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 requirements.

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 matter.

There was no cross-examination of Mr. Brassell.