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GENERIC VERIFICATION PROTOCOL FOR
PAINT OVERSPRAY ARRESTORS
EPA Cooperative Agreement No. CR 826152-01-0
RTI Project No. 93U-7012-20
Prepared by:
Research Triangle Institute
APPROVED BY:
RTI Program Manager: J. R. Farmer _ Original signed by J. Farmer Date: 8/24/99_
RTI Quality Manager: R. S.Wright Original signed by R. Wright Date: 8/24/99_
RTI Task Leader:
J. T. Hanley _ Original signed by J. Hanley Date: 8/24/99_
RTI Quality Leader:
C. E. Tatsch _ Original signed by C. Tatsch Date: 8/16/99
EPA Project Manager:
T.G. Brna _ Original signed by T. Brna Date: 9/21/99
EPA Quality Manager:
P. W. Groff _ Original signed by P. Groff Date: 9/20/99_
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TABLE OF CONTENTS
Section Page
1. INTRODUCTION 1
2. OBJECTIVE, SCOPE, VERIFICATION PARAMETERS AND DATA QUALITY
INDICATORS 3
3. TEST METHOD 7
4. REPORTING REQUIREMENTS 10
5. DISSEMINATION OF VERIFICATION REPORTS AND
VERIFICATION STATEMENTS 11
6. MANUFACTURER'S OPTIONS IF A PRODUCT PERFORMS
BELOW EXPECTATIONS 11
7. LIMITATIONS ON TESTING AND REPORTING 11
8. ACQUISITION OF PAINT ARRESTORS FOR TESTING 12
9. REQUIREMENTS FOR PRODUCT LABELING 12
10. PRODUCT CHANGE 13
11. PRODUCT DEFINITION 13
12. TEST LABORATORIES 13
13. INITIATION OF VERIFICATION TESTING 14
14. TEST LABORATORY SUBMITTAL OF RESULTS TO RTI 14
15. REQUIREMENT FOR QUALITY ASSURANCE PROJECT PLAN (QAPP) 15
16. ASSESSMENT AND RESPONSE 17
17. REFERENCES 18
METHOD 319 Appendix A
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LIST OF TABLES
Number Page
TABLE 1. EXISTING FACILITIES; LIQUID-PHASE CHALLENGE
AEROSOL PARTICLES 5
TABLE 2. EXISTING FACILITIES; SOLID-PHASE CHALLENGE
AEROSOL PARTICLES 5
TABLE 3. NEW FACILITIES; LIQUID-PHASE CHALLENGE
AEROSOL PARTICLES 5
TABLE 4. NEW FACILITIES; SOLID-PHASE CHALLENGE
AEROSOL PARTICLES 5
TABLE 5. SUMMARY OF DATA QUALITY OBJECTIVES 6
TABLE 6. METHOD 319 EXAMPLE TEST SERIES 9
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List of Acronyms
APCT Air Pollution Control Technology
DQO data quality objective
EPA Environmental Protection Agency
ETV environmental technology verification
NESHAP National Emission Standard for Hazardous Air Pollutants
POA paint overspray arrestor
QA quality assurance
QC quality control
QMP quality management plan
RTI Research Triangle Institute
SOP standard operating procedure
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1. INTRODUCTION
1.1 Environmental Technology Verification
The U.S. Environmental Protection Agency (EPA) has instituted the Environmental Technology
Verification (ETV) Program to verify the performance of innovative technical solutions to
problems that threaten human health or the environment. EPA created ETV to substantially
accelerate the entrance of new environmental technologies into the domestic and international
marketplace.
ETV supplies technology buyers and developers, consulting engineers, states, and U.S. EPA
regions with high-quality, objective data on the performance of new technologies. This
encourages more rapid protection of the environment with better and less expensive approaches.
ETV has established verification efforts in 12 pilot areas. In these pilot programs, EPA utilizes
the expertise of partner organizations to design efficient processes for conducting performance
tests of new technologies. EPA selects its partners from the non-profit public and private sector,
including federal laboratories, states, universities, and private sector facilities. Verification
organizations oversee and report verification activities based on testing and quality assurance
protocols developed with input from all major stakeholder/customer groups associated with the
technology area.
The ETV goal is to verify the environmental performance characteristics of commercial-ready
technologies through the evaluation of objective and quality assured data so that potential
purchasers and permitters are provided with an independent and credible assessment of what they
are buying and permitting.
1.2 Air Pollution Control Technology Program
One of the 12 ETV pilot programs is the Air Pollution Control Technology (APCT) program.
The U.S. EPA's partner in the APCT program is Research Triangle Institute (RTI), a non-profit
contract research organization with headquarters in Research Triangle Park, NC. The APCT
program will verify the performance of commercial-ready technologies used to control air
pollutant emissions. The initial emphasis of the APCT program is on technologies for controlling
particulate matter, volatile organic compounds, nitrogen oxides, and hazardous air pollutants. As
the program matures, more technologies will be added.
RTI will cooperatively organize and develop the APCT program for verification testing of air
pollution control technologies. The focus is on commercial-ready technologies. The APCT
program will not evaluate technologies that are at the pilot or bench scale.
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The APCT program will develop standardized verification protocols and test plans, conduct
independent testing of technologies, and prepare verification test reports for broad dissemination.
A goal of the APCT program is to ultimately become self-sustaining, or "privatized," by operating
on project-generated income (user fees) and other resources.
The APCT program has selected paint overspray arrestors (POAs) as a technology to be verified.
1.3 The Paint Overspray Arrestor Program
Paint overspray arrestors are particle collection devices (e.g., filters) used to control particle
emissions from paint spraying operations. Much of the impetus for this verification program
comes from the recently promulgated National Emission Standard for Hazardous Air Pollutants
(NESHAP) for Aerospace Manufacturing and Rework Facilities (Code of Federal Regulations,
Volume 40, Part 63, Appendix A). The NESHAP establishes filtration efficiency requirements for
paint overspray arrestors used in new and existing aerospace facilities and presents the test
method to be used to make these filtration efficiency determinations (Method 319, "Determination
of Filtration Efficiency for Paint Overspray Arrestors").
Testing within the POA program will be performed by RTI and by other laboratories that elect,
and qualify, to participate in the POA program. In addition to RTI, it is anticipated that from one
to three other laboratories will be available for testing. Regardless of where the testing is
performed, all verification reports and statements will be reviewed by the APCT program for
compliance with this test protocol and associated quality assurance (QA) documents. The APCT
program will resolve any issues with the testing laboratory and, once all issues are resolved, send
the verification report and statement to EPA for review and approval. (Laboratory participation
is discussed further in Sections 12 through 14.)
1.4 Quality Management Documents
Management and testing within the POA program is performed in accordance with procedures
and protocols defined by a series of quality management documents. These include EPA's
Quality Management Plan (QMP) for the overall ETV program, the QMP for the overall APCT
program, the Generic Verification Protocol for Paint Overspray Arrestors, and Test/QA Plans
prepared by each participating test laboratory.
