the data sheets

every 5 min.

18. Has effective seal made around

probe when in-stack?

T Sealed with hand gloves or a cloth and

found to be acceptable.

19. Nozzle & pitot tube parallel to

stack wall at all times.

T

20. Has filter changed during run? 

Any particulate lost?

T No filter changed during the run. No

particulate was lost.

21. Have data sheets complete and data

properly recorded?

T Data sheets are filled out properly with

a legible ink pen.

Additional Questions and Comments:

1. Due to problems in the silo tunnel and silo exhaust, the samples collected on the first day

(7/23/98) were voided after approval from EPA WAM. After 2 hr sampling, it was noted that

the silo exhaust damper was closed. Therefore, the damper was operated and continued the

sampling for another 2 hr. The first day run will be repeated on 7/27/98. 

2. Observed the Method 315 sampling run at the silo 2 exhaust at the roof on 7/25/98. Flow rate

0.75 ft3/min. Sampling was done only for 2 hr due to expected high concentrations. Method 315

and MM5 trains were operated at two different times. Due to smaller stack diameter, traverse

readings were taken from one place and probe was kept in another hole and readings were noted

for every 5 min. Stack is at negative pressure. Stack hole is covered with gloves.

3. 4-hr sampling was performed from the silo 2 tunnel while two trucks were going through the

tunnel to get the background emissions.

LABORATORY INFORMATION NECESSARY FOR EPA METHOD 315

1. Was the calibration information

documented in log books?

T

2. Have the previous calibrations met

the acceptable tolerances?
AUDIT QUESTIONS

RESPONSE

COMMENT

Y N

N

A

Technical Systms Audit of Test Methods Performed by PES 3.13

3. Has the Type-S pitot tube been

verified using standards outside of

the laboratory?

4. Describe the pitot tube calibration

apparatus.

Additional Questions and Comments:

Calibrations were performed in the laboratory prior to the testing on the site. Calibration sheets will

be supplied to the auditors after the field test.

Calibration and General

1. Have the dry gas meters been

calibrated against a standard? (If

so, which standard?)

T

2. Have the stack and train

temperature sensors been

calibrated against a reference

thermometer?

T

3. Has the nozzle been calibrated to

nearest 0.025 mm (0.001 in), and

has the nozzle size been properly

selected?

T

4. Is the train correctly setup up and

leak-checked to less than 4% or

0.00057 m3/min (0.02 ft3/ min),

whichever is less?

T Leak checks were performed before and

after the sample collection and found to

be acceptable.

5. Are the train components clean and

free of breaks, cracks and leaks,

and is the probe liner clean and

leak free at 380 mm (15 in) Hg?

T

6. Are the pitot tube lines free of

plugs or leaks?

T

7. Is the probe heating system

operating correctly?

T
AUDIT QUESTIONS

RESPONSE

COMMENT

Y N

N

A

Technical Systms Audit of Test Methods Performed by PES 3.14

8. Are the pitot tube and temperature

sensors properly attached to probe?

T

9. Are the nozzle and pitot tube

located parallel to stack wall? 

Observe handling and positioning

of the probe.

T

10. Is the filter holder temperature

maintained at 120 ± 14EC (248 ±

25EF) throughout the tests?

T

11. Is the sample gas temperature at

the last impinger maintained at <

20EC (68EF) throughout the tests?

T

12. Is isokinetic sampling maintained

within ± 10% and checked every

five minutes?

T

13. Is the sample site selection an

appropriate distance downstream

from any flow disturbance?

T

14. Are filters free of irregularities,

properly installed, and properly

labeled?

T

15. Do the equipment operators have

access to test protocols and

methods, are data sheets available,

and is equipment in good repair.

T Equipment operators have copies of the

protocols and methods. Data sheets are

available to each train operator.

16. Are all data recorded and

calculations checked? Is at least

one decimal point beyond that of

acquired data retained?

T Calculations will be checked in the

office.

17. Are all impingers cooled in an ice

bath at all times?

T Crushed ice was added periodically to

maintain the temperature.

18. Is full stack traversing being

conducted?

T

19. Do recovery methods prevent

contamination?

T Sample recovery was performed in the

trailer, which is relatively clean.
AUDIT QUESTIONS

RESPONSE

COMMENT

Y N

N

A

Technical Systms Audit of Test Methods Performed by PES 3.15

20. Are graduated cylinders within 2

ml (or less) subdivisions used?

