Environmental Technology Verification Coatings and Coating Equipment Program (ETV CCEP) High Transfer Efficiency Spray Equipment - Generic Verification Protocol (Revision 0) September 30, 2006 Distribution Statement "A" applies Approved for public release; distribution is unlimited Requests for this document shall be referred to: Office of the Assistant Secretary of the Army for Installations and Environment ASA (I&E) - ESOH 1235 Clark Street Crystal Gateway 1, Suite 307 Arlington, VA 22202-3263 Contract No. W74V8H-04-D-0005 Task No. 0428 CDRL No. A004 Prepared by National Defense Center for Environmental Excellence (NDCEE) Submitted by Concurrent Technologies Corporation 100 CTC Drive Johnstown, PA 15904 ------- This Page Intentionally Left Blank ------- REPORT DOCUMENTATION PAGE Form APProved OMB No 0704-0188 Public reporting burden for this collection of information is estimated to average 1 hour per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. Send comments regarding this burden estimate or any other aspect of this collection of information, including suggestions for reducing this burden to Washington Headquarters Services, Directorate for information operations and Reports, 1215 Jefferson Davis Highway, Suite 1204, Arlington, VA 22202-4302, and to the Office of Management and Budget, Paperwork Reduction Project (0704-0188), Washington, DC 20503. 1. AGENCY USE ONLY (Leave blank) 2. REPORT DATE 3. REPORT TYPE AND DATES COVERED 30 September 06 Generic Verification Protocol / Sep. 2005 - Jun. 2007 4. TITLE AND SUBTITLE ETV CCEP, High Transfer Efficiency Spray Equipment - Generic Verification Protocol (Revision 0) 6. AUTHOR(S) Principal Author/PMt: Robert J. Fisher, CTC 1. PERFORMING ORGANIZATION NAME(S) AND ADDRESS(ES) National Defense Center for Environmental Excellence Operated by Concurrent Technologies Corporation 100 CTC Drive Johnstown, PA 15904 9. SPONSORING/MONITORING AGENCY NAME(S) AND ADDRESS(ES) NDCEE Program Office (Office of the Assistant Secretary of the Army for Installations and Environment) 1235 Clark Street, Suite 307 Arlington, VA 22202-3263 Program Manager: Dr. Chuck Lecher, NDCEE Program Manager, 703-602-5538 5. FUNDING NUMBERS Contract: W74V8H-04-D-0005 Task: NDCEE Task No. 0428 8. PERFORMING ORGANIZATION REPORT NUMBER 10. SPONSORING/MONITORING AGENCY REPORT NUMBER NDCEE-CR-2006-082 10 SUPPLEMENTARY NOTES 12a. DISTRIBUTION/AVAILABILITY STATEMENT Distribution authorized to the DoD and DoD contractors only. 12b. DISTRIBUTION CODE 13. ABSTRACT (Maximum 200 words) The Environmental Technology Verification (ETV) Program has been established by the U.S. Environmental Protection Agency (EPA) to verify the performance characteristics of innovative environmental technologies across all media and report this objective information to the states, buyers, and users of environmental technology; thus, accelerating the entrance of these new technologies into the marketplace. Verification organizations oversee and report verification activities based on testing and quality assurance protocols developed with input from major stakeholders and customer groups associated with the technology area. ETV consists of six technology centers. Information about each of these centers can be found on the Internet at http://www.epa.gov/etv/. EPA's ETV Program, through the National Risk Management Research Laboratory (NRMRL), Air Pollution Prevention and Control Division (APPCD) has partnered with Concurrent Technologies Corporation (CTC), through the National Defense Center for Environmental Excellence (NDCEE), to verify innovative coatings and coating equipment technologies for reducing air emissions from coating operations. Pollutant releases to other media are considered in less detail. The following protocol outlines the basis for completing an ETV verification test of High-Transfer Efficiency Spray Guns. 14. SUBJECT TERMS 15. NUMBER OF PAGES 59 16. PRICE CODE 17. SECURITY CLASSIFICATION 18. SECURITY CLASSIFICATION 19. SECURITY CLASSIFICATION 20. LIMITATION OF ABSTRACT OF REPORT OF THIS PAGE OF ABSTRACT None Unclassified Unclassified Unclassified NSN 7540-01-280-5500 Standard Form 298 Rev. 12/00 Prescribed by ANSI ST. 239-18 880922 ------- This Page Intentionally Left Blank ------- Section No. i Revision No. 0 9/30/2006 Page i of v TABLE OF CONTENTS Page SI TO ENGLISH CONVERSIONS iv LIST OF ABBREVIATIONS AND ACRONYMS v 1.0 INTRODUCTION 1 1.1 Purpose of the High Transfer Efficiency Spray Equipment GVP 1 1.2 Quality Assurance for the ETV CCEP 1 1.3 Organization of the High-TE GVP 1 1.4 Formatting 2 1.5 Approval Form 2 2.0 PROJECT DESCRIPTION 4 2.1 General Overview 4 2.1.1 Demonstration Factory Testing Site 5 2.1.2 Laboratory Facilities 6 2.2 Technical/Experimental Approach and Guidelines 7 2.2.1 Test Approach 8 2.2.2. Verification Test Objectives 8 2.2.3 Large Target Description 8 2.2.4 Small Target Description 9 2.2.5 Coating Specification 11 2.2.6 Standard Apparatus 12 2.2.7 Process Standards 12 2.2.8 Design of Experiment 13 2.2.9 Performance Testing 13 2.2.10 Quantitative Measurements 14 2.2.11 Participation 14 2.2.12 Critical and Non-Critical Factors 14 2.3 Schedule 19 3.0 PROJECT ORGANIZATION AND RESPONSIBILITIES 20 4.0 QUALITY ASSURANCE OBJECTIVES 23 4.1 General Objectives 23 4.2 Quantitative Quality Assurance Objectives 23 4.2.1 Accuracy 25 4.2.2 Precision 26 4.2.3 Completeness 26 4.2.4 Impact and Statistical Significance Quality Objectives 26 4.3 Qualitative QA Objectives: Comparability and Representativeness 26 4.3.1 Comparability 26 4.3.2 Representativeness 27 4.4 Other QA Objectives 27 4.5 Impact of Quality 27 5.0 SITE SELECTION AND SAMPLING PROCEDURES 28 High- TE Spray Equipment Generic Verification Protocol ------- Section No. i Revision No. 0 9/30/2006 Page ii of v 5.1 Site Selection 28 5.2 Site Description 28 5.3 Sampling Procedures and Handling 28 5.4 Sample Custody, Storage and Identification 29 6.0 ANALYTICAL PROCEDURES AND CALIBRATION 30 6.1 Facility and Laboratory Testing and Calibration 30 6.1.1 Facility Testing and Calibration 30 6.1.2 Laboratory Testing and Calibration Procedures 30 6.2 Product Quality Procedures 31 6.3 Standard Operating Procedures and Calibration 31 6.4 Non-Standard Methods 33 7.0 DATA REDUCTION, VALIDATION, AND REPORTING 34 7.1 Raw Data Handling 34 7.1.1 Variables Used In Analysis 34 7.1.2 Error in Mass of Coating Sprayed 34 7.1.3 Error in Solids Content 35 7.1.4 Error in Mass Deposited 35 7.1.5 Calculation of Transfer Efficiency 35 7.2 Preliminary Data Package Validation 36 7.3 Final Data Validation 36 7.4 Data Reporting and Archival 37 7.4.1 Calculation of DFT 37 7.4.2 Interpretation of the Numerical Results 37 7.4.3 Evaluation of the High-TE Spray Gun 37 7.5 Verification Statement 38 8.0 INTERNAL QUALITY CONTROL CHECKS 39 8.1 Guide Used for Internal Quality Program 39 8.2 Types of QA Checks 39 8.3 Basic QA Checks 39 8.4 Specific Checks 40 9.0 PERFORMANCE AND SYSTEM AUDITS 41 10.0 CALCULATION OF DATA QUALITY INDICATORS 42 10.1 Precision 42 10.2 Accuracy 42 10.3 Completeness 42 10.4 Project Specific Indicators 42 11.0 CORRECTIVE ACTION 43 11.1 Routine Corrective Action 43 11.2 Nonroutine Corrective Action 43 12.0 QUALITY CONTROL REPORTS TO MANAGEMENT 44 High- TE Spray Equipment Generic Verification Protocol ------- Section No. i Revision No. 0 9/30/2006 Page iii of v LIST OF TABLES Table 1. Testing and Laboratories and Representative Laboratory Equipment Holdings 7 Table 2. Overall Guidelines and Procedures Applied to this Test/QAPlan 7 Table 3. Critical Control Factors 16 Table 4. Non-Critical Control Factors 17 Table 5. Critical Response Factors 18 Table 6. Estimated Schedule as of 9/27/06 19 Table 7. Summary of ETV CCEP Experience and Responsibilities 21 Table 8. Frequency and Mechanisms of Communications 22 Table 9. Responsibilities During Testing 22 Table 10. QA Objectives for Precision, Accuracy and Completeness for All Non-Critical Control Factor Performance Analyses 24 Table 11. QA Objectives for Precision, Accuracy and Completeness for All Critical Response Factor Performance Analyses 25 Table 12. Process Responsibilities 29 Table 13. Non-Critical Control Factor Testing and Calibration Criteria 32 Table 14. Critical Response Factor Testing and Calibration Criteria 33 Table 15. CTC Laboratory QA/QC Format Sources 39 LIST OF FIGURES Figure 1. Test/QAPlan Approval Form 3 Figure 2. Demonstration Factory Layout 5 Figure 3. Demonstration Factory Organic Finishing Line 6 Figure 4. Large Target Application Diagram 9 Figure 5. Small Target Application Diagram 10 Figure 6. Test Panel Measurement Locations 11 Figure 7. Project Organization Chart 20 LIST OF APPENDICES A ASTM International Methods High- TE Spray Equipment Generic Verification Protocol ------- Section No. i Revision No. 0 9/30/2006 Page iv of v SI to English Conversions Multiply SI by factor to SI Unit English Unit obtain English °C °F (1.80 E +00), then add 32 L gal. (U.S.) 2.642 E-01 m ft 3.281 E + 00 kg Ibm 2.205 E + 00 kPa psi 1.4504 E-01 cm in. 3.937 E-01 mm mil (1 mil = 1/1000 in.) 3.937 E + 01 m/s ft/mm 1.969 E + 02 kg/L Ibm/gal (U.S.) 8.345 E + 00 High- TE Spray Equipment Generic Verification Protocol ------- Section No. i Revision No. 0 9/30/2006 Page v of v List of Abbreviations and Acronyms %C percent completeness %R percent recovered %S percent solids ACGIH American Conference of Governmental Industrial Hygienists ACS American Chemical Society ANSI American National Standards Institute AOAC Association of Official Analytical Chemists ASQC American Society for Quality Control CCEP Coatings and Coating Equipment Program CTC Concurrent Technologies Corporation CS coating sprayed DFT dry film thickness DOI distinctness-of-image EP empty pan EPA U.S. Environmental Protection Agency ES empty syringe ETF environmental technology facility ETV environmental technology verification FS full syringe GVP generic verification protocol HVLP high-volume, low-pressure IR infrared ISO International Standardization Organization NDCEE National Defense Center for Environmental Excellence NIST National Institute for Standards and Technology OFL organic finishing line P2 pollution prevention PLC programmable logic controller PS pan solids QA/QC quality assurance/quality control QMP quality management plan RPD relative percent difference RSD relative standard deviation SD solids deposited srm standard reference material SS solids sprayed TE transfer efficiency VOC volatile organic compound WBS work breakdown structure High- TE Spray Equipment Generic Verification Protocol ------- ------- This Page Intentionally Left Blank ------- ------- Section No. 1 Revision No. 0 9/30/2006 Page 1 of 44 1.0 INTRODUCTION 1.1 Purpose of the High Transfer Efficiency Spray Equipment GVP The primary purpose of this document is to establish the generic verification protocol (GVP) for high transfer efficiency (TE) spray equipment, to which reference will be made frequently throughout this document as the High-TE GVP. The secondary purpose is to establish the generic format and guidelines for product specific Testing and Quality Assurance Plans (test/QA plans) that relate to this GVP. Environmental Technology Verification Coatings and Coating Equipment Program (ETV CCEP) project level test/QA plans will establish the specific data quality requirements for all technical parties involved in each project. A defined format, as described below, is to be used for all ETV CCEP High-TE test/QA plans to facilitate independent reviews of project plans and test results, and to provide a standard platform of understanding for stakeholders and participants. 1.2 Quality Assurance for the ETV CCEP Projects conducted under the auspices of the ETV CCEP will meet or exceed the requirements of the American National Standards Institute/American Society for Quality Control (ANSI/ASQC), Specifications and Guidelines for Quality Systems for Environmental Data Collection and Environmental Technology Programs, ANSI/ASQC E-4 (1994) standard. This GVP will ensure that project results are compatible with and complementary to similar projects. All ETV CCEP High-TE test/QA plans are adapted from this standard and the ETV Program Quality Management Plan (QMP). These test/QA plans will contain sufficient detail to ensure that measurements are appropriate for achieving project objectives, that data quality is known, and that the data are legally defensible and reproducible. 