DRAFT Generic Verification Protocol for ETV DRT Version 0.0 April 2007 Page i DRAFT GENERIC VERIFICATION PROTOCOL FOR THE VERIFICATION OF PESTICIDE SPRAY DRIFT REDUCTION TECHNOLOGIES FOR ROW AND FIELD CROPS This protocol has been reviewed and approved by: Original signed by Andrew Trenholm 5/3/07 A. Trenholm, Verification Organization Manager, RTI International Date Original signed by W. Gary Eaton 5/3/07 C. Eaton, Verification Organization Quality Manager, RTI International Original signed by Michael Kosusko 5/9/07 M. Kosusko, EPA Project Manager Date Original signed by Paul Groff 5/10/07 P. Groff, EPA Quality Manager Date ------- Generic Verification Protocol for ETV DRT Version 0.0 April 2007 Page ii A2: Table of Contents List of Figures v List of Tables v List of Acronyms/Abbreviations vi Preface viii Acknowledgements x GROUP A: PROJECT MANAGEMENT 1 A4: Project/Task Organization 1 A5: Project Definition and Background 3 A6: Project/Task Description 5 A6.1 Description 5 A6.2 Test Facility Description 5 A6.3 Schedule 9 A7: Quality Objectives and Criteria 9 A8: Special Training/Certifications 15 A9: Documentation and Records 16 Bl: Sampling Process Design (Experimental Design) 17 B2: Sampling Methods for Measurement of Droplet Size, Deposit, and Test Conditions 17 B2.1 Sampling Locations 19 B2.2 Process/Application Data Collection 19 B2.3 Wind Tunnel Measurement of Spray Drift Potential 21 B2.4 Measurement of Droplet Size Spectrum Near the Nozzle (Determination of appropriate reference test system) 23 B2.5 Measurement of Deposition within Wind Tunnel 24 B2.6 Wind Tunnel and Spray System Operation Data Collection 24 B3: Sample Handling and Custody Requirements 24 B4: Analytical Methods 24 B5: Quality Control 25 B6: Instrument/Equipment Testing, Inspection, and Maintenance 25 B7: Instrument/Equipment Calibration and Frequency 25 B8: Inspection/Acceptance of Supplies and Consumables 25 B9: Non-Direct Measurements 26 ------- Generic Verification Protocol for ETV DRT Version 0.0 April 2007 Page iii BIO: Data Management 26 B10.1 Data Flow 26 B10.2 Data Reduction 27 BIO.3 Analysis of Verification Data 28 GROUP C: DATA GENERATION AND ACQUISITION FOR HIGH SPEED WIND TUNNEL TESTS 29 Cl: Sample Process Design (Experimental Design) 29 C2: Sampling Methods for Measurement of Droplet Size and Test Conditions 29 C2.1 Sampling Locations 30 C2.2 Process/Application Data Collection 31 C2.3 Wind Tunnel Measurement of Spray Drift Potential (Droplet Size Distribution at Aerial Application Air Speeds at the nozzle) 31 C2.4 Measurement of Droplet Size Spectrum Near the Nozzle, Without the Effects of Flight Speed Air Flow (Determination of appropriate reference test system) 33 C2.5 Wind Tunnel and Spray System Operation Data Collection 33 C3: Sample Handling and Custody Requirements 33 C4: Analytical Methods 33 C5: Quality Control 34 C6: Instrument/Equipment Testing, Inspection, and Maintenance 34 C7: Instrument/Equipment Calibration and Frequency 34 C8: Inspection/Acceptance of Supplies and Consumables 34 C9: Non-Direct Measurements 35 CIO: Data Management 35 C10.1 Data Flow 35 C10.2 Data Reduction: 35 CIO.3 Analysis of Verification Data: 35 GROUP D: DATA GENERATION AND ACQUISITION FOR FIELD STUDIES 36 Dl: Sampling Process Design (Experimental Design) 36 D2: Sampling Methods for Measurement of Droplet Size, Deposit, and Test Conditions 36 D2.1 Sampling Locations 37 D2.2 Process/Application Data Collection 38 D2.3 Ambient Data Collection 38 ------- Generic Verification Protocol for ETV DRT Version 0.0 April 2007 Page iv D3: Sample Handling and Custody Requirements 38 D4: Analytical Methods 39 D5: Quality Control 39 D6: Instrument/Equipment Testing, Inspection, and Maintenance 40 D7: Instrument/Equipment Calibration and Frequency 40 D8: Inspection/Acceptance of Supplies and Consumables 40 D9: Non-Direct Measurements 40 D10: Data Management 40 D10.1 Data Flow 40 D10.2 Data Reduction 40 D10.3 Analysis of Verification Data 41 GROUP E: DATA REPORTING 42 El: Outline of the Verification Test Report 42 E2: Draft Report Preparation 43 E3: Data Storage and Retrieval 43 GROUP F: ASSESSMENT/OVERSIGHT 44 Fl: Assessments and Response Actions 44 Fl.l Internal Audits 44 F1.2 Audits of Data Quality 44 F1.3 External Audits 44 F1.4 Corrective Action 44 F2: Reports to Management 44 GROUP G: DATA VALIDATION AND USABILITY ELEMENTS 45 Gl: Data Review, Verification, and Validation 45 G2: Verification and Validation Methods 45 G3: Reconciliation with Data Quality Objectives 45 APPENDIX A: APPLICABLE DOCUMENTS AND PROCEDURES 47 1. EPA Documents 47 2. Verification Organization Documents 47 APPENDIX B: EXAMPLE FORMAT FOR TEST DATA 48 ------- Generic Verification Protocol for ETV DRT April 2007 Version 0.0 Page v List of Figures Figure 1. Example of a low speed wind tunnel (by permission of Silsoe Spray Application Unit - part of The Arable Group) 7 Figure 2. Example of a high speed wind tunnel 8 Figure 3. Example of schedule 9 Figure 4. Low speed wind tunnel sampling locations 21 Figure 5. ETV data management system 27 Figure 6. Sampling locations for field testing 38 List of Tables Table 1. DRT versus Testing Approach 6 Table 2. Data Quality Indicator Goals (DQIGs) 11 Table 3. Summary of Spray and Test Condition Measurements for Low Speed Wind Tunnels 18 Table 4. Summary of Spray and Test Condition Measurements for High Speed Wind Tunnels 30 Table 5. Summary of Spray and Test Condition Measurements for Field Testing 37 Table B-l. Example of Test Data Report Format 48 ------- Generic Verification Protocol for ETV DRT April 2007 Version 0.0 Page vi List of Acronyms/Abbreviations ADQ audit of data quality ANSI American National Standards Institute APCT Center Air Pollution Control Technology Verification 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 American Society for Testing and Materials BBA Biologische Bundesanstalt fur Land- und Forstwirtschaft (Germany's Federal Biological Research Center for Agriculture and Forestry) °C degrees Celsius cfm cubic feet per minute cm centimeter CV coefficient of variance DQIG data quality indicator goal DQO data quality objective DRT drift reduction technology DVO.X droplet diameter (|im) 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 Hz hertz ISO International Standards Organization kPa kilopascal L liter LERAP Local Environmental Risk Assessment for Pesticides (UK scheme) m meters mph miles per hour min minute mg milligram mL milliliter mm millimeter ms millisecond m/s meters per second uL microliter um microns OPP Office of Pesticide Programs ORD Office of Research and Development ------- Generic Verification Protocol for ETV DRT April 2007 Version 0.0 Page vii PE PES PMT psi QA QC QM QMP QSM RH RTI S SNR SOP ISA VMD v/v performance evaluation performance evaluation system photo multiplier transistor pounds per square inch quality assurance quality control quality manager quality management plan quality system manual relative humidity Research Triangle Institute second signal to noise ratio standard operating procedure technical systems audit volume median diameter volume/volume ------- Generic Verification Protocol for ETV DRT Version 0.0 April 2007 Page viii Preface This generic verification protocol was prepared by stakeholders and staff for the Environmental and Sustainable Technology Evaluations (ESTE) project Verification of Pesticide Drift Reduction Technologies. The protocol provides a detailed methodology for conducting and reporting results from a verification test of pesticide drift reduction technologies (DRTs). The plan was reviewed by U.S. Environmental Protection Agency (EPA) and interested stakeholders. These stakeholders are acknowledged below. The EPA is charged with licensing the sale and use of pesticides and ensuring that when applicators use pesticides according to product label directions the pesticides will not cause unreasonable adverse effects to humans or the environment. To perform these important functions, EPA must rely, in part, on quality scientific data and other information to estimate a pesticide's potential hazards, exposures, and risks from its intended use. An important component of this scientific assessment is the potential risks to humans and the environment from pesticide droplets or particles that drift from the application target site (e.g., a corn field) during or shortly after application. Generally, applications of most if not all sprays result in some amount of drift; however, application equipment and technologies, as well as meteorological conditions and the applicator's behavior and use of the equipment and technologies, can all profoundly affect the amount of pesticide drift. The pesticide industry and government have conducted considerable research and assessments in recent years to determine the sources, pathways, and exposure to the environment from airborne spray which can often drift off-target at the time of spray application. However, most of the research has focused on "conventional" technologies. A number of underutilized commercial technologies exist for managing drift; however, little information exists on their effectiveness in reducing spray drift levels. Verification of the effectiveness of pesticide spray drift reduction technologies is a focus of this EPA initiative. EPA's Office of Research and Development (ORD) is partnering with EPA's Office of Pesticide Programs to complete this project under the ESTE program. The ESTE program is part of EPA's Environmental Technology Verification Program (ETV), which was created in 1995 to facilitate the commercialization of innovative or improved environmental technologies through performance verification and dissemination of information. In 2005, ETV established the ESTE program to focus these verifications specifically on Agency needs. Consistent with other ESTE efforts, a technical panel of knowledgeable and interested stakeholders representing application equipment manufacturers or vendors, pesticide applicators and government agencies, as well as research scientists, educators and others related to spray application technology and drift management prepared this test protocol to be used to evaluate the performance of technologies that reduce pesticide spray drift. This protocol describes the testing approach used to generate high-quality, peer-reviewed data for several drift reducing technologies, including test design and quality assurance aspects. The ultimate goal is to accelerate acceptance and use of improved and cost-effective application technologies which, when used properly, have the potential to significantly reduce pesticide spray drift. The Agency will encourage equipment manufacturers to voluntarily use this test plan ------- Generic Verification Protocol for ETV DRT Version 0.0 April 2007 Page ix for testing their equipment. Initially, EPA will work closely with several vendors of DRTs to evaluate DRT performance. If proven significantly effective for reducing spray drift, DRTs will be considered in EPA's scientific review of pesticides and development of spray drift restrictions for product labels. Eventually, pesticide manufacturers can request EPA approval of product labels with these technologies and reduced application restrictions. These technologies will allow pesticide applications equally, or more, protective of the environment and the health of those in the vicinity than current methods. In addition, applicators will have more flexibility in making application decisions. Use of DRTs will allow more targeted, and therefore more effective, pesticide applications. The ETV APCT Center can conduct this testing and resulting datasets would be readily accepted by OPP as inputs in their review of pesticides and spray drift restrictions for product labels. ------- Generic Verification Protocol for ETV DRT Version 0.0 April 2007 Page x Acknowledgements Stakeholder Technical Panel Individuals selected for their technical expertise to participate on a Drift Reduction Technology Stakeholder Technical Panel are listed below. We want to thank the panel members for contributing their technical input to this protocol document. Carolyn Baecker, CP Products Co., Inc. Tom Bals, Micron Inc. Aldos Barefoot, DuPont Crop Protection, CropLife America Terrell Barry, Ph.D., California Department of Pesticide Regulation Sandra Bird, EPA/Office of Research and Development Clare Butler Ellis, Pesticide Action Network (Pesticide Action Network UK) Dennis Gardisser, Ph.D., University of Arkansas Ken Giles, Ph.D., University of California, Davis W. Clint Hoffmann, USD A-Agricultural Research Service Ted Kuchnicki, Pesticide Management Regulatory Agency Canada Stephen Pearson, Ph.D., Spraying Systems Co Carmine Sesa, Rhodia Harold Thistle, USDA Forest Service David L. Valcore, Dow AgroSciences, Spray Drift Task Force Jan Van de Zande, WUR-A&F Tom Wolf, Agriculture & Agri-Food Canada Alvin R. Womac, Ph.D., University of Tennessee Other Contributors In addition to the STP members listed above, several other individuals provided technical input and resources in the development of this protocol. We would like to thank the following for making contributions to this protocol document. Norman Birchfield, Ph.D., EPA/Office of the Science Advisor Kerry Bullock, Ph.D., EPA/ Office of Research and Development Jay Ellenberger, EPA/Office of Pesticide Programs Christine Hartless, EPA/Office of Pesticide Programs Andrew Hewitt, Ph.D., Centre for Pesticide Application and Safety, University of Queensland Faruque Khan, EPA/Office of Pesticide Programs Michael Kosusko, EPA/Office of Research and Development Steven Perry, EPA/Office of Research and Development Mohammed Ruhman, EPA/Office of Pesticide Programs Karen Schaffner, RTI International Dee Ann Staats, CropLife America Bill Taylor, Hardi International Drew Trenholm, RTI