T Graduated cylinders within 2 mL

subdivisions were not used. However,

standard impingers were used and a

known volume of solutions was added.

21. Are all openings capped during

train disassembly?

T Capped with Teflon tape.

22. Is the clean-up area clean and

protected from the wind?

T It was performed in the trailer. The area

is relatively clean.

23. Are any particulates spilled? T The operators are very careful in

transferring the filter paper to the glass

jar.

24. Do any visible particles remain

inside the probe?

T None was noticed inside the probe.

25. How is the pitot tube cleaned? T Cleaned with methylene chloride and

methanol (50:50) mixture.

26. Are sample containers labeled and

sealed tight, and is the liquid level

marked?

T Electronically printed labels were

affixed to the containers. Liquid level is

marked with a pen and sealed with

Teflon tape.

27. What is the history of the S-type

pitot being calibrated against a std

pitot?

The calibration was performed in the

laboratory and the calibration data will

be supplied to the auditors after the field

test.

28. How was the inside diameter of the

stack measured?

It was measured prior to the testing and

noted to be 32 inches.

29. How is the probe marked to ensure

proper sampling locations?

T Probe is wrapped with tape at each

traverse point and marked with a pen.

30. How long does the probe remain at

each sample point? Is the reading

stable?

T The probe remained at 10 min at each

sample point. Readings are noted in the

data sheets.

31. How is alignment ensured while

sampling? Guidance manuals

specify visual observations and not

the highest delta p.

T Visual observations indicate that

alignment appears to be QC.
AUDIT QUESTIONS

RESPONSE

COMMENT

Y N

N

A

Technical Systms Audit of Test Methods Performed by PES 3.16

32. Were the unused ports plugged

while sampling occurred?

T Unused ports were sealed with electric

tape.

33. Was the equipment damaged

during the test? Explain.

T A few of the glass nozzles were broken

during recovery operation. They were

replaced with new ones for the next run.

34. How is static pressure measured,

and what is it? ...sampling?

Static pressure was measured with an

inclined manometer.

35. How is steady state process

indicated during sampling?

....would be the impact?

T It will not be a steady-state process.

Impact will be minimal due to an

integrated sample.

36. Were they any changes in the

facility emissions during sampling?

T Emissions may vary at the facility due

to the nature of the operation.

37. If changes in emissions did occur

during sampling, what was the

impact?

Impact will be minimal due to an

integrated sample collection method.

Additional Questions and Comments:

G. METHOD SPECIFIC - EPA Method 18

1. Have you performed presurvey

sampling using Method 18

procedures?

T Presurvey sampling was not performed

using Method 18 procedures. However,

grab samples were collected and

analyzed using canisters. Method SW

846 M0030 VOST data were collected

at the hot mix dryer stack.

2. What are the approximate

concentrations of the targeted

compounds?

3. What is the sampling rate? Is it

constant or proportional?

T Sampling rate was 1 L/min and sampled

for 4 hr at silo tunnel, whereas 2 hr

sampling was done at silo exhaust.

4. What is the sample time? T 4 hr at the silo tunnel, 2 hr at the silo

exhaust.
AUDIT QUESTIONS

RESPONSE

COMMENT

Y N

N

A

Technical Systms Audit of Test Methods Performed by PES 3.17

5. Probe heat or not. If so, what

temperature?

T Not heated. Teflon lines were used.

Ambient temperature.

Additional Questions and Comments:

Apparatus

6. What type of probe is used—

stainless steel, glass or Teflon?

T Teflon lines were used.

7. Is it heated and any filter used? T No filter was used and Teflon lines are

not heated.

8. Silica gel tube or extra adsorption

tube used prior to adsorption tube

when moisture content is > 3

percent.

T None was used at the silo 2 tunnel

emissions sampling. However, two

impingers at ice path temperature were

used at the silo exhaust.

9. Is the leakless sample pump

calibrated within limiting (sonic)

orifice or flow meter?

KNS Teflon pump was used to pull the

sample gas. The pump was calibrated in

the laboratory with a bubble flow meter.

10. Is rotameter used to detect changes

in flow?

T

11. Are the two sampling trains run in

parallel?

T The gas is pulled through a Tconnection into spiked and unspiked

sampling tubes.

12. Are the pre-spiked adsorbent tubes

used in one train and non-spiked

adsorbent tubes used in the second

train?

T Two different probes but pulled through

a common pump.