1.3 Organization of the High-TE GVP This GVP contains the sections outlined in the ANSI/ASQC E-4 standard. As such, this GVP identifies processes to be used, test and quality objectives, measurements to be made, data quality requirements and indicators, and procedures for the recording, reviewing and reporting of data. High- TE Spray Equipment Generic Verification Protocol ------- Section No. 1 Revision No. 0 9/30/2006 Page 2 of 44 The major technical sections discussed in this GVP are as follows: Project Description Project Organization and Responsibilities Quality Assurance (QA) Objectives Site Selection and Sampling Procedures Analytical Procedures and Calibration Data Reduction, Validation and Reporting Internal Quality Control (QC) Checks Performance and System Audits Calculation of Data Quality Indicators Corrective Action Quality Control Reports to Management Appendices 1.4 Formatting In addition to the technical content, this GVP also contains standard formatting elements required by the ANSI/ASQC E-4 standard and Concurrent Technologies Corporation (CTC) deliverables. Standard format elements include, at a minimum, the following: . Title Page . Test/QA Plan Approval Form . Table of Contents . Document Control Identification (in the plan header): Section No. _ Revision No. _ Date: Page: of 1.5 Approval Form Key ETV CCEP personnel will indicate their agreement and common understanding of the project objectives and requirements by signing the test/QA plan Approval Form for each piece of equipment tested. Acknowledgment by each key person indicates commitment toward implementation of the plan. Figure 1 shows the Approval Form format to be used. High- TE Spray Equipment Generic Verification Protocol ------- Section No. 1 Revision No. 0 9/30/2006 Page 3 of 44 APPROVAL FORM Date Submitted: QTRAKNo.: Revision No.: Project Category: Title: Project/Task Officer: EPA/Address/Phone No.: U.S. EPA- U.S.DCC-W Interagency Agreement No.: U.S. AEC/ NDCEE Contract No.: Task No. APPROVALS ETV CCEP Project Manager Signature Date ETV CCEP QA Manager Signature Date ETV EPA Project Officer Signature Date ETV EPA Project QA Manager Signature Date EPA - U.S. Environmental Protection Agency DCC-W - Defense Contracts Command - Washington AEC - Army Environmental Center Figure 1. Test/QA Plan Approval Form High- TE Spray Equipment Generic Verification Protocol ------- Section No. 2 Revision No. 0 9/30/2006 Page 4 of 44 2.0 PROJECT DESCRIPTION 2.1 General Overview Organic finishing processes are used by many industries for the protection and decoration of their products. Organic coatings contribute nearly 20 percent of total stationary area source volatile organic compound (VOC) emissions, as well as a significant percentage of air toxic emissions. Coating application equipment is continually being developed or redesigned to reduce any detrimental effects to the environment. This is primarily accomplished by increasing the TE of the coating operation and, therefore, reducing the amount of coating used, (i.e., less overspray) and VOCs released into the environment. Often these coating equipment technologies are slow to penetrate the market because potential users, especially an ever-growing number of small companies, do not have the resources to test the new equipment in their particular application and may be constructively skeptical of the equipment provider's claims. If an unbiased, third-party facility could provide pertinent test data, environmentally friendly coating equipment technologies would penetrate the industry faster and accelerate environmental improvements. The ETV CCEP, a joint venture of the U.S. Environmental Protection Agency (EPA) and CTC of Johnstown, Pennsylvania, in conjunction with the National Defense Center for Environmental Excellence (NDCEE) Program, has been established to provide unbiased, third-party data. The ETV CCEP has been tasked to develop, and subsequently utilize, a series of standardized protocols to verify the performance characteristics of coatings and coating equipment. This GVP will verify the performance of high-TE spray equipment. To maximize the ETV CCEP's exposure to the coatings industry, the data from the verification testing will be made available on the Internet at the EPA's ETV Program website (http://www.epa.gov/etv/) under the Pollution Prevention (P2) Innovative Coatings and Coating Equipment Pilot, as well as through other sources (e.g., publications, seminars). This will help establish the ETV CCEP's reputation in the private sector. A long-range goal of this initiative is to become a vital resource to the industry and, thus, self-sustaining through private support. This is in addition to its primary objective of improving the environment by rapidly introducing more environmentally friendly coating technologies into the industry. High- TE Spray Equipment Generic Verification Protocol ------- Section No. 2 Revision No. 0 9/30/2006 Page 5 of 44 2.1.1 Demonstration Factory Testing Site CTC has been tasked under the NDCEE Program to establish a demonstration factory capable of prototyping processes that will reduce or eliminate environmentally harmful materials used or produced in manufacturing. To accelerate the transition of environmentally friendly processes to the manufacturing base, CTC offers the ability to test processes and products on full-scale, commercial equipment. It includes a combination of organic finishing, cleaning, stripping, inorganic finishing, and recycle/recovery equipment. The organic finishing equipment in the demonstration factory will be available for the ETV CCEP testing performed in this project. A layout of the CTC Demonstration Factory is shown in Figure 2. A schematic of the organic finishing line (OFL) is shown in Figure 3. Demonstration Factory Organic Finishing Powder Coat Conventional Spray Electrocoat (E-Coat) CO2 2 I Inorganic Finishing Advanced Electroplating Ion Plating Ion Implantation Plasma Spray High Velocity 02 Fuel Ion Beam Assisted Deposition | 3 | Advanced Cleaning Power Washer Dual-Use Ultrasonic Advanced Immersion Supercritical CO2 Honeycomb Cleaning | 4 | Coatings Removal Solid Media Blast Wet/Dry Blast High-Pressure Waterjet CO2 Pellet/Turbine Wheel Ultrahigh-Pressure Waterjet Laser Building Support System Shipping & Receiving Process Water Reuse/Recycle Cross-Flow Microfiltration Diffusion Dialysis Electrowinning Ion Exchange Membrane Electrolysis Reverse Osmosis Vacuum Evaporation Figure 2. Demonstration Factory Layout High- TE Spray Equipment Generic Verification Protocol ------- Section No. 2 Revision No. 0 9/30/2006 Page 6 of 44 POWDER COAT SUBSYSTEM CLEANING PRETREATMENT Figure 3. Demonstration Factory OFL In the event that a particular technology demonstration or laboratory analysis cannot be performed at CTC, arrangements will be made to ensure the requirements of the test/QA plan and all associated QA procedures are completed. 2.1.2 Laboratory Facilities In support of the demonstration factory coating processes, CTC maintains extensive, state-of-the-art laboratory testing facilities. These laboratory facilities are used for the measurement and characterization of processes and specimens, as well as for bench-scale coating technology evaluations. Table 1 lists the various testing and evaluation laboratories and the representative equipment holdings that are relevant to ETV CCEP equipment projects. High- TE Spray Equipment Generic Verification Protocol ------- Section No. 2 Revision No. 0 9/30/2006 Page 7 of 44 Table 1. Testing and Laboratories and Representative Laboratory Equipment Holdings Laboratory Environmental Testing Destructive and Nondestructive Evaluation Materials and Mechanical Testing Calibration Laboratory Focus 1 ) Identification and quantification of biological, organic, and inorganic chemicals and pollutants to all media. 2) Industrial process control chemical analysis. Evaluation of product and process performance, and surface cleanliness. Measurement of service and processing material and mechanical properties. Calibration of equipment, sensors, and components to nationally traceable standards. Laboratory Equipment Hewlett Packard 5 972 A GC/MS P-E Headspace GC/ECD/FID Magnetic/Eddy Current Thickness Salt Spray Corrosion Chamber Microhardness/Tensile/Fatigue/Wear Noran and CAMScan Electron Microscopes Nikon and Polaroid Light Optical Microscopes EDAX Energy Dispersive Spectrometer Impact Testers Transmation Signal Calibrator (milliamps, millivolts) Thermacal Dry Block Calibrator (Temperature) Druck Pressure Calibrator (Pressure) Fluke Digital Multimeter (Voltage) 2.2 Technical/Experimental Approach and Guidelines The following tasks are proposed for tests completed according to this GVP: Develop product-specific test/QA plan Conduct verification and baseline (as needed) tests Prepare Verification Report and Data Notebook Prepare Verification Statement for approval and distribution Table 2 describes the general guidelines and procedures that will be applied to each test/QA plan. Table 2. Overall Guidelines and Procedures Applied to Test/QA Plans A detailed description of each part of the test will be given. Critical and non-critical factors will be listed. Non-critical factors will be held constant throughout the testing. Critical factors will be listed as control (process) factors or response (coating product quality) factors. The product-specific test/QA plans will identify the testing site. The testing will be under the control and close supervision of ETV CCEP representatives to ensure the integrity of the third party testing. The QA portions of this GVP will be strictly adhered to. A statistically significant number of samples will be analyzed for each critical response factor. Variances (or standard deviations) of each critical response factor will be reported for all results. High- TE Spray Equipment Generic Verification Protocol ------- Section No. 2 Revision No. 0 9/30/2006 Page 8 of 44 2.2.1 Test Approach The following approach will be used for this GVP: The vendor will select the performance parameters to be verified and recommend the optimum equipment settings for application and curing; The ETV CCEP will obtain enough test panels and foil for the verification and baseline tests; The ETV CCEP will obtain enough coating to complete the verification and baseline tests; The vendor will provide the high-TE spray gun and all necessary accessories to be verified; The ETV CCEP will obtain the baseline spray equipment; Data such as foil or panel weight (before coating and after curing), quantity of sprayed coating, quantity of supplied coating, and mil thickness of coating will be collected, following the ASTM International methods, or equivalent; A statistically valid test program that efficiently accomplishes the required objectives will then be used to analyze the test results. 2.2.2. Verification Test Objectives The objectives of the verification test performed per this GVP are to verify the transfer efficiency and the finish quality achieved by the candidate technology and determine the technology's P2 benefits relative to a baseline. During the coating application phase, parameters such as: inlet air pressure, outlet air pressure, and airflow will be measured. During the laboratory analysis phase, coated test panels and foils will be used to measure TE. At a minimum, coated test panels will also be used to measure parameters such as: dry film thickness (DFT), gloss, distinctness- of-image (DOT), and visual appearance. The vendor may request additional performance tests to verify a specific claim. 