EPA's ETV QMP lays out the definitions, procedures, processes, inter-organizational
relationships, and outputs that will assure the quality of both the data and the programmatic
elements of ETV. Part A of the ETV QMP contains 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 ETV QMP contains the specifications and guidelines
that apply to test-specific environmental activities involving the generation , collection, analysis,
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evaluation, and reporting of test data. (EPA's Quality and Management Plan for the Pilot Period
(1995-2000), May 1998.)
APCT's QMP describes the quality systems in place for the overall APCT 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 specific technology and define
the data quality objectives (DQOs). The document herein is the generic verification protocol for
paint overspray arrestors and was written by RTI, with input from the POA Technical Panel, and
approved by EPA. While specific to the testing of paint overspray arrestors, the document is
"generic" in that it applies to many types and brands of paint overspray arrestors.
Test/QA Plans are prepared by each participating test laboratory. The Test/QA Plan describes,
in detail, how the testing laboratory will implement and meet the requirements of the Generic
Verification Protocol. The Test/QA Plan addresses issues such as the laboratory's management
organization, test schedule, documentation, analytical method and data collection requirements,
calibration traceability, and specifies the QA and QC requirements for obtaining verification data
of sufficient quantity and quality to satisfy the DQOs of the Generic Verification Protocol.
2. OBJECTIVE, SCOPE, AND VERIFICATION PARAMETERS
2.1 Objective
The objective of the Paint Overspray Arrestor program is to verify the filtration efficiency
performance of arrestors using Method 319, "Determination of Filtration Efficiency for Paint
Overspray Arrestors" (Code of Federal Regulations, Volume 40, Part 63, Appendix A and
attached as Appendix A of this protocol) and to produce verification statements for
dissemination to the public.
2.2 Scope
Testing will be performed on dry-type paint overspray arrestors; water-wash systems are not
included. The arrestors must be commercial-ready. The focus will be on arrestors used in the
aerospace industry, but arrestors used in other fields may also be evaluated. The test arrestors
will not exceed 24-inch x 24-inch face dimensions.
For arrestors that operate on principles not compatible with testing by Method 319 (as may occur
with innovative technologies), the APCT program will prepare separate verification protocols for
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these technologies. These protocols must be approved by the Technical Panel prior to performing
verification testing. The general approach of these protocols, if needed, will be to use Method
319 to the extent that is reasonable and have any deviations remain consistent in spirit with
Method 319 (i.e., verifying an arrestor's filtration efficiency performance for respirable particles
as listed in Tables 1 - 4.)
2.3 Verification Parameters
Verification parameters will consist of the 0.3 - 10 |im filtration efficiency (curves and data
tables), the computed filtration efficiency corresponding to the particle diameters specified in the
Aerospace NESHAP (see Tables 1 - 4), and the pressure drop across the arrestor at the test flow
rate.
2.4 Data Quality Objectives (DQOs)
The data quality objectives (Table 5) combine those specified in Method 319 with added
requirements on airflow and particle measurement to ensure comparability between testing
laboratories. The DQOs include the zero and sizing accuracy of the optical particle counter
(OPC), the minimum and maximum particle concentrations to be used during testing, the standard
deviation of the measured penetration, the acceptable range of penetration measured during 0%
and 100% penetration control tests, the accuracy of the airflow measurement, and the operation
of the aerosol charge neutralizer. These DQOs are fully compliant with Method 319 and are
believed adequate to provide accurate, reproducible test results.
In addition to the daily calibration check of the optical particle counter using a calibration aerosol
(polystyrene latex (PSL) spheres), reference filters will be used to check for shifts in OPC
calibration. Each participating laboratory will maintain a set of at least three reference filters.
These filters will provide a filtration efficiency that passes through 50% efficiency within in the
0.7 - 5 |im particle diameter range. Prior to each Method 319 test, the filtration efficiency of one
of the reference filter will be measured. The measured efficiency must fall within +/- 10% of
previous measurements of that reference filter (i.e., within a 10% shift in particle size and/or
filtration efficiency). If the measurement falls outside this range, and the other reference filters
also fall outside this range, corrective action must be taken (such as recalibration of the OPC)
prior to performing the Method 319 test.
Static charge is often a natural results of the aerosol generation process. If left uncontrolled,
variations in the degree of charging could affect the repeatability of the efficiency measurement.
Method 319 requires that a charge neutralizer be used to neutralize electrostatic charge on the
aerosol. In addition to this, the DQOs include a monthly check of the operation of the charge
neutralizer.
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TABLE 1. EXISTING SOURCES*
LIQUID-PHASE CHALLENGE AEROSOL PARTICLES
Filtration efficiency requirement,
%
Aerodynamic particle diameter range,
|iim
>90
>5.7
>50
>4.1
> 10
>2.2
TABLE 2. EXISTING SOURCES*
SOLID-PHASE CHALLENGE AEROSOL PARTICLES
Filtration efficiency requirement,
%
Aerodynamic particle diameter range,
|iim
>90
>8.1
>50
>5.0
> 10
>2.6
TABLE 3. NEW SOURCES*
LIQUID-PHASE CHALLENGE AEROSOL PARTICLES
Filtration efficiency requirement,
%
Aerodynamic particle diameter range,
|iim
>95
>2.0
>80
> 1.0
>65
>0.42
TABLE 4. NEW SOURCES*
SOLID-PHASE CHALLENGE AEROSOL PARTICLES
Filtration efficiency requirement,
%
Aerodynamic particle diameter range,
|iim
>95
>2.5
>85
> 1.1
>75
>0.70
* A new source is any affected source that commenced construction after
October 29, 1996. An existing source is any affected source that is not new.
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TABLE 5. Data Quality Objectives
Parameter
Frequency and description
Control Limits
Minimum counts per channel
for challenge aerosol
Each efficiency test.
Minimum total of 500 particle counts per channel.
Maximum particle
concentration
Each efficiency test. Needed to ensure OPC is not
overloaded.
<10%o of manufacturer's claimed upper limit
corresponding to a 10%o count error.
Standard Deviation of
Penetration
Computed for each efficiency test based on the
coefficient of variation (CV) of the upstream and
downstream counts.
<0.10 for 0.3 to 3 (im diameter
<0.30 for >3 (im diameter
0% Penetration
Monthly.
<0.01
100% Penetration - Solid-phase
aerosol (KC1)
A 100%) penetration test using KC1 aerosol is
performed immediately before each KC1 arrestor
efficiency test.
Particle Acceptable
Size range Penetration Range:
0.3tol(im: 0.90 to 1.10
1 to 3(im: 0.75 to 1.25
3tol0|im: 0.50 to 1.50
100% Penetration - Liquid-
phase aerosol (oleic acid)
A 100%o penetration test using oleic acid aerosol is
performed immediately before each oleic acid arrestor
efficiency test.
Particle Acceptable
Size range Penetration Range:
0.3tol(im: 0.90 to 1.10
1 to 3(im: 0.75 to 1.25
3tol0(im: 0.50 to 1.50
Temperature
The test duct air temperature measured as part of each
run.