International ------- Generic Verification Protocol for ETV DRT Version 0.0 April 2007 Page 1 GROUP A: PROJECT MANAGEMENT A4: Project/Task Organization The U.S. Environmental Protection Agency (EPA) 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 ESTE Program operates as part of the Agency's larger ETV Program. ETV develops testing protocols and verifies the performance of innovative technologies that have the potential to improve protection of human health and the environment. Both the EPA's Office of Pesticide Programs (OPP) and Office of Research and Development (ORD) are involved in the project. In 2005, the EPA created a new program element, ESTE, under its current ETV. This program is designed to support the Agency's ability to address important environmental issues (and environmental sustainability) and to protect human health. As part of ESTE, innovative, commercial-ready technologies showing potential to significantly reduce risks may be selected for verification testing. Testing—conducted with the same commitment to quality assurance, cost-sharing, and stakeholder involvement fundamental to the larger ETV program—provides credible performance data needed for accurate assessment of the effectiveness of these technologies. The future verification testing program could be conducted by the APCT Center, under the sponsorship of EPA, with the participation of DRT manufacturers and vendors. The APCT Center's role as verification organization is to provide technical and administrative leadership and manage the conduct of verification testing and reporting. Subcontractors may have roles as testing organizations. Site specific test/QA plans are prepared to meet the requirements of the generic verification protocols (this document) and approved by the APCT Center. Management and testing of pesticide DRTs within the APCT Center are performed in accordance with procedures and protocols defined by a series of 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: ------- Generic Verification Protocol for ETV DRT Version 0.0 April 2007 Page 2 • EPA Requirements for Quality Management Plans (EPA QA/R-2) • EPA Environmental Technology Verification Program, Quality Management Plan (EPA ETV QMP), for the overall ETV program • APCT Verification Center's Verification Testing of Air Pollution Control Technology - Quality Management Plan (APCT Center QMP)1 • [Testing Organization's Standard Operating Procedures (SOP)]1 • This protocol. EPA's ETV QMP provides the definitions, procedures, processes, organizational relationships, and outputs that will ensure the quality of the data and the programmatic elements of ETV. Part A of the EPA ETV QMP includes the specifications and guidelines that are applicable to common or routine quality management functions and activities necessary to support the ETV program. Part B of the EPA ETV QMP includes the specifications and guidelines that apply to test-specific environmental activities involving the generation, collection, analysis, evaluation, and reporting of test data. APCT Center QMP describes the quality systems in place for the overall APCT Center program. It was prepared by RTI and approved by EPA. Among other quality management items, it defines what must be covered in the generic verification protocols and test/QA plans for technologies undergoing verification testing. Generic verification protocols are prepared for each technology to be verified. These documents describe the overall procedures to be used for testing a type of technology and define the critical data quality objectives (DQOs). The document herein is the generic verification protocol for pesticide spray DRTs. It was written with input from the technical panel and approved by EPA. Test/QA plans are prepared by the testing organization. The test/QA plan describes in detail how the testing organization will implement and meet the testing requirements of the generic verification protocol. The test/QA plan also sets data quality objectives (DQOs) for supplemental non-critical measurements that are specific to the site of the test. The test/QA plan addresses issues such as the test organization's management organization, test schedule, documentation, analytical methods, data collection requirements, calibration, and traceability. It also specifies the QA and quality control (QC) requirements for obtaining verification data of sufficient quantity and quality to satisfy the DQOs of the generic verification protocol. A test plan addendum will also be developed that describes the specific DRT. For pesticide spray DRT, the critical measurements include the droplet size distribution, the spray flux (low speed wind tunnels only), and deposition (field testing only). Other supplemental, non-critical measurements may also be conducted (e.g., application rate, material usage, dose, worker exposure). 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 Verification 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. The testing organization for this ESTE effort has not yet been identified. ------- Generic Verification Protocol for ETV DRT Version 0.0 April 2007 Page 3 Appendix A lists full citations for these documents. This protocol 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. A testing organization with a quality system in compliance with the EPA ETV and APCT Center QMPs and with the capability to carry out the methods and procedures contained in this plan will conduct the testing. The testing organization will verify the emissions reductions of drift reduction technologies. The testing organization will perform the testing, evaluate the data, and submit a report documenting the results. The APCT Center will use the data to prepare the verification reports and the verification statements. The various QA and management responsibilities are divided among the testing organization, APCT Center, and EPA key project personnel. A5: Project Definition and Background For the purpose of this document and associated testing projects, 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. Spray drift management is of interest to pesticide and other chemical manufacturers, application equipment manufacturers, pesticide applicators, government agencies, advocacy groups, and the public. Spray drift risks are correlated to deposition in EPA risk assessment. To reduce exposure, DRTs that can reduce drift downwind are beneficial; the results of the testing to be conducted under the ETV program are to be used to estimate downwind deposition. For example, the testing results from wind tunnel testing (droplet size distribution and/or spray flux) will be used as inputs to models that will estimate deposition downwind. (Any model results will be determined outside of this ETV protocol, the test/QA plan, and results.) This test approach to evaluate DRT is one more approach in addition to other understood methods for testing DRT. Industry, including pesticide applicators, and government researchers have over many years developed and employed a variety of pesticide application strategies and technologies to reduce spray drift. Examples include low drift spray nozzles and sprayers, drift control chemical adjuvants, barrier structures, and vegetation. Although these and other technologies have the potential to provide drift reduction, there is often uncertainty about their effectiveness or performance for this goal. Verification testing of DRTs provides objective, quality-assured data regarding the effectiveness of the tested technologies to reduce spray drift. Effective employment of these test results by EPA and pesticide and equipment manufacturers will enable pesticide applicators to make more informed and confident decisions for selecting and using DRTs. Use of these DRTs in the application of pesticides has the potential for significant benefits: reduced spray drift and the associated risks to humans and the environment; greater on-target deposition of pesticides applications; increased efficacy; and applications under a wider range of environmental conditions. Testing will be performed on application technologies with one or more of the following test methods: low speed wind tunnel testing, high speed wind tunnel testing, and field testing. Field testing is an acceptable method of testing all DRTs. Low speed would be the speed of the air in the wind tunnel crossing the spray nozzle for ground application, and high speed would be the ------- Generic Verification Protocol for ETV DRT Version 0.0 April 2007 Page 4 speed of the air in the wind tunnel crossing the nozzle for aerial application; for example, low speed would be less than 20 mph and high would be greater than 20 mph. For certain DRTs, wind tunnel testing may be an appropriate test method. The verification tests will gather information and data for evaluating the performance of the strategies and technologies as claimed by the vendors and the technologies' associated environmental impacts and resource requirements. The scope will, in most cases, cover four principal study questions: 1. What is the performance of the technology in terms of the manufacturer/vendor's statement of capabilities for reducing downwind deposition? Answering this question is critical to determining the performance of the technology and thus the measurements made to address this question are critical. The specific DQOs for these measurements are included in Element A7. 2. What are the test conditions (a range for equipment conditions and ambient conditions) over which the performance is measured (e.g., spray pressure, formulation type, release height, crop canopy, ambient temperature, wind speed, relative humidity)? The range of conditions that the technology is evaluated will be used to determine the conditions required for performance in the field. The DQOs for the measurement the test conditions are described in Element A7. 3. What are the associated environmental impacts, if any, of operating the technology within this range other than drift reduction (e.g., effects on application rate/material usage, dose, other sources of environmental exposure, worker exposure)? Evaluation of the associated environmental impacts is a supplemental non-critical product of this test plan and as a result available instrumentation may be used to make measurements for this purpose. No DQOs are defined for this question. 4. What are the resources associated with operating the technology within this range relative to standard pesticide application equipment (e.g., energy, waste disposal, and product usage, as well as sprayer handling - for example, some technologies may affect the safety of operation of aircraft or other sprayers)? Measurement of consumption of resources is a supplemental non-critical measurement of this test plan and as a result, available instrumentation may be used to make measurements for this purpose. No DQOs are defined for this question. This ETV protocol describes the overall procedures to be used. The test/QA plan for pesticide drift reduction technology will describe how test procedures will be specifically implemented for this testing program. Each test site or testing organization will need to develop a test/QA plan for its test facility. The plan will address application of pesticides to row and field crops (including bare ground) using aerial and ground spraying systems that spray swaths. (Other applications such as radial orchard and vineyard spraying may be addressed in the future.) Where the test procedures allow flexibility (e.g., "alternate methods ... may be used"), the specific implementation using this flexibility will be described by the testing organization. Where flexibility in test procedures is not stated, it is intended that the methods will be followed without deviation. Deviations from described protocols must be described by the testing organization in its test/QA plan and addenda. ------- Generic Verification Protocol for ETV DRT Version 0.0 April 2007 Page 5 A6: Project/Task Description A6.1 Description This ETV protocol describes the test and QA procedures that will 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. The test/QA plan will specifically describe the quality system required of the testing organization and the procedures applicable to meeting EPA quality requirements that are common to all ETV tests. Test/QA plans, developed for each test site, and test plan addenda, developed for each technology, will be reviewed and approved by EPA prior to testing. The verification tests will gather information and data for evaluating the performance of the DRT. Also, any adverse environmental impacts of operating the DRT will be evaluated. The specific operating conditions used during the testing will be documented as part of the verification process. Table 3 in Element B2, Table 4 in Element C2, and Table 5 in Element D2 of this protocol, present a summary of all measurements that will be made to evaluate the performance of the DRT and document the test conditions. A description of a specific technology, the test procedures to be used and test-specific details will be documented as a applicant-specific addendum to the test/QA plan that will be prepared and submitted for EPA review and approval prior to the start of testing. The applicant-specific addendum will provide additional information needed to conform to required Elements A5 (Problem Definition/Background) and A6 (Project/Task Description) of EPA QA/R-5. Categories of DRTs include: 1. Spray nozzles (e.g., atomizers with fewer fines); 2. Sprayer (passive delivery assistance) modifications (e.g., shields and shrouds, wingtip devices); 3. Spray (active) delivery assistance (e.g., air assisted spraying); 4. Spray property modifiers (e.g., formulation/tank mix ingredients that modify spray solution physical