2.2.3 Large Target Description The large target will consist of an uncoated steel plate backboard measuring 91.4 cm by 91.4 cm (36 in. x 36 in.) attached to a stationary stand in the middle of the spray booth. The backboard will be covered with heavy gage (approximately 50 |j,m (0.002 in.)) aluminum foil by wrapping the excess foil around the edges of the backboard. Clean pre- weighed foil will be used to determine TE. In addition, cold-rolled steel panels will be coated to determine finish quality. Each spray gun will utilize multiple passes per coat on the finish quality panels and foils using 50% overlap. The pattern for applying the coats High- TE Spray Equipment Generic Verification Protocol ------- Section No. 2 Revision No. 0 9/30/2006 Page 9 of 44 will typically follow passes 1, 2, 3, then 4 (see Figure 4). If a second coat is necessary, the pattern of the first coat will be repeated after a predetermined flash time. All passes will begin and end on the backboard (i.e., no lead or lag overspray). Also, there will be no overspray above or below the backboard. All guns will travel the same horizontal distance while spraying for each pass. All guns will be operated at the same distance from the target. The fan pattern heights will vary depending on the characteristics of the gun-coating interaction. The spray guns will typically be operated with the fluid and fan adjustments set at full open. However, the maximum variation between the fan patterns for each coating will be no greater than 2.5 cm (1 in.). In other words, assuming the smallest fan pattern is 25.4 cm (10 in.) for a particular coating, no spray gun shall have a fan pattern greater than 27.9 cm (11 in.) for that coating. For each large target combination, a minimum of four (4) samples will be collected per gun, per coating. First, three TE (foil only) samples will be collected. Then, the backboard will be covered with a clean piece of aluminum foil. A cold-rolled steel finish quality panel, meeting SAE 1008 specifications, measuring 30.5 cm tall by 45.7 cm wide (12 in. by 18 in.), and treated with zinc phosphate at CTC, will be attached to the center of the foil-covered backboard. The spray guns will coat the finish quality panels using the same application pattern as the TE foils. A minimum of one finish quality panel will be collected for each test combination. The finish quality panels must be prepared under conditions representative of those used to obtain the TE data. Figure 4. Large Target Application Diagram 2.2.4 Small Target Description High- TE Spray Equipment Generic Verification Protocol ------- Section No. 2 Revision No. 0 9/30/2006 Page 10 of 44 The small target will not use aluminum foil. The TE and finish quality analyses will be conducted on the same type of panel. Therefore, only three samples will be coated per gun per coating. The small panels will measure approximately 12.7 cm by 30.5 cm (5 in. x 12 in.) and will be made of 22-gauge cold-rolled steel meeting SAE 1008 specifications. The small panels will be obtained and will be treated with a zinc phosphate pretreatment at CTC. Each spray gun will typically make 2 passes per coat on the small panels using 50% overlap. The pattern for applying the coats will be passes 1 then 2 (see Figure 5). If a second coat is necessary, the pattern of the first coat will be repeated after a predetermined flash time. Both the top and bottom passes will lose 50% of their fan pattern to overspray above and below the small panels. All passes will begin/end 6.4 cm (2.5 in.) from the leading/trailing edges of the fan pattern to the beginning/ending edges of the small panels (i.e., the spray guns will be triggered while in motion and when the center of the air cap is 6.4 cm plus half the horizontal width of the fan pattern away from the edge of the small panel). The guns will maintain a fan pattern height of 25.4 cm (10 in.) by varying the gun-to- target distance. The spray guns will be operated with the fluid and fan adjustments set at full open. Three small panels will be coated for each test combination and at least one of those panels will be randomly selected and evaluated for finish quality. Figure 5. Small Target Application Diagram The small panels will be manually transported into and out of the spray booth. A stand will be placed in the booth to hold the large backboard and the small panels. Figure 6 is a schematic of the small panels and the large finish quality panels showing the measurement locations for DFT and gloss. High- TE Spray Equipment Generic Verification Protocol ------- Section No. 2 Revision No. 0 9/30/2006 Page 11 of 44 12.7cm 30.5 cm 0 A 0 A 0 0 A 0 A 0 E o in Small TE/Finish Quality Panels ° | Wet Film Fbints O DFT Fbints A Gloss Fbints 45.7cm 0 0 000 A A 000 A ° ° ° A A A O O O 0 0 Large Target Finish Quality Panels Figure 6. Test Panel Measurement Locations The test will consist of a number of test combinations. Each test combination will consist of a spray gun (high-TE, high-volume, low- pressure (HVLP) #1, or HVLP #2), a coating (e.g., primer, basecoat, or topcoat), and a test panel (large combination foil, large combination finish quality panel, or small combination TE/fmish quality panel). The large foils will not be used for finish quality and the large finish quality panels will not be used for TE analysis. The small panels will be used for both TE and finish quality analysis. 2.2.5 Coating Specification The vendor will choose the test coating(s) based on its use in the target industry. The ETV CCEP will obtain a quantity of the test coating(s) to complete the verification and baseline tests. The test coating(s) will be prepared following the coating manufacturer's recommendations. The exact coating preparation procedures will be recorded. For comparison, the test coating(s) used during the verification test will be prepared the same as the coating batches prepared for the baseline test. Coating samples will be taken just prior to coating the test panels or foils to measure the coating temperature, viscosity, percent solids, volatile content and density. The coating measurements will be recorded on the coating batch worksheet. High- TE Spray Equipment Generic Verification Protocol ------- Section No. 2 Revision No. 0 9/30/2006 Page 12 of 44 2.2.6 Standard Apparatus Figure 3 shows the testing location of the wet spray booth relative to the OFL. All testing will be performed in the same wet spray booth. The test panels and foils will be attached to a stand in the spray booth. A programmable logic controller (PLC) will activate the motors that drive the linear motion translators. The translator can move the spray gun horizontally and vertically. The translator set-up could potentially cover an area approximately 1.37 m by 1.37 m (4.5 ft x 4.5 ft). The test panels and foils will be automatically sprayed using vertical overlap of the fan pattern. The spraying mechanism's PLC will control the triggering of the spray guns by way of pneumatically actuated clamp. During dwell time between passes, coating flow will be interrupted to minimize coating usage. Once the spray application is complete, the next rack or target will be moved into position. The spray booth air filters will be changed prior to setting up the standard apparatus for the verification test. The pressure drop across the filters will be checked prior to each run and at the end of the test. The pressure drop is monitored in the event that the filter bank system malfunctions. A pressure drop across the filter bank greater than 1 cm (0.4 in.) of water shall indicate that the system requires service. As a comparison, the spray booth air filters will also be changed before the baseline spray guns are set up and tested as part of the TE baseline. This will minimize the difference in the initial air booth velocity between the guns. The air booth velocity will be measured in close proximity to the test panels or foils. Although the air velocity through the booth will exceed 0.5 m/s (100 ft/min), the velocity measured near the test panels or foils will be lower due to the disruption of the air currents by the test panel or foil. After a target is coated, the next target in that test combination will be moved into position. After the test panels or foils have been cured, they will be transferred to the laboratory for analysis. 2.2.7 Process Standards The cold-rolled steel panels will consist of two sizes (see Figure 6). The pretreatment method will be the same for all steel panels. The preparation of the test coatings used for the verification test will be the same as the HVLP tests. The TE analysis will follow Procedure A of ASTM D 5286. The environmental (ambient) conditions of the demonstration factory will be monitored, both inside the booth near the test panels or foils and near the outside of the curing oven. The curing process for the verification test will be similar to the baseline tests. Operating parameters during the verification test will be held relatively constant and will be comparable to the HVLP tests. High- TE Spray Equipment Generic Verification Protocol ------- Section No. 2 Revision No. 0 9/30/2006 Page 13 of 44 2.2.8 Design of Experiment This GVP provides procedures used to determine the performance characteristics of high-TE spray equipment. A mean value and variance (or standard deviation) will be reported for each critical response factor. A confidence and specification limit of 95% will be applied to these tests. Several test combinations will be used for each gun (multiple coating types, two target sizes). The order in which the combinations will take place will be randomized. This will enable both coating-to-coating and gun-to-gun variations to be determined for each response factor. The statistical analyses for all response factors will be performed using a statistical software package. 2.2.9 Performance Testing The ETV CCEP will consult the manufacturers' recommendations for key operating factors to be used for testing, including the coating specifications: viscosity, weight % solids, etc. Recommended equipment settings for the coating will be obtained from the vendor. The ETV CCEP will test these conditions prior to starting the verification test. These conditions may be modified during the start-up phase to ensure proper gun performance. During the actual tests, no attempt will be made to optimize the equipment. The high-TE spray equipment will be evaluated for both inlet and outlet air pressures and airflow. Test panels and foils will be used to measure equipment performance. The small panels and large finish quality panels will be used for DFT, gloss, DOT, and visual appearance. The small panels and large foils will be used for TE analysis. The coating characteristics may be affected by other parameters of the testing process, such as pretreatment, apparatus setup, and cleanup methods. The pretreatment process will be the same for all test panels; therefore, the variability of the pretreatment process should not be a significant factor. Non-critical control factors will be monitored or held relatively constant for the verification test. DFT measurements will be used to determine the variations in film thickness. Gloss, DOT, and visual appearance tests will be used to analyze the quality of the coating finish. TE measurements will be used to determine the quantitative difference between the high-TE spray equipment and a HVLP baseline. The TE test will follow Procedure A of ASTMD5286. High- TE Spray Equipment Generic Verification Protocol ------- Section No. 2 Revision No. 0 9/30/2006 Page 14 of 44 The small panels and large foils will be weighed and the weights recorded prior to being placed in the spray booth. The weight of the gun, cup, coating, and coating container will be recorded on the worksheets immediately before applying the coating to each test panel. After each test panel or foil has been coated, the spray gun, cup, coating, and coating container will be re-weighed and the weights will be recorded. After the panels or foils are cured, they will be re-weighed. 2.2.10 Quantitative Measurements In order to evaluate the TE and the finish quality obtained by using the high-TE and baseline spray guns, several measurements will be taken from the non-coated and coated test panels and foils. In the case of the non-coated panels or foils, the area in square feet and the weight of the TE foils or panels will be measured. For the coated panels or foils, weight of the TE foils and panels will be measured and DFT will be measured on the finish quality panels. This procedure will follow ASTM D 5286 whenever practical. The uniformity of the coating applied can be determined by measuring DFT at several specified locations on the test panels. Measurements will be taken fifteen (15) locations on the large panels and at nine (9) locations on the small panels. Figure 6 displays the test panels with their respective locations of the film thickness and gloss measurements. Gloss measurements will be taken at five (5) locations on both the large and small panels. These sites will be numbered and measurements will be taken accordingly. The recorded measurements will be correlated to a specific site on each test panel for each test. In addition to the performance analyses, the ETV CCEP will evaluate the potential environmental benefits associated with using the high-TE spray gun. Therefore, TE values will be quantitatively measured for each test combination using nearly identical test conditions as the HVLP baseline. A qualitative comparison will then be made to determine if the high-TE spray gun exhibits a comparable or higher TE than the HVLP baseline. 2.2.11 Participation The vendor of the technology being verified is welcome to participate in the start-up phase and observe the verification and baseline testing. The ETV CCEP personnel will be responsible for performing all necessary test and demonstrations required for performance evaluation and full-scale validation. 