13. What are the compounds spiked

and at what concentrations?

T 200 μg each of benzene, toluene,

xylene, hexane, and cumene was spiked.

Liquid mixture was spiked onto the

cartridge prior to sampling.

14. Is accurately measured sample time

with a stop watch?

T
AUDIT QUESTIONS

RESPONSE

COMMENT

Y N

N

A

Technical Systms Audit of Test Methods Performed by PES 3.18

15. Is the sampling pump and flow

meter recently calibrated with

bubble meter?

T

16. Whether extreme care is taken to

ensure that no sample is lost in the

probe or sample line prior to the

adsorption tube.

T

17. Is pretest leak check acceptable?

(No flow indicated or meter.)

T

18. Total sample time, sample flow

rate, barometric pressure, and

ambient temperature are recorded?

T Recorded in data sheets.

19. Total sample volume

commensurate with expected

concentration and recommended

sample loading factors?

T 4 hr sampling was performed at the silo

tunnel. 2 hr sampling at the silo exhaust.

20. Is post-test leak check and volume

rate meter check acceptable? (No

flow indicated on meter, post-test

calculated flow rate is within 5

percent of pretest flow rate?)

T The gas sample is pulled into spiked and

unspiked sampling tubes.

21. Is desorption efficiency determined

for adsorbent to be used for field

sampling? If so, what are the

desorption efficiencies?

T The analyst reported that the desorption

efficiencies were determined in the lab

prior to the testing and they are 95

percent for each compound.

22. Is collection efficiency determined

for adsorption tubes used for actual

field sampling?

The analyst reported that the collection

efficiencies were determined in the lab.

The acceptable range is 70-130 percent.

However, 85 percent was found.

23. Are the adsorbent tubes stored

properly after sampling?

T They were stored in an ice cooler after

sampling.
AUDIT QUESTIONS

RESPONSE

COMMENT

Y N

N

A

Technical Systms Audit of Test Methods Performed by PES 3.19

Additional Questions and Comments:

AnaSorb 747 (1,000 mg front + 1,000 mg backtrap) was used. Carbon disulfide + dimethyl

formanide will be used for desorption. No glass wool was used in the Teflon lines. Sample gas is

pulled through a vacuum pump and maintained a flow through a critical orifice. There may be a

small pulsation and the impact is minimal. Method 18 was performed for two losses at 1 L/min at the

silo exhaust. Impingers were used prior to the sampling tubes at the silo exhaust to condense the

water vapor.

H. METHOD SPECIFIC - SW-846 Method 0030 (VOST)

1. Will the total run time be a

minimum of 2 hours?

T The total run time is 20 min. Four runs

were performed on each day.

2. Is the maximum load time 20 min.

For each pair of cartridges? At

1L/min sampling rate?

T Generally, 1 L/min sampling rate was

used at silo 2 tunnel emissions.

However, 0.25 L/min for 10 min was

used at the silo exhaust emissions.

3. Is a quartz liner wed inside the

stainless steel probe?

T Glass wool was inserted in the front of

the quartz liner to remove any

particulates.

4. Is the probe maintained at a

temperature greater than 150EC?

T Probe temperature was maintained at

255 EF.

5. Do the sorbent cartridges appear to

be sealed tightly in their carry

cases?

T The sealed cartridges were kept in

carrying cases.

6. Have the sorbent cartridges been

placed correctly in the sample train

(1st cartridge Tenax; 2nd cartridge

Tenax/charcoal)?

T

7. Do all vacuum gauges, pump

connections, calibrated rotameters,

and dry gas meters appear in good

working order with leak-tight

seals?

T
AUDIT QUESTIONS

RESPONSE

COMMENT

Y N

N

A

Technical Systms Audit of Test Methods Performed by PES 3.20

8. Is there an available thermal couple

reading between the first condenser

and first Tenax cartridge? CHECK

TEMPERATURE. MUST BE

LESS THAN 20EC.

T Temperature was measured and it is less

than 20 EC.

9. Is the sample line between the

probe and the first condenser less

than 5 ft.?

— Is it Teflon?

— Is it heat traced to 150EC?

— Are compression fittings used?

T Teflon line was used. It is not heat

traced.

10. Does each individual cartridge

have its own unique ID number

and flow direction arrow marked

on it?

T

11. Were the sorbent cartridges

received in the field on cold packs

(~4EC)?

T

12. Is the cooling water to the

condenser being maintained at or

near 0EC?