properties); 5. Landscape modifications (e.g., artificial or natural hedges and shelterbelts). A6.2 Test Facility Description A description of the test facility will be included in the test/QA plan for each test site. A6.2.1 Test Site Description Three potential testing sites or approaches are covered in this protocol: low speed wind tunnel, high speed wind tunnel, and field testing. The low speed wind tunnel and the high speed wind tunnel test results will be used by EPA in conjunction with modeling to determine downwind ------- Generic Verification Protocol for ETV DRT April 2007 Version 0.0 Page 6 drift deposition reduction. Low speed wind tunnel testing is appropriate for certain types of DRTs intended for use on or with some ground boom sprayers while high speed wind tunnel testing is for certain DRTs, such as nozzles and devices intended to reduce air shear, on aerial application equipment. Field testing is acceptable for testing all types of DRTs. In Table 1, the DRT categories are matched to the potential testing approaches and a map to the testing procedures laid out in this document is provided. Table 1. DRT versus Testing Approach Test Method Low speed wind tunnel1 High speed wind tunnel2 Field testing3 Type of Drift Reduction Technology Spray Nozzle Acceptable Acceptable Acceptable Spray Material Property Modifiers Acceptable Acceptable Acceptable Sprayer Modification Questionable4 and Supplemental5 Not Acceptable Acceptable Spray Delivery Assistance Not Acceptable Not Acceptable Acceptable Landscape Modification Supplemental5 Not Acceptable Acceptable 1 For DRTs intended for use on or with ground boom spray equipment 2 For DRTs intended for use on or with aerial spray equipment 3 For DRTs intended for use with either ground boom or aerial spray equipment 4 It is advisable to confirm with the EPA ETV project manager that the test methods will be adequate for verification of these types of DRTs. 5 Low speed wind tunnel testing may provide information that can reduce the extent of field testing required for validation, or supplement field data; however, field testing is also required. Low speed wind tunnel testing A wind tunnel with the following characteristics will be used: 1. A wind tunnel with working section dimensions at least 1.75 meter (m) wide x 1.75 m high x 7 m long shall be used for measurement of the spray distribution vertically ("airborne drift potential") and horizontally ("deposition drift potential") and droplet size distribution for a spray. 2. An example of a suitable wind tunnel setup is shown on Figure 1. 3. The airflow characteristics of the wind tunnel shall be known and documented. The air speed at different horizontal and vertical locations in the wind tunnel must be documented in order to identify the distance from the tunnel's surface that edge effects occur and document the space where air flows uniformly in the working section. The wind tunnel working section used for sampling shall have less than 8 percent turbulence and local variability of air velocity below 5 percent. ------- Generic Verification Protocol for ETV DRT April 2007 Version 0.0 Page 7 ryiw.TĄ!*vn Figure 1. Example of a low speed wind tunnel (by permission of Silsoe Spray Application Unit - part of The Arable Group). High speed wind tunnel testing For high speed wind tunnel testing, a wind tunnel of the following characteristics will be used: 1. A wind tunnel with working section dimensions at least 0.8m wide x 0.8 m high x 2 m long shall be used for measurement of droplet size distribution for a spray. 2. An example of a suitable wind tunnel setup is shown on Figure 2. 3. The airflow characteristics of the wind tunnel shall be known and documented. The air speed at different horizontal and vertical locations in the wind tunnel must be documented in order to identify the distance from the tunnel's surface that edge effects occur and document the space where air flows uniformly in the working section. The wind tunnel working section used for sampling shall have less than 8 percent turbulence and local variability of air velocity below 5 percent. ------- Generic Verification Protocol for ETV DRT April 2007 Version 0.0 PageS Pressure and Flow Control Systems 1 ft X 1ft wind tunnel outlet Droplet Sizing Equipment PMS, Sympatec, or LaVision Airspeeds of 40-150 mph can be produced Spray nozzle can be held static or traverse with a configuration not shown. 3D Traverse System Figure 2. Example of a high speed wind tunnel. Field testing For field testing, the test site with the following characteristics will be used: For field testing, the designated trial/spray site should be an exposed area with no obstructions that could influence the air flow in the areas of application or measurement. There should be a bare ground (or stubble less than 7.5 cm high) treatment area and a similarly bare downwind area for sampling stations. The measurement area should be downwind of the treatment area. The length of the spray track should be at least twice that of the largest downwind sampling distance and should be symmetrical about the axis of the sampling array. All downwind distances should be measured from the downwind edge of the directly sprayed treatment area. The requirements for the field test site are consistent with requirements from United Kingdom's Local Environmental Risk Assessments for Pesticides (LERAP), Germany's Biologische Bundesanstalt fur Land- und Forstwirtschaft (Federal Biological Research Center for Agriculture and Forestry [BBA]), the International Standards Organization (ISO), and the American Society of Agricultural and Biological Engineers (ASABE) (formerly known as the American Society of Agricultural Engineers [ASAE]). ------- Generic Verification Protocol for ETV DRT April 2007 Version 0.0 Page 9 A 6.2.2 Application/Process Equipment Description The description of the application and process equipment including photographs will be included in the applicant-specific addendum. A6.2.3 Control Technology (i.e., DRT) Description The technology to be verified must be described fully and concisely. The description, provided by the technology manufacturer/vendor, must include: technology name, model number, the DRT principle, key specifications, manufacturer's name and address, serial number or other unique identification, warning and caution statements, capacity or output rate, and other information necessary to describe the specific DRT. The performance guarantee coupled with operating conditions and instructions will be provided. Examples of an ETV verification statement are presented on the ETV Website [http://www.epa.gov/etv/]. If combinations of independent technologies are being submitted, the description of the combined technology should completely identify and describe those technologies being combined. A6.3 Schedule Figure 3 shows an example schedule for completion of a first draft verification report and statement. The test-specific schedule is expected to vary from technology to technology based on the scheduling needs of the applicant and the testing organization. TASK APCT Center develops applicant-specific test/QA plan < addendum Applicant accepts addendum, signs Terms & Conditions EPA approves applicant-specific test/QA plan addendum Testing organization receives test items from applicant Testing organization conducts testing Testing organization delivers test report to APCT Center APCT Center completes first draft verification report and statement MONTH 1 > • < 2 > < 3 > ^m 4 ^m 5 < 6 > 4 Figure 3. Example of schedule. A7: Quality Objectives and Criteria The DQOs of this testing focus on the direct or indirect measurements of spray drift deposition using field testing or wind tunnel testing. For field tests, measurements of spray drift on horizontal collectors are collected to directly measure spray drift deposition in the area downwind. For wind tunnel testing, the testing organization will measure droplet size and spray volume data (and will later use these generated data with spray drift models such as the dispersion models, AGDISP or WTDISP, capable of translating the droplet size and spray volume measurements made using this protocol to downwind deposition). Test requirements for low speed wind tunnels, high speed wind tunnels, and field testing are found in Groups B, C, and D, respectively. ------- Generic Verification Protocol for ETV DRT Version 0.0 April 2007 Page 10 For wind tunnel testing, the 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 (jim) at which 0.1 fraction of the spray volume is contained in smaller droplets (Dvo.i) and droplet diameter (|im) at which 0.9 fraction of the spray volume is contained in smaller droplets (Dvo.9) are used as a measure of data quality. Variation of less than ±3 percent is considered acceptable. The rationale for the number of test runs will be included in the site-specific test/QA plans and the applicant-specific addenda, which will conform to required Element Bl of EPA QA/R-5. In general, the number of test runs would include: (1) a minimum of three test runs, (2) additional test runs indicated to meet certain statistical criteria, and (3) additional test runs desired by the applicant vendor or manufacturer. The number of test runs (or sample size) necessary depends on the variance of the data and the size of the difference that is to be detected. For the validation testing of this protocol, three test runs will be conducted. The data results from the validation testing of the protocol will be used to decide what additional test runs will be necessary to meet statistical criteria. In field testing, for example, it has been discussed that candidate test systems will be assigned a drift reduction bin of 25 to 50 percent, 50 to 75 percent, 75 to 90 percent, and greater than 90 percent. If the candidate test system is anticipated to achieve a drift reduction in the middle of a drift reduction bin, then it is likely that three test runs are necessary; however, for those candidate test systems with drift reduction near the edge of a drift reduction bin, it is likely that three test runs may be too few and additional test runs may be necessary to demonstrate the drift reduction bin with sufficient confidence. The DQIG for individual measurements will conform to those specified in relevant sections of the test protocols and referenced procedures, as shown in Table 2. The DQOs for this testing are the Table 2 DQIG. Test-specific DQIG will be documented in the site-specific test/QA plans and its applicant-specific addenda. ------- Generic Verification Protocol for ETV DRT April 2007 Version 0.0 Page 11 Table 2. Data Quality Indicator Goals (DQIGs) Parameter Standard Operating Procedure (if applicable) Acceptance Criteria Section 1. Droplet Size Measurement at the atomizer for LSWT and HSWT and Droplet Size Measurement at 2 m for LSWT Spray material flow rate Spray pressure (nozzle operating pressure) Dynamic surface tension of spray liquid (not for use with drift retardant adjuvants) Spray volume in largest and smallest droplet size class bands in laser diffraction measurements Number of size class bands for reported data Spray measurement chamber or wind tunnel cross-section diameter Distance of farthest edge of spray from collecting lens (Malvern instruments) Standard deviation around mean Dv0 5 for three replicate droplet size measurements 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/ end trigger using traverse with laser diffraction systems) Spray material temperature Ambient air temperature ASAE S572 ASAE S572 ASHRAE Standard 41.1 ASHRAE Standard 41.1 ±0.04 L/min of values specified in the ASAE standard for reference and evaluation nozzles. ±3.4 kPa of values specified in the ASAE standard for reference and evaluation nozzles. 40 ±4 dynes/cm at surface lifetime age of 10 to 20 ms <1% of total volume in each case (i.e., < 2 percent 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 Cross section at least three diameters larger than plume of nozzle (at measurement location) <1 lens focal length to avoid vignetting sampling errors <7% for measurements with the same nozzle <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% Measured within 0. 1°C Measured within 0. 1°C ------- Generic Verification Protocol for ETV DRT April 2007 Version 0.0 Page 12 Parameter Standard Operating Procedure (if applicable) Acceptance Criteria Relative spray material and air temperatures Spray material temperature must be within 2°C of the air temperature to avoid atomization anomalies Air speed For low speed wind tunnels, between 2 m/s and 10 m/s, and measured to an accuracy within 0.1 m/s, close to nozzle location (with nozzle absent). For high speed wind tunnels, 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) Sample size per replicate measurement >10,000 droplets for particle counting instruments or > 5 s for laser diffraction instruments Diode suppression (laser diffraction systems) 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.) Replicate measurements Measurements to be carried out with an atomizer or nozzle with a maximum deviation of output rate of ±2.5% from the value specified by the manufacturer at the nominal rated recommended spray operating conditions. A randomly selected representative nozzle must be used. 