2.2.12 Critical and Non-Critical Factors High- TE Spray Equipment Generic Verification Protocol ------- Section No. 2 Revision No. 0 9/30/2006 Page 15 of 44 For the purpose of this GVP, the following definitions will be used for critical control factors, non-critical control factors, and critical response factors. A critical control factor is a factor that is varied in a controlled manner within the design of the experiment to determine its effect on a particular outcome of a system. Non-critical control factors are all the factors that are to be held relatively constant or randomized throughout the testing for each specific piece of equipment (some non-critical factors may vary from equipment to equipment). Critical response factors are the measured outcomes of each combination of critical and non-critical control factors given in the design of experiments. In this context, the term "critical" does not convey the importance of a particular factor (that can only be determined through experimentation and characterization of the total process), but its relationship within the design of experiments. In the case of the verification testing of a particular piece of coating equipment, the only critical control factors are the pieces of coating equipment themselves. All other processing factors will be held relatively constant (or randomized) and are non-critical control factors. Therefore, the multiple runs and sample measurements within each run for each critical response factor will be used to determine the amount of variation expected for each critical response factor. For this GVP, the critical control factors, non-critical factors, and critical response factors are identified in a table format along with acceptance criteria (where appropriate), data quality indicators, measurement locations, and measurement frequencies, broken down by each run. For example, parameters associated with the test panel pretreatment will remain constant and thus be non-critical control factors, while a parameter such as DFT is identified as a critical response factor. The only critical control factors are the high-TE and HVLP spray guns themselves (see Table 3). Examples of the non-critical control factors are shown in Table 4, and examples of the critical response factors to be measured are shown in Table 5. For finish quality targets, the pretreatment process provides a continuous surface on which the test coating can then be applied. To verify that these panels have been pretreated properly, coating weights will be determined on three (3) large panels and three (3) small panels prior to the coating application phase. Where appropriate, the output air pressure will be measured using a pressure gauge obtained from the spray gun manufacturers. The ETV CCEP will check the accuracy of these gauges before and after testing. High- TE Spray Equipment Generic Verification Protocol ------- Section No. 2 Revision No. 0 9/30/2006 Page 16 of 44 The airflow requirements of the high-TE and baseline spray guns will be determined during this test. The airflow will be measured using a calibrated flow meter. Data will be recorded in m3/min. The DFT measurements will follow ASTM B 499 (Magnetic), and will be taken on all coated test panels. The gloss analysis will follow ASTM D 523, and will be taken on all coated test panels. DOT analysis will follow ASTM D 5767 Test Method B (except that an eight-bladed rotating disc will be used instead of the sliding combed shutter). The visual appearance analysis will use normal lighting to examine the surface of the coated panel. The panels will be examined for fish-eyes in the finish, the presence of orange peel, the evenness of the coating, and the difference in the visual gloss caused by sandpaper finish, drips, runs, and inclusions (such as dirt, fuzz, and fibers). The TE test will follow ASTM D 5286. An average TE value will be determined for each combination. The values in the total number column reflect the experimental design of coating eighty test panels. Table 3. Critical Control Factors Critical Control Factor High-TE HVLP#1 HVLP#2 Air Cap TBE TBE TBE Fluid Nozzle TBE TBE TBE Fan Adjustment TBE TBE TBE Fluid Adjustment TBE TBE TBE Fan Pattern at the Target TBE TBE TBE TBE - To be established in each product specific test/QA plan High- TE Spray Equipment Generic Verification Protocol ------- Section No. 2 Revision No. 0 9/30/2006 Page 17 of 44 Table 4. Non-Critical Control Factors Non-Critical Factor Product Involved in Testing Pretreatment Analysis Surface Area of Test Panels Ambient Factory Relative Humidity Ambient Factory Temperature Spray Booth Relative Humidity Spray Booth Temperature Spray Booth Air Flow Temperature of Panels as Coated Distance from Gun to Panels Horizontal Gun Traverse Speed Vertical Drop Between Passes Volatile Content of Applied Coating Density of Applied Coating Wt.% Solids of Applied Coating Coating Temperature, as Applied Coating Viscosity as Applied (#4 Ford) Cure Time Cure Temperature Set Points/ Acceptance Criteria Two sizes of test panels Varies < 1.2 g/m2 Varies <10% within and between tests Varies < 10% during test Varies <5 °C during test Varies < 10% during test Varies <5 °C during test 0.4-0.6 m/s (80-120 ft/min) Varies <5 °C during test Varies < 1.3 cm (<0.5 in.) during test TBE TBE Varies <5% for each coating Varies <50 g/L for each coating Varies <5% for each coating Varies <5 °C during test Varies <5 seconds for each coating 1 hour 110°C (230 °F) Measurement Location Factory floor Random panels removed prior to start-up Factory floor Factory floor Factory floor Factory floor Factory floor Factory floor Center of test panel Factory floor Factory floor Factory floor Sample from coating pot Sample from coating pot Sample from coating pot Sample from coating Sample from coating pot Factory floor Factory floor Frequency TBE based on the number of test coatings chosen 3 large and 3 small from initial lot of panels Once per test combination Once per test combination Once per test combination Once per test combination Once per test combination Once per test combination Once per test combination Once per test combination Once per test combination Once per test combination 1 sample per test combination 1 sample per test combination 1 sample per test combination 1 sample per test combination 1 sample per test combination Once per test combination Once per test combination Total Number for the Test TBE 6 TBE TBE TBE TBE TBE TBE TBE TBE TBE TBE TBE TBE TBE TBE TBE TBE TBE TBE - To be established in each product specific test/QA plan High- TE Spray Equipment Generic Verification Protocol ------- Section No. 2 Revision No. 0 9/30/2006 Page 18 of 44 Table 5. Critical Response Factors Critical Response Factor Dynamic Inlet Air Pressure Dynamic Outlet Air Pressure (Air Cap) Air Consumption DFT (Magnetic method) Gloss DOI Visual Appearance Transfer Efficiency Measurement Location Factory Floor Factory Floor Factory Floor Figure 6 shows location of measurement points. From ASTMD 523 ASTMD 5767 Test Method B2 Entire test panel From ASTM D 5286 Frequency Once per test combination Once per test combination Once per test combination 1 5 points on each large panel 9 points on each small panel 5 points on each panel 1 point on one random panel per test combination 1 per panel One per test combination (average of all panels in combination) Total Number for the Test TBE TBE TBE TBE TBE TBE TBE TBE TBE - To be established in each product specific test/QA plan 1 See Sections 2.1.3 and 2.2 for the environmental basis to which these factors relate. 2 Will follow the ASTM International method except that an eight-bladed rotating disc will be used instead of the combed shutter. This is an optional test, dependent on the types of coatings chosen. Some target factors that may be used to test high-TE spray equipment include: Overlap Number of passes Number of coats Target dry film thickness 50% Established in test/QA plan Established in test/QA plan Established in test/QA plan High- TE Spray Equipment Generic Verification Protocol ------- Section No. 2 Revision No. 0 9/30/2006 Page 19 of 44 2.3 Schedule ETV CCEP uses standard tools for project scheduling. Project schedules are prepared in Microsoft Project, which is an accepted industry standard for scheduling. Project schedules show the complete work breakdown structure of the project, including technical work, meetings and deliverables. Table 6 shows the estimated schedule for the testing of high-TE spray equipment. Table 6. Estimated Schedule as of 9/27/06 ID Taskl Task 2 TaskS Task 4 TaskS Task 6 Name Approval of Test/Q A Plan Verification Testing Complete Data Analyses Prepare Verification Report Approval of Verification Report Issue Verification Statement Duration 30d 20d 20d 30d 60d 15d Start Date TBE TBE TBE TBE TBE TBE Finish Date TBE TBE TBE TBE TBE TBE TBE - To be established in each product specific test/QA plan High- TE Spray Equipment Generic Verification Protocol ------- Section No. 3 Revision No. 0 9/30/2006 Page 2 Oof 44 i .0 PROJECT ORGANIZATION AND RESPONSIBILITIES CTC employs a matrix organization, with program and line management, to perform projects. The laboratory supports the ETV CCEP project manager by providing test data. Laboratory analysts report to the ETV CCEP laboratory leader. The ETV CCEP laboratory leader and organic finishing engineer coordinate with the ETV CCEP project manager on testing schedules. The ETV CCEP project manager will be responsible for preparing the test/QA plans and Verification Report and Statement for each test. The ETV CCEP QA manager, who is organizationally independent of both the laboratory and the program, is responsible for administering CTC policies developed by the Quality Committee. These policies provide for, and ensure that quality objectives are met for each project. The policies are applicable to laboratory testing, factory demonstration processing, engineering decisions, and deliverables. The ETV CCEP QA manager reports directly to CTC senior management and is organizationally independent of the project or program management activities. The project organization chart, showing lines of responsibility and the specific CTC personnel assigned to this project, is presented in Figure 7. A summary of the responsibilities of each ETV CCEP participant, his/her applicable experience, and his/her anticipated time dedication to the project during testing and reporting is given in Table 7. ETV CCEP Project Manager Robert Fisher _L ETV CCEP Laboratory Leader Lynn Summerson ETV CCEP Organic Finishing Leader Stephen Kendera Figure 7. Project Organization Chart High- TE Spray Equipment Generic Verification Protocol ------- Section No. 3 Revision No. 0 9/30/2006 Page 21 of 44 Table 7. Summary of ETV CCEP Experience and Responsibilities Key CTC Personnel and Roles Heather Moyer NDCEE Program Manager Shannon Miller - ETV CCEP QA Manager Rob Fisher Staff Process Engineer/ ETV CCEP Project Manager Lynn Summerson - ETV CCEP Laboratory Leader/ Statistical Support Staff Stephen Kendera - ETV CCEP Organic Finishing Leader Responsibilities Manages NDCEE Program Accountable to CTC Technical Services Manager and CTC Corporate Management Responsible for overall project QA Accountable to NDCEE Program Manager Technical project support Process design and development Accountable to NDCEE Program Manager Laboratory analysis Accountable to ETV CCEP Project Manager QC Analysis Accountable to ETV CCEP Project Manager Applicable Experience Project Manager (10 years) Quality Mgmt. /ISO 9000 (6 years) Environmental Compliance and ISO 14000 Management Systems (6 years) ISO Internal Auditor (5 years) Organic Finishing Regulations (10 years) Organic Finishing Operations (10 years) Registered Professional Engineer Industrial and Environmental Laboratory Testing (22 years) Organic Finishing Operations (25 years) Education B.S., Chemical Engineering B.A., Communications M.S., Manufacturing Systems Engineering B.S., Chemical Engineering M.S., Chemistry B.S., Chemistry N/A Time Dedication 1% 5% 60% 15% 5% High- TE Spray Equipment Generic Verification Protocol ------- Section No. 3 Revision No. 0 9/30/2006 Page 2 2 of 44 The ETV CCEP personnel specified in Table 7 are responsible for maintaining communication with other responsible parties working on the project. The frequency and mechanisms for communication are shown in Table 8. In addition, the individuals listed in Table 9 will have certain responsibilities during the testing phase. Table 8. Frequency