Test/QA Plan for Pesticide Spray DRT at USDA
March 2009
                                        Version 1.0
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TEST/QA PLAN FOR THE VALIDATION OF THE VERIFICATION PROTOCOL FOR
HIGH SPEED PESTICIDE SPRAY DRIFT REDUCTION TECHNOLOGIES FOR ROW
                           AND FIELD CROPS
USDAHRTI
                        INTERNATIONAL
USDA-ARS

2771F&B Road
College Station, TX 77845

Phone:  979.260.9351
FAX:   979.260.9386
E-mail:  choffmann@tamu.edu
RTI International

3040 Cornwallis Road
P.O. Box 12194
Research Triangle Park, NC 27709-
2194
Phone:  919-541-3742
FAX:   919-541-6936
E-mail:  jwt@rti.org
USEPA-ETV

109 T.W.Alexander Drive
E434-02
Research Triangle Park, NC 27711
Phone:  919-541-2734
FAX:   919-541-0359
E-mail:  kosusko.mike@epa.gov
                   This plan has been reviewed and approved by:
 Signed by W. C. Hoffmann
 W. C. Hoffmann, Technical Leader, U.S. Department of Agriculture

 Signed by D.E. Martin	
 D. E. Martin, Quality Manager, U.S. Department of Agriculture

 Signed by J. W. Thornburg
 J. W. Thornburg, Project Leader, RTI International

 Signed by W. C. Eaton
 W.C. Eaton, Quality Manager, RTI International

 Signed by M. Kosusko
 M. Kosusko, EPA Project Manager

 Signed by P. W.Groff
 P. W. Groff, EPA Quality Manager
                                 March 30, 2009
                                      Date

                                 March 30, 2009
                                      Date

                                 March 12, 2009
                                      Date

                                 March 17, 2009
                                      Date

                                 March 18, 2009
                                      Date

                                 March 24, 2009
                                      Date

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                                A2: Table of Contents

List of Figures	iv
List of Tables	iv
List of Acronyms/Abbreviations	v
Group A: Project Management	1
       A4:  Project/Task Organization	1
            A4.1   Management Responsibilities	1
            A4.2   Quality Assurance Responsibilities	2
       A5:  Problem Definition/Background	4
       A6:  Project/Task Description	4
            A6.1   Description	4
            A6.2   Schedule	5
       A7:  Quality Objectives and Criteria	5
       A8:  Special Training/Certifications	8
       A9:  Documentation and Records	8
Group B: Data Generation and Acquisition  for High Speed Wind Tunnel Tests	9
       Bl:  Sample Process Design (Experimental Design)	9
       B2:  Sampling Methods for Measurement of Droplet Size and Test Conditions	9
            B2.1   Sampling Locations	12
            B2.2   Process/Application Data Collection	12
            B2.3   Wind Tunnel Measurement of Spray Drift Potential (Droplet Size
                   Distribution at Aerial Application Air Speeds at the Nozzle)	13
            B2.4   Measurement of Droplet Size Spectrum near the Nozzle, Without the
                   Effects of Flight Speed Air Flow	14
       B3:  Sample Handling and Custody Requirements	15
       B4:  Analytical Methods	15
       B5:  Quality Control	15
       B6:  Instrument/Equipment Testing, Inspection, and Maintenance	15
       B7:  Instrument/Equipment Calibration and Frequency	15
       B8:  Inspection/Acceptance of Supplies and Consumables	16
       B9:  Non-Direct Measurements	16
       BIO:  Data Management	16
            B10.1  Data Acquisition and Management	16

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            B10.2 Reporting	17
Group C: Assessments and Oversight Elements	19
       Cl:   Assessments and Response Actions	19
            Cl.l  Internal Audits	19
            C1.2  Audits of Data Quality	19
            C1.3  External Audits	19
            C1.4  Corrective Action	19
       C2:   Reports to Management	19
Group D: Data Validation and Usability Elements	20
       Dl:   DataReview, Verification, and Validation	20
       D2:   Verification and Validation Methods	20
       D3:   Reconciliation with Data Quality Objectives	20
Appendix A: Applicable Documents and Procedures	21
       1.    EPA Documents	21
       2.    RTI Documents	21
       3.    USDA-ARS Documents	21
Appendix B: Organizational Charts for Testing the High Speed Pesticide Spray DRT Protocol 22

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                                    List of Figures
Figure 1. Schedule	5
Figure 2. Overview of HSWT with enclosure removed for clarity	10
Figure 3. ETV data management system for USDA-ARS	17
Figure 4. Organizational chart for the high speed pesticide spray DRT protocol validation	22
                                     List of Tables
Table 1. Data Quality Indicator Goals (DQIGs)	6
Table 2. Summary of Spray and Test Condition Measurements for High Speed Wind Tunnels. 11
Table 3. Summary of Data and Background Information to Include in the Test Report	18

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                            List of Acronyms/Abbreviations
ADQ        audit of data quality
ANSI        American National Standards Institute
APCT Center Air Pollution Control Technology Center
AS ABE      American Society of Agricultural and Biological Engineers
ASAE       American Society of Agricultural Engineers (precursor to ASABE)
ASHRAE    American Society of Heating, Refrigerating, and Air Conditioning Engineers
ASME       American Society of Mechanical Engineers
ASTM       ASTM International, formerly American Society for Testing and Materials
°C           degrees Celsius
cfm          cubic feet per minute
cm          centimeter
cP           centipoise
CV          coefficient of variance
DQIG       data quality indicator goal
DQO        data quality objective
DRT         drift reduction technology
Dv0.x         droplet diameter (jim) at which 0.x fraction of the spray volume is contained in
             smaller droplets
dyne/cm      dynes per centimeter
EC          emulsifiable concentrates
EPA         United States Environmental Protection Agency
ESTE        Environmental and Sustainable Technology Evaluations
ETV         Environmental Technology Verification
fpm          feet per minute
ft            foot
gal/acre      gallons per acre
gpm         gallons per minute
GVP         Generic Verification Protocol
HELOS      helium neon laser optical system
HSWT       high speed wind tunnel
Hz          hertz
in.           inches
ISO          International  Standards Organization
kPa          kilopascal
L            liter
m            meters