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) Vary by less than ±3% Section 2. Drift Potential Measurement in Wind Tunnel (Spray Flux and Deposition in LSWT) Ambient air temperature (dry bulb air temperature) ASHRAE Standard 41.1 Measured to an accuracy within 0.1°C Wet bulb/dew point temperature or Percent relative humidity Thermohygrometer equivalent to ASTM E337-84(1996)el; or ASHRAE Standard 41.1 Measured to an accuracy within 0.1°C or Within 5% ------- Generic Verification Protocol for ETV DRT April 2007 Version 0.0 Page 13 Parameter Air speed Sampling rate for air speed Wind tunnel working section width Wind tunnel turbulence Consistency of air speed in wind tunnel working section Spray nozzle and sampling height measurement Spray material flow rate Spray pressure (nozzle operating pressure) Spray material temperature Ambient air temperature Relative spray material and air temperatures Percent relative humidity (low speed wind tunnel) Solvent volume for extraction of tracer, if using collectors Spray duration for replicate measurements Spray duration for similar nozzle types Standard Operating Procedure (if applicable) ASAES561.1 ISO 22856 ISO 22856 ISO 22856 ASAE S572 ASAE S572 ISO 22856 ISO 22856 ISO 22856 Acceptance Criteria Between 2 m/s and 10 m/s, and measured to an accuracy within 0. 1 m/s, close to nozzle location (with nozzle absent) Sampling should occur over a measuring period of 10 s Minimum to avoid boundary layer and blockage effects <8% <5% Within 5 mm (without airflow) ±0.04 L/min of values specified in the ASAE standard for reference and evaluation nozzles. ±3.4 kPa of values specified in the ASAE standard for reference and evaluation nozzles. Measured within 0. 1°C Measured within 0. 1°C Spray material temperature must be within 2°C of the air temperature to avoid atomization anomalies 80% ±5% Within 5% of volume required for analytical recovery and assessments (i.e., all samples should be washed with the same volume of solvent within 5% of the target volume) Minimum spray time of 5 s for each replicate measurement should be used, to allow stability of spray formation and to avoid under- or over-dosing of samplers or collectors. (Appropriate spray duration should be verified prior to measurement). Replicate measurements for a nozzle type should be within ±5% of mean time duration for a given setup. Similar nozzle types from different vendors/manufacturers should be tested for a similar time duration, within ±5%. ------- Generic Verification Protocol for ETV DRT April 2007 Version 0.0 Page 14 Parameter For spray flux sampling using droplet size analyzers, also see Droplet Size Measurement section criteria in this table Standard Operating Procedure (if applicable) Acceptance Criteria Instrument criteria as listed in droplet size measurement section Sections. Field Study Dry bulb air temperature Wet bulb/dew point temperature or Percent relative humidity Horizontal wind speed Horizontal wind direction Nozzle flow rate Horizontal wind angle relative to sample line Frequency of meteorological measurement sampling Dynamic surface tension of spray liquid Surface vegetation height Sample line and collection station locations Sampling media area for individual collectors Collector orientation for flat card/ plate/ cylindrical collectors Diameter of cylindrical collectors (if used) Number of samples at each sampling location ISO 22866 ASAES561.1 ISO 22866 ASAES561.1 ASAES561.1 ASAES561.1 ASAES561.1 ASAES561.1 ASAES561.1 ASAES561.1 Between 5 and 35°C, measured to an accuracy within 0.5°C Measured to an accuracy within 0.5°C or Within 5% At least 1 m/s for all applications, measured at an accuracy within 0.2 m/s at nozzle height 90° + 30° to the spray track or the downwind edge of the sprayed area during the spray application. > 70% of results shall be > 45° from the perpendicular of spray track when sampling at a frequency of 1.0 Hz within 2° Repeat measurements for individual nozzles within ±2. 5% Mean angle between the sample line and the horizontal wind direction should not exceed 30° > 1.0 Hz sampling rate 40 ±4 dynes/cm at surface lifetime age of 10 to 20 ms < 7.5 cm absolute height for all vegetation surface heights in drift sampling areas ±2.5% of required location distances (at a minimum 2 m downwind of nozzle) > 1000 cm2 for deposition cards Horizontal ±15° relative to spirit level instrument or for vertical towers (optional additional collector), vertical ±15° 2 mm ±5% Determined from tests for the specific setup to produce confidence interval of ±10% ------- Generic Verification Protocol for ETV DRT April 2007 Version 0.0 Page 15 Parameter Boom length (swath width) and boom height above ground Application rate of tank mix in treated area Forward speed of sprayer Solvent volume for extraction of tracer if using collectors Stability of tracer under conditions of study (light intensity, relative humidity, temperature, sampling media, storage conditions/ duration, etc.) measured as the amount recovered relative to the amount mixed for control samples Standard Operating Procedure (if applicable) Acceptance Criteria Measured with accuracy within 1.0 cm when stationary Within 2.5% of intended application rate Within 10% of target speed throughout entire application period. For aerial, at least 140 mph, and measured to an accuracy within 5 mph. 5% of volume required for analytical recovery and assessments (i.e., all samples should be washed with the same volume of solvent within 5% of the target volume) Tracer must exhibit adequate photostability (documented or published) allowing within 10% of the initial mixture detection values for all samples (note: samples should be collected in minimum possible time after exposure to drift sampling, stored in dark containers at <4°C and analyzed as soon as possible after collection) 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. ASAE S561.1 Procedure for Measuring Drift Deposits from Ground, Orchard and Aerial Sprayers. American Society of Agricultural and Biological Engineers, St. Joseph, MI. ASAE S572 (1999) (sometimes referred to as ASABE S572) Spray Nozzle Classification by Droplet Spectra. Standard No. S572, American Society of Agricultural and Biological Engineers, St. Joseph, MI. ISO Standard 22866 Field Measurement of Spray Drift. International Standards Organization. ISO Draft Standard 22856: Equipment for Crop Protection - Laboratory Drift Methods Measurements. International Standards Organization. A8: Special Training/Certifications The testing organization may include any registrations, accreditations, qualifications, independently-assessed quality systems of the testing organization in the test site-specific test/QA plan. ------- Generic Verification Protocol for ETV DRT Version 0.0 April 2007 Page 16 A9: Documentation and Records Test-specific documentation and records will be processed as specified in the testing organization's SOPs, protocols, etc.. See Element BIO for details of test data acquisition and management. In accordance with Part A, Sections 5.1 and 5.3 of EPA's QMP, the testing organization will retain all test-specific documentation and records for 7 years after the final payment of the agreement between the testing organization and the APCT Center. RTI will retain all verification reports and statements for 7 years after final payment of the agreement between RTI and EPA. ------- Generic Verification Protocol for ETV DRT Version 0.0 April 2007 Page 17 GROUP B: DATA GENERATION AND ACQUISITION FOR LOW SPEED WIND TUNNELS Bl: Sampling Process Design (Experimental Design) The measure of performance for the DRT for low speed wind tunnels will be derived from airborne droplet size distribution measurements and airborne liquid volume measurements. These values will be used by EPA to model deposition from 0 to 200 ft downwind. The basic experimental design will be to measure the droplet size spectrum under targeted test conditions with the DRT operating at specified spray pressure, air speed, boom height, and the "ambient" conditions. The measurement of droplet size spectrum and flux volume at 2 m distance downwind of the spray nozzle are the critical measurements for this verification test. Wind tunnel conditions and application conditions are important measurements for establishing the bounds of the verification test design. Deposition measurements in the wind tunnel are important for comparison to model estimates and evaluating model mass accountancy. Deposition measurements made in the wind tunnel and compared to near-field model predictions are an indicator of model accuracy. In order to meet the DQOs, three replications will be used for each set of applications conditions intended for actual use in the field. For instance, three replications will be conducted for each combination of release height and nozzle pressure. 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 sections 1 and 2 of Table 2 must be met. For example, the measured volume median diameter (VMD), Dv0.i and Dv0.9 (the droplet diameter bounding the upper and lower 10 percent fractions of the spray) should vary by less than ±3 percent. The standard deviation around mean Dvo.s should be less than 7 percent for three replicate droplet size measurements for the same nozzle. Measurements of candidate test systems are compared to measurements from a reference spray system based on the ASAE S572 standard for droplet size. Before drift potential measurements are conducted, the candidate test system is categorized into droplet size category for very fine, fine, medium, coarse, very coarse, and extremely coarse using ASAE S572. The reference system should use the ASAE S572 reference nozzle associated with the lower (coarser) boundary of the droplet size category in which the candidate test system falls. During drift potential measurements, the height of the reference nozzle (and nozzle spacing, if multiple nozzles are used) should be appropriate for the spray angle produced by the reference nozzle and does not need to be identical to the candidate test system. The reference nozzle should be directed straight down. The vendor may select the spray angle for the candidate test system nozzle. B2: Sampling Methods for Measurement of Droplet Size, Deposit, and Test Conditions Table 3 lists all the measurements required for this verification test. Measurements are categorized in the table as performance factors and test conditions. Performance factors are ------- Generic Verification Protocol for ETV DRT April 2007 Version 0.0 Page 18 critical to verifying the performance of the DRT. Test conditions are important to understand the conditions of performance. Further detail is provided in Elements B2.1 through B2.4 and B4. Table 3. Summary of Spray and Test Condition Measurements for Low Speed Wind Tunnels Factors to Be Verified Parameter to be Measured Sampling and Measurement Method Comments Performance Factors Spray flux 2 m downwind from the atomizer Droplet size 2 m downwind from the atomizer Tracer flux (|jL or mg/cm2/min) at the 6 (or more) measurement heights used in the downwind droplet size distribution measurement. At least six measurements of droplet size distribution corresponding to six or more heights. Multiple horizontal monofilament lines (or non- intrusive sampling methods appropriate for the spray material may be used). Non-intrusive sampling methods appropriate for the spray material such as laser diffraction, phase-Doppler, laser imaging instruments If a method other than monofilament line is used, less than 2 percent total of the spray volume should be contained in the uppermost or lowermost size classes. Less than 2 percent total of the spray volume should be contained in the uppermost or lowermost size classes. Test Conditions Documentation Deposition Droplet size at the atomizer Spray pressure Spray materials temperature Spray nozzle height/ or boom height Deposition within 7 m downwind of the atomizer Droplet size distribution produced by the atomizer Pressure of spray mix at the atomizer Temperature of the spray mixture Height of the atomizer above the floor of the wind tunnel Sampled using smooth horizontal surfaces such as filter paper. Measurement of extracted tracer using spectrofluorometer or other appropriate method. Non-intrusive sampling methods appropriate for the spray material such as laser diffraction, phase-Doppler, laser imaging instruments. See ASAE S572, section 3. Calibrated thermometers accurate within 0. 1°C Deposition should be described in terms of mass of tracer per unit area. Less than 2 percent total of the spray volume should be contained in the uppermost or lowermost size classes. Temperature of the ambient air and spray mixture should be within 2°C ------- Generic Verification Protocol for ETV DRT April 2007 Version 0.0 Page 19 Factors to Be Verified Wind tunnel conditions Parameter to be Measured Air speed Ambient air temperature Air humidity Sampling and Measurement Method 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 1°C Thermohygrometer equivalent to ASTM E337-84(1996)el; ASHRAEStd41.1; or other similar approach Comments 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 simultaneously. B2.1 Sampling Locations Spray shall be sampled using one of several laser measurement systems: laser diffraction, phase- Doppler (excluding multi-phase droplets, e.g., air inclusion or emulsions), or laser imaging. For droplet size distribution for determining the appropriate reference test system nozzle, the continuous traverse method is usually the optimal technique for sampling the spray plume, and data should be expressed as mass-balanced average droplet size data across the traverse. Multiple chordal measurements or (for phase-Doppler measurement systems), two- or three-dimensional mapping of droplet size and velocity throughout the spray plume, may also be used. Sampling should occur across a representative cross-sectional sample of the spray. Sampling should occur 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 spray is not contacting the wind tunnel's surfaces. The sampling distance may need to be adjusted for different atomizers, flow rates, and test substances, but in general, the optimal sampling distance is between 20 to 50 cm from a nozzle. For droplet size distribution and spray flux for drift potential, sampling will occur at the same locations for both, i.e., at 2 m downwind of the atomizer and at a minimum of six positions (or heights). Measurement of air temperature and humidity should 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 1. Droplet size distribution sampling - Droplet size at the atomizer: Near the nozzles, see Element B2.4, Measurement of Droplet Size Spectrum Near the Nozzle (Determination of appropriate reference test system). ------- Generic Verification Protocol for ETV DRT Version 0.0 April 2007 Page 20 - Spray flux 2 m downwind from the atomizer and Droplet size 2 m downwind from the atomizer: For all measurements the downwind sampling distance will be 2 m from the nozzle orifice. The spray droplet size distribution and volume per unit time (i.e., spray flux) will be sampled at a minimum of six heights evenly distributed from the O.lm above the wind tunnel floor to a height equal to the nozzle height. The flux at the highest measurement height must be less than 1 percent of the cumulative flux measurements from lower heights. If amount of spray measured at the highest height exceeds 1 percent of the total volume measured at the lower heights, additional measurements at increments consistent with the lower measurement heights must be made. Alternatively, a continuous traverse spanning the specified height range may be used if the data droplet size distribution and spray volume data for specific heights can be recovered and it can be demonstrated that flux above the measured range accounts for less than 1 percent of the cumulative flux below. See Element B2.3, Wind Tunnel Measurement of Spray Drift Potential. 