and Mechanisms of Communications Initiator NDCEE Program Manager, ETV CCEP Project Manager ETV CCEP Project Manager ETV CCEP Laboratory Leader ETV CCEP QA Manager EPA ETV CCEP Project Officer Recipient EPA ETV CCEP Project Officer NDCEE Program Manager ETV CCEP Project Manager NDCEE Program Manager CTC Mechanism Written Report Verbal Status Report Written or Verbal Status Report Data Reports Quality Review Report Onsite Visit Frequency Monthly Weekly Weekly As Generated As Required At Least Once per Year Special Occurrence Schedule or Financial Variances Major (will prevent accomplishment of verification cycle testing) Quality Objective Deviation Initiator NDCEE Program Manager or ETV CCEP Project Manager NDCEE Program Manager or ETV CCEP Project Manager Recipient EPA ETV CCEP Project Officer EPA ETV CCEP Project Officer Mechanism/ Frequency Telephone Call, Written Follow-up Report as Necessary Telephone Call with Written Follow-up Report Table 9. Responsibilities During Testing Position ETV CCEP Project Manager ETV CCEP QA Manager Statistical Support Responsibility Overall coordination of project Audits of verification testing operations and laboratory analyses Coordinates interpretation of test results High- TE Spray Equipment Generic Verification Protocol ------- Section No. 4 Revision No. 0 9/30/2006 Page 23 of 44 4.0 QUALITY ASSURANCE OBJECTIVES 4.1 General Objectives The overall objectives of this ETV CCEP GVP are to verify the performance of high-TE spray equipment spray by establishing the TE improvement and by documenting finish quality. These objectives will be met by controlling and monitoring the critical and non-critical factors, which are QA objectives for each technology-specific test/QA plan based on this GVP. Tables 3 and 4 list the critical and non-critical control factors, respectively. The analytical methods that will be used for coating evaluations are adapted from ASTM International Standards, or equivalent. The QA objectives of the project and the capabilities of these test methods for product and process inspection and evaluation are synonymous because the methods were specifically designed for evaluation of the coating properties under investigation. The methods will be used as published, or as supplied, without major deviations unless noted otherwise. The specific methods to be used for this project are attached to this document as Appendix A (ASTM International Methods). 4.2 Quantitative Quality Assurance Objectives Quality assurance parameters such as precision and accuracy are presented in Tables 10 and 11. Table 10 presents the manufacturers' stated capabilities of the equipment used for measurement of non-critical control factors. The precision and accuracy parameters listed are relative to the true value that the equipment measures. Table 11 presents the precision and accuracy parameters for the critical response factors. The precision and accuracy are determined using duplicate analysis and known standards and/or spikes and must fall within the values found in the specific methods expressed. The ETV CCEP will coordinate efforts to statistically evaluate test results and QA objectives. High- TE Spray Equipment Generic Verification Protocol ------- Section No. 4 Revision No. 0 9/30/2006 Page 2 4 of 44 Table 10. QA Objectives for Precision, Accuracy and Completeness for All Non-Critical Control Factor Performance Analyses Measurement Product Involved in Testing Pretreatment Analysis Surface Area of Test Panels Ambient Factory Relative Humidity Ambient Factory Temperature Booth Relative Humidity Booth Temperature Spray Booth Air Flow Temperature of Panels as Coated Distance to Panels Horizontal Gun Traverse Speed Vertical Drop Between Passes Volatile Content of Applied Coating Density of Applied Coating Wt.% Solids of Applied Coating Coating Temperature, as Applied Coating Viscosity as Applied (Ford #4 Cup) Cure Time Cure Temperature Method Test panels ASTM B 767 Ruler Thermal Hygrometer Thermal Hygrometer Thermal Hygrometer Thermal Hygrometer per ACGIH Infrared (IR) Thermometer Ruler Stopwatch Ruler ASTM D 3 960 ASTM D 1475 ASTM D 2369 Thermometer ASTM D 1200 Stopwatch Thermocouple Units N/A g/m2 cm2 (ft2) RH °C RH °C m/s (ft/min) °C cm (in.) cm/s (in./s) cm (in.) g/L (Ib/gal) g/L (Ib/gal) % °C seconds minutes °C Precision N/A ±0.005 ±0.025 (±0.0036) ±3% of full scale ±3% of full scale ±3% of full scale ±3% of full scale ±0.03* (±5) ±0.5% ±0.15 (±0.06) ±5% ±0.15 (±0.06) ±0.6% ±0.6% ±1.5% ±0.5 °C ±10% ±5% ±0.5 °C Accuracy N/A ±0.01 ±0.025 (±0.0036) ±3% of full scale ±3% of full scale ±3% of full scale ±3% of full scale ±0.03* (±5) ±1.0% ±0.15 (±0.06) ±5% ±0.15 (±0.06) ±1.8% ±1.8% ±4.7% ±0.2 °C ±10% ±5% ±0.2 °C Completeness 100% 90% 90% 90% 90% 90% 90% 90% 90% 90% 90% 90% 90% 90% 90% 90% 90% 90% 90% ACGIH - American Conference of Governmental Industrial Hygienists, Inc. * Accuracy and Precision stated by the manufacturer for velocities ranging from 20-100 ft/min High- TE Spray Equipment Generic Verification Protocol ------- Section No. 4 Revision No. 0 9/30/2006 Page 25 of 44 Table 11. QA Objectives for Precision, Accuracy and Completeness for All Critical Response Factor Performance Analyses Measurement Dynamic Inlet Air Pressure Dynamic Outlet Air Pressure (Air Cap) Air Consumption DFT - Magnetic Gloss DOI Visual Appearance Transfer Efficiency Method Pressure Gauge Pressure Gauge Flow Meter ASTMB499 ASTM D 523 ASTM D 5767 Method B N/A ASTM D 5286 Units psig psig nrVmin mils(1) gloss units DOI units N/A % Precision +0.5 psig +0.5 psig +0.5% RPD 20% 20% 20% N/A 25% Accuracy +0.5% +0.5% +0.5% 10% true thickness +0.3 +3 DOI units N/A RSD< 20%(2) Completeness 90% 90% 90% 90% 90% 90% N/A 90% (1) 1 mil = 0.001 in. (2) Unknown according to ASTM D 5286 RPD = relative percent difference RSD = relative standard deviation N/A = Not Applicable 4.2.1 Accuracy Standard reference materials, traceable to national sources such as the National Institute for Standards and Technology (NIST) for instrument calibration and periodic calibration verification, will be procured and utilized where such materials are available and applicable to this project. For reference calibration materials with certified values, acceptable accuracy for calibration verification will be within the specific guidelines provided in the method if verification limits are given. Otherwise, 80-120 percent of the true reference values will be used (see Tables 10 and 11). Reference materials will be evaluated using the same methods as for the actual test specimens. High- TE Spray Equipment Generic Verification Protocol ------- Section No. 4 Revision No. 0 9/30/2006 Page 2 6 of 44 4.2.2 Precision The experimental approach of this GVP specifies guidelines for the number of test panels to be coated. The analysis of replicate test panels for each coating property at each of the experimental conditions will occur per the specified test method. The degree of precision will be assessed based on the agreement of all replicates within a property analysis group. 4.2.3 Completeness The OFL and laboratory strive for at least 90% completeness. Completeness is the number of valid determinations expressed as a percentage of the total number of analyses conducted, by analysis type. 4.2.4 Impact and Statistical Significance Quality Objectives All OFL and laboratory analyses will meet the accuracy and completeness requirements specified in Tables 10 and 11. The precision requirements also should be achieved; however, a non-conformance may result from the analysis of replicates due to limitations of the coating technology under evaluation, and not due to processing equipment or laboratory error. Regardless, if any non-conformance from test/QA plan QA objectives occurs, the cause of the deviation will be determined by checking calculations, verifying the test and measurement equipment, and re- analysis. If an error in analysis is discovered, re-analysis of a new batch for a given run will be considered and the impact to overall project objectives will be determined. If the deviation persists despite all corrective action steps, the data will be flagged as not meeting the specific quality criteria and a written discussion will be generated. If all analytical conditions are within control limits and instrument and/or measurement system accuracy checks are valid, the nature of any non- conformance may be beyond the control of the laboratory. If, given that laboratory quality control data are within specification, any non- conforming results occur, the results will be interpreted as the inability of the coating equipment undergoing testing to produce panels meeting the performance criteria at the given set of experimental conditions. 4.3 Qualitative QA Objectives: Comparability and Representativeness 4.3.1 Comparability Participating technologies will be operated per the vendor's recommendations. The data obtained will be comparable from the standpoint that other testing programs could reproduce similar results using a specific test/QA plan. Coating and environmental performance High- TE Spray Equipment Generic Verification Protocol ------- Section No. 4 Revision No. 0 9/30/2006 Page 27 of 44 will be evaluated using EPA, ASTM International, and other nationally or industry-wide accepted testing procedures as noted in previous sections of this GVP. Process performance factors will be generated and evaluated according to standard best engineering practices. In addition, vendors will be asked to provide performance data for their product and the results of preliminary or prior testing relevant to this GVP, if available. Test panels used in these tests will be compared to the performance characteristics of the HVLP baseline guns and to other applicable end-user and industry specifications. The specifications will be used to verify the performance of the participating technology. Additional assurance of comparability comes from the routine use of precision and accuracy indicators as described above, the use of standardized and accepted methods and the traceability of reference materials. 4.3.2 Representativeness The limiting factor to representativeness is the availability of a large sample population. An experimental design has been developed so that this project will either have sufficiently large sample populations or otherwise statistically significant fractional populations. The tests will be conducted at optimum conditions based on the manufacturers' and the coating suppliers' literature and verified by setup testing. If the test data meets the quantitative QA criteria (precision, accuracy, and completeness) then the samples will be considered representative of the technology under evaluation and will be used for interpreting the outcomes relative to the specific project objectives. 4.4 Other QA Objectives There are no other QA objectives as part of this evaluation. 4.5 Impact of Quality Due to the highly controllable nature of the test panel evaluation methods and predictability of factors affecting the quality of the laboratory testing of panels, the quality control of test panel performance characteristics is expected to fall within acceptable levels. Comparison of response factors will be checked for run- to-run process variations. High- TE Spray Equipment Generic Verification Protocol ------- Section No. 5 Revision No. 0 9/30/2006 Page 2 8 of 44 5.0 SITE SELECTION AND SAMPLING PROCEDURES 5.1 Site Selection Where possible, this project will be conducted at CTC, in Johnstown, PA, and ETV CCEP personnel will perform all processing and testing, when possible. The site for application and evaluation will be at the NDCEE demonstration factory in the environmental technology facility (ETF) under the direct control of the Engineering, Statistical Support, and OFL Groups. Application of the coating involves transporting test panels in and out of the spray booth. The test panel will be coated in the first of the two wet spray booths. Test panels will be evaluated prior to application and after curing. The experimental design involves applying coatings according to the manufacturers' recommended optimum conditions. The test panels will be sampled and analyzed to generate performance data. 5.2 Site Description Figure 2 illustrates the overall layout of the NDCEE demonstration factory and the location of the process equipment that will be used for this project. This project may involve the use of the pretreatment line, the wet spray booths, and the wet cure oven. Other equipment or testing sites may be used, as necessary. 