50 - 100 °F acceptable test condition range.
Measurement accuracy of +/- 2 °F
Relative Humidity
The test duct relative humidity measured as part of
each run.
< 65%o acceptable test condition range.
Measurement accuracy of +/- 10 % RH
Airflow accuracy
Every 6-months. Compare duct airflow measurement
to reference flow device.
Duct airflow measurements must be within ±5%o of
reference measurement.
Precision of airflow
measurement
For a given airflow setting, the measurement device
must provide a steady airflow reading. Checked
annually.
Ten consecutive measures of airflow made at 10-
second intervals. Precision computed as the 95%o
confidence interval for the mean airflow
measurement: must be within 5%o of the set point
airflow.
Resolution of Airflow
measurement
Airflow measurement must be readable to within 5% of
set point. Changes in airflow of 5% from set point
must be clearly discernable. Checked annually.
The resolution of the airflow measurement system
shall not exceed 5%o of the set point airflow.
OPC zero count
Each test. OPC samples HEPA-filtered air.
<50 counts per minute.
OPC sizing accuracy check:
Polystyrene latex spheres (PSL)
Daily. Sample aerosolized PSL spheres.
Peak of distribution should be in correct OPC
channel.
OPC sizing accuracy check:
Reference filter
Performed immediately prior to beginning Method 319
test of a product. Measure filtration efficiency of
laboratory reference filter
Measured efficiency must fall within +/- 10%o of
previous measurements (i.e., within a 10%o shift in
particle size and/or filtration efficiency) when
compared to efficiency of reference filter measured
after primary OPC calibration.
OPC calibration: Primary
calibration
Primary calibration performed by manufacturer at
manufacturer-specified intervals; but at least annually.
Manufacturer provides certificate of calibration.
Pressure drop across the
arrestor
Annual. Compare to reference manometer.
Inclined manometer readable to within ±0.01 in.
H20. 10%o or better accuracy.
Aerosol charge neutralizer
Monthly. Confirm activity of radioactive charge
neutralizers. Confirm balance of corona discharge
neutralizers.
Activity must be detected in radioactive
neutralizers. Corona discharge neutralizers must
be in balance.
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Airflow accuracy will be checked monthly by comparing the test duct's airflow reading to a
calibrated reference device temporarily installed in series with the duct's flow measurement
device. The reference device will be a calibrated laminar flow element, calibrated flow nozzle, or
calibrated orifice plate. The reference flow device must have received a primary calibration by the
manufacturer within the manufacturer's recommended recalibration period.
3. TEST METHOD
Method 319
The Aerospace NESHAP includes Test Method 319 "Determination of Filtration Efficiency for
Paint Overspray Arrestors" and requires that this method be used for determining the filtration
efficiency for paint overspray arrestors. The NESHAP specifies the minimum filtration efficiency
required for various aerodynamic particle sizes. Therefore, Method 319 will be used to verify
arrestor performance. A brief overview of the method is given below; the complete method is
presented in Appendix A.
Many of the issues related to a verification protocol are addressed in Method 319 including: (1)
scope and application; (2) summary of the method; (3) definitions; (4) interferences; (5) safety; (6)
equipment and supplies; (7) reagents and standards; (8) sample collection, preservation, and
storage; (9) quality control; (10) calibration and standardization; (11) procedures; (12) data
analysis and calculation; (13) pollution prevention; and (14) waste management.
Where appropriate and necessary, this protocol expands, clarifies and adds to Method 319. This
protocol addresses several issues that Method 319 does not cover, including periodic testing,
acquisition of paint overspray arrestors for testing, and product definition.
Computation of Filtration Efficiency
Filtration efficiency is computed from aerosol concentrations measured upstream and downstream
of an arrestor installed in a laboratory test rig that is documented to meet the requirements listed
in Table 5. The aerosol concentrations upstream and downstream of the arrestors are measured
with an aerosol analyzer that simultaneously counts and sizes the particles in the sample aerosol
stream. The aerosol analyzer covers the particle diameter size range from 0.3 to 10 |im in a series
of contiguous sizing channels. Each sizing channel covers a narrow range of particle diameters.
For example, Channel 1 may cover from 0.3 to 0.4 |im, Channel 2 from 0.4 to 0.5 |im, ... and
Channel 15 from 7-10 |im. By taking the ratio of the downstream to upstream counts on a
channel by channel basis, the efficiency is computed for each of the sizing channels:
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,,...... . ,,,,, , , Channel 1 downstream concentration.
Filtration Efficiency @ 0.35 |i/?? = 100 x ( 1 )
Channel 1 upstream concentration
,,,,,, , , Channel 2 downstream concentration.
Filtration Efficiency @ 0.45 = 100 x ( 1 )
Channel 2 upstream concentration
.... . ,,,,, , , Channel 15 downstream concentration.
Filtration Efficiency @ 8.4 = 100 x ( 1 )
Channel 15 upstream concentration
The upstream and downstream aerosol measurements are made while injecting a test aerosol into
the air stream upstream of the arrestor. (Ambient aerosol is removed with HEP A filters on the
inlet of the test rig.) This test aerosol spans the particle size range from 0.3 to 10 |im and
provides a sufficient upstream concentration in each of the sizing channels to allow accurate
calculation of filtration efficiencies up to 99%.
The efficiency measurements are performed with both solid-phase particles and liquid-phase
particles. Solid-phase particles (simulating dry oversprays) penetrate some arrestors at a higher
level than liquid-phase particles (i.e., wet oversprays). The higher penetration of solid particles is
due to "particle bounce" (i.e., the particles strike the fiber of the filter but, rather than being
captured, bounce off and are reentrained in the airflow). Under normal filtration air velocities,
particle bounce is a solid particle phenomenon often associated with flat panel type filters; particle
bounce is less likely with filters of extended surface area (e.g., pleated and bag filters) for which
the air flow rate through the media is reduced, and does not occur with liquid-phase particles
which readily adhere to the fibers of the filter.
Method 319 Test Series
A Method 319 test performed under this protocol consists of a total of 15 filtration efficiency runs
consisting of:
One reference filter check
Triplicate tests using a liquid-phase aerosol challenge
Triplicate tests using a solid-phase aerosol challenge
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"No-filter" control tests (one performed prior to each arrestor test and the
reference filter test)
One HEPA filter control test.
Table 6 illustrates one acceptable testing sequence. All the tests are performed at a face velocity
of 120 feet per minute with the arrestors in their initial (i.e., clean) condition.
TABLE 6. EXAMPLE RUN SEQUENCE
FOR METHOD 319 TESTING UNDER THIS PROTOCOL
TEST
Run No.
Reference
Filter
No-Filter
Test
Arrestor
HEPA
Filter
Challenge Aerosol
1
X
2
X
3
X
4
X
Solid-Phase
5
X
6
X
7
X
8
X
9
X
10
X
11
X
12
X
Liquid-Phase
13
X
14
X
15
X
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4. REPORTING REQUIREMENTS
There will be two types of reports prepared for products tested under this protocol: Verification
Statements and Verification Reports.