2. Horizontal samplers - Horizontal sampler location will be defined as the vertical distance below the atomizer's orifice and horizontal distance downwind of the atomizer. - Horizontal samplers will be placed directly downwind from atomizers. - Horizontal samplers will be placed at a height of 0.1 m above the wind tunnel floor to avoid boundary layer effects. - Horizontal samplers will be placed at 2, 3, 4, 5 and 6 m downwind of the atomizer. 3. Wind tunnel conditions - The following conditions shall be measured at the same height as the nozzle, upwind of the nozzle in the wind tunnel working section at the time of spray release: ambient air temperature, air speed, relative humidity. 4. Sprayer conditions - Spray pressure shall be measured at the nozzle tip using a capillary connected to a pressure gauge (as is consistent with ASAE S572, section 3). The sampling locations for these parameters are shown in Figure 4. ------- Generic Verification Protocol for ETV DRT April 2007 Version 0.0 Page 21 D nozzle -0- D Windspeed .0. Measurement heights for droplet size distribution and spray flux (monofilament lines). | | Horizontal samples •e- 2m 3m 4m 5m 6m Figure 4. Low speed wind tunnel sampling locations. B2.3 Wind Tunnel Measurement of Spray Drift Potential All sampling will follow the requirements of the specific test method being used unless otherwise stated in this document or approved by EPA ETV project manager prior to the verification test. Laser-based measurement devices are used to measure droplet size distribution at 2 m and monofilament line is used to measure flux in the wind tunnel at 2 m at various heights. Horizontal sampling (for example, with filter paper) is used to measure horizontal deposition within the wind tunnel (see Element B2.5). 1. The spraying system shall be mounted to minimize effects on airflow. 2. The orientation of the nozzle (predominant spray direction or axis of rotation) that the fan sprays discharge relative to the air flow direction must be measured with a protractor and recorded. 3. Droplet size shall be measured using one of several laser or optical measurement systems: laser diffraction, phase-Doppler (excluding multi-phase droplets, e.g., air inclusion or emulsion) or laser imaging. The instruments and apparatus used in the test shall be listed. Names, model numbers, serial numbers, scale ranges, software version number, and calibration verification shall be recorded. 4. The test spray nozzle(s) shall be mounted at a defined height not less than of 600 mm above the wind tunnel floor and not greater than a height 100 mm below the wind tunnel ceiling. Nozzles must be positioned in a place free from edge effects. 5. A representative cross-section average sample must be obtained, using a mass- weighted traverse or multiple chordal measurements of the full spray (or half spray for axi-symmetric spray plumes). ------- Generic Verification Protocol for ETV DRT Version 0.0 April 2007 Page 22 6. For each height, the sampling system must be configured to measure the entire dynamic size range of the instrument with less than 2 percent total of the spray volume contained in the uppermost or lowermost size classes. 7. The wind tunnel floor shall be covered with an artificial turf surface to minimize droplet bounce and mimic stubble vegetation for field conditions. 8. For monofilament spray flux measurements, approximately 2 mm in diameter monofilament sampling lines should be used, extended horizontally across the wind tunnel, and cause minimal disruption to air flow in the wind tunnel. 9. For testing atomizers without using adjuvants, water containing surfactant may be used. Acceptable surfactants and surfactant concentrations are those that will provide a Newtonian tank mix with dynamic surface tension of 40 dyne/cm at surface lifetime age of 10 to 20 ms. - Use of other surfactants or concentrations should be approved by the EPA ETV project manager prior to testing. 10. When adjuvants are included as the DRT in the test spray material, emulsifiable concentrates (EC) formulations (blank or containing pesticide) must be included to make the results of the test extend to EC formulation. Water with surfactant (as described in Item 9 above) may be used if the results are only intended for aqueous solutions of 15 gal/acre or higher. An example of a commonly-used adjuvant in the U.S. is Triton X-77 in water at 0.25 percent v/v. 11. 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 of machining burrs or plastic mold residue. 12. Spray material flow rate shall be measured at the operating pressure for the tests. The liquid flow rate measurement may include techniques using liquid collected for a known duration, using Coriolis mass flow sensors, calibrated flow turbine, oval displacement meter, weighing system for the spray mix tank, or other method. Nozzle output should remain constant with a maximum deviation of ±2.5 percent. These liquid flow rate measurements are consistent with ISO 5682 part 1. 13. The wind tunnel shall be operated during sampling to provide a wind speed between 2 m/s and 10 m/s at the nozzle height. 14. To minimize evaporation effects, the relative humidity in the working section at the time of measurements shall be at least 80 percent ±5 percent. 15. The wind tunnel measurements of spray drift potential should comply with ISO Draft Standard 22856. 16. The type of nozzle being tested must be documented as follows: ------- Generic Verification Protocol for ETV DRT Version 0.0 April 2007 Page 23 - 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, 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 (Determination of appropriate reference test system) The droplet size of the test system near the nozzle is used to determine the appropriate reference test system. The droplet size measurement and classification shall be consistent with ASAE S572 in addition to the criteria below. The candidate test system is categorized into droplet size category for very fine, fine, medium, coarse, very coarse, and extremely coarse. 1. Droplet size spectra for spray drift tests shall be made under the same conditions (e.g., spray material, spray pressure, nozzle settings) and following the same procedures outlined in Element B2.3 except the measurements do not need to be made within a wind tunnel. 2. Droplet size may be measured using one of several laser measurement systems: laser diffraction, phase-Doppler (excluding multi-phase droplets, e.g., air inclusion or emulsion) or laser imaging. The instruments and apparatus used in the test shall be listed. Names, model numbers, serial numbers, scale ranges, software version number, and calibration verification shall be recorded. 3. A representative cross-section average sample must be obtained, using a mass- weighted traverse or multiple chordal measurements of the full spray (or half spray for axi-symmetric spray plumes). 4. The sampling distance from the nozzle must be sufficient that the spray has atomized into droplets, for example through completion of breakup of sheets or ligaments of liquid following discharge from the nozzle. 5. The sampling system must be configured to measure the entire dynamic size range of the instrument with less than 2 percent total of the spray volume contained in the uppermost and lowermost size classes. 6. If a number-density weighted ("spatial") sampling system is used, the setup should minimize the development of a size-velocity profile within the spray (e.g., by using a concurrent airflow if spray discharge is in the horizontal plane) to avoid data bias toward slower-moving (usually smaller) droplets. ------- Generic Verification Protocol for ETV DRT Version 0.0 April 2007 Page 24 7. The droplet size measurements should include assessment of the droplet size category of the candidate test system and reference system according to ASAE S572. B2.5 Measurement of Deposition within Wind Tunnel Horizontal samplers (e.g., filter papers, strings, monofilament line) of known collection efficiency characteristics should be placed in the wind tunnel at the distances specified in Element B2.2. A representative photograph of a sampler placed in the wind tunnel should be provided. B2.6 Wind Tunnel and Spray System Operation Data Collection The following conditions shall be measured at the same height as the nozzle, upwind of the nozzle in the wind tunnel working section at the time of spray release: ambient air temperature, air speed, and relative humidity. Spray pressure shall be measured at the nozzle tip using a capillary connected to a pressure gauge, as is consistent with ASAE S572, section 3. Spray material temperature shall be measured and shall be within ±2°C of the ambient air temperature. B3: Sample Handling and Custody Requirements Procedures consistent with ISO 22856-1, Annex A should be followed. The samples collected during the test program will consist of horizontal samplers (filter paper) and monofilament line, if used. Analysis of these samples will be conducted using spectrofluorometers, as described in Element B4. To maintain sample integrity, the following procedure will be used. Each horizontal sampler and monofilament line will, prior to use, be stamped with a unique identification number or other numbering system to identify testing, test run, and position. A file folder or envelope will also be stamped with the identification number and the sampler will be placed in the corresponding folder. The horizontal sampler filters and monofilament line containing tracer are placed in individual protective containers and then into numbered folders or envelopes. For transport, groups of samplers are sealed in heavy-duty plastic bags and stored in a heavy corrugated cardboard or plastic filing box equipped with a tight-fitting lid. All exposed and unexposed samplers are always kept separate to avoid any cross-contamination. The date and time of sample collection and analysis must be recorded. Sample holding conditions (e.g., temperature, containers, light) must be noted for the period between sample collection and analysis. If data collection and analysis is to be done on-site and no samples will be transported to a laboratory, sample custody requirements are not a required part of this verification test program. B4: Analytical Methods Measurement of deposited material will occur by extracting tracer from the horizontal samplers and monofilament lines followed by measurement of the amount of tracer in the extract. Tracer measurements should be expressed as the amount of material per unit area. Instruments used to ------- Generic Verification Protocol for ETV DRT Version 0.0 April 2007 Page 25 measure tracer (e.g., spectrofluorometers) should be of adequate sensitivity to measure deposition at the most distant sampler. B5: Quality Control Air speed should vary by less than 5 percent within a trial and less than 5 percent across replicates. Horizontal samplers and monofilament lines should be spiked with tracer at levels below that observed at the largest sampling distance in order to demonstrate adequate (>93 percent) recovery at the lowest measured deposition levels. Linearity of deposition relative to measurement instrumentation response should be demonstrated in the deposition range measured. B6: Instrument/Equipment Testing, Inspection, and Maintenance The site-specific test/QA plan resulting from this protocol needs to reference the testing organization's SOP for testing, inspection, and maintenance of instruments and equipment. B7: Instrument/Equipment Calibration and Frequency Calibration verification of some laser diffraction particle size analyzers can be achieved using ASTM Standard Test Method E 1458 "Test Method for Calibration Verification of Laser Diffraction Particle Sizing Instruments using Photomask Reticles." Alternative techniques include reference particles and sprays of known size distribution. Phase-Doppler instruments are optically calibrated during production - this is a lifetime calibration. Electronic phase calibration is normally done for each set of instrument settings, particularly photo multiplier transistor (PMT) voltage, sampling rate (pass band), and laser power level. This is done using a built-in calibration diode that generates a Doppler burst-like signal. Calibration values may also be obtained for various PMT voltages, for example, and recorded for later input during testing. 