5.3 Sampling Procedures and Handling Test panels and foils will be used in this project. These will be pre-labeled by marking their ID (identification) number with permanent marker on the untreated side of the test panels or foils. The number of test panels and foils processed during the testing depends on the experimental design, which in turn, depends on any equipment provider's claim(s) about performance and the respective confidence levels given in the responses to the Request for Technology. If no specific performance characteristics are requested for verification by the high-TE equipment providers, the default experimental design of three TE targets and one finish quality target per test combination will be used. A factory operations technician and laboratory analysts will process the test panels according to a pre-planned sequence of stages, which includes those identified in Table 12. High- TE Spray Equipment Generic Verification Protocol ------- Section No. 5 Revision No. 0 9/30/2006 Page 29 of 44 Table 12. Process Responsibilities Procedure Visual inspection of test panels or foils Numbering of test panels or foils Initial weight of test panels or foils Arrange test panels or foils in the spray booth Prepare the coating Setup the high-TE gun or baseline guns Take coating samples and measurements Load coating & prime gun Perform setup trials (before first run only) Initial weight of gun, pump, and coating container Apply coating to test panels or foils Take process measurements Cure test panels or foils Final weight of gun, pump, and coating container Wrap/stack/transfer test panels or foils to lab Operations Technician X X X X X X X X X Laboratory Analyst X X X X X X X X A laboratory analyst will record the date and time of each run and the time each measurement was taken. After curing, the test panels will be removed from the racks, separated by a layer of packing material, and stacked for transport to the laboratory. The laboratory analyst will process the test panels through the laboratory login prior to performing the required analyses. 5.4 Sample Custody, Storage and Identification The test panels will be given a unique laboratory ID number and logged into the laboratory record sheets. The analyst delivering the test panels will complete a custody log indicating the sampling point IDs, sample material IDs, quantity of samples, time, date, and analyst's initials. The test panels will remain in the custody of ETV CCEP, unless a change of custody form has been completed. The change of custody form should include a signature from ETV CCEP, the test product ID number, the date of custody transfer, and the signature of the individual to whom custody was transferred. Laboratory analyses may only begin after each test product is logged into the laboratory record sheets. The laboratory's sample custodian will verify this information. Both personnel will sign the custody log to indicate transfer of the samples from the coating processing area to the laboratory analysis area. The laboratory sample custodian will log the test panels into a bound record book; store the test panels under appropriate conditions (ambient room temperature and humidity); and create a work order for the various laboratory departments to initiate testing. The product evaluation tests also will be noted on the laboratory record sheet. Testing will begin within several days of coating application. High- TE Spray Equipment Generic Verification Protocol ------- Section No. 6 Revision No. 0 9/30/2006 Page 3 Oof 44 6.0 ANALYTICAL PROCEDURES AND CALIBRATION 6.1 Facility and Laboratory Testing and Calibration The NDCEE shall maintain a record of calibrations and certifications for all applicable equipment used during ETV CCEP testing. Testing and measuring equipment shall be calibrated prior to the verification test and after the verification test analyses are complete. 6.1.1 Facility Testing and Calibration Calibration procedures the ETV CCEP within the OFL and laboratory shall be recorded. Certified solutions and reference materials traceable to NIST shall be obtained as appropriate to ensure the proper equipment calibration. Where a suitable source of material does not exist, a secondary standard is prepared and a true value obtained by measurement against a technical-grade NIST-traceable standard. After the coating is mixed, the temperature and viscosity of the coating will be measured. In addition, coating samples will be taken to the lab for density and percent solids analyses. All equipment used within the OFL during ETV CCEP testing will be calibrated according to relevant portion of Tables 13 and 14. 6.1.2 Laboratory Testing and Calibration Procedures The analytical methods performed at CTC are adapted from standard ASTM International, MIL-SPEC, EPA, Association of Official Analytical Chemists and/or industry protocols for similar manufacturing operations. Initial calibration and periodic calibration verification are performed to insure that an instrument is operating sufficiently to meet sensitivity and selectivity requirements. At a minimum, all equipment are calibrated before use and are verified during use and/or immediately after each sample batch. Standard solutions are purchased from reputable chemical supply houses in neat and diluted forms. Where certified and traceable to NIST reference materials and solutions are available, the laboratory purchases these for calibration and standardization. Data from all equipment calibrations and chemical standard certificates from vendors are stored in laboratory files and are readily retrievable. No samples are reported in which the full calibration curve, or the periodic calibration check standards, are outside method performance standards. As needed, equipment will be sent off-site for calibration or certification. The listing of ASTM International Methods for dry film thickness, gloss, DOI, and transfer efficiency can be found in Appendix A. All equipment, used for these analyses, is calibrated according to Tables 13 and 14. High- TE Spray Equipment Generic Verification Protocol ------- Section No. 6 Revision No. 0 9/30/2006 Page 31 of 44 Like the test panels and foils, the solids pans will be prepared as specified by the ASTM International standard for determining volatile content of coatings (ASTM D 2369). The solids pans will be labeled with an identification number and letter. Two separate solids pans will be used for each batch of coating and the values obtained will be averaged. The data required for the solids test is recorded on the coating batch worksheet. The percent of solids is calculated as: N = [(W2-Wl)/S]x 100 where: Wl = the weight of the dish W2 = weight of dish plus specimen after heating S = Specimen weight (Syl - Sy2) Syl = Syringe before dispensing coating Sy2 = Syringe after dispensing coating The ambient temperature and relative humidity is measured both inside and outside the spray booth. Also, the temperature of one product per run is measured prior to starting each test run. All equipment used for these analyses will be calibrated according to Tables 13 and 14. 6.2 Product Quality Procedures Each apparatus that will be used to assess the quality of a coating on a test product is set up and maintained according to each manufacturer's, and/or the published reference method's, instructions. Actual sample analysis will take place only after setup is verified per the reference method and the equipment manufacturer's instructions. As available, samples of known materials with established product qualities are used to verify that a system is functioning properly. For example, traceable thickness standards are used to calibrate the dry film thickness instrument. Applicable ASTM International methods are listed in Appendix A. 6.3 Standard Operating Procedures and Calibration Tables 13 and 14 summarize the methods and calibration criteria that will be used for the evaluation of the coatings. Each analysis shall be performed as adapted from published methods and references, such as ASTM International and EPA, and from accepted protocols provided by industrial suppliers. High- TE Spray Equipment Generic Verification Protocol ------- Section No. 6 Revision No. 0 9/30/2006 Page 3 2 of 44 Table 13. Non-Critical Control Factor Testing and Calibration Criteria Non-Critical Factor Products Involved in Testing Pretreatment Analysis Surface Area of Test Panels Ambient Factory Relative Humidity Ambient Factory Temperature Spray Booth Relative Humidity Spray Booth Temperature Spray Booth Air Velocity Temperature of Test Panels, as Coated Distance From Gun to Test Panels Horizontal Gun Traverse Speed Vertical Drop Between Passes Volatile Content of Applied Coating Density of Applied Coating Wt. % Solids of Applied Coating Coating Temperature, as Applied Coating Viscosity, as Applied Cure Time Cure Temperature Method Test panels ASTMB767 Ruler Thermal Hygrometer Thermal Hygrometer Thermal Hygrometer Thermal Hygrometer perACGIH IR Thermometer Ruler Stopwatch Ruler ASTMD3960 ASTMD1475 ASTMD2369 Thermometer ASTMD1200 Stopwatch Thermocouple Method Type N/A Chromate solution 50g/L Cr03 Ruler Thermal Hygrometer Thermal Hygrometer Thermal Hygrometer Thermal Hygrometer Anemometer IR Thermometer Ruler Stopwatch Ruler Volatile content Weight Weight Thermometer #4 Ford Cup Stopwatch Thermocouple/ (controllers) Calibration Procedure N/A Comparison to NIST-traceable standard Inspect for damage, replace if necessary Sent for calibration or certification Sent for calibration or certification Sent for calibration or certification Sent for calibration or certification Sent for calibration or certification Sent for calibration or certification Inspect for damage, replace if necessary Sent for calibration or certification Inspect for damage, replace if necessary Comparison to NIST-traceable standard Comparison to NIST-traceable standard Comparison to NIST-traceable standard Comparison to NIST-traceable standard Comparison to NIST-traceable standard Sent for calibration or certification Comparison to NIST-traceable standard Calibration Frequency N/A With each use With each use Annually Annually Annually Annually Annually Annually With each use Six months With each use With each use With each use With each batch of coating Annually Prior to each test Six months Semi-annually Calibration Accept. Criteria(l) N/A 80-120% Lack of damage Calibration or certification documentation Calibration or certification documentation Calibration or certification documentation Calibration or certification documentation Calibration or certification documentation Calibration or certification documentation Lack of damage N/A Lack of damage ±0.003 g ±0.003 g ±0.003 g ±1°C ±10% N/A ±1°C (1) As a percent recovery of a standard N/A = Not Applicable High- TE Spray Equipment Generic Verification Protocol ------- Section No. 6 Revision No. 0 9/30/2006 Page 33 of 44 Table 14. Critical Response Factor Testing and Calibration Criteria Critical Measurement Dynamic Inlet Air Pressure Dynamic Outlet Air Pressure (Air Cap) Air Consumption DFT Gloss DOI Visual Appearance Transfer Efficiency (product and coating weights) Method Number(1) Manufacturer's recommendation Manufacturer's recommendation Manufacturer' s recommendation ASTM B 499 ASTMD523 ASTM D 5767 Method B N/A ASTM D 5286 Method Type Pressure gauge Test cap Flow Meter Magnetic Glossmeter Image analyzer Visual Weight Calibration Procedure Comparison to NIST-traceable standard Manufacturer' s recommendation Comparison to NIST-traceable standard Comparison to NIST-traceable standard Comparison to NIST-traceable standard Manufacturer's recommendation N/A Comparison to NIST-traceable standard Calibration Frequency Annually Manufacturer' s recommendation Six months Verify calibration after each run Verify calibration after each run Manufacturer's recommendation N/A Verify calibration prior to each use Calibration Accept. Criteria ±5 psig Manufacturer' s recommendation ±1% of full scale 90-110% 90-110% Manufacturer's recommendation N/A ±3.0 g (1) Listing of ASTM International methods to be used is provided in Appendix A. (2) As a percent recovery of a standard N/A = Not Applicable 6.4 Non-Standard Methods CTC will not use any non-standard methods for this project. However, for methods that are non-standard (i.e., no commonly accepted or specified method exists or no traceable calibration materials exist), procedures will be performed according to the manufacturer's instructions or to the best capabilities of the equipment and the laboratory. This information will be documented. The performance will be judged based on the manufacturer's specifications, or will be judged based