T Higher than 0 EC, but lower than 20 EC.

Ice water circulated.

13. Is the train leak-checked at the

beginning of a run to the following

specifications? (1) pull a vacuum

to 250 mm Hg (10 in Hg), (2) leak

rate less than 2.5 mm Hg after 1

minute?

T

14. Is a charcoal canister used to filter

the ambient air used to return

system to ambient pressure after

the leak check?

T

15. Was the sample train leak-checked

after 20L of gas was sampled and

was the highest pressure drop

encountered recorded so that his

value can be used during the

second leak test?

T Leak test was performed before and

after each run. The sampling rate and

volume are different at the silo exhaust

emissions testing. It was approved by

the EPA WAM.
AUDIT QUESTIONS

RESPONSE

COMMENT

Y N

N

A

Technical Systms Audit of Test Methods Performed by PES 3.21

16. Are the field blanks exposed for

the same amount of time as it takes

to change sorbent cartridges in the

VOST?

T Field blank was performed on 7/25/98.

17. Was there a field blank exposed for

each run?

T Field blank was performed on 7/25/98.

Additional Questions and Comments:

7/25/98. Due to higher concentrations at the silo exhaust, it was authorized to run VOST at 0.25

L/min for 10 min. Four runs were done each day. Stack is at negative pressure. No moisture

condensation was observed in the impinger. The flow rate of 0.25 L/min is at low setting in the

VOST console box. Rotameter setting is 0.2, which is the bottom of the scale.

I. METHOD SPECIFIC - SW-846-0010 (Modified Method 5)

1. Is the probe nozzle made of 316

stainless steel or glass with a sharp,

tapered (30E angle) leading edge?

T The probe nozzle is made of glass.

2. Is the nozzle of buttonhook or

elbow design and seamless?

T The nozzle is buttonhook.

3. Is the nozzle calibrated? T It is calibrated in the laboratory.

4. Is the probe glass lined and heated

to 120 ± 14EC at the exit end

during sampling?

T

5. Is the type s pitot tube on a plane

even with or above the nozzle entry

plane during sampling?

T

6. Does the pitot tube have a known

coefficient? What is it?

T The coefficient is 0.84.

7. Does the train have two

manometers: one for velocity-head

()P) readings and one for orifice

differential pressure readings

()H)?

T Two inclined manometers were used.

8. Is the filter holder made of glass,

and the gasket of Teflon?

T Glass
AUDIT QUESTIONS

RESPONSE

COMMENT

Y N

N

A

Technical Systms Audit of Test Methods Performed by PES 3.22

9. Is the XAD-2 module cooled to 17

± 3EC?

T Ice water bath was maintained.

10. Is there a thermocouple in the glass

well of the sorbent module to

monitor temperature of the trap?

T The temperature is 42 EF.

Additional Questions and Comments:

Train Components

1. Is the sorbent module followed by

a condensate knockout trap?

T

2. Is stack gas moisture being

monitored with four 500 mL

impingers following the knockout

trap? List the impinger solutions.

First impinger is empty. Second and

third impingers contained 200 mL of

HPLC-DI water. Fourth impinger is

empty. Fifth impinger 200 g of silica

gel.

3. Is the metering system consisting

of vacuum gauge, leak-free pump,

thermometer, and dry gas meter,

keeping the sampling rate of the

MM5 train within 10% of

isokinekticity?

T

4. Is the metering system determining

the sample volume within 2% of

the true volume?

T

5. Is the barometric pressure being

recorded and corrected for

elevation differences between the

location of the barometric and the

sampling point at a rate of -2.5 mm

Hg per 30-m elevation increase (or

+2.5 mm Hg per 30-m elevation

decrease)?

T Barometric pressure is noted from the

Met Station and at the truck.
AUDIT QUESTIONS

RESPONSE

COMMENT

Y N

N

A

Technical Systms Audit of Test Methods Performed by PES 3.23

6. Is the stack gas temperature sensor

attached to the pitot tube, such that

the tip of the sensor extends

beyond the leading edge of the

probe sheath and does not interfere

with the pitot tube opening?

T

7. Are calibration and preparation

data being recorded in a

permanently bound laboratory

notebook (i.e., filter and silica get

tare weights, clean XAD-2,

QA/QC check results, dry-gas

meter, and thermocouple

calibrations)?

T Noted in the data sheets but not in the

bound notebook.