2° The accuracy depends on instrument settings, mainly through the signal to noise ratio (SNR). Typical values for experienced users can be expected to be within ±1 percent of the reading + phase. The resolution in phase is 1/4096, or 0.0878906°. The repeatability also depends on instrument settings, and with experience an operator may be expected to achieve typical values of ±2° phases. Single particle counting/imaging systems should measure at least 10,000 droplets per sample for statistical validity. Calibration can be achieved using reference materials of known size and/or following instrument manufacturer instructions such as lens focal length/size factor relationships. B8: Inspection/Acceptance of Supplies and Consumables The primary supplies and consumables for this exercise consist of the horizontal samplers, monofilament lines, and tracer materials. Prior to labeling, each sampler is visually inspected and ------- Generic Verification Protocol for ETV DRT Version 0.0 April 2007 Page 26 is discarded for use if any damage is found. The tracer selected should allow for adequate sensitivity to measure deposition at all test distances. The tracer should be stable and nonvolatile in the test frame for testing and analysis. Background measurement samples from the testing site should demonstrate negligible levels of tracer or other interfering compounds. Water used in spray tanks should have a hardness of less than 300 ppm. B9: Non-Direct Measurements If applicable, data that are not gathered directly by the testing organization may be used, however, the testing organization must describe these measurements in the test/QA plan or the applicant-specific addendum. BIO: Data Management Results will be calculated as droplet size distribution and flux [i.e., volume or mass per unit area per unit time] at 2 m downwind from the nozzle at six heights and horizontal deposition at 2, 3, 4, 5, and 6 m for each set of sampling conditions (e.g., air speed, nozzle pressure, nozzle orientation). Droplet size distributions will be described by 32 categories of droplet diameter. Higher resolution distributions (more categories of droplet diameter) may be presented in addition to the 32-category description. Requirements for the verification test report, verification statement, and data storage and retrieval are provided in Group E, Data Reporting. B10.1 Data Flow Data measurement and collection activities are shown in Figure 5. This flow chart includes all data activities from the initial pretest QA steps to the passing of the data to EPA. ------- Generic Verification Protocol for ETV DRT April 2007 Version 0.0 Page 27 1 1 1 Oversight Testing Organization Technical Leader: Test Oversight and Data Production Testing Organization Quality Manager: Quality System and Data Integrity 1 Data Flow DRT Information from Manufacturer/Vendor Instrument Data and Sampling Data QC Data Assemble Data Calculations & Data Analysis QA Review Report Data Flow • Figure 5. ETV data management system. B10.2 Data Reduction Data from each measurement for droplet size from the verification test will be reported as the incremental and cumulative volumes of 32 appropriately spaced and described bins of droplet diameter (microns). The Dv0.i, Dv0.s, Dv0.9, and relative span will also be presented. An example of a presentation of the output data is shown in Table B-l in Appendix B. Raw data of droplet sizing instrument output should be provided as an appendix. Data from measurements for flux (i.e., volume/unit area/unit time) from the verification test will be reported as "mL/cm2/min" and labeled with the height at which the flux measurement was taken. ------- Generic Verification Protocol for ETV DRT Version 0.0 April 2007 Page 28 B10.3 Analysis of Verification Data Measurements should be presented separately (raw data) and as an average across repetitions for the following types of measurements. 1. Downwind measurements: - Flux at each height - Volume per droplet size category (i.e., each of the 32 droplet size categories) at each height - Deposition on horizontal samplers at each downwind distance 2. Droplet size at the nozzle: Volume per droplet size category and reference spray type. ------- Generic Verification Protocol for ETV DRT Version 0.0 April 2007 Page 29 GROUP C: DATA GENERATION AND ACQUISITION FOR HIGH SPEED WIND TUNNEL TESTS Cl: Sample Process Design (Experimental Design) The measure of performance for the DRT for high speed wind tunnels will be derived from droplet size distribution measurements. These values will be used by EPA to model deposition from 0 to 200 ft downwind. The basic experimental design will be to measure the droplet size spectrum under targeted test conditions with the DRT operating at specified spray pressure, air speed, and the "ambient" conditions. Droplet size spectrum is the critical measurement for this verification test. Wind tunnel conditions and application conditions are important measurements for establishing the bounds of the verification test design. Unlike the low speed wind tunnel testing, no deposition measurements are made with high speed wind tunnel testing. In order to meet the DQOs, at least three replications will be used for each set of application conditions intended for actual use in the field. For instance, at least three replications will be conducted for each combination of air speed and nozzle pressure. 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 sections 1 and 2 of Table 2 must be met. For example, the measured volume median diameter (VMD), Dv0.i and Dv0.9 (the droplet diameter bounding the upper and lower 10 percent fractions of the spray) should vary by less than ±3 percent. Measurements of candidate test systems are compared to a reference spray system based on the ASAE S572 standard for droplet size. Before drift potential measurements are conducted, the candidate test system is categorized into droplet size category for very fine, fine, medium, coarse, very coarse, and extremely coarse using ASAE S572. The reference system should use the ASAE S572 reference nozzle associated with the lower (coarser) boundary of the droplet size category in which the candidate test system falls. During drift potential measurements, the angle of the candidate test system does not need to be identical to that of the reference spray system. The vendor may select the spray angle for the candidate test system nozzle. Acceptable nozzles, associated wind tunnel air speeds, and nozzle angles relative to air direction are identified below. C2: Sampling Methods for Measurement of Droplet Size and Test Conditions Table 4 lists all the measurements required for this verification test. Measurements are categorized in the table as performance factors and test conditions. Performance factors are critical to verifying the performance of the DRT. Test conditions are important to understand the conditions of performance. Further detail is provided in Elements C2.1 through C2.4. ------- Generic Verification Protocol for ETV DRT April 2007 Version 0.0 Page 30 Table 4. Summary of Spray and Test Condition Measurements for High Speed Wind Tunnels Factors to Be Verified Parameter to Be Measured Sampling and Measurement Method Comments Performance Factors Droplet size at the atomizer Droplet size distribution produced by the atomizer Non-intrusive sampling methods appropriate for the spray material such as laser diffraction, phase-Doppler, laser imaging instruments. The range of droplet size categories measured must account for at least 99% of the spray volume. Test Conditions Documentation Spray pressure Spray materials temperature Wind tunnel conditions Pressure of spray mix at the atomizer Temperature of the spray mixture Air speed Ambient air temperature Air humidity See ASAE S572, section 3. 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; ASHRAE Std 4 1 . 1 ; or other similar approach 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. C2.1 Sampling Locations Spray shall be sampled using one of several laser measurement systems: laser diffraction, phase- Doppler (excluding multi-phase droplets, e.g., air inclusion or emulsions) or laser imaging. For both droplet size distribution for determining the appropriate reference test system nozzle and for determining drift potential, the continuous traverse method is usually the optimal technique for sampling the spray plume, and data should be expressed as mass-balanced average droplet size data across the traverse. Multiple chordal measurements or (for phase-Doppler measurement systems), two- or three-dimensional mapping of droplet size and velocity throughout the spray plume may also be used. Sampling should occur across a representative cross-sectional sample of the spray. Sampling should occur 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 spray is not contacting the wind tunnel's surfaces. The sampling distance may need to be adjusted for different atomizers, flow rates, and test substances but in general the optimal sampling distance is between 20 to 50 cm from a nozzle. ------- Generic Verification Protocol for ETV DRT Version 0.0 April 2007 Page 31 Measurement of air temperature and humidity should occur upwind of the atomizer and as close as possible to the atomizer without affecting its performance or the air speed at the atomizer. C2.2 Process/Application Data Collection 1. Droplet size distribution sampling - Droplet size at the atomizer, for classification: Near the nozzles, see Element C2.4, Measurement of Droplet Size Spectrum Near the Nozzle, Without the Effects of Flight Speed Air Flow (Determination of appropriate reference test system). - Droplet size at the atomizer, drift potential: Near the nozzles, see Element C2.3, Wind Tunnel Measurement of Spray Drift Potential (Droplet Size Distribution at Aerial Application Air Speeds at the nozzle). 2. Wind tunnel conditions - The following conditions shall be measured at the same height as the nozzle, upwind of the nozzle in the wind tunnel working section at the time of spray release: ambient air temperature, air speed, relative humidity. 3. Sprayer conditions - The Spray pressure shall be measured at the nozzle tip using a capillary connected to a pressure gauge (as is consistent with ASAE S572, section 3). C2.3 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 ETV project manager prior to the verification test. Laser-based measurement devices are used to measure droplet size distribution at the nozzle in the wind tunnel. 1. The spraying system shall be mounted to minimize effects on airflow. 2. The orientation of the nozzle (predominant spray direction or axis of rotation) that the fan sprays discharge relative to the air flow direction must be measured with a protractor and recorded. 3. Droplet size shall be measured using one of several laser or optical measurement systems: laser diffraction, phase-Doppler (excluding multi-phase droplets, e.g., air inclusion or emulsion) or laser imaging. The instruments and apparatus used in the test shall be listed. Names, model numbers, serial numbers, scale ranges, software version number, and calibration verification shall be recorded. 4. Nozzles must be positioned in a place free from edge effects. ------- Generic Verification Protocol for ETV DRT Version 0.0 April 2007 Page 32 5. A representative cross-section average sample must be obtained, using a mass- weighted traverse or multiple chordal measurements of the full spray (or half spray for axi-symmetric spray plumes). 6. The sampling system must be configured to measure the entire dynamic size range of the instrument with less than 2 percent total of the spray volume contained in the uppermost or lowermost size classes. 7. If a number-density weighted ("spatial") sampling system is used, the setup should minimize the development of a size-velocity profile within the spray (e.g., by using a concurrent airflow if spray discharge is in the horizontal plane) to avoid data bias toward slower-moving (usually smaller) droplets. 8. The droplet size measurements should include assessments of the droplet size category of the candidate test system and reference system according to ASAE S572. 9. For testing atomizers without using adjuvants, water containing surfactant may be used. Acceptable surfactants and surfactant concentrations are those that will provide a Newtonian tank mix with dynamic surface tension of 40 dyne/cm at surface lifetime age of 10 to 20 ms.Use of other surfactants or concentrations should be approved by the EPA ETV project manager prior to testing. 10. When adjuvants are included as the DRT in the test spray material, emulsifiable concentrates (EC) formulations (blank or containing pesticide) must be included to make the results of the test extend to EC formulation. Water with surfactant (as described in item 9 above) may be used if the results are only intended for aqueous solutions of 15 gal/acre or higher. An example of a commonly-used adjuvant in the U.S. is Triton X-77 at 0.25 percent v/v. 11. 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. 12. Spray material flow rate shall be measured at the operating pressure for the tests. The liquid flow rate measurement may include techniques using liquid collected for a known duration, using Coriolis mass flow sensors, calibrated flow turbine, oval displacement meter, weighing system for the spray mix tank, or other method. Nozzle output should remain constant with a maximum deviation of ±2.5 percent. These liquid flow rate measurements are consistent with ISO 5682 part 1. 13. 