on in-house developed protocols. These protocols will be similar or representative in magnitude and scope to related methods performed in the laboratory, which do have reference performance criteria for precision and accuracy. For instance, if a non-standard quantitative chemical procedure is being performed, it should produce replicate results of+/- 25 relative percent difference and should give values within +/- 20 percent of true or expected values for calibration and percent recovery check samples. For qualitative procedures, replicate results should agree as to their final evaluations of quality or performance (i.e., both should either pass or both should fail if sampled together from a properly functioning process). The intended use and any limitations would be explained and documented for a non-standard procedure. High- TE Spray Equipment Generic Verification Protocol ------- Section No. 7 Revision No. 0 9/30/2006 Page 3 4 of 44 7.0 DATA REDUCTION, VALIDATION, AND REPORTING 7.1 Raw Data Handling Raw data will be generated and collected by the analysts at the bench and/or process level. Process data is recorded into a process log during factory operations. Bench data will include original observations, printouts and readouts from equipment for sample, standard and reference QC analyses. Data will be collected both manually and electronically. At a minimum, the date, time, sample ID, instrument ID, analyst ID, raw signal or processed signal, and/or qualitative observations will be recorded. Comments to document unusual or non-standard observations also will be included on the forms as necessary. Raw data will be processed manually by the analyst, automatically by an electronic program, or electronically after being entered into a computer. The analyst will be responsible for scrutinizing the data according to specified precision, accuracy, and completeness policies. Raw data bench sheets, calculations and data summary sheets will be kept together for each sample batch. From the documented procedures and the raw data bench files, the steps leading to a final result may be traced. 7.1.1 Variables Used In Analysis CS - The mass of (wet) coating sprayed %S - The percent of the coating which is non-volatile (solids) SS - The mass of coating solids sprayed is equal to (CS x %S) /100% SD - The mass of solids deposited TE - Transfer efficiency is equal to (SD / SS) x 100%, expressed as a percentage The accuracy of the TE values can be calculated based on the accuracy of each of the measurements involved. Random errors propagate as follows. 7.1.2 Error in Mass of Coating Sprayed. The coating sprayed (CS) is the difference between two masses, the mass of the coating pot prior to and after applying the coating to the foils. The scale has an accuracy of+/- 0.01 g. The mass of coating sprayed on each foil should be on the order of 50 g. Since two weight measurements must be made, and each contains an uncertainty of 0.01 g, the total uncertainty in a worst-case scenario is 0.02 g. The uncertainty in the mass sprayed, is +/- 0.04%. High- TE Spray Equipment Generic Verification Protocol ------- Section No. 7 Revision No. 0 9/30/2006 Page 35 of 44 7.1.3 Error in Solids Content. The solids content is the difference between two masses, the wet mass and the dry mass of the coating. The procedure specifies four measurements to be made, mass of the empty pan (EP), mass of the full syringe (FS) the mass of the empty syringe (ES) and the mass of the pan with the deposited pan solids (PS). %S = (PS - EP) / (FS-ES) x 100% Since two measurements are made in the numerator and the denominator, the total uncertainty in each of these values is the sum of the uncertainties, or 2 x 0.0005 g. Since between 0.2 and 0.3 g of coating is used in the test, this uncertainty becomes negligible compared to the numerator uncertainty. Only about 0.05-0.1 g of solids remain in the pan after drying, making the numerator value uncertain by a maximum of 2%. Therefore, the solids content reported can be safely reported as within 2% of the actual value. 7.1.4 Error in Mass Deposited. The mass of the solids deposited on the foils is measured by weighing the foils before and after spraying. The scale used has an accuracy of+/- 0.001 g. The mass of solids typically deposited on each foil is on the order of 20 g. A control foil is also weighed to determine whether the foils gain or lose weight during the curing process, which results in two additional weight measurements. Since four weight measurements must be made, and each contains an uncertainty of 0.001 g, the total uncertainty in a worst-case scenario is 0.004 g. The uncertainty in the mass deposited, is +/- 0.02 %. 7.1.5 Calculation of Transfer Efficiency. SD is the weight of the product after spraying and curing, minus the weight of the bare product. SS is the product of CS and %S divided by 100. The transfer efficiency is calculated as below: TE% = (SD/SS)xlOO% The method for calculating %TE has been redefined (per ASTM D 5286) to consider the TE per run. By this method, the formula is as follows: TE (%) = (average weight gain of test panels in a run) x 100% (weight of paint solids sprayed) / (number of panels per run) An example calculation is included below: High- TE Spray Equipment Generic Verification Protocol ------- Section No. 7 Revision No. 0 9/30/2006 Page 3 6 of 44 TE (%) = 0.8 gx 100% (4.8 g)/3 TE (%) = 80% 1.6 TE (%) = 50% The relative TE improvement is determined using the equation below: TERI (%) = (TEHirf.-TF. - TEHVT.P Ave) X 100% TEHVLP_Ave T£RI - the relative improvement over the HVLP baseline average TEniph-TF, - the average TE for the High-TE system TEHVLP Ave - the average TE for all three HVLP guns For example, for the TE data (High-TE = 60%, HVLP average = 50%): TEm(%)= (60% - 50%) x 100% = 20% 50% 7.2 Preliminary Data Package Validation The generating operation technician and analyst will assemble a preliminary data package. This package will contain the QC and raw data results, calculations, electronic printouts, conclusions and laboratory sample tracking information. The ETV CCEP laboratory leader will review the entire package and may also check sample and storage logs, standard logs, calibration logs, and other files, as necessary, to insure that tracking, sample treatments and calculations are correct. After the package has been peer reviewed in this manner, a preliminary data report will be prepared. The entire package and final laboratory report will be submitted to the ETV CCEP laboratory manager. 7.3 Final Data Validation The ETV CCEP laboratory manager shall be ultimately responsible for all final data released from this project. The ETV CCEP laboratory manager will review the final results for adequacy to project QA objectives. If the manager suspects an anomaly or non-concurrence with expected or historical performance values, with project QA objectives, or with method specific QA requirements of the laboratory procedures, he will initiate a second review of the raw data and query the generating analyst and the ETV CCEP laboratory leader about the non- conformance. Also, he will request specific corrective action. If suspicion about data validity still exists after internal review of laboratory records, the ETV CCEP High- TE Spray Equipment Generic Verification Protocol ------- Section No. 7 Revision No. 0 9/30/2006 Page 37 of 44 Laboratory manager may authorize a re-analysis. If sufficient sample is not available for re-testing, a re-sampling will occur. If the sampling window has passed, or re-sampling is not possible, the ETV CCEP laboratory manager will flag the data as suspect and notify the ETV CCEP project manager. The ETV CCEP laboratory manager will sign and date the final data package. 7.4 Data Reporting and Archival 7.4.1 Calculation of DFT The DFT gauge has a stated accuracy of 0.1 mil. NIST traceable thickness standards will be used to calibrate the DFT gauge. DFT measurements will be made at several locations on each product. The location of each measurement is indicated in Figure 6. 7.4.2 Interpretation of the Numerical Results The overall accuracy of the test data will allow calculation of TE to within a few percent. The largest uncertainty lies in the mass-used values, which contain a random error of about 2%, due to the solids calculation. The mass-deposited values are estimated to be within 1% and an overall accuracy of 3% leaves a reasonable margin. 7.4.3 Evaluation of the High-TE Spray Gun A report signed and dated by the ETV CCEP laboratory manager will be submitted to the ETV CCEP project manager, the ETV CCEP QA manager, the EPA QA manager, and other technical principals involved in the project. The ETV CCEP project manager will decide on the validity of the data and will make any interpretations with respect to project QA objectives. The final laboratory report will contain the lab sample ID, date reported, date analyzed, the analyst, the procedures used for each parameter, the process or sampling point identification, the final result and the units. The NDCEE Environmental Laboratory will retain the data packages at least 10 years. The ETV CCEP project manager or the NDCEE program manager will forward the results and conclusions to EPA in their regular reports for final EPA approval of the test data. This information will be used to prepare the Verification Report, which will be published by the ETV CCEP. The ETV CCEP staff, the vendor, EPA technical peer reviewers, and the EPA technical editor will review the Verification Report. The EPA and the ETV CCEP will then approve the revised document prior to it being published. High- TE Spray Equipment Generic Verification Protocol ------- Section No. 7 Revision No. 0 9/30/2006 Page 3 8 of 44 7.5 Verification Statement The ETV CCEP will also prepare a 3-7 page Verification Statement summarizing the information contained in the Verification Report. After receiving the results and conclusions from the ETV CCEP project manager or the NDCEE program manager, the EPA will approve the Verification Report and Verification Statement. Only after agreement by the vendor, will the Verification Statement be disseminated. High- TE Spray Equipment Generic Verification Protocol ------- Section No. 8 Revision No. 0 9/30/2006 Page 39 of 44 8.0 INTERNAL QUALITY CONTROL CHECKS 8.1 Guide Used for Internal Quality Program The ETV CCEP uses the NDCEE facility and its QA system to verify coating technologies. The NDCEE has established an International Organization for Standardization (ISO) 9001 operating program for its laboratories and the Demonstration Factory. The laboratory is currently establishing a formal quality control program for its specific operations. The format for laboratory QA/QC is being adapted from several sources, as listed in Table 15. The ETV CCEP verifications adhere to the ETV Program QMP, the ETV CCEP QMP, and the ANSI/ASQC standards. Table 15. NDCEE Environmental Laboratory QA/QC Format Sources Document General Requirements for the Competence of Calibration and Testing Laboratories Critical Elements for Laboratories Chapter One, Quality Control Requirements of 100-300 series of methods Handbook of Quality Assurance for the Analytical Chemistry Laboratory, 2nd Ed. Reference Source ISO Guide 25, ISO Quality Programs Pennsylvania Department of Environmental Protection SW-846, EPA Test Methods EPA Test Methods James P. Dux 8.2 Types of QA Checks The NDCEE ETF Environmental Laboratory and OFL used by ETV CCEP follow published methodologies, wherever possible, for testing protocols. Laboratory methods are adapted from Federal Specifications, Military Specifications, ASTM International Test Methods, and supplier instructions. The laboratory adheres to the QA/QC requirements specified in these documents. In addition, where QA/QC criteria are not specified, or where the laboratory performs additional QA/QC activities, these protocols are explained in the laboratory's work instructions. Each NDCEE facility that uses supplied products implements its own level of QA/QC. During ETV CCEP testing, the NDCEE laboratory at ETF will perform the testing and QA/QC verification outlined in Tables 10 and 11 (Precision, Accuracy, and Completeness) and Tables 13 and 14 (Calibration); therefore, these tables should be referred to for the method-specific QA/QC that will be performed. 