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mg          milligram
min          minute
mL          milliliter
mm          millimeter
mph         miles per hour
ms          millisecond
m/s          meters per second
NTS          nonionic surfactant
NIST        National Institute of Standards and Technology
uL          microliter
um          microns
OPP         Office of Pesticide Programs
ORD        Office of Research and Development
PE          performance evaluation
PES         performance evaluation system
PMT        photo multiplier transistor
psi          pounds  per square inch
QA          quality assurance
QC          quality control
QM          quality manager
QMP        quality management plan
QSM        quality system manual
RH          relative humidity
RTI          Research Triangle Institute
s            second
SNR        signal to noise ratio
SOP         standard operating procedure
TSA         technical systems audit
USDA-ARS  United States Department of Agriculture - Agricultural Research Service
VMD        volume median diameter
v/v          volume/volume

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A3:          Distribution List

U.S. EPA

Michael Kosusko
Paul Groff

RTI International

Jonathan Thornburg, Ph.D.
W. Gary Eaton, Ph.D.
Jenia Tufts

U.S. Department of Agriculture-Agricultural Research Service

W. Clint Hoffmann, Ph.D.
Daniel E. Martin, Ph.D.

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                             Group A: Project Management

A4:    Project/Task Organization

The U.S. Environmental Protection Agency (EPA) Office of Research and Development (ORD)
has overall responsibility for the Environmental Technology Verification (ETV) Program and for
the Verification of Pesticide Drift Reduction Technologies project under the Environmental and
Sustainable Technology Evaluations (ESTE) Program.  The EPA's Office of Pesticide Programs
(OPP) is a major contributor to the project.

Management and testing of pesticide drift reduction technologies (DRTs) will be performed in
accordance with procedures and protocols defined by a series of Air Pollution Control
Technology Center (APCT Center) quality management documents. The primary source for the
APCT Center quality system is EPA's Policy and Program Requirements for the Mandatory
Agency-Wide Quality System, EPA Order  5360.1 A2 (May 2000). The quality system that will
govern testing under this plan is in compliance with the following:
       •  EPA Requirements for Quality Management Plans (EPA Q A/R-2)
       •  EPA Environmental Technology Verification Program, Quality Management Plan
          (EPA ETV QMP), for the overall ETV program
       •  APCT Center's Verification Testing of Air Pollution Control Technology —Quality
          Management Plan (APCT Center QMP)1
       •  RTF s Draft Generic Verification Protocol for the Verification of Pesticide Spray
          Drift Reduction Technologies for Row and Field Crops (GVP)
       •  USDA-ARS's  Standard Operating Procedures (SOPs)
       •  This test/quality assurance plan (test/QA plan).

Appendix A lists full citations for these documents. This test/QA plan is in conformance with
EPA Requirements for Quality Assurance Project Plans (EPA QA/R-5), EPA Guidance for
Quality Assurance Project Plans (EPA QA/G-5), and the documents listed above.

USDA-ARS will perform  the testing, evaluate the data, and submit a report documenting the
results to RTI. RTI will use the data to prepare the project reports and recommend revisions to
the GVP. The various QA and management responsibilities are divided among USDA-ARS,
RTI, and EPA key project personnel as defined below.  The lines of authority among key
personnel for this project are shown on the project organization chart in Figure B-l.

A4.1   Management Responsibilities

Project management responsibilities are divided among the USDA-ARS, RTI, and EPA staff as
described below.
1 Each ESTE project is required to have a QMP in place and is allowed to use the QMP of an existing ETV Center.
This project has elected to use the QMP from the Air Pollution Control Technology Center (APCT Center). The
verification organization for DRT verifications that occur after completion of this ESTE project is anticipated to be
the APCT Center and this document reflects that assumption. This does not preclude other testing organizations
from using the protocol.

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A4.1.1   EPA Project Manager

The EPA project manager, Michael Kosusko, has overall technical responsibility for the
program. He is responsible for obtaining final approval of GVPs, test/QA plans, and reports, and
he recommends the resources necessary to meet project objectives and requirements.

A4.1.2   RTI Project Leader

The RTI project leader is Jonathan Thornburg. He has overall responsibility for liaison with the
EPA project manager and technical and administrative oversight of project activities. He
prepared this test/QA plan and technical questions should be directed to him. He will assign task
leaders and review project documents, as appropriate.

A4.1.3   RTI Field Auditor

The RTI field auditor is Jonathan Thornburg or his designee, who will:
    •   Review test/QA plans,
    •   Conduct technical systems audits (TSA) at USDA-ARS, and
    •   Provide  oversight of test site activities.

A4.1.4   Testing Organizations' Technical Leaders

The USDA-ARS technical leader is W. Clint Hoffmann, who will:
    •   Assist the RTI project leader with the test scope,
    •   Review/prepare operating procedures applicable to the testing,
    •   Review test apparatus and procedures prior to commencement of testing,
    •   Oversee testing of the pesticide spray DRT systems,
    •   Review test data/results for attainment of data quality indicator goals (DQIGs) and
       reasonableness,
    •   Initiate corrective actions when needed,
    •   Review test results, and
    •   Submit test results to the RTI proj ect leader.

Hoffmann has overall responsibility for technical and administrative activities, and exercises
technical leadership to promote quality in project performance. He will also function as liaison
to RTI and U.S. EPA in specific technical areas and supervise the activities of project leaders at
USDA-ARS.

A4.2   Quality Assurance Responsibilities

QA responsibilities are divided among the EPA, RTI, and USDA-ARS  personnel as listed below.

A4.2.1   EPA Quality Manager

The EPA quality manager (EPA QM), Paul Groff, will conduct audits of RTFs QA system  and
of specific technical activities on the project.  He will be available to resolve any QA issues
relating to performance and EPA's QA requirements. Specific functions and duties of the EPA

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QM include approving the contents of this test/QA plan and subsequent revisions and reviewing
QA reports prepared by RTI, including QA evaluations and audits. In addition, the EPA QM
will:
    •   Communicate quality systems requirements, quality procedures, and quality issues to the
       EPA project manager and the RTI project leader,
    •   Review and approve this test/QA plan specific to USDA-ARS,
    •   Oversee technical systems audits (TSAs) as appropriate,
    •   Review and approve project test reports, and
    •   Provide assistance to project personnel in resolving QA issues.

A4.2.2   RTI Quality Manager

The RTI quality manager (RTI QM), W. Gary Eaton,  is organizationally independent of the RTI
project leader and is responsible for ensuring that QA/quality control (QC) procedures described
in this test/QA plan are followed. In addition, Eaton will:
    •   Maintain regular communication with the EPA QM and RTI project staff regarding QA
       issues,
    •   Report on the adequacy, status, and effectiveness of the QA program on a regular basis to
       the RTI project leader,
    •   Conduct audits of lab activities as necessary and prepare audit reports,
    •   Ensure that corrective action, if necessary, is properly implemented and documented,
    •   Review and approve test/QA plans and SOPs,
    •   Review the TS A reports of USDA-ARS testing,
    •   Review the audit of data quality (ADQ) reports of USDA-ARS testing,
    •   Review and approve test (including QC) reports, and
    •   Prepare the QA section of the project report.

