TESTIMONY OF GILBERT W. BRASSELL; March 5, 1999.
Mr. Brassell represents NFT, Incorporated, a private
company that has developed and patented an alternative
method for TRU waste container venting and headspace gas
sampling and analysis.
In the current draft Permit only 2 prescribed sampling
methods involving use of a side-port needle or retractable
drum lid-punch are allowed. These methods were those
submitted in the Permit Application several years ago and at
that time were the only documented methods developed and
tested (to a limited extent). Since then, these methods
have been improved, and alternative sampling methods have
been developed which meet or exceed current quality
Headspace gas sampling and analysis data are used mostly
for documentation purposes, and there does not appear to be
any technical or regulatory basis for having such
restrictive sampling/analysis requirements in the Permit.
Sampling methods should be flexible as long as they meet the
draft Permit specified data quality objectives. NFT,
Incorporated urges a permit modification be incorporated
into relevant portions of the final Permit to allow
alternative methods of headspace gas sampling and analysis.
So long as performance requirements such as acceptable
quality control, successful participation in the Performance
Demonstration Program (PDP), and audit approval are
achieved, the specific method/equipment used should not
There was no cross-examination of Mr. Brassell.