8.3 Basic QA Checks During each test, an internal Process QA Checklist will be completed by the laboratory and OFL staff to ensure the appropriate parts, panels, samples, and operating conditions are used. The laboratory also monitors its reagent deionized water to ensure it meets purity levels consistent with analytical methodologies. High- TE Spray Equipment Generic Verification Protocol ------- Section No. 8 Revision No. 0 9/30/2006 Page 40 of 44 The filters are replaced quarterly before failures are encountered. Samples are not processed until the filters are replaced when failures do occur. The quality of the water is assessed with method reagent water blanks. Blank levels must not exceed minimum detection levels for a given parameter to be considered valid for use. Thermometers are checked against NIST-certified thermometers at two temperatures. The laboratory checks and records the temperatures of sample storage areas, ovens, hot plate operations, and certain liquid baths that use thermometers. Balances are calibrated by an outside organization using standards traceable to NIST. The ETF laboratory also performs in-house, periodic verifications with ASTM International Class 1 weights. The ETF laboratory maintains records of the verification activities and calibration certificates. The laboratory analyst also checks the balances prior to use with ASTM International Class 1 weights. Reagents purchased directly by the laboratory are American Chemical Society grade or better. Reagents are not used beyond their certified expiration dates. Reagents are dated on receipt and when first opened. Laboratory waste is segregated according to chemical classifications in labeled containers to meet hazardous waste handling requirements. 8.4 Specific Checks The NDCEE Environmental Laboratory will analyze uncoated panels for dry film thickness to verify that the instrument has not drifted from zero, perform duplicate analyses on the same samples, and perform calibration checks of the laboratory equipment during ETV CCEP testing. Laboratory personnel will also check any referenced materials and equipment as available and specified by the referenced methodology and/or the project-specific QA/QC objectives. Laboratory records are maintained with the sample data packages and/or in centralized files, as appropriate. To ensure comparability, the laboratory will carefully control process conditions and perform product evaluation tests consistently for each specimen. The specific QA checks listed in Tables 10, 11, 13, and 14 provide the necessary data to determine whether process control and product testing objectives are being met. ASTM International, Federal, and Military methods that are accepted in industry for product evaluations and supplier-endorsed methods for process control, will be used for all critical measurements, thus satisfying the QA objective. A listing of the published methods that will be used for this GVP is included in Appendix A. High- TE Spray Equipment Generic Verification Protocol ------- Section No. 9 Revision No. 0 9/30/2006 Page 41 of 44 9.0 PERFORMANCE AND SYSTEM AUDITS The ETV CCEP uses the NDCEE facility and its QA systems to verify coating technologies. The NDCEE has developed a system of internal and external audits to monitor both program and project performance, which is consistent with the audit requirements specified in the ETV Program and ETV CCEP QMPs. These include monthly managers meetings and reports, financial statements, EPA reviews and stakeholders meetings, and In-Process Reviews. The ETF laboratory also analyzes performance evaluation samples in order to maintain Pennsylvania Department of Environmental Protection Certification. ISO Internal Audits The NDCEE has established its quality system based on ISO 9000 and 14000 and has implemented a system of ISO internal audits. This information will be used for internal purposes. On-Site Visits The EPA ETV CCEP project officer and EPA ETV CCEP QA manager may visit the ETV CCEP for an on-site visit during the execution of this project. All project, process, quality assurance, and laboratory testing information will be available for review. Performance Evaluation Audits The EPA will periodically audit the ETV CCEP during this project. All project, process, quality assurance, and laboratory testing information will be made available per the EPA's auditing procedures. Technical Systems Audits A listing of all coating equipment, laboratory measuring and testing devices, and procedures, coating procedures, and a copy of the approved ETV QMP and the approved ETV CCEP QMP will be given to the ETV CCEP QA manager. The ETV CCEP QA manager will conduct an initial audit, and additional audits thereafter according to the ETV CCEP QMP, of verification and testing activities. The results of this activity will be forwarded to EPA in reports from the NDCEE program manager or the ETV CCEP project manager. Audits of Data Quality Peer review in the laboratory constitutes a process whereby two analysts review raw data generated at the bench level. After data are reduced, they undergo review by laboratory management. For this GVP, laboratory management will spot check 10 percent of the project data by performing a total review from raw to final results. This activity will occur in addition to the routine management review of all data. Records will be kept to show which data have been reviewed in this manner. High- TE Spray Equipment Generic Verification Protocol ------- Section No. 10 Revision No. 0 9/30/2006 Page 42 of 44 10.0 CALCULATION OF DATA QUALITY INDICATORS 10.1 Precision Duplicates will be performed on separate samples, as well as on the same sample source, depending on the method being employed. In addition, the final result for a given test may be the arithmetic mean of several determinations on the part or matrix. In this case, duplicate precision calculations will be performed on the means. The following calculations will be used to assess the precision between duplicate measurements. Relative Percent Difference (RPD) = [(Cl - C2) x 100%] / [(Cl + C2) / 2] where: C1 = larger of the two observations C2 = smaller of the two observations Relative Standard Deviation (RSD) = (s/y) x 100% where: s = standard deviation y = mean of replicates. 10.2 Accuracy Accuracy will be determined as percent recovery of a check standard, check sample, or matrix spike. For matrix spikes and synthetic check samples: Percent Recovery (%R) = 100% x [(S - U)/T] where: S = observed concentration in spiked sample U = observed concentration in unspiked sample T = true value of spike added to sample. For standard reference materials (srm) used as calibration checks: %R= 100%x(Cm/Csrm) where: Cm = observed concentration of reference material Csrm = theoretical value of srm. 10.3 Completeness Percent Completeness (%C) = 100% x (V/T) where: V = number of determinations judged valid T = total number of determinations for a given method type. 10.4 Project Specific Indicators Process control limit: range specified by supplier for a given process parameter. High- TE Spray Equipment Generic Verification Protocol ------- Section No. 11 Revision No. 0 9/30/2006 Page 43 of 44 11.0 CORRECTIVE ACTION 11.1 Routine Corrective Action Routine corrective action will be undertaken in the event that a parameter in Tables 10, 11, 13, and 14 is outside the prescribed limits specified in these tables, or when a process parameter is beyond specified control limits. Examples of nonconformances include, but are not limited to, invalid calibration data, inadvertent failure to perform method-specific QA tests, process control data outside specified control limits, and failed precision and/or accuracy indicators. Such nonconformances will be documented on a process or laboratory form. Corrective action will involve taking all necessary steps to restore a measuring system to proper working order and summarizing the corrective action and results of subsequent system verifications on a standard form. Some nonconformances will be detected while analysis or sample processing is in progress, and can be rectified in real time at the bench level. Other nonconformances may be detected only after a processing trial and/or sample analyses are completed. These types of nonconformances are typically detected at the laboratory manager level of data review. In all cases of nonconformance, the laboratory manager will consider repeating the sample analysis as one method of corrective action. If a sufficient sample is not available, or the holding time has been exceeded, complete reprocessing may be ordered to generate new samples if a determination is made by the ETV CCEP project manager that the nonconformance jeopardizes the integrity of the conclusions to be drawn from the data. In all cases, a nonconformance will be rectified before sample processing and analysis continues. If corrective action does not restore the production or analytical system, causing a deviation from the ETV CCEP QMP, the NDCEE will contact the EPA ETV CCEP project officer. In cases of routine nonconformance, EPA will be notified in the NDCEE program manager's or ETV CCEP project manager's regular reports to the EPA ETV CCEP project officer. A complete discussion will accompany each nonconformance. 11.2 Nonroutine Corrective Action While not anticipated, activities such as internal audits by the ETV CCEP QA manager, and on-site visits by the EPA ETV CCEP project officer, may result in findings that contradict deliverables in the ETV CCEP QMP. In the event that nonconformances are detected by bodies outside the laboratory organizational unit, as for routine nonconformances, these problems will be rectified and documented prior to processing or analyzing further samples or specimens. High- TE Spray Equipment Generic Verification Protocol ------- Section No. 12 Revision No. 0 9/30/2006 Page 44 of 44 12.0 QUALITY CONTROL REPORTS TO MANAGEMENT As shown on the Project Organization Chart in Figure 7, the ETV CCEP QA manager is independent from the project management team. It is the responsibility of the ETV CCEP QA manager to monitor ETV CCEP verifications for adherence to the ETV CCEP QMP. The laboratory manager monitors the operation of the laboratory on a daily basis and provides comments to the ETV CCEP QA manager to facilitate their activities. The ETV CCEP QA manager will audit the operation records, laboratory records, and laboratory data reports and provide a written report of the findings to the ETV CCEP project manager and laboratory manager. The ETV CCEP project manager will ensure these reports are included in the report to the EPA. The laboratory manager will be responsible for achieving closure on items addressed in the report. Specific items to be addressed and discussed in the QA report include the following: . General assessment of data quality in terms of general QA objectives in Section 4.1 . Specific assessment of data quality in terms of quantitative and qualitative indicators listed in Sections 4.2 and 4.3 Listing and summary of all nonconformances and/or deviations from the ETV CCEP QMP . Impact of nonconformances on data quality Listing and summary of corrective actions Results of internal Q A audits Closure of open items from last report or communications with EPA in current reporting period . Deviations or changes in the ETV CCEP QMP . Progress of the NDCEE QA programs used by the ETV CCEP in relation to current projects Limitations on conclusions, use of the data Planned QA activities, open items for next reporting period High- TE Spray Equipment Generic Verification Protocol ------- Section No. A Revision No. 0 9/30/2006 Page Al APPENDIX A ASTM International Methods High- TE Spray Equipment Generic Verification Protocol ------- ------- Section No. A Revision No. 0 9/30/2006 Page A2 ASTM International Methods ASTM B 499 Standard Test Method for Measurement of Coating Thickness by the Magnetic Method: Nonmagnetic Coatings on Magnetic Basis Metals ASTM B 767 Standard Guide for Determining Mass per Unit Area of Electodeposited and Related Coatings by Gravimetric and other Chemical Analysis Procedures ASTM D 523 -- Standard Test Method for Specular Gloss ASTM D 1200 -- Standard Test Method for Viscosity by Ford Viscosity Cup ASTM D 1475 -- Standard Test Method for Density of Liquid Coatings, Inks, and Related Products ASTM D 2369 -- Standard Test Method for Volatile Content of Coatings ASTM D 3960 -- Standard Practice for Determining Volatile Organic Compound (VOC) Content of Paints and Related Coatings ASTM D 5286 Standard Test Method for Determination of Transfer Efficiency Under General Production Conditions for Spray Application of Paint. ASTM D 5767 Standard Test Methods for Instrumental Measurement of Distinctness-of- Image Gloss of Coating Surfaces High- TE Spray Equipment Generic Verification Protocol ------- |