The Verification Statement will be a two- to three-page summary report. The Verification
Statement will include the arrestor manufacturer, model number, a physical description of the
arrestor, and the filtration efficiencies corresponding to the particle sizes specified in the
aerospace NESHAP. A manufacturer, upon review of test results, may request that a Verification
Statement not be issued.
The Verification Report is a fully documented report and contains a complete description of the
test method and equipment, results of all measurements, and raw data. The Verification Report
will include:
testing date
test laboratory
arrestor manufacturer, arrestor model number
acquisition procedures used to obtain the tested arrestors
physical description of the arrestor
filtration efficiency curves from each test and their averages
tabulated efficiency data
interpolated efficiencies at particle sizes corresponding to NESHAP
results of control tests
raw upstream/downstream particle counts
pressure drop across the arrestor
an overview of the test method and facilities/equipment used for the tests
a copy of the annual calibration certificate for the optical particle counter
any deviations from Method 319
any deviations from this test protocol
a note that the test protocol (i.e., this document) is available on the APCT web
site.
The measurement data are to be presented in a format that allows a reviewer to easily determine
whether the testing has met the data quality objectives. Verification Reports will be prepared and
issued for all products tested.
Verification Statements and Verification Reports will be reviewed and approved by the APCT
program and EPA prior to release.
The Verification Statements and Verification Reports will follow fixed formats. The formats will
be consistent with prior POA Verification Statements and Verification Reports (available on
EPA's ETV web site at http://www.epa.gov/etv).
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5. DISSEMINATION OF VERIFICATION REPORTS AND VERIFICATION
STATEMENTS
After a product has been tested, the APCT program will send a draft verification statement and
report to the manufacturer for review prior to submission to EPA and release to the public. The
purpose of this draft review is to give the manufacturer an opportunity to review the results, test
methodology, and report terminology. The manufacturer may submit comments and revisions on
the draft statement and report to the APCT program. The APCT program will consider these
comments and suggested revisions when preparing the final verification statement and report for
submission to EPA. Also, upon review of the draft results, the manufacturer may request that a
Verification Statement not be issued.
Verification Statements will be posted on the ETV web site for public access without restriction.
A copy of the signed statement will be provided to the manufacturer of the paint overspray
arrestor.
Verification Reports will be provided to the manufacturer and made available to the public upon
request. Further distribution, if desired, is at the manufacturer's discretion and is the
manufacturer's responsibility.
6. MANUFACTURER'S OPTIONS IF A PRODUCT PERFORMS BELOW
EXPECTATIONS
In the event that a product fails to meet the manufacturer's expectations, the manufacturer may
request that a Verification Statement not be issued. The manufacturer may improve the product
and resubmit it under a new model number for verification testing. Verification Statements for
tests of the new product will be issued as they are processed by the APCT program and EPA.
Note that Verification Reports will always be available from EPA for review by the public
regardless of a request not to issue a Verification Statement.
7. LIMITATIONS ON TESTING AND REPORTING
To avoid having multiple ETV reports for the same product and to maintain the verification
testing as a cooperative effort with manufacturers, the following restrictions apply to verification
testing under this protocol:
! Manufacturers may submit only their own products for testing; manufacturers may
not submit arrestors from other manufacturers for verification testing.
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! For a given product (e.g., brand and model number) only one ETV Verification
Report and Statement will be issued during the 1-year period the report and
statement are valid.
! Verification Statements will not be issued for products that fail to meet the
NESHAP filtration efficiency requirements for either new or existing facilities.
8. ACQUISITION OF PAINT ARRESTORS FOR TESTING
The test arrestors will be supplied to the test laboratory directly from the manufacturer with a
letter signed by the manufacturer's chief executive officer, president, or other responsible
corporate representative, attesting that all components of the products being submitted for testing
comply with what is specified in the manufacturer's Bill of Materials for each arrestor. No
additional inspection was performed for these arrestors beyond that which is specified in the
manufacturer's normal manufacturing procedures. The manufacturer will supply the test
laboratory with 12 arrestors; from these 12, the test laboratory will randomly select six for testing.
The test laboratory will retain the six tested arrestors for a minimum of 6 months after testing.
The untested arrestors may be disposed of per agreement between the test laboratory and the
manufacturer.
9. REQUIREMENTS FOR PRODUCT LABELING
For purposes of product identification (by, for example, the test laboratory, auditors, end-user,
and local inspectors), the manufacturer must label or tag the arrestors in a reasonably permanent
manner to show the name of the manufacturer, model number, and date (year and month) of
manufacture.
For arrestors that are impractical to label directly (for example, it is often not practical to directly
label unframed loose fibrous or expanded paper pads that are frequently used as the first stage of
a multi-staged system), the manufacturer must label the smallest unit of packaging of the product
with this information.
If the arrestors are not labeled in the above manner, the test laboratory will reject the arrestors for
testing.
This labeling must be present on all products that the manufacturer claims to be covered by the
verification test; products that are not labeled in the above manner are not covered by the
verification test.
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10. PRODUCT CHANGE
Anytime a manufacturer changes a product, including process changes in production of raw
materials or arrestor assembly, the verification statement is no longer valid (for the new product),
and a new verification test is required if verification of the new product is desired. In the case of
paint overspray arrestors, there is a reasonable probability of an unintentional product change
occurring over a 12-month production cycle due to variations in assembly lines, media, and/or
components. To address this product variability, it is assumed that sufficient changes could occur
over a 12-month period that a new verification test is warranted. Therefore, a new verification
test will be required every 12 months for paint overspray arrestors bearing the same model
number as a previously verified manufacturer's product.
11. PRODUCT DEFINITION
Manufacturers often offer paint overspray arrestors in several standard sizes (e.g. nominal face
dimensions of 20" x 20" and 24" x 24") as well as in roll stock. Arrestors of different size may be
considered the same product when they have:
! the same media velocity (within 20%) for a 120 fpm face velocity
! the same media composition and structure
In multi-staged systems, the above requirements apply to each stage.
If the manufacturer knowingly changes the product, such as changing the filtration media
composition, media density, or media area, the changed product is defined as a new product. As
such, a verification test is required to verify the performance of the new product. The new
product must be given a new model number to distinguish it from the prior model.
12. TEST LABORATORIES
The APCT ETV program is open to multiple test laboratory participation. In addition to RTI, it
is anticipated that from one to three other laboratories will be available for testing. All
participating laboratories must meet the ETV program's QA requirements and accept on-site
audits by EPA and/or APCT personnel. The audits may include running one or more efficiency
tests on a reference filter(s) provided by the APCT program.
Test laboratory qualifications include:
Possession of the equipment and facilities required to perform Method 319 tests
Independence from manufacturers
ISO 9000 registration or ANSI/ASQ E4 compliance with specifications and guidelines
for Quality Systems for Environmental Data collection and Environmental Technology
Programs
EPA or APCT Approved Quality Management Plan (QMP)
EPA or APCT Approved Test/QA Plan
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Successful completion of on-site audit by APCT
Capability and agreement to conduct testing in accordance with APCT program-
approved protocol.