A4.2.3   Testing Organizations' Quality Managers

The USDA-ARS QM, Daniel E. Martin plays a central role in the introduction, implementation,
and consistent application of continuous quality improvement at USDA-ARS. He will fulfill the
role as quality management representative for the department and conduct audits of all pertinent
quality standards to ensure compliance, and is organizationally independent of the unit
generating the data.  Martin will:
    •   Maintain regular communication with the RTI QM and testing staff regarding QA issues,
    •   Report on the adequacy, status, and effectiveness of the QA program on a regular basis to
       the USDA-ARS technical leader,
    •   Conduct audits of lab activities as necessary and prepare audit reports,
    •   Ensure that corrective action, if necessary, is properly implemented and documented,
    •   Review and approve input of the test organization to the test/QA plans and SOPs,
    •   Review and approve test data and documentation submitted to RTI reports (including
       QC), and
    •   Provide input to the QA section of the project report.

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A5:    Problem Definition/Background

In 2007, U.S. EPA completed a draft protocol for the verification of pesticide spray drift
reduction technologies for row and field crops. The Draft Generic Verification Protocol for the
Verification of Pesticide Spray Drift Reduction Technologies for Row and Field Crops
(http://www.epa.gov/etv/pubs/600etv07021.pdf) was developed by U.S. EPA with input and
commentary from stakeholders that included academia, industry,  and other government agencies.
Before the pesticide spray DRT protocol can be implemented as an approved protocol for use by
the ETV APCT Center, the draft protocol will be tested and evaluated. This test/QA plan for high
speed wind tunnel testing at USDA-ARS describes how the draft  protocol for pesticide  spray
DRTs verification at high speeds, to simulate aerial applications, will be validated. Once U.S.
EPA approves the final report, U.S. EPA, RTI, vendors, test facilities, and other stakeholders
will use the validation report to evaluate the high speed pesticide  spray DRT protocol and
suggest changes that will provide improvements.

Pesticide spray drift is defined as the movement of spray droplets through the air at the time of
application or soon thereafter from the target site to any non- or off-target site, excluding
pesticide movements by erosion, migration, volatility, or windblown soil particles after
application.  High speed drift reduction technologies include nozzle designs and chemical
adjuvants. High speed is defined as a speed of the air in the wind  tunnel crossing the nozzle
representative of aerial application. Within this test/QA plan, the pesticide spray DRT protocol
was validated only for nozzle designs. Validation of the protocol through modification of spray
liquid formulation characteristics (e.g., viscosity or surface tension) was not part of the planned
effort.

A6:    Project/Task Description

A6.1   Description

This test/QA plan describes the test and QA procedures that will validate the Generic
Verification Protocol for the Verification of Pesticide Spray Drift Reduction Technologies for
Row and Field Crops for spray nozzles in a high speed wind tunnel.  This test/QA plan  is written
to conform to all specifications of EPA Requirements for Quality Assurance Project Plans, EPA
QA/R-5, the EPA ETV QMP, and the ETV APCT Center QMP. It describes the quality system
required of USDA-ARS and the procedures applicable to meeting EPA quality requirements that
are common to all ETV tests. This document will be reviewed and approved by EPA prior to
testing.

This testing  will gather information and data for evaluating the applicability of the pesticide
spray DRT protocol for successfully testing commercially ready pesticide spray DRT nozzles
that will be used for aerial spraying applications. All  high speed tests will be conducted in the
USDA-ARS wind tunnel located in College Station, TX. The specific operating conditions used
during the testing will be documented as part of the testing process. Table 2 in element B2 of
this test/QA plan presents a summary of measurements that will be made to evaluate the
performance of the DRT and document the test conditions.

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Two candidate nozzles and a reference nozzle will be tested using the pesticide spray DRT
protocol. The AI-11003 VS nozzle (Teejet Technologies, Wheaton, IL) is one nozzle to be
tested. This air eduction nozzle will produce a "very coarse" spray, as defined by ASAE S572
(1999), at the operating conditions defined in element Bl. This nozzle is used extensively by
industry and its performance characteristics have been extensively studied. The ULD 120-04
nozzle (Hypropumps, New York, NY) is the second nozzle to be tested. This dual air eduction
nozzle also is extensively used by industry. The ULD 120-04 nozzle will produce a "coarse"
spray at the operating conditions defined in element Bl. The characteristics of the reference
nozzle to be used during the testing are specified in element Bl. USDA-ARS will provide the
reference nozzle.

A report containing results of the pesticide spray DRT protocol validation tests  will be prepared
by USDA-ARS; see element BIO.2. RTI will review and approve the report before submittal of
the entire data package to U.S. EPA.

A6.2   Schedule

Figure 1 shows the schedule for completion of the high speed wind tunnel pesticide spray DRT
protocol validation. Testing was completed March 30-31, 2009.
Item
1
2
3
4
5
6
7
Milestone
Test/QA Plan - Submission to EPA for Approval
Test/QA Plan - Review Comments
Final, Revised, Approved Test/QA Plan
Testing
Report - Draft to RTI
Report - Review Comments
Final Report to EPA
By Whom?
RTI
EPA
RTI
USDA-ARS
USDA-ARS
RTI
RTI
Schedule
January 30, 2009
February 27, 2009
March 24, 2009
March 3 0-3 1,2009
April 29, 2009
May 13, 2009
September 9, 2009
Figure 1. Schedule
A7:    Quality Objectives and Criteria

The DQO of this testing focus on the direct or indirect measurements of spray drift deposition
using wind tunnel testing. For wind tunnel testing, the testing organization (USDA-ARS) will
measure droplet size and spray volume data.

For wind tunnel testing, the primary product of this test design will be the measurement of a
droplet size distribution consisting of 32 or more droplet size bins (32 droplet size bins are
necessary for input to the models). The degree of consistency of volume median diameter
(VMD), droplet diameter (|im) at which 10% of the spray volume is contained in smaller
droplets (Dvo.i) and droplet diameter (jim) at which 90% of the spray volume is contained in
smaller droplets (Dvo.g) are used as a measure of data quality. Variation of less than ± 3% is
considered acceptable.