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 must be maintained between 50 and ISOmph. 14. The type of nozzle being tested must be documented as follows: ------- Generic Verification Protocol for ETV DRT Version 0.0 April 2007 Page 33 - 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, 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. C2.4 Measurement of Droplet Size Spectrum Near the Nozzle, Without the Effects of Flight Speed Air Flow (Determination of appropriate reference test system). The droplet size of the candidate test system near the nozzle is used to determine the appropriate reference test system. The droplet size measurement and classification shall be consistent with ASAE S572 in addition to the criteria below. The candidate test system is categorized into droplet size category for very fine, fine, medium, coarse, very coarse, and extremely course. 1. Droplet size spectra for spray drift tests shall be made under the same conditions (e.g., spray material, spray pressure, nozzle settings) and following the same procedures outlined in Element C2.3 except the measurements do not need to be made within a wind tunnel. 2. Follow methods in Element B2.4, items 2 through 7. C2.5 Wind Tunnel and Spray System Operation Data Collection The following conditions shall be measured at the same height as the nozzle, upwind of the nozzle in the wind tunnel working section at the time of spray release: ambient air temperature, air speed, and relative humidity. Spray pressure shall be measured at the nozzle tip using a capillary connected to a pressure gauge (as is consistent with ASAE S572, section 3). Spray material temperature shall be measured and shall be within ±2°C of the ambient air temperature. C3: Sample Handling and Custody Requirements If data collection and analysis is to be done on-site and no samples will be transported to a laboratory, sample custody requirements are not a required part of this verification test program. C4: Analytical Methods No analytical methods are used. ------- Generic Verification Protocol for ETV DRT Version 0.0 April 2007 Page 34 C5: Quality Control At least three replicates for each set of test conditions should be conducted. Measured volume median diameter (VMD), Dv0.i and Dv0.9 (the droplet diameter bounding the upper and lower 10 percent fractions of the spray) should vary by less than 3 percent. Air speed should vary by less than 5 percent within a trial and less than 5 percent across replicates. Air speed must be maintained between 50 and 180 mph. If the air speed is less than 140 mph, there may be constraints on the application use label conditions. C6: Instrument/Equipment Testing, Inspection, and Maintenance The site-specific test/QA plan resulting from this protocol needs to reference the testing organization's SOP for testing, inspection, and maintenance of instruments and equipment. C7: Instrument/Equipment Calibration and Frequency Calibration verification of some laser diffraction particle size analyzers can be achieved using ASTM Standard Test Method E 1458 "Test Method for Calibration Verification of Laser Diffraction Particle Sizing Instruments using Photomask Reticles." Alternative techniques include reference particles and sprays of known size distribution. Phase-Doppler instruments are optically calibrated during production - this is a lifetime calibration. Electronic phase calibration is normally done for each set of instrument settings, particularly PMT voltage, sampling rate (pass band), and laser power level. This is done using a built-in calibration diode that generates a Doppler burst-like signal. Calibration values may also be obtained for various PMT voltages, for example, and recorded for later input during testing. The accuracy depends on instrument settings, mainly through the signal to noise ratio (SNR). Typical values for experienced users can be expected to be within ±1 percent of the reading + phase. The resolution in phase is 1/4096, or 0.0878906°. The repeatability also depends on instrument settings, and with experience an operator may be expected to achieve typical values of ±2° phases. Single particle counting/imaging systems should measure at least 10,000 droplets per sample for statistical validity. Calibration can be achieved using reference materials of known size and/or following instrument manufacturer instructions such as lens focal length/size factor relationships. C8: Inspection/Acceptance of Supplies and Consumables Water used in spray tanks should have a hardness of less than 300 ppm. As there are no other supplies and consumables, additional inspection and acceptance requirements are not a required part of this verification test protocol. 2° ------- Generic Verification Protocol for ETV DRT Version 0.0 April 2007 Page 35 C9: Non-Direct Measurements If applicable, data that are not gathered directly by the testing organization may be used, however, the testing organization must describe these measurements in the test/QA plan or the applicant-specific addendum. CIO: Data Management Results will be calculated as droplet size distribution at the nozzle for each set of sampling conditions (e.g., air speed, nozzle pressure, nozzle orientation). Droplet size distributions will be described by 32 categories of droplet diameter. Higher resolution distributions (more categories of droplet diameter) may be presented in addition to the 32-category description. Requirements for the verification test report, verification statement, and data storage and retrieval are provided in Element E, Data Reporting. C10.1 Data Flow Data measurement and collection activities are shown in Figure 5 in Element BIO. This flow chart includes all data activities from the initial pretest QA steps to the passing of the data to EPA. C10.2 Data Reduction: Data from each measurement for droplet size from the verification test will be reported as the incremental and cumulative volumes of 32 appropriately spaced and described bins of droplet diameter (microns). The Dv0.i, Dv0.5, Dv0.9, and relative span will also be presented. An example presentation of the output data is shown in Table B-l of Appendix B. Raw data of droplet sizing instrument output should be provided in an appendix. C10.3 Analysis of Verification Data: Measurements should be presented separately (raw data) and as an average across repetitions for the following types of measurements. Measurements would include droplet size at the nozzle: volume per droplet size category (i.e., each of the 32 droplet size categories) and reference spray type. ------- Generic Verification Protocol for ETV DRT Version 0.0 April 2007 Page 36 GROUP D: DATA GENERATION AND ACQUISITION FOR FIELD STUDIES Dl: Sampling Process Design (Experimental Design) The measure of performance for the DRT in field studies will be directly determined by deposition measured on horizontal fallout collectors according to either ASAE 561.1 APR04 or ISO/DIS 22866:2005(E) standard methods with modifications specified in Element D below. The specific placement of collectors will allow for an estimate of the integrated deposition from 0 to 61 m (200 ft) and the point deposition at 30.5 m (100 ft) downwind of the application site. The treatment area/spray track must be at least 100 m long and perpendicular to wind direction. If samplers are placed beyond 61m downwind, the length of the treatment area should be at least the product of the outermost sampler distance and 1.15 plus the distance between the outermost samplers in the sampling array.2 This arrangement allows for the outermost samplers to be downwind of the treatment area when the wind direction approaches ±30 degrees relative to the length of the treatment area. The conditions of the study will be selected to allow for the measurement of the DRT and the reference spray systems under identical or similar conditions (e.g., wind speed, wind direction, temperature, relative humidity, release height). The measurements of deposition are the critical measurements for this verification test. Measurements of field and application conditions are important for establishing the limitations of the verification test design. As required by the DQO in Element A7, the DQIGs for the parameters identified in section 3 of Table 2 must be met. Measurements of candidate test systems are compared to a reference spray system based on the ASAE S572 standard for droplet size. The reference system should use the ASAE S572 nozzle model associated with the lower (coarser) boundary of the droplet size category (very fine, fine, medium, coarse, very coarse, and extremely coarse) in which the test system falls. The height and spacing of the standard nozzle should be appropriate for the spray angle produced by the reference nozzle and does not need to be identical to the candidate test system. The reference nozzle should be directed straight down. D2: Sampling Methods for Measurement of Droplet Size, Deposit, and Test Conditions Table 5 lists all the measurements required for this verification test. Measurements are categorized in the table as performance factors and test conditions. Performance factors are critical to verifying the performance of the DRT. Test conditions are important to understand the conditions of performance. Further detail is provided in Elements D2.1 through D2.3 and D4. 2 [Outermost sampler distance] x [2 tan(30)] + [distance between outmost array of samplers] ------- Generic Verification Protocol for ETV DRT April 2007 Version 0.0 Page 37 Table 5. Summary of Spray and Test Condition Measurements for Field Testing Factors to Be Verified Parameter to Be Measured Sampling and Measurement Method Comments Performance Factors Deposition Tracer deposit at multiple locations downwind of the treatment area Sampled using smooth horizontal surface collectors such as filter paper. Deposition should be described in terms of mass of nonvolatile tracer per unit area Test Conditions Documentation Spray pressure Spray materials temperature Flow rate Release height Travel speed Meteorological conditions Pressure of spray mix at the atomizer Temperature of the spray mixture Volume per unit time produced by the nozzle under test conditions. Height above the ground the spray materials are released Rate of speed for the equipment used to apply the spray material Wind speed Wind direction Ambient air temperature Ambient pressure Relative humidity See ASAE S572, section 3. Calibrated thermometers accurate within 1°C SeeASAES561.1 See ASAE S561.1, section 3.2. 3 See ASAE S561.1, section 3.2.4 See ASAE S561.1, section 3.2 See ASAE S561.1, section 3.2 See ASAE S561.1, section 3.2.2 Temperature of the air and spray mixture should be within 2°C Repeat measurements for individual nozzles within ±2.5% D2.1 Sampling Locations Three parallel lines of horizontal collectors within the sampling array should be used. Collector lines in the sampling array should be spaced at least 15m apart. The center collector line in the sampling array should be in the center of the application area. Horizontal deposition samplers should be placed at a minimum of 4 m, 8 m, 16 m, 30.5 m, and 61 m from the downwind edge of the treated area. At least one collector should be placed in the swath and upwind of the treatment area. The placement of the station(s) for measuring meteorological conditions should be located in the open within 30 m of the treatment area and away from any obstruction or topographical irregularities. A map should be provided showing the treatment area, sampler placements, position of the meteorological station(s), and any obstructions or identifying features of the test area. ------- Generic Verification Protocol for ETV DRT April 2007 Version 0.0 Page 38 o o -L_ L1J L 1 _ 4m 8m 16m 30.5m 61m Treatment Site Horizontal Sampling Area Figure 6. Sampling locations for field testing. D2.2 Process/Application Data Collection All sampling will follow the requirements of the specific test method being used, either ASAE 561.1 APR04 or ISO/DIS 22866:2005(E) standard methods, unless otherwise stated in this document or approved by EPA prior to the verification test. Example sampling locations for field testing are shown in Figure 6. D2.3 Ambient Data Collection Meteorological conditions will be measured with at least one weather station during applications. The sampling rate for wind speed and direction should be at least 4 samples per minute. The wind speed must be at least 1 m/s for all applications. D3: Sample Handling and Custody Requirements The date and time of sample collection and analysis must be recorded. Sample holding conditions (e.g., temperature, containers, light) must be noted for the period between sample collection and analysis. ------- Generic Verification Protocol for ETV DRT Version 0.0 April 2007 Page 39 The samples collected during the test program will consist of horizontal samplers (filter paper). Analysis of these samples will be conducted using gas chromatography, as described in Element D4. To maintain sample integrity, the following procedure will be used. Each horizontal sampler will, prior to use, be stamped with a unique identification number or other numbering system to identify testing, test run, and position. A file folder or envelope will also be stamped with the identification number and the sampler will be placed in the corresponding folder. The horizontal sampler filters containing tracer are placed in individual protective containers and then into numbered folders or envelopes. For transport, groups of samplers are sealed in heavy- duty plastic bags and stored in a heavy corrugated cardboard or plastic filing box equipped with a tight-fitting lid. All exposed and unexposed samplers are always kept separate to avoid any cross-contamination. The date and time of sample collection and analysis must be recorded. Sample