13. INITIATION OF VERIFICATION TESTING
To provide an orderly and controlled start to the ETV testing program, testing will begin in a
staged manner with two "rounds," a round being a group of arrestors that will go through the
ETV verification testing and reporting process as one batch. The first round (Round 1) of testing
will include one arrestor model from each manufacturer that chooses to participate. For Round 1,
the arrestors will be those intended to meet the NESHAP filtration efficiency requirements for
new facilities (i.e., Tables 1-4 presented earlier). To facilitate conducting these first tests and
working through the ETV process, the Round 1 tests will be performed at RTI. The Verification
Statements and Reports resulting from all the Round 1 tests will be released simultaneously.
For Round 2, the arrestors may be either those intended to meet the NESHAP filtration efficiency
requirements for existing or new sources (Tables 1 through 4 presented earlier). To facilitate
conducting these first tests and working through the ETV process, the Round 1 tests will be
performed at RTI. Again the statements and reports from all Round 2 tests will be issued
simultaneously.
To facilitate conducting these first rounds of testing and working through the ETV process,
testing for Rounds 1 and 2 tests will be performed at RTI. It is anticipated that after Round 2, all
participating test laboratories that meet the requirements of Section 12 will be eligible to perform
testing.
After Round 2, verification testing will proceed based on market demands (i.e., based on
manufacturer's requests for testing and the test laboratory's testing schedule). After Round 2, to
have an arrestor tested under this protocol, manufacturers must contact one of the approved
testing laboratories to arrange for testing. Each test laboratory is responsible for establishing its
own price and testing schedule for conducting an ETV verification test under this protocol. The
APCT program will maintain a list of approved testing laboratories that will be available on
request and on the ETV web site. Verification Statements and Reports will be released as they
are completed. When more than one product is evaluated within a round of tests, the Verification
Statements and Reports for all products tested in that round will be released simultaneously.
14. TEST LABORATORY SUBMITTAL OF RESULTS TO THE APCT PROGRAM
Upon completion of a verification test, the test laboratory will prepare a draft Verification
Statement and a draft Verification Report for the product following the format shown in
Appendices B and C, respectively. The test laboratory will submit the draft Verification
Statement and draft Verification Report to the APCT Test QA Officer. The submittal will be in
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both hard copy and electronic format (either Word or WordPerfect). Example reports will be
available in electronic form to participating laboratories to facilitate consistent formatting. The
APCT program will review the draft Verification Statement and Report, interact with the testing
laboratory as needed to resolve any questions or comments, and then forward the (revised)
documents to EPA for their review, and signature.
Test laboratories will retain all applicable testing data for a period of seven years in accordance
with the APCT QMP and Part B, Section 5.3 of EPA's quality and management plan. Among the
electronic and printed records that are covered in this section are the following items: test/QA
plans; verification reports, verification statements, raw data (including relevant calibration data),
and internal and external reviews and audit reports.
15. REQUIREMENT FOR TEST/QA PLAN
15.1 Quality Management
It is required that all laboratories participating in the paint overspray arrestor verification testing
program meet the QA/QC requirements defined below and have an adequate quality system to
manage the quality of work performed. Documentation and records management must be
performed in accordance with the EPA's QMP. Laboratories must also perform assessments and
allow audits by APCT program (headed by the APCT QA Officer) and EPA corresponding to
those specified in Section 16.
All participating laboratories must have an ISO 9000-accredited or ANSI E4-1994-compliant
quality system and an EPA- or APCT-approved QMP. EPA will approve RTFs APCT QMP;
the APCT program will approve the QMP from other participating test laboratories.
15.2 Quality Assurance
All verification testing will be carried out under approved Test/QA Plans that meet the
requirements of EPA Requirements for Quality Assurance Project Plans, EPA Publication No.
EPA QA/R-5, Draft, 1997 and Part B, Section 2.2.2 of EPA's quality and management plan.
These documents establish the requirements for Test/QA Plans and the companion guidance
document, EPA QA/G-5, provides guidance on how to meet these requirements. The Test/QA
Plan describes how Method 319 will be implemented at the individual laboratory and the steps the
laboratory will take to ensure acceptable data quality in the test results. RTFs Test/QA Plan,
under preparation, will be available to other laboratories for information purposes; however, each
laboratory will need to tailor its plan to its specific laboratory, equipment, instrumentation, and
procedures.
Each participating test laboratory must prepare a Test/QA Plan and submit it for approval. RTFs
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Test/QA Plan will be approved by EPA. Test/QA Plans for other participating laboratories will be
approved by the APCT program. The Test/QA Plan must be approved before the test laboratory
may begin verification testing.
A Test/QA Plan contains the following required elements. Not all elements listed are appropriate
to every test. Each Test/QA Plan will note and explain those elements that are not applicable.
Title and approval sheet
Table of contents, distribution list
Test description, test objectives
Identification of the critical measurements, data quality objectives, data quality
indicators, test schedule, and milestones
Test (including QA) organization and responsibilities
Documentation and records
Experimental design
Sampling procedures
Sample handling and custody
Analytical procedures
Test-specific procedures for assessing data quality indicators
Instrument calibration and its frequency
Data acquisition and data management procedures
Internal systems audits
Internal performance audits (where applicable)
Corrective action procedures (response actions to audit findings)
Assessment reports to EPA
Data reduction, data review, data validation, data reporting
Reporting of data quality indicators for critical measurements
Limitations of the data
Any deviations from Method 319 or this Test Protocol
The verification protocol is incorporated by reference into the Test/QA Plan. In addition to the
APCT QMP, a reference document available for writing test/QA plans is EPA/QA G-5, Guidance
for Quality Assurance Project Plans.
15.3 Standard Operating Procedures
If a level of detail beyond that of the Test/QA Plan is required for describing test activities (for
example operation of an instrument), a standard operating procedure may be written and attached
to the Test/QA Plan. The following topics, from EPA QA/G-6, Guidance for Development of
Standard Operating Procedures (SOPs), may be included (or a reference provided) in the
standard operating procedure:
Scope and applicability
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Summary of procedures
Definitions (acronyms, abbreviations, etc.)
Personnel qualifications
Health and safety warnings (Warn of activities which could result in possible personal
injury.)
Cautions (Warn of activities which could damage equipment, degrade samples, or
invalidate results.)
Apparatus and materials
Calibration
Sample collection, sample labeling, sample tracking
Handling and preservation of samples
Interferences
Sample preparation and analysis
Data acquisition, calculations and data reduction
Requirements for computer hardware and software used in data reduction and
reporting
Data management and records management
16 ASSESSMENT AND RESPONSE
The APCT program and/or EPA will conduct assessments to determine testing laboratory's
compliance with its Test/QA Plan. The requirement to conduct assessments is specified in EPA's
Quality Management Plan for the Pilot Period (1995 - 2000), and in RTI QMP. EPA will assess
RTFs compliance to RTFs Test/QA Plan. RTI will assess the compliance of other participating
laboratories to their Test/QA Plans. The assessments will be conducted in accordance to
Guidance on Technical Assessments for Environmental Data Operations, EPA Publication No.