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Secondary measurements to be collected during testing include spray material conditions (flow,
pressure, temperature, etc.), wind tunnel air speed, and ambient environmental conditions. These
measurements may provide explanations if the droplet size distribution data quality indicator is
not achieved. This information may also be used for other potential revisions to the pesticide
spray DRT protocol.

The DQIG for individual measurements will conform to those specified in relevant sections of
the test protocols and referenced procedures, as shown in Table 1.  The DQO for this testing is to
meet the Table 1 DQIGs. One purpose of performing protocol evaluation testing is to assess the
appropriateness of the DQIGs. (NOTE:  Once the generic verification protocol is final, tests will
be repeated if DQIGs for the primary measurements listed in Table 1 are not achieved.)
Table 1. Data Quality Indicator Goals (DQIGs)
Parameter
Standard Operating
Procedure
(if applicable)
Acceptance Criteria
Spray Liquid DQIGs
Nozzle spray angle
Spray liquid pressure (nozzle
operating pressure)
Spray liquid temperature
Spray liquid flow rate
Dynamic surface tension of
spray liquid
Viscosity of spray liquid
n/a
ASAE S572
ASHRAE Standard 4 1.1
ASAE S572
USDA SOP -4.2
USDA SOP-4.2
Variation within ± 5% during test.
±3.4 kPa of values specified in the ASAE standard
for reference and evaluation nozzles.
Measured within 0. 1 °C
± 0.04 L/min of values specified in the ASAE
standard for reference and evaluation nozzles.
52 ± 4 dynes/cm at surface lifetime age of 10 to 20
ms for test fluids with adjuvants. 70 ± 4 dynes/cm for
water, if used as test fluid.
1.1 ±0.1 cPat20°C
Droplet Size Distribution DQIGs
Spray volume in largest and
smallest droplet size class bands
in laser diffraction
measurements
Number of size class bands for
reported data
Standard deviation around mean
Dv0.5 for three replicate droplet
size measurements
Measured volume median
diameter (VMD), Dv0.i and
Dv0.9 (i.e., the droplet diameter
bounding the upper and lower
10% fractions of the spray)
USDA SOP-4.4
USDA SOP-4.4
USDA SOP-4.4
USDA SOP-4.4
< 1% of total volume in each case (i.e., < 2% total of
the spray volume)to be achieved through selection of
appropriate lens and instrument configuration for the
dynamic size range of the spray being sampled
> 32
Vary by less than ± 3% for replicate measurements
with the same nozzle
Vary by less than ± 7% for replicate measurements
with the same nozzle

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Parameter
Obscuration for spray
measurements across a spray
diameter (for laser diffraction
systems)
Minimum obscuration for
sampling to achieve cross-
section average spray (e.g., start
and end trigger using traverse
with laser diffraction systems)
Sample size per replicate
measurement
Diode suppression (laser
diffraction systems)
Standard Operating
Procedure
(if applicable)
USDA SOP-4.4
USDA SOP-4.4
USDA SOP-4.4
n/a
Acceptance Criteria
< 60% unless corrected for multiple scattering,
whereupon the report shall include the measured
obscuration, the algorithm used to correct for
multiple scattering, and the manufacturer-stated
limits of applicability for that algorithm.
2%
> 10,000 droplets for particle counting instruments or
> 5 s for laser diffraction instruments
Diodes may not be suppressed (no channels may be
killed) in sampling. Correct selection of focal length
lens, system alignment, avoidance of vibrations, and
cleanliness of optical surfaces should prevent the
need for diode suppression (data loss). (If the laser is
displaced during sampling, all diodes will measure
incorrect scattering angles, and diode suppression is
not an appropriate solution to such sampling
problems.)
HSWT Operation DQIGs
Air speed inside wind tunnel
Wind tunnel cross-section
diameter
Wind tunnel ambient air
temperature
Wind tunnel wet bulb/dew point
temperature or percent relative
humidity
Relative spray material and air
temperatures
USDA SOP-4.4
n/a
ASHRAE Standard 4 1.1
ASHRAE Standard 4 1.1
USDA SOP-4.4
Between 50 mph (22 m/s) and 180 mph (80 m/s), and
measured to an accuracy within 5 mph (2 m/s), close
to nozzle location (with nozzle absent). Acceptance
criteria between measurements ± 5%.
Cross-section at least three diameters larger than
spray plume diameter (at size distribution
measurement location).
Measured within 0.1 °C.
Measured within ± 0. 1 °C or ± 1%.
Spray material temperature must be within 2 °C of
the air temperature to avoid atomization anomalies.
       n/a = not applicable

Standards Cited

ANSI/ASHRAE 41.1 (1986) Standard Method for Temperature Measurement., American Society
of Heating, Refrigerating and Air Conditioning Engineers, Inc. 1791 Tullie Circle, NE, Atlanta,
GA 30329.

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ASAE S572 (1999) (sometimes referred to as AS ABE S572) Spray Nozzle Classification by
Droplet Spectra. Standard No.  S572, American Society of Agricultural and Biological
Engineers, St. Joseph, MI.

A8:    Special Training/Certifications

All USDA personnel associated with this program must have completed the training specified in
USDA SOP-4.1: "Personnel Records, Training Logs, and Laser Safety."  This training
encompasses general laboratory safety and laser safety. Training specific for spray drift
reduction technology evaluation includes wind tunnel operation, laser-diffraction instrument
operation, and data handling procedures. The USDA-ARS test leader will ensure that all persons
assigned to the field crew have appropriate training and are fully capable of performing the tasks
assigned to them. Each field crew member will be thoroughly familiar with this test/QA plan, the
measurement equipment, procedures,  and  methods for their assigned jobs. All field test
personnel will receive the required and appropriate safety training, and a safety briefing will be
given to all test team members by the USDA-ARS test leader.

A9:    Documentation and Records

All information associated with data collection during a test will be recorded. Test data will be
recorded legibly on a standardized form in permanent ink and initialed and dated by the person
making the entry. At a minimum, the test data recorded will include information specified in
Table 1 that is not recorded electronically.  In accordance with Part A, sections 5.1 and 5.3 of
EPA's QMP, USDA-ARS will retain all test-specific documentation and records for 7 years after
completion of the tests. RTI will retain all reports for 7 years after completion of the project.
Archived raw data, documents, and electronic  files will be easily accessible.