8. Is the train grease-free upstream of

the module?

T

Additional Questions and Comments:

Preparation of the Train

1. Are the probe liner brushes

provided at least as long as the

probe?

T

2. Are the probe brushes made of

nylon bristles and stainless steel

wire handles with extensions?

T Probe brushes were made of nylon

bristles.

3. Are the wash bottles made of

Teflon or glass?

T Teflon bottles were used.

4. Are the sample storage bottles

made of amber glass and screwtype Teflon lined caps?

T Amber glass bottles with Teflon-lined

caps were used.

5. Are the filters made of glass or

quartz fiber?

T Glass fiber filters were used.

6. Has the XAD-2 resin been cleaned

prior to use and QC to a blank less

than 4 mg/kg?

T Quanterra labs provided the XAD-2

cartridges.
AUDIT QUESTIONS

RESPONSE

COMMENT

Y N

N

A

Technical Systms Audit of Test Methods Performed by PES 3.24

7. Is distilled organic-free water

(Type II) provided for the impinger

solutions?

T HPLC grade DI water was used.

8. Are the clean up solvents pesticide

grade?

T Methylene chloride + methanol (50:50)

pesticide grade solvents were used.

9. Are the filters desiccated at 20 ±

5.6EC and ambient pressure for at

least 24 hours, weighed at intervals

of at least 6 hours to a constant

weight (± 0.5 mg), and recorded at

0.1 mg?

T Weight of particulates is not measured

with MM5 train.

10. Have the number of minimum

sampling points been determined

for each sampling location (inlet,

outlet, and stack): What are the

numbers?

T 24 points.

11. Have the pitot lines been leak

checked?

T Leak checked before and after the run

and found to be leak free within the

specifications.

12. Has the stack gas moisture content

been determined? What is it?

T Stack gas moisture content at the silo

tunnel is -1-2 percent. The moisture is

higher at silo exhaust.

13. Were there any nozzle changes

during sampling?

T No nozzle changes during sampling.

Nozzle diameter is 0.252 inches.

14. Is the sample volume as outlined in

the sampling plan being pulled? 

What is it?

T 0.75 ft3/min for 4 hr at the silo tunnel.

0.75 ft3/min for 2 hr at the silo exhaust.

15. Are all openings to the train kept

covered with Teflon film prior to

assembly?

T

16. Are the XAD-2 modules assembled

off-site?

T XAD-2 modules were supplied by

Quanterra labs. Assembled in the rack.

17. Is the filter placed in the filter

holder with tweezers or while

wearing surgical gloves?

T
AUDIT QUESTIONS

RESPONSE

COMMENT

Y N

N

A

Technical Systms Audit of Test Methods Performed by PES 3.25

18. Is a pre-test leak check of the train

administered?

T Noted in the data sheets.

19. If a train component is changed

during sampling, is the train leakchecked prior to the change? Is the

leakage rate less than 4% of the

average sampling rate?

T No components were changed during

sampling.

20. Is a post-test leak check

performed? Is the leakage rate less

than 4% of the sampling rate?

T Leak rate is 0.02 inch.

Additional Questions and Comments:

Running the Train

1. Is the sampling rate maintained

within 10% of true isokinetic?

T

2. Is the filter maintained at 120 ±

14EC?

T

3. Is the sorbent module maintained

at 17 ± 3EC?

T Ice water temperature was maintained.

The module is covered with aluminum

foil.

4. Are the dry gas meter readings

recorded on field data sheets?

T Noted in the data sheets.

Additional Questions and Comments:

Sample Recovery

1. Is the filter removed from the filter

holder and placed in an identified

Petri dish container with tweezers?

T The filter was kept in an amber glass

jar.

2. Is the filter folded with the filter

cake inside?

T The filter is folded and kept in an amber

glass jar.
AUDIT QUESTIONS

RESPONSE

COMMENT

Y N

N

A

Technical Systms Audit of Test Methods Performed by PES 3.26

3. Is any particular matter adhering to

the filter-holder gasket transferred

to the Petri dish?

T The particulate matter adhering to the

filter-holder gasket was transferred into

the glass jar.

4. Is the Petri dish sealed and labeled

container No. 1?

T The amber glass jar is sealed and

labeled.

5. Is the particulate matter from the

probe nozzle, probe fitting, probe

liner, and front half of the filter

holder recovered quantitatively by

washing with (1:1 v/v)

methanol/methylene chloride into a

glass container? Labeled container

No. 2?