holding conditions (e.g., temperature, containers, light) must be noted for the period between sample collection and analysis. If data collection and analysis is to be done on-site and no samples will be transported to a laboratory, sample custody requirements are not a required part of this verification test program. D4: Analytical Methods Measurement of deposited material will occur by extracting tracer from the horizontal sample collectors followed by measurement of the amount of tracer in the extract. Tracer measurements should be expressed as the amount of material per unit area of sampler. Instruments used to measure tracer (e.g., gas chromatographs) should be of adequate sensitivity to measure deposition at the most distant sampler. D5: Quality Control The boom width, intended swath width, nozzle placement, and nozzle orientation of the application equipment will be reported. Wind direction during and for 2 minutes after application should be ±30 degrees perpendicular to the swath. Drive speed for ground equipment will be between 4 and 24 km/h (2.5 to 15 mph). Aerial application equipment speed must be at least 140 mph. If the aerial application equipment speed is less than 140 mph, there may be constraints on the application use label conditions. Randomly selected, unused horizontal sample collectors should be spiked with tracer at 2 and 200 times the level of quantitation for the analytical equipment to be used for measuring tracer. Tracer recovery should be within 80 to 120 percent of the spiked amount. Stock solutions used in testing should also be tested. Linearity of deposition relative to measurement instrumentation response should be demonstrated in the deposition range measured. Tracer concentration in the spray material tank will be measured and reported before and after testing on each test day and for each tank mix used. ------- Generic Verification Protocol for ETV DRT Version 0.0 April 2007 Page 40 D6: Instrument/Equipment Testing, Inspection, and Maintenance The site-specific test/QA plan needs to reference the testing organization's SOP for testing, inspection, and maintenance of instruments and equipment. D7: Instrument/Equipment Calibration and Frequency Analytical instruments used to measure tracer extracts from collectors will be calibrated on the same day of analysis. Calibration will use a standard curve consisting of at least three points spanning the level of quantitation and the highest measured concentration level. The standard curve should be linear (r2 greater than 0.95). D8: Inspection/Acceptance of Supplies and Consumables The primary supplies and consumables for this exercise consist of the horizontal samplers and tracer materials. Prior to labeling, each sampler is visually inspected and is discarded for use if any damage is found. The tracer selected should allow for adequate sensitivity to measure deposition at all test distances. The tracer should be stable and nonvolatile in the test frame for testing and analysis. Background measurement samples from the testing site should demonstrate negligible levels of tracer or other interfering compounds. Water used in spray tanks should have a hardness of less than 300 ppm. D9: Non-Direct Measurements If applicable, data that are not gathered directly by the testing organization may be used, however, the testing organization must describe these measurements in the test/QA plan or the applicant-specific addendum. DIG: Data Management Results will be calculated as deposition for each set of sampling conditions at downwind positions at 4 m, 8 m, 16 m, 30.5 m, and 61 m, including a summary of meteorological conditions and application conditions. Requirements for the verification test report, verification statement, and data storage and retrieval are provided in Group E, Data Reporting. D10.1 Data Flow Data measurement and collection activities for deposition are shown in Figure 5 of Element BIO. This flow chart includes all data activities from the initial pretest QA steps to the passing of the data to EPA. D10.2 Data Reduction Data from each measurement for deposition from the verification test will be reported in units of mass/area for each downwind distance and the meteorological and application conditions will clearly be reported. ------- Generic Verification Protocol for ETV DRT Version 0.0 April 2007 Page 41 D10.3 Analysis of Verification Data Measurements should be presented separately (raw data) and as an average across repetitions for each downwind measurements for the deposition on horizontal samplers at each downwind distance. ------- Generic Verification Protocol for ETV DRT Version 0.0 April 2007 Page 42 GROUP E: DATA REPORTING El: Outline of the Verification Test Report • Verification statement - DRT manufacturer/vendor information - Summary of verification test program including testing location and type (LSWT, HSWT, or Field) - Results of the verification test - Droplet size classification, using ASAE S572. - Any limitations of the verification results - Brief QA statement • Introduction • Description and identification of the DRT • Procedures and methods used in testing - The instruments and measurement apparatus used for droplet size measurement (including name and type, model number, serial number, scale ranges, software version number, and date of most recent calibration verification) - Spray flux and deposition sampling (including description of monofilament lines, size and type of horizontal samplers, placement of monofilament lines and samplers, and photograph of samplers place for collection) • Statement of operating range and testing conditions over which the test was conducted including: - Nozzle orifice height - Spray pressure at nozzle - Volume/unit time produced by nozzle - Test spray material composition - Source of spray materials (including water) - Sampling locations - Temperature - Humidity - Wind speed - wind tunnel testing only - Flight speed or ground equipment speed - field testing only - Wind speed/direction - field testing only - Atmospheric stability (Pascal) - field testing only - Results of the ASAE S572 droplet size measurement ------- Generic Verification Protocol for ETV DRT Version 0.0 April 2007 Page 43 • Summary and discussion of results - Results supporting verification statement - Deviations and explanations from test plan - Discussion of QA and QA statement • References • Appendices - QA/QC activities and results - Raw test data - Equipment calibration results - Sample handling E2: Draft Report Preparation At the conclusion of the field and wind tunnel testing effort, a copy of all electronic and paper data will be made and retained by the testing organization task leader. The testing organization will develop a verification report that verifies and summarizes the DRT test results. E3: Data Storage and Retrieval This section describes the handling and storage of the data. After the completion of a verification test, labeled three-ring binders containing manually recorded information and data output generated from instrumentation will be stored with a copy retained by the testing organization. This is called the 'Data Notebook' in the ETV and APCT Center QMPs. After the completion of a verification test, a computer diskette containing spreadsheet data files will be stored with a copy retained by the test analyst. All data, verification reports, and verification statements will be retained for a period of not less than 7 years per Part A, Section 5.3 of the EPA ETV QMP. ------- Generic Verification Protocol for ETV DRT Version 0.0 April 2007 Page 44 GROUP F: ASSESSMENT/OVERSIGHT Fl: Assessments and Response Actions Fl.l Internal Audits Internal audits by the testing organization are conducted as specified in the testing organization's SOP, which must conform to required Element Cl (Assessments and Response Actions) and C2 (Reports to Management) of EPA QA/R-5. The testing organization SOP documents must be identified in the site-specific test/QA plan. F1.2 Audits of Data Quality In accordance with Table 9.1 of the EPA ETV QMP, the testing organization QM will conduct an ADQ of at least 10 percent of all of the verification data. 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 ADQ report ends with conclusions about the quality of the data from the project and their fitness for their intended use. F1.3 External Audits The testing organization will cooperate with any external assessments by the EPA. EPA assessors will conduct a single mandatory quality and technical systems assessment of the testing organization before the start of the first test for each test facility. They may conduct optional witness assessments during the first test or any subsequent test. The external assessments will be conducted as described in EPA QA/G-7. F1.4 Corrective Action Corrective action to any audit or assessment is performed according to the testing organization's SOPs, which must conform to required Elements B5 (Quality Control) and Cl (Assessments and Response Actions) of EPA QA/R-5. F2: Reports to Management Internal assessment reports will be reviewed by the testing organization 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 Fl.2 of this protocol. ------- Generic Verification Protocol for ETV DRT Version 0.0 April 2007 Page 45 GROUP G: DATA VALIDATION AND USABILITY ELEMENTS Gl: Data Review, Verification, and Validation Data review and validation will primarily occur at the following stages: • On site following each test run - by the test technician • On site following completion of the test program - by the testing organization technical leader • Before writing the draft verification test report - by the testing organization 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 2) and the DQIG analysis of the parameter test data. Those individuals responsible for onsite data review and validation are noted in Figure 5, Element BIO, and above. The testing organization technical leader is responsible for verification of data with all written procedures. Finally the testing organization QM reviews and validates the data and the draft report using the site-specific test/QA Plan, test methods, general SOPs, and project- specific SOPs. The data review and data audit will be conducted in accordance with the testing organization's SOP. G2: Verification and Validation Methods The process for validating and verifying data has been described in Elements B, C, and D of this protocol. Results of the testing are conveyed to the data users through the ETV verification statements and verification reports. Examples of an ETV verification statement are presented on the ETV Web site [http://www.epa.gov/etv/]. G3: Reconciliation with Data Quality Objectives DQO requirements have been defined [in Table 2]. This reconciliation step is an integral part of the test program and will be done at the test site. Attainment of the DQO is confirmed by analyzing the test data as described in Element A7 and will be completed by the testing organization test technician and testing organization technical leader at the conclusion of the scheduled test runs. The DQO is defined as meeting the DQIG in Table 2. The reconciliation of the results with the DQO will be evaluated using the data quality assessment process. This process started with the review of the DQO and the sampling design to assure that the sampling design and data collection documentation are consistent with those needed for the DQO. When the preliminary data is collected, the data will be reviewed to ensure that the data are consistent with what was expected and to identify patterns, relationships, and potential anomalies. The data will be summarized and analyzed using appropriate statistical procedures to identify the key assumptions. The assumptions will be evaluated and verified with all deviations from procedures assessed as to their impact on the data quality and the DQO. Finally, the quality of the data will be assessed in terms of precision, bias, and statistical significance as they relate to the measurement objectives and the DQO. ------- Generic Verification Protocol for ETV DRT Version 0.0 April 2007 Page 46 Results from verification testing of the DRT will be presented in a verification statement and a verification report as described in Element BIO.2. ------- Generic Verification Protocol for ETV DRT Version 0.0 April 2007 Page 47 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. Verification Organization Documents RTI International. Verification Testing of Air Pollution Control Technology - Quality Management Plan, Revision 2.2. RTI International. Research Triangle Park, NC. February 2005. ------- Generic Verification Protocol for ETV DRT April 2007 Version 0.0 Page 48 APPENDIX B: EXAMPLE FORMAT FOR TEST DATA Table B-l. Example of Test Data Report Format Droplet Size Bin No. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Dv o.i (M.m) Dv 0.5 (M.m) Dv 0.9 ((J.m) Relative Span Measures of droplet size categories (|j,m) Largest 1504 1297 1120 965 833 719 620 535 461 399 344 296 256 220 191 164 141 122 105 90.9 78.5 67.7 58.4 50.4 43.5 37.5 32.4 27.9 24.1 20.8 17.9 15.5 74 160 335 0.82 Arithmetic Mean 1400.5 1208.5 1042.5 899 776 669.5 577.5 498 430 371.5 320 276 238 205.5 177.5 152.5 131.5 113.5 97.95 84.7 73.1 63.05 54.4 46.95 40.5 34.95 30.15 26 22.45 19.35 16.7 9.75 Smallest 1297 1120 965 833 719 620 535 461 399 344 296 256 220 191 164 141 122 105 90.9 78.5 67.7 58.4 50.4 43.5 37.5 32.4 27.9 24.1 20.8 17.9 15.5 4.0 Mass Fraction Incremental 0 0 0 0 0 0.01 0.01 0.02 0.03 0.01 0.06 0.05 0.06 0.09 0.09 0.08 0.12 0.11 0.08 0.06 0.03 0.02 0.03 0.01 0.01 0.01 0.01 0.0 0.0 0.0 0.0 0.0 Cumulative 0 0 0 0 0 0.01 0.02 0.04 0.07 0.08 0.14 0.19 0.25 0.34 0.43 0.51 0.63 0.74 0.82 0.88 0.91 0.93 0.96 0.97 0.98 0.99 1.0 1.0 1.0 1.0 1.0 1.0 ------- |