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                       Group B: Data Generation and Acquisition
                           for High Speed Wind Tunnel Tests

Bl:    Sample Process Design (Experimental Design)

All of the measurements in this section of the test/QA plan will be conducted in the high speed
wind tunnel at the USDA-ARS in College Station, TX.  The validity of and applicability of the
pesticide spray DRT protocol will be evaluated using two test nozzles and a reference nozzle.
Measurements of the droplet size distribution produced by the candidate test systems will be
compared to the reference spray system based on the ASAE S572 standard for droplet size.

Two candidate nozzles and a reference nozzle will be tested using the pesticide spray DRT
protocol. The AI-11003 VS nozzle (Teejet Technologies, Wheaton, IL) and the ULD 120-04
nozzle (Hypropumps, New York, NY) are the nozzles to be tested. Both test nozzles will be
operated at 300 kPa (43.5 psi). The AI-110 flow is 1.13 L/min (0.3 gpm). The ULD 12-04 flow
is 1.51 L/min (0.4 gpm).The reference nozzle will be the ASAE S572 nozzle associated with the
fine/medium boundary. Specifically, this nozzle is a 110° flat-fan nozzle operated at 300 kPa
(43.5 psi) and 1.18 L/min (0.31 gpm). The spray solution for all nozzles will be a distilled water
solution containing a 0.25% volume/volume (v/v) of a 90% nonionic surfactant (NTS) (R-900,
Wilbur-Ellis Company, San Antonio, TX).

The primary performance measure for the high speed pesticide spray DRT protocol will be
derived from droplet size distribution measurements. The basic experimental design will be to
measure the droplet size spectrum under targeted test conditions with the DRT operating at the
specified spray pressure, air speed, and the ambient environmental conditions. Droplet size
spectrum is the critical measurement for this test. Droplet size measurements of interest are the
Dvo.s, DVO.I, and Dvo.9. Dvo.s is the volume  median diameter (|im) where 50% of the spray volume
is contained in droplets of smaller diameter. Similarly, DVQ.I and Dvo.9 describe the percentage
(10% or 90%, respectively) of the droplet volume in the specified size or less. Wind tunnel and
spray liquid conditions measurements, see section B2, are supplemental measures that will
establish the bounds of the spray size distribution data.

To meet the DQO, at least three replicate  experiments using each nozzle will be performed. As
required by the DQO in element A7, the product of this test design will be the measurement of a
droplet size distribution consisting of 32 or more droplet size bins for the specified operating
range. The DQIGs for appropriate parameters identified in Table 1 must be achieved for
acceptance of the test data.

B2:    Sampling Methods for Measurement of Droplet Size and Test Conditions

The sampling system is comprised of the HSWT at USDA-ARS, as depicted in Figure 2. The
USDA-ARS HSWT consists of a high speed centrifugal blower powered by a 48.5 kw (65 hp)
gasoline engine.  The blower speed is controlled by adjusting the engine's throttle.  The high
speed air generated by the blower exhausts through a 30 x 30 cm outlet. Prior to leaving the

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outlet, the high speed air passes through air straighteners mounted inside the tunnel.  Airspeed is
measured directly at the outlet using a pitot tube attached to an airspeed indicator.  A 30 cm
section of aircraft boom is mounted directly at the tunnel's outlet. The boom is affixed to a pair
of linear slides and a linear motor to allow it to be traversed vertically across the length of the
outlet. The boom section is plumbed to a pressured spray tank.  The center of the boom has a
fitting to mount the required check valves and nozzles. A pressure gauge is also plumbed to the
boom to monitor pressure at the nozzle. A movable 40 x 40 cm plexiglass tunnel is positioned in
line with the airstream flush against the tunnel's outlet.  This section is moveable to allow access
to the spray boom and nozzle.  The plexiglass tunnel has a pair of access holes downwind of the
nozzle through which the laser diffraction instrument operates.
Figure 2. Overview of HSWT with enclosure removed for clarity.

Table 2 lists all the measurements required for each test.  The measurements are categorized as
performance factors and test conditions. Performance factors verify the performance of the DRT,
and test conditions are important to understand the environmental conditions during the
evaluation.

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Table 2. Summary of Spray and Test Condition Measurements for High Speed Wind
Tunnel Tests.
Parameter to Be
Verified
Set-Point
Sampling and
Measurement Method
Comments
Performance Factors
Droplet size
distribution at the
atomizer
n/a
Non-intrusive sampling
methods appropriate for
the spray material such as
laser diffraction, phase-
Doppler, laser imaging
instruments.
Document operating conditions
and experimental data to satisfy
all droplet size distribution
DQIGs listed in Table 1.
Test Conditions Documentation
Spray liquid pressure
(nozzle operating
pressure)
Spray liquid flow
rate
Spray angle
Spray liquid
viscosity
Spray liquid surface
tension
Spray liquid
temperature
Wind tunnel air
speed
Wind tunnel ambient
temperature
Wind tunnel wet
bulb/dew point
temperature or
percent relative
humidity
43.5psi
Reference: 1.2L/min
AI-11003: l.lL/min
ULD 120-04: 1.5L/min
Reference: 110 degrees
AI-11003: Angle
specified by
Manufacturer
ULD 120-04: Angle
specified by
Manufacturer
1.1 cPat20°C
52.5 dynes/cm
n/a
lOOmph
n/a
n/a
See ASAE S572, section
o
J.
See ASAE S572, section
3.
See ASAE S572, section 3
Manufacturer specified
Manufacturer specified
Calibrated viscometer
Calibrated tensiometer
Calibrated thermometers
accurate within 0. 1 °C
An appropriate and
calibrated anemometer
such as hot wire or pitot-
static tubes. Measurement
should occur as close as
possible to the atomizer
without affecting its
performance.
Calibrated thermometers
accurate within 0. 1 °C
Thermohygrometer
equivalent to ASTM E337-
84(1996)el;orASHRAE
Standard 4 1.1
1 reading per test
1 reading per test
Measurement before and after
test
1 measurement per test
1 measurement per test
Temperature of the ambient air
and spray mixture should be
within 2 °C
The air speed measured in the
wind tunnel will be used to
define acceptable field
conditions of use.
Testing organization conducts
air speed, temperature, and
humidity measurements
concurrently.