EPA QA/G-7, August 1998, working draft.
16.1 Assessment types
Management system review - Audit of a quality system for conformance to a quality
management plan
Technical systems audit - Qualitative onsite audit of the physical setup of the test. The
auditors determine the compliance of testing personnel with the Test/QA Plan.
Performance evaluation audit - Quantitative audit in which measurement data are
independently obtained and compared with routinely obtained data to evaluate the
accuracy (bias and precision) of a measurement system.
Audit of data quality - Qualitative and quantitative audit in which data and data handling
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are reviewed and data quality and data usability are assessed.
16.2 Assessment frequency
Activities performed during technology verification performance operations that affect the quality
of the data shall be assessed regularly, and the findings reported to management to ensure that the
requirements stated in the generic verification protocols and the test/QA plans are being
implemented as prescribed.
The types and minimum frequency of assessments for the ETV program are listed in
Part A Section 9.0 of EPA's Quality Management Plan for the Pilot Period (1995 - 2000). The
pilot tests will have at minimum the following types and numbers of assessments:
management systems review - one independent assessment, as provided in the pilot
quality management plan
technical systems audits - self-assessments for each test as provided for in the test/QA
plan and independent assessments, twice per pilot
performance evaluation audits - self-assessments, as applicable, for each test as
provided in the test/QA and independent assessments, as applicable for each pilot
audits of data quality - self-assessments of at least 10% of all the verification data;
and independent assessment, as applicable for each pilot
The independent assessments of RTF s tests will be performed by EPA. The independent
assessments of other participating laboratories will be by the APCT program.
16.3 Response to assessment
Appropriate corrective actions shall be taken and their adequacy verified and documented in
response to the findings of the assessments. Data found to have been taken from non-conforming
equipment shall be evaluated to determine its impact on the quality of the data. The impact and
the action taken shall be documented. Assessments are conducted according to procedures
contained in the APCT QMP. Findings are provided in audit reports. Responses to adverse
findings are required within 10 working days of receiving the audit report. Follow-up by the
auditors and documentation of response are required.
17. REFERENCES
Method 319: Determination of Filtration Efficiency for Paint Overspray Arrestors. Code
of Federal Regulations, Volume 40, Part 63, Appendix A.
National Emission Standards for Hazardous Air Pollutants Aerospace Manufacturing
and Rework Facilities. Federal Register, 40 CFR Part 63.
U.S. EPA, Environmental Technology Verification Program: Quality and Management
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Page 19 of 19
Plan for the Pilot Period (1995-2000), May 1998.
U.S. EPA, EPA Requirements for Quality Management Plans, EPA QA/R-2. Draft
interim final, August 1994.
U.S. EPA, EPA Requirements for Quality Assurance Project Plans, EPA QA/R-5. Draft,
October 1997.
U.S. EPA, Guidance on Quality Assurance Project Plans, EPA QA/G-5.
EPA/600/R98/018. February 1998.
U.S. EPA Guidance on Technical Assessments for Environmental Data Operations, EPA
Publication No. EPA QA/G-7, August 1998, working draft.
U.S. EPA EPA Requirements for Quality Assurance Project Plans, EPA Publication No.
EPA QA/R-5, Draft, 1997.
ANSI/ASQC. Specifications and Guidelines for Quality Systems for Environmental Data
Collection and Environmental Technology Program; ANSI/ASQC E4. American Society
for Quality Control, Milwaukee, Wise., 1994.
ANSI/ASQC. Quality SystemsModel for Quality Assurance in Designing, Development,
Protection, Installing and Servicing; ANSI/ASQC Q9001-1994, American Society for
Quality Control, Milwaukee, Wise., 1994. This is the most recent U.S. version of the
International Organization for Standards ISO 9001 standard.
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APPENDIX A
METHOD 319
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Federal Register/Vol. 63, No. 59/Friday, March 27, 1998/Rules and Regulations 15027
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Appendix A to Part 63Test Methods
Method 319: Determination of Filtration
Efficiency for Paint Overspray Arrestors
1.0 Scope and Application.
1.1 This method applies to the
determination of the initial, particle size
dependent, filtration efficiency for paint
arrestors over the particle diameter range
from 0.3 to 10 |im. The method applies to
single and multiple stage paint arrestors or
paint arrestor media. The method is
applicable to efficiency determinations from
0 to 99 percent. Two test aerosols are used
one liquid phase and one solid phase. Oleic
acid, a low-volatility liquid (CAS Number
112-80-1), is used to simulate the behavior
of wet paint overspray. The solid-phase
aerosol is potassium chloride salt (KC1, CAS
Number 7447-40-7) and is used to simulate
the behavior of a dry overspray. The method
is limited to determination of the initial,
clean filtration efficiency of the arrestor.
Changes in efficiency (either increase or
decrease) due to the accumulation of paint
overspray on and within the arrestor are not
evaluated.
1.2 Efficiency is defined as 1
Penetration (e.g., 70 percent efficiency is
equal to 0.30 penetration). Penetration is
based on the ratio of the downstream particle
concentration to the upstream concentration.
It is often more useful, from a mathematical
or statistical point of view, to discuss the
upstream and downstream counts in terms of
penetration rather than the derived efficiency
value. Thus, this document uses both
penetration and efficiency as appropriate.
1.3 For a paint arrestor system or
subsystem which has been tested by this
method, adding additional filtration devices
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15028 Federal Register/Vol. 63, No. 59/Friday, March 27, 1998/Rules and Regulations
to the system or subsystem shall be assumed
to result In an efficiency of at least that of the
original system without the requirement for
additional testing. (For example, if the final
stage of a three-stage paint arrestor system
has been tested by itself, then the addition of
the other two stages shall be assumed to
maintain, as a minimum, the filtration
efficiency provided by the final stage alone.
Thus, in this example, if the final stage has
been shown to meet the filtration
requirements of Table 1 of § 63.745 of subpart
GG, then the final stage in combination with
any additional paint arrestor stages also
passes the filtration requirements.)
2.0 Summary of Method.
2.1 This method applies to the
determination of the fractional (i.e., particle-
size dependent) aerosol penetration of
several types of paint arrestors. Fractional
penetration is computed from aerosol
concentrations measured upstream and
downstream of an arrestor installed in a
laboratory test rig. The aerosol concentrations
upstream and downstream of the arrestors are
measured with an aerosol analyzer that
simultaneously counts and sizes the particles
in the aerosol stream. The aerosol analyzer
covers the particle diameter size range from
0.3 to 10 |im in a minimum of 12 contiguous
sizing channels. Each sizing channel covers
a narrow range of particle diameters. For
example, Channel 1 may cover from 0.3 to
0.4 |im, Channel 2 from 0.4 to 0.5 |im, * * *
By taking the ratio of the downstream to
upstream counts on a channel by channel
basis, the penetration is computed for each
of the sizing channels.