T Collected into amber glass container

and labeled. The liquid level is marked

on the container with a pen.

6. Is a solvent blank retained and

analyzed?

T

7. Is the sorbent module labeled

container No. 3, capped, and

packaged cold for shipment?

T The sorbent module weighed, labeled,

and kept in blue ice.

8 Is the condensate from the back

half of the filter module and the

knockout trap measured and

transferred to container No. 4?

T Collected into amber glass jar and

labeled. The liquid level is marked on

the jar with a pen.

9. Are the sample train components

between the filter and the first wet

impinger rinsed into container No.

5?

T

10. Is the silica gel transferred to

container No. 6?

T Weighed for the moisture content; silica

gel changed for each train.

11. Is the volume of the impinger

water in the first three impingers

measured to ± 1 ml and any color

or film noted? Is the impinger

catch discarded?

T No color or film was noticed. The

impinger catch is saved in the glass jars.

12. Are all containers sealed and all

shipped refrigerated except the

filter?

T
AUDIT QUESTIONS

RESPONSE

COMMENT

Y N

N

A

Technical Systms Audit of Test Methods Performed by PES 3.27

Additional Questions and Comments:

J. SAMPLING GENERAL

1. Is the duration of sampling

sufficient to detect all important

pollutant(s) generated by the

process under investigation?

T Sampling for 4 hr at the silo 2 tunnel

and 2 hr at the silo exhaust is quite

sufficient.

2. Are there specified limits for

which sampling will be stopped? 

Describe.

T Sampling will be stopped only when

loading or process problems

experienced at the site.

3. Were duplicate or replicate

samples taken for each sampling

location?

T One run was performed on each day.

4. Was the sampling performed in

accordance with the approved

QAPP?

T Generally followed the approved QAPP.

However, few changes such as sampling

rate at the silo exhaust testing were

made at the site after EPA WAM

authorization.

5. Do sample tracking numbers

indicate when, how, and where the

samples were collected?

T Labels were attached to the glass jars.

6. Are records available of who

collected the sample?

T Noted in the data sheets.

7. Are field log books and laboratory

log notebooks recorded in ink?

T Data sheets were used. Recorded legibly

with ink.

8. Are audit histories recorded in the

field log notebooks?

— thermocouple

— solid state temperature

— wood scale performance

— other

T Noted in the data sheets in the office.

Additional Questions and Comments:
AUDIT QUESTIONS

RESPONSE

COMMENT

Y N

N

A

Technical Systms Audit of Test Methods Performed by PES 3.28

K. QUALITY ASSURANCE/QUALITY CONTROL/GENERAL

1. Have there been any changes in the

project organization and the

personnel as outlined in the

QAPP?

T

2. Are there written plans to report

changes in the QAPP during datagathering activities?

T

3. Were field biased blanks and/or

trip blanks used?

T One field blank was collected.

4. Calibration information and data

sheets available for:

— Probe/nozzle

— Type-S pitot

— Meter Box including: dry gas 

 meter and thermocouple

— Barometer

T Data sheets will be given.

Additional Questions and Comments:
AUDIT QUESTIONS

RESPONSE

COMMENT

Y N

N

A

Technical Systms Audit of Test Methods Performed by PES 3.29

L. SAMPLE CUSTODY AND INTEGRITY

1. Is there an SOP or other source of

documentation which describes the

organization’s sample custody

procedures?

T There is no SOP at the site. However,

sample custody data sheets and

procedures are available.

2. Are records available of when,

how, and where the sample was

collected?

T Data sheets are available. Information is

noted in the data sheets and labeled on

the bottles.

3. Are records available of who

collected the sample?

T Recorded on the data sheets.

4. Who is the field custodian for the

samples? (Name)

T Jairo Barreda, a summer intern, is

responsible for the shipping and sample

custody.

5. Are samples individually identified

by number or code so that they can

be traced?

T Labels are electronically made, printed

for each run with identification, and

affixed to the glass jars.

6. Were deviations (if any) from all

SOPs or protocols properly

documented?

T Recorded by the Task Manager in a

small notebook. It would have been

better if the train operators noted on the

data sheets also.

7. Sample liquid levels marked on

each container such that the mark

can be seen on the container or on

the label itself.

T Marked with a pen on the container.

8. Sample container lids sealed on

outside with Teflon tape and

sample label covered with solvent

resistant tape?