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Parameter to Be
Verified
Wind tunnel cross-
section diameter
Sympatec HELOS
Laser Diffraction
System
Nozzle Description
Set-Point
n/a
n/a
n/a
Sampling and
Measurement Method
Calibrated tape measure
n/a
n/a
Comments
Cross-section at least three
diameters larger than spray
plume diameter at size
distribution measurement
location.
Record model number, serial
number, scale ranges, software
version number, and calibration
verification.
Record nozzle information for
each test [i.e., flat fan, cone
(hollow, full), impingement
(deflector), and solid stream
nozzles; manufacturer; fan
angle at reference operating
pressure; orifice size; material
of manufacture]. Nozzle part
number, type of nozzle body
and type of cap are also
recorded for every test.
B2.1   Sampling Locations

For most tests, the nominal distance between the center of the atomizer tip and the plane of the
size distribution measurements will be 6 to 30 in. (15 to 76 cm), accurate to within 0.5 in. (13
mm). In general, the optimal sampling distance is 8 to 20 in. (20 to 50 cm). The sampling
distance may need to be adjusted for different atomizers, flow rates, and test fluids. The plane is
defined by the movement of the centerline of the laser beam as it traverses the spray. The
experimental set-up must insure complete span of the spray cross-section, particularly when the
atomizer orientation is perpendicular to air velocity. The nominal distance must be far enough
from the atomizer to allow for both atomization of ligaments and secondary break up of droplets
in the air stream to be complete. However, the sampling distance must be close enough to the
atomizer that the spray plume diameter is less than one-third of the wind tunnel cross-section. A
traverse must be completed in a minimum of 5 s, with 20 to 30 s the most likely range.

Air temperature, humidity, and wind speed will be measured immediately upstream of the spray
nozzle.  This location provides representative measurements without affecting atomizer
performance or air speed within the wind tunnel. Measurement of air temperature and humidity
will occur upwind of the atomizer and as close as possible to the atomizer without affecting its
performance or the air speed at the atomizer.

B2.2   Process/Application Data Collection

Droplet size distribution measurements will be collected with a Sympatec HELOS laser
diffraction system (Sympatec Inc., Lawrenceville, NJ).  The full spray volume will be traversed
three times during the test. The maximum time between traverses will be 20 s. The primary
operator of the laser diffraction instrumentation control software will input all appropriate test

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parameter information into the software's database system which will tag each test replication
with the appropriate identification data.  The database software settings will be adjusted such that
collected data cannot be modified or removed once collected. The primary operator of the
system will back up the collected data in database format to appropriate archival media labeled
with test identification parameters. Additionally, all collected data will be archived in database
format on the laser diffraction system computer hard drive. Collected droplet size distribution
data will be processed or analyzed to insure that the appropriate DQIGs in Table 1 are achieved.

Wind tunnel conditions are measured at the same height as the nozzle, upwind of the nozzle in
the wind tunnel working  section at the time of spray release. These measurements include
ambient air temperature,  relative humidity, and air speed.  The data will be recorded to document
the DQIGs are achieved.  Measurements will be collected using NIST-certified instruments.

Sprayer operational parameters will be measured.  Spray pressure will be measured at the nozzle
tip using a capillary connected to a NIST-certified pressure gauge. The liquid flow rate to the
sprayer will be measured between the liquid tank and the nozzle using a NIST-certified
flowmeter. Spray liquid temperature will be measured in the liquid tank with a NIST-certified
thermometer. The sprayer performance data will be processed to insure that DQIGs are achieved.
Spray liquid viscosity and surface tension will be measured using appropriate instruments with
valid calibration certificates.

B2.3  Wind Tunnel Measurement of Spray Drift Potential (Droplet Size Distribution at
       Aerial Application Air Speeds  at the Nozzle)

All sampling will follow the requirements of the specific test method being used unless
otherwise stated in this document or approved by EPA project manager prior to the test. Test
procedures will provide data and information to assess the DQIGs specified in Table 1. A
summary of the experimental procedure described in USDA SOP-4.4:  "Determining Cross-
Section Average Drop Size Distributions of Sprays" is provided below.

    1.    The nozzle is installed in the wind tunnel at or near the centerline at the appropriate orientation
         to the airflow with the nozzle tip at an upwind distance of 15 to 60 cm from the center of the
         laser beam. Nozzles must be positioned in the center of the wind tunnel to be free from edge
         effects.

   2.    The fan spray angle relative  to the air flow direction (i.e., predominant spray direction or axis
         of rotation) is measured with a protractor and recorded. During drift potential measurements,
         the angle of the candidate test system does not need to be identical to that of the reference
         spray system (See Table 2).

   3.    Droplet size shall be measured using the Sympatec HELOS laser diffraction system. The
         model number, serial number, scale ranges, software version number, and calibration
         verification will be recorded for each test. The R5 lens will be the standard lens to provide
         sufficient working distance along the laser beam to avoid vignetting. For a very fine spray, a
         shorter focal length lens, R3, may be required. In such cases, accommodation of the spray
         cloud must be confirmed. For coarser sprays, the R7  lens may be used.

   4.    The droplet size measurements will include assessments of the droplet size category of the
         candidate test system and reference system according to ASAE S572.

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    5.     The test fluid will be deionized water containing 0.25% v/v 90% NIS (R-900, Wilbur-Ellis
          Company, San Antonio, TX). Spray material characteristics will be measured following USDA
          SOP-4.2: "Measurement of Physical Properties of Liquids."

    6.     The spraying system shall be primed with spray prior to measurements to ensure that rinsing
          liquid is removed from the line and the liquid discharging from the nozzle is the actual
          intended tank mix. In addition, sprayer systems should be "run-in" for 5 min to ensure removal
          machining burrs or plastic mold residue.

    7.     Spray material flow rate shall be measured at the operating pressure for the tests. Prior to
          testing each nozzle,  it will be plumbed to a pressurized spray tank and operated at the specified
          pressure. Spray volume will be collected in a container over 60 s and weighed on a scale.
          This will be replicated three times. The spray rate will then be determined for each replication
          the average and standard deviation calculated.  Nozzle output should remain constant with a
          maximum deviation of ± 2.5%. Spray volume will also be measured during the HSWT test by
          placing the pressured spray tank on a scale to measured the volume sprayed (based on the
          starting and ending mass and fluid density).  Spray time will be measured using a stop watch to
          allow determination of spray rate. These liquid flow rate measurements are consistent with
          ISO 5682 part 1.

    8.     The air speed in the  working section of the wind tunnel must be measured as close as possible
          to the nozzle without affecting nozzle performance or allowing the atomizer to influence the
          air speed measurement. Air speed target is 100 mph ± 5 mph.

    10.    The design characteristics of the test and reference nozzles must be documented as follows:

             -   Flat fan, cone (hollow or full), impingement (deflector), and solid stream nozzles:
                 manufacturer, fan angle at reference operating pressure, orifice size, material of
                 manufacture.