2.2 The upstream and downstream
aerosol measurements are made while
injecting the test aerosol into the air stream
upstream of the arrestor (ambient aerosol is
removed with HEPA filters on the inlet of the
test rig). This test aerosol spans the particle
size range from 0.3 to 10 |im and provides
sufficient upstream concentration in each of
the optical particle counter (OPC) sizing
channels to allow accurate calculation of
penetration, down to penetrations of
approximately 0.01 (i.e., 1 percent
penetration; 99 percent efficiency). Results
are presented as a graph and a data table
showing the aerodynamic particle diameter
and the corresponding fractional efficiency.
3.0 Definitions.
Aerodynamic Diameterdiameter of a unit
density sphere having the same aerodynamic
properties as the particle in question.
Efficiency is defined as equal to 1
Penetration.
Optical Particle Counter (OPC)an
instrument that counts particles by size using
light scattering. An OPC gives particle
diameters based on size, index of refraction,
and shape.
Penetrationthe fraction of the aerosol
that penetrates the filter at a given particle
diameter. Penetration equals the downstream
concentration divided by the upstream
concentration.
4.0 Interferences.
4.1 The influence of the known
interferences (particle losses) are negated by
correction of the data using blanks.
5.0 Safety.
5.1 There are no specific safety
precautions for this method above those of
good laboratory practice. This standard does
not purport to address all of the safety
problems, if any, associated with its use. It
is the responsibility of the user of this
method to establish appropriate safety and
health practices and determine the
applicability of regulatory limitations prior to
use.
6.0 Equipment and Supplies.
6.1 Test Facility. A schematic diagram of
a test duct used in the development of the
method is shown in Figure 319-1.
BILLING CODE 6560-50-P
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aerosol generation
spray nozzle
spray tower
(12 in. ID,
51 in. tall)
pressure drop manometer
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15030 Federal Register/Vol. 63, No. 59/Friday, March 27, 1998/Rules and Regulations
6.1.1 The test section, paint spray section,
and attached transitions are constructed of
stainless and galvanized steel. The upstream
and downstream ducting is 20 cm diameter
polyvinyl chloride (PVC). The upstream
transition provides a 7° angle of expansion to
provide a uniform air flow distribution to the
paint arrestors. Aerosol concentration is
measured upstream and downstream of the
test section to obtain the challenge and
penetrating aerosol concentrations,
respectively. Because the downstream
ducting runs back under the test section, the
challenge and penetrating aerosol taps are
located physically near each other, thereby
facilitating aerosol sampling and reducing
sample-line length. The inlet nozzles of the
upstream and downstream aerosol probes are
designed to yield isokinetic sampling
conditions.
6.1.2 The configuration and dimensions
of the test duct can deviate from those of
Figure 319-1 provided that the following key
elements are maintained: the test duct must
meet the criteria specified in Table 319-1;
the inlet air is HEPA filtered; the blower is
on the upstream side of the duct thereby
creating a positive pressure in the duct
relative to the surrounding room; the
challenge air has a temperature between 50°
and 100°F and a relative humidity of less
than 65 percent; the angle of the upstream
transition (if used) to the paint arrestor must
not exceed 7°; the angle of the downstream
Table 319-1.QC Control Limits
transition (if used) from the paint arrestor
must not exceed 30°; the test duct must
provide a means for mixing the challenge
aerosol with the upstream flow (in lieu of any
mixing device, a duct length of 15 duct
diameters fulfills this requirement); the test
duct must provide a means for mixing any
penetrating aerosol with the downstream
flow (in lieu of any mixing device, a duct
length of 15 duct diameters fulfills this
requirement); the test section must provide a
secure and leak-free mounting for single and
multiple stage arrestors; and the test duct
may utilize a 180° bend in the downstream
duct.
OPC zero count
OPC sizing accuracy check
Minimum counts per channel for challenge
aerosol.
Maximum particle concentration
Standard Deviation of Penetration
0% Penetration
100% PenetrationKCI
100% PenetrationOleic Acid
Frequency and description
Each Test. OPC samples HEPA-filtered air
Daily. Sample aerosolized PSL spheres
Each Test
Each Test. Needed to ensure OPC is not
overloaded.
Computed for each test based on the CV of
the upstream and downstream counts.
Monthly
Triplicate tests performed immediately before,
during, or after triplicate arrestor tests.
Triplicate tests performed immediately before,
during, or after triplicate arrestor tests.
Control limits
<50 counts per minute.
Peak of distribution should be in correct OPC
channel.
Minimum total of 500 particle counts per chan-
nel.
<10% of manufacturer's claimed upper limit
corresponding to a 10% count error.
<0.10 for 0.3 to 3 |im diameter.
<0.30 for >3 |im diameter.
<0.01.
0.3 to 1 urn: 0.90 to 1.10.
1 to 3 urn: 0.75 to 1.25.
3 to 10 urn: 0.50 to 1.50.
0.3 to 1 urn: 0.90 to 1.10.
1 to 3 urn: 0.75 to 1.25.
3 to 10 urn: 0.50 to 1.50.
6.2 Aerosol Generator. The aerosol
generator is used to produce a stable aerosol
covering the particle size range from 0.3 to
10 |im diameter. The generator used in the
development of this method consists of an air
atomizing nozzle positioned at the top of a
0.30-m (12-in.) diameter, 1.3-m (51-in.) tall,
acrylic, transparent, spray tower. This tower
allows larger sized particles, which would
otherwise foul the test duct and sample lines,
to fall out of the aerosol. It also adds drying
air to ensure that the KCI droplets dry to
solid salt particles. After generation, the
aerosol passes through an aerosol neutralizer
(Kr85 radioactive source) to neutralize any
electrostatic charge on the aerosol
(electrostatic charge is an unavoidable
consequence of most aerosol generation
methods). To improve the mixing of the
aerosol with the air stream, the aerosol is
injected counter to the airflow. Generators of
other designs may be used, but they must
produce a stable aerosol concentration over
the 0.3 to 10 |im diameter size range; provide
a means of ensuring the complete drying of
the KCI aerosol; and utilize a charge
neutralizer to neutralize any electrostatic
charge on the aerosol. The resultant
challenge aerosol must meet the minimum
count per channel and maximum
concentration criteria of Table 319-1.
6.3 Installation of Paint Arrestor. The
paint arrestor is to be installed in the test
duct in a manner that precludes air bypassing
the arrestor. Since arrestor media are often
sold unmounted, a mounting frame may be
used to provide back support for the media
in addition to sealing it into the duct. The
mounting frame for 20 in. x 20 in. arrestors
will have minimum open internal
dimensions of 18 in. square. Mounting
frames for 24 in. x 24 in. arrestors will have
minimum open internal dimensions of 22 in.
square. The open internal dimensions of the
mounting frame shall not be less than 75
percent of the approach duct dimensions.
6.4 Optical Particle Counter. The
upstream and downstream aerosol
concentrations are measured with a high-
resolution optical particle counter (OPC). To
ensure comparability of test results, the OPC
shall utilize an optical design based on wide-
angle light scattering and provided a
minimum of 12 contiguous particle sizing
channels from 0.3 to 10|im diameter (based
on response to PSL) where, for each channel,
the ratio of the diameter corresponding to the
upper channel bound to the lower channel
bound must not exceed 1.5.
6.5 Aerosol Sampling System. The
upstream and downstream sample lines must
be made of rigid electrically-grounded
metallic tubing having a smooth inside
surface, and they must be rigidly secured to
prevent movement during testing. The
upstream and downstream sample lines are
to be nominally identical in geometry. The
use of a short length (100 mm maximum) of
straight flexible tubing to make the final
connection to the OPC is acceptable. The
inlet nozzles of the upstream and
downstream probes must be sharp-edged and
of appropriate entrance diameter to maintain
isokinetic sampling within 20 percent of the
air velocity.
6.5.1 The sampling system may be
designed to acquire the upstream and
downstream samples using (a) sequential
upstream-downstream sampling with a single
OPC, (b) simultaneous upstream and
downstream sampling with two OPC's, or (c)
sequential upstream-downstream sampling
with two OPC's.
6.5.2 When two particle counters are
used to acquire the upstream and
downstream counts, they must be closely
matched in flowrate and optical design.
6.6 Airflow Monitor. The volumetric
airflow through the system shall be measured
with a calibrated orifice plate, flow nozzle, or
laminar flow element. The measurement
device must have an accuracy of 5 percent or
better.
7.0 Reagents and Standards.
7.1 The liquid test aerosol is reagent
grade, 98 percent pure, oleic acid (Table 319-
2). The solid test aerosol is KCI aerosolized
from a solution of KCI in water. In addition
to the test aerosol, a calibration aerosol of
monodisperse polystyrene latex (PSL)
spheres is used to verify the calibration of the
OPC.
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Table 319-2.Properties of the Test and Calibration Aerosols
Refractive index
Density,
g/cm3
Shape
Oleic Acid (liquid-phase challenge aerosol)
KCI (solid-phase challenge aerosol)
PSL (calibration aerosol)
1.46 nonabsorbing
1.49
1.59 nonabsorbing
0.89
1.98
1.05
Spherical.
Cubic or agglomerated cubes.
Spherical.
8.0 Sample Collection, Preservation, and
Storage.
8.1 In this test, all sampling occurs in
real-time, thus no samples are collected that
require preservation or storage during the
test. The paint arrestors are shipped and
stored to avoid structural damage or soiling.
Each arrestor may be shipped in its original
box from the manufacturer or similar
cardboard box. Arrestors are stored at the test
site in a location that keeps them clean and
dry. Each arrestor is clearly labeled for
tracking purposes.
9.0 Quality Control.
9.1 Table 319-1 lists the QC control
limits.
9.2 The standard deviation (a) of the
penetration (P) for a given test at each of the
15 OPC sizing channels is computed from the
coefficient of variation (CV, the standard
deviation divided by the mean) of the
upstream and downstream measurements as:
Op =
2
upstream
+ cvr
downstream J
(Eq. 319-1)
For a properly operating system, the standard
deviation of the penetration is < 0.10 at
particle diameters from 0.3 to 3 |im and less
than 0.30 at diameters > 3 |im.
9.3 Data Quality Objectives (DQO).
9.3.1 Fractional Penetration. From the
triplicate tests of each paint arrestor model,
the standard deviation for the penetration
measurements at each particle size (i.e., for
each sizing channel of the OPC) is computed
S =
[EfPi-p)2/^-1)
(Eq. 319-2)
where Pi represents an individual penetration
measurement, and P the average of the 3 (n
= 3) individual measurements.
9.3.2 Bias of the fractional penetration
values is determined from triplicate no-filter
and F1EPA filter tests. These tests determine
the measurement bias at 100 percent
penetration and 0 percent penetration,
respectively.
9.3.3 PSL-Equivalent Light Scattering
Diameter. The precision and bias of the OPC
sizing determination are based on sampling
a known diameter of PSL and noting whether
the particle counts peak in the correct
channel of the OPC. This is a pass/fail
measurement with no calculations involved.
9.3.4 Airflow. The precision of the
measurement must be within 5 percent of the
set point.
10.0 Calibration and Standardization.
10.1 Optical Particle Counter. The OPC
must have an up-to-date factory calibration.
Check the OPC zero at the beginning and end
of each test by sampling HEPA-filtered air.
Verify the sizing accuracy on a daily basis
(for days when tests are performed) with 1 -
size PSL spheres.
10.2 Airflow Measurement. Airflow
measurement devices must have an accuracy
of 5 percent or better. Manometers used in
conjunction with the orifice plate must be
inspected prior to use for proper level, zero,
and mechanical integrity. Tubing
connections to the manometer must be free
from kinks and have secure connections.
10.3 Pressure Drop. Measure pressure
drop across the paint arrestor with an
inclined manometer readable to within 0.01
in. H2O. Prior to use, the level and zero of
the manometer, and all tubing connections,
must be inspected and adjusted as needed.
11.0 Procedure.
11.1 Filtration Efficiency. For both the
oleic acid and KCI challenges, this procedure
is performed in triplicate using a new
arrestor for each test.
11.1.1 General Information and Test Duct
Preparation
11.1.1.1 Use the "Test Run Sheet" form
(Figure 319-2) to record the test information.
Run Sheet
Part 1. General Information
Date and Time:
Test Operator:
Test #:
Paint Arrestor:
Brand/Model
Atm. Pressure:.
_in. Hg
Arrestor Assigned ID #
Condition of arrestor (i.e., is there any
damage? Must be new condition to proceed):
Manometer zero and level confirmed?
Part 2. Clean Efficiency Test
Date and Time:
Optical Particle Counter:
20 min. warm up
Zero count (< 50 counts/min)
Daily PSL check
PSL Diam: |im
File name for OPC data:
Test Conditions:
Air Flow:
Temp & RH: Temp °F RH _
(From mercury barometer)
Aerosol Generator: (record all operating
parameters)
Test Aerosol:
(Oleic acid or KCI)
Arrestor:
Pressure drop: at start in. H2O
at end in. H2O
Condition of arrestor at end of test (note
any physical deterioration):
Figure 319-2. Test Run Sheet
Other report formats which contain the
same information are acceptable.
11.1.1.2 Record the date, time, test
operator, Test #, paint arrestor brand/model
and its assigned ID number. For tests with no
arrestor, record none.
11.1.1.3 Ensure that the arrestor is
undamaged and is in "new" condition.
11.1.1.4 Mount the arrestor in the
appropriate frame. Inspect for any airflow
leak paths.
11.1.1.5 Install frame-mounted arrestor in
the test duct. Examine the