T Solvent-resistant tape is not used to

cover the sample label.

9. Are integrity seals affixed over the

caps of each container?

T Labels are affixed on the side of the

glass jar.

10. Are seals signed and numbered by

recovery person?

T Seals are not signed. Numbered on the

labels.

Additional Questions and Comments:
AUDIT QUESTIONS

RESPONSE

COMMENT

Y N

N

A

Technical Systms Audit of Test Methods Performed by PES 3.30

M. MISCELLANEOUS MEASUREMENTS - Wind Speed, Wind Direction, Ambient

Temperature and Humidity

1. Is the meteorological station

operated according to the

manufacturer’s specification?

T

2. Is the manufacturer’s

specifications manual available at

the site?

T

3. Are the readings recorded

continuously through out the test

period?

T Recorded on a data-logger.

4. Was the wind speed measured and

calibrated?

T Calibrated at the office but not at the

site.

5. How the wind direction measured

and calibrated?

T Calibrated at the office but not at the

site.

6. How the temperature is measured

and what is the range?

T Thermometer -50 to 50 EC

7. Is the ambient humidity measured

once per test run by wet bulb using

a sling psychrometer and properly

recorded?

T Measured once in the beginning and

once at the end of the day.

Additional Questions and Comments:

The MET Station was kept at the top of the load-out tunnel near the entrance.

N. Estimation of Particulate Deposition on the Ceiling of the Load-Out Tunnel

Downstream and Silo No. 5

1. Is one test plate for each section is

installed properly in the beginning

of the test program?

T

2. Are the test plates and ceiling

sections cleaned with acetone

properly in the beginning and at

the end of the test program?

T
AUDIT QUESTIONS

RESPONSE

COMMENT

Y N

N

A

Technical Systms Audit of Test Methods Performed by PES 3.31

3. Have they collected three acetone

rinse samples and analyzed

gravimetrically?

Analysis will be performed in the office.

Additional Questions and Comments:

Measured the distance from Silo No. 5 to the end of the tunnel which is approximately 57 feet.

Divided the distance into three equal areas. Three test plates and ceiling sections were cleaned with

acetone. Each test plate is screwed to the top of the roof at 19 feet distance from one another on

7/2/98 morning. They were removed on 7/26/98 and rinsed with acetone and will be analyzed

gravimetrically.

O. Estimation of Particulate Deposition on the Inside Walls of Loud-Out-Tunnel

Exhaust Plenum

1. Are six pieces of box pipe installed

properly inside the exhaust plenum

under Silo No. 3 in the beginning

of the test program?

T Charged under Silo No. 2 on 7/23/98

and removed on 7/26/98 morning.

2. Are the box pipes and installation

sections cleaned with acetone

properly in the beginning and at

the end of the test program?

T Installation sections were not cleaned at

the end of the test program.

3. Have they collected six acetone

rinse samples and analyzed

gravimetrically?

T Acetone rinse samples will be analyzed

later in the laboratory.

Additional Questions and Comments:

Installed at the downstream of the exhaust plenum.

P. Estimation of Particulate Deposition on the Inside Walls of the Temporary

Silo Exhaust and Wind Tunnel Exhaust

1. Have they collected one acetone

rinse sample from inside walls of

the temporary silo exhaust and four

samples from the wind tunnel

exhaust?

T One was kept at the silo exhaust and

three samples were taken from the wind

tunnel exhaust.
AUDIT QUESTIONS

RESPONSE

COMMENT

Y N

N

A

Technical Systms Audit of Test Methods Performed by PES 3.32

2. Have they cleaned the areas and

installed the test plates properly?

T

Additional Questions and Comments:

Old silo exhaust pipe was cleaned and taken for metals analysis.

Q. Direct Interface Portable GC/MS

1. Is heated sample line used to draw

the sample into the GC/MS?

T Teflon lines were used at ambient

temperature.

2. How the instrument was

calibrated?

T Calibrated with 36 compounds in the

laboratory. Checked with 9 component

mixture at the field site daily.

3. What is the flow rate and sample

volume collected?

T Sample is drawn at 2 L/min.

Subsequently 150 cm3/min is diverted

into the mass spectrometer. A 20-30 μL

sample was used to inject into the GC.

4. How is the sample concentrated? T No concentration step.

5. Is the thermal desorption technique

used and at what temperature it

was desorbed?

T No concentration step. Therefore,

thermal desorption is not required.

6. Are there blank runs performed? T Nitrogen blank daily was performed.

7. How is the moisture interference

that was eliminated or minimized

during the analysis?

Up to 8 percent moisture levels, no

conditioning is required. Above that day

the sample used an impinger before

introducing it into GC/MS.

Additional Questions and Comments:

1. GC/MS runs were done at silo tunnel, silo exhaust, ambient air, end of the tunnel, and dryer

exhaust.

2. Lot of moisture was condensed at the silo exhaust and dryer exhaust. Impinger was used to

collect the water. Linearity checked in the laboratory, 6 injections ±20 percent RSD.
AUDIT QUESTIONS

RESPONSE

COMMENT

Y N

N

A

Technical Systms Audit of Test Methods Performed by PES 3.33

Additional Questions and Comments:

Column used: SPB-1 3-inch wound capillary column sample drawn through 0.3 μm glass fiber filter.

Detection limits vary from compound to compound.
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TECHNICAL REPORT DATA

(Please read Instructions on reverse before completing)

1. REPORT NO.

 EPA-454/R-00-026

2. 3. RECIPIENT'S ACCESSION NO.

4. TITLE AND SUBTITLE

 HOT MIX ASPHALT PLANTS

 TECHNICAL SYSTEMS AUDIT of TESTING at PLANT C

 ASPHALT PLANT C

 LOS ANGELES, CALIFORNIA

5. REPORT DATE

 May 2000

6. PERFORMING ORGANIZATION CODE

7. AUTHOR(S)

 Lara Autry (EPA)

 R.K.M. Jayanty (RTI)

 Robert S. Wright (RTI) 

8. PERFORMING ORGANIZATION REPORT NO.

9. PERFORMING ORGANIZATION NAME AND ADDRESS

 Research Triangle Institute

 Center for Environmental Measurements and Quality Assurance

 3040 Cornwallis Road, Post Office Box 12194

 Research Triangle Park, NC 27709-2194

10. PROGRAM ELEMENT NO.

11. CONTRACT/GRANT NO.

 68-D4-0091

12. SPONSORING AGENCY NAME AND ADDRESS

 Office of Air Quality Planning and Standards

 Office of Air and Radiation

 U.S. Environmental Protection Agency

 Research Triangle Park, NC 27711

13. TYPE OF REPORT AND PERIOD COVERED

Final

14. SPONSORING AGENCY CODE

 EPA/200/04

15. SUPPLEMENTARY NOTES

16. ABSTRACT

The United States Environmental Protection Agency (EPA) Emission Factors and Inventory Group (EFIG) is

investigating the Hot Mix Asphalt industry to identify and quantify criteria and hazardous air pollutants (HAP’s) emitted from

transport truck loading and silo filling. EFIG requested that EPA’s Emission Measurement Center (EMC) conduct the required

testing. Under separate EPA contracts, Midwest Research Institute (MRI) and Pacific Environmental Services (PES)

performed this emissions testing. An independent technical systems audit was performed as part of the quality assurance

evaluation of this testing effort. The EMC issued a work assignment to Research Triangle Institute (RTI) to perform this

technical system audit. The primary objective of the testing program was to characterize uncontrolled emissions of the criteria

pollutants particulate matter (PM) and total hydrocarbons (THC) and emissions of volatile and semi-volatile organic HAP’s

including polycyclic organic matter, phenol, benzene, toluene, xylene, ethylbenzene, 2-butanone, cumene, formaldahyde,

hexane, isooctane and others.

This report includes a summary of the independent audit results and detailed Technical Systems Audit checklists of

the evaluations RTI performed of the testing by MRI and PES.

17. KEY WORDS AND DOCUMENT ANALYSIS

a. DESCRIPTORS b. IDENTIFIERS/OPEN ENDED TERMS c. COSATI Field/Group

Hot Mix Asphalt

Silo Filling

Truck Loading

Particulate Matter

Volatile Organic Compounds

Total Hydrocarbons

Hazardous Air Pollutants

Polycyclic Organic Matter

Air Pollution control

18. DISTRIBUTION STATEMENT

 Release Unlimited

19. SECURITY CLASS (Report)

 Unclassified

21. NO. OF PAGES

142

20. SECURITY CLASS (Page)

 Unclassified

22. PRICE

EPA Form 2220-1 (Rev. 4-77) PREVIOUS EDITION IS OBSOLETE
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