             -   Other types  of atomizers (e.g., rotary, electrostatic, and ultrasonic): the type of nozzle
                 must be described in the test/QA plan provided to EPA prior to testing in order to
                 identify the  appropriate parameters to be recorded.

             -   Include a close-up photograph of the nozzle and manifold and a cross-sectional
                 drawing.

             -   Include the manufacturer nozzle part number.

             -   Document the type of nozzle body and cap used in the tests.

B2.4   Measurement of Droplet Size Spectrum near the Nozzle, Without the Effects of
       Flight Speed Air Flow

The five, official reference nozzles that determined the Classification Category boundaries
specified in ASAE S572 will be evaluated prior to starting any tests. Using the operational
parameters specified  in ASAE S572, the spray plume size distribution will be measured along
the traverse plane with the Sympatec HELOS system without any high speed air. The spray
solution will be deionized  water with 0.25% v/v a 90% NIS (R-900, Wilbur-Ellis Company, San
Antonio, TX). These tests will insure that all equipment is properly working and that HELOS
calibration has not been lost. The results from the five nozzles will serve as a reference

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measurement between tests. The nozzle that defines the fine/medium category [flat fan 110° at
300 kPa (43.5 psi)] will serve as the reference nozzle for all subsequent tests.

The droplet size measurement and classification will be consistent with ASAE S572 in addition
to the criteria below.
   1.    Droplet size spectra for spray drift tests will be made under the same conditions (e.g.,
         spray material, spray pressure, nozzle settings) and following the same procedures
         outlined in elements B2.2 and B2.3.
   2.    The DQIGs specified in Table 1 are achieved.

B3:    Sample Handling and Custody Requirements

No physical samples requiring handling or custody are collected.

B4:    Analytical Methods

No analytical methods are used.

B5:    Quality Control

The USDA QM is responsible for ensuring that the procedures specified in this document and
USDA SOP-4.4 are followed.  Prior to any tests, the QM will review the data requirements with
the technical leader and establish which personnel are responsible for collecting, recording, and
storing all data obtained during the tests.

The USDA QM will monitor the performance factors and auxiliary test conditions described in
Table 2 and DQIGs specified in Table 1. These QC  objectives are applicable to reference
nozzles and the test DRT. If the DQIGs for the spray volume size distribution or test conditions
are not achieved, the test will be repeated.

B6:    Instrument/Equipment Testing, Inspection, and Maintenance

All temperature, relative humidity, pressure, and airspeed instrumentation must be NIST-
traceable instruments.  All procedures for calibration and testing of these instruments must be
followed and recorded as required by the manufacturer's specifications.

B7:    Instrument/Equipment Calibration and Frequency

The Sympatec HELOS System will be calibrated and certified by Sympatec-provided technicians
on a yearly basis.  A copy of this calibration procedure and all appropriate documents will be
kept in the Sympatec Operator's Manual. The calibration procedure follows ASTM Standard
Test Method E 1458 "Test Method for Calibration Verification of Laser Diffraction Particle
Sizing Instruments using Photomask Reticles."

Calibration of all other instrumentation will be current and documented.

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B8:    Inspection/Acceptance of Supplies and Consumables

Inspection and acceptance criteria for vendor supplied or USDA-ARS purchased materials and
equipment are coordinated by the USDA-ARS technical leader or task leader.  This process is
conducted in accordance with SOP-4.3: "Reception, storage and distribution of active
chemicals." Water used in spray tanks should have a hardness of less than 300 ppm.

B9:    Non-Direct Measurements

All data used in this project will be generated by this project. No non-measurement sources,
such as computer databases, programs, literature files, and historical databases, will be used.

BIO:   Data Management

B10.1  Data Acquisition and Management

Data acquisition and data management are performed according to USDA SOP-4.4. The planned
data, with responsibilities of the USDA-ARS technical leader and USDA-ARS QM, are depicted
in Figure 3. This flow chart includes all data activities  from the initial pretest QA steps to the
passing of the data to EPA. The USDA-ARS technical  leader is operationally responsible for all
aspects of a test.  The technical leader collects and assembles the data necessary to assess the
spray volume size distribution. Documentation of auxiliary information to validate the  DQIGs
will also be included in the data package. The USDA-ARS QM is operationally responsible for
data validation; including confirmation the DQIGs  are achieved. RTI will perform an
independent QA assessment of the final test report prior to  submission to EPA.

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                     Oversight
                         USDA-ARS Technical Leader: Test Oversight and Data Production
                          USDA-ARS Quality Manager: Quality System and Data Integrity
                     Data Flow
                       DRT Information from
                       Manufacturer/Vendor
Sampling Data and
 Instrument Data
                                                           QC Data
                                         Assemble Data
                                     Calculations & Data Analysis
                                          QA Review
                                           Report
                      Data Flow •
                 Figure 3. ETV data management system for USDA-ARS.

B10.2 Reporting
The data report will contain sufficient details and background information to provide a complete
description of the testing in the report.  The minimum information to be contained in the report is
detailed in Table 3. The USDA-ARS will prepare the draft test report which will be reviewed by
the USDA-ARS project manager and then by the USDA-ARS QM prior to submission to the
RTI project leader for RTI and vendor reviews. After comments from RTI and the vendor are
addressed, RTI (with assistance and review by the USDA-ARS) will revise the draft report and
prepare a draft executive summary for EPA's review.

The final test report, which will be prepared by RTI, includes a results summary and  a detailed
discussion of the testing, as outlined in Table 3 below.

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Table 3. Summary of Data and Background Information to Include in the Test Report
Report Section
Executive Summary
Introduction
Procedures and Methods
Summary and Discussion of
Results
References
Appendices
Contents
DRT manufacturer/vendor information
Summary of the test program, including test location and type
Results (tabular or graphical format)
Droplet size classification using ASAE S572
Discussion of limitations of the results
Brief QA statement
Description and identification of the DRT
Brief description of instrument used for droplet size measurement (including
name and type, model number, serial number, scale ranges, software version
number, and date of most recent calibration)
Nozzle conditions: including nozzle manufacturer, nozzle model number,
spray pressure at nozzle, volume per unit time produced by the nozzle
Spray liquid conditions: including chemical composition, chemical sources,
surface tension, viscosity, and temperature
Wind tunnel conditions: including all measurement locations, temperature,
humidity, and wind speed
Results of the ASAE S572 droplet size measurements for reference nozzle(s)
and test nozzle
Discussion of test results
Explanations for deviation from test plan
QA statement and discussion
List of cited materials
QA/QC activities and detailed results
Raw test data
Equipment calibration results (if applicable)

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                     Group C: Assessments and Oversight Elements

Cl:    Assessments and Response Actions

Cl.l   Internal Audits

Internal audits by USDA-ARS are conducted as specified in the USDA-ARS SOP-4.4:
Determining Cross-Section Average Drop-Size Distributions of Sprays, which conforms to
required element Cl (Assessments and Response Actions) and C2 (Reports to Management) of
EPAQA/R-5.

C1.2   Audits of Data Quality

In accordance with Table 9.1 of the EPA ETV QMP, the USDA-ARS QM will conduct an audit
of data quality (ADQ) of at least 10% of all test data collected during testing at the respective test
sites. The ADQ will be conducted in accordance with EPA's Guidance on  Technical Audits and
Related Assessments for Environmental Data Operations, EPA QA/G-7, including:
       •   a written report detailing the results of custody tracing,
       •   a study of data transfer and intermediate calculations,
       •   a review of QA and QC data, including reconciliation to user requirements (e.g.,
          DQOs and DQIGs), and
       •   a study of project incidents that resulted in lost data, and a review of study statistics.

The USDA-ARS ADQ report will end with conclusions about the quality of the data from the
project and their fitness for their intended use.

C1.3   External Audits

USDA-ARS will cooperate with any external assessments by the EPA or RTI. RTI or EPA will
conduct a single technical systems assessment of USDA-ARS during the test. The external
assessments will be conducted as described in EPA QA/G-7.

C1.4   Corrective Action

Corrective action to any audit or assessment at USDA-ARS is performed according to USDA-
ARS SOP-4.5 "Corrective and Preventive Actions," which conforms to required elements B5
(Quality Control) and Cl (Assessments and Response Actions) of EPA QA/R-5.

C2:    Reports to Management

Internal assessment reports will be reviewed by the USDA-ARS QM, who will respond as noted
in element Cl of EPA QA/R-5. The written report of the ADQ will be submitted for review as
noted in element C1.2 of this test/QA  plan.

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                    Group D: Data Validation and Usability Elements

Dl:    Data Review, Verification, and Validation

Data review and validation will primarily occur at the following stages:
       •   On the USDA-ARS test site following each test run
       •   On the USDA-ARS test site test site following completion of the test program
       •   Before writing the draft data report - by the USDA-ARS QM
       •   During QA review of the draft report and audit of the data - The criteria used to
          review and validate the data will be the QA/QC criteria specified in each test
          procedure, protocol, guideline, or method (see Table 1) and the DQIG analysis of the
          parameter test data. Those individuals responsible for onsite data review and
          validation are noted in  Figure 3, element BIO, and above. The USDA-ARS technical
          leader is responsible for verification of data with all written procedures. Finally, the
          USDA-ARS QM reviews and validates the data and the draft data report using the
          site-specific test/QA Plan, test methods, general SOPs, and project-specific SOPs.
       •   RTI will QA review the data reports.

The data review and data audit will be conducted in accordance with USDA-ARS's SOP.

D2:    Verification and Validation Methods

Activities are specified in USDA-ARS SOP-4.4: Determining Cross-Section Average Drop-Size
Distributions of Sprays, which conforms to required element D2 (Verification and Validation
Methods) of EPA QA/R-5.

D3:    Reconciliation with Data Quality Objectives

Activities are specified in USDA-ARS SOP-4.4: Determining Cross-Section Average Drop-Size
Distributions of Sprays, which conform to requirement element D3 (Reconciliation with User
Requirements) of EPA QA/R-5.

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                  Appendix A: Applicable Documents and Procedures

1.     EPA Documents

EPA. Policy and Program Requirements for the Mandatory Agency-wide Quality System. EPA
Order 5360.1 A2. U.S. Environmental Protection Agency. May 2000.

EPA. EPA Requirements for Quality Management Plans. EPA QA/R-2, EPA Publication No.
EPA/240/B-01/002. U.S. Environmental Protection Agency, Office of Environmental
Information. Washington, DC. March 2001.

EPA. Environmental Technology Verification Program, Quality Management Plan. EPA
Publication No. EPA/600/R-03/021. Office of Research and Development, U.S. Environmental
Protection Agency. Cincinnati,  OH. December 2002.

EPA. EPA Requirements for Quality Assurance Project Plans. EPA QA/R-5, EPA Publication
No. EPA/240/B-01/003. Office of Environmental Information, U.S. Environmental Protection
Agency. March 2001.

EPA. Guidance for Quality Assurance Project Plans. EPA QA/G-5, EPA Publication No.
EPA/600/R-98/018. Office of Environmental Information, U.S. Environmental Protection
Agency. February 1998.

EPA. Guidance on Technical Audits and Related Assessments for Environmental Data
Operations. EPA QA/G-7, EPA Publication No. EPA/600/R-99/080. Office of Environmental
Information, U.S. Environmental Protection Agency. January 2000.

2.     RTI Documents

RTI International. Verification  Testing of Air Pollution Control Technology - Quality
Management Plan, Revision 2.2. RTI International. Research Triangle Park, NC. February
2005. http://www.epa.gov/nrmrl/std/etv/pubs/600etvl001 l.pdf.

3.     USDA-ARS Documents2
USDA SOP-4.1: Personnel Records, Training Logs, and Laser Safety. September 2007.

USDA SOP-4.2: Measurement of Physical Properties of Liquids. September 2007.

USDA SOP-4.3: Reception, Storage, and Distribution of Active Chemicals. September 2007.

USDA SOP-4.4: Determining Cross-Section Average Drop-Size Distributions of Sprays.
September 2007.

USDA SOP-4.5: Corrective and Preventive Actions. September 2007.
2 The USDA SOPs can be obtained from Bradley Fritz of USDA-ARS in College Station, TX, at
brad.fritz@ars.usda.gov.

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   Appendix B: Organizational Charts for Testing the High Speed Pesticide Spray DRT
                                       Protocol

DRT Vendor






EPA Project Manager
Michael Kosusko
•



EPA Quality Manager
Paul Groff
;
RTI Project Leader
Jonathan Thornburg
<
-
RTI Field Auditor
Jonathan Thornburg
(or designee)

enotes normal lines of
enotes informal commi
enotes organizational i


:ommunication
nication
idependence
RTI Quality Manager
Gary Eaton



Quality Manager
Daniel Martin j
Technical Leader
Clint Hoffmann

Task Leaders
Technical Staff

 Figure 4. Organizational chart for the high speed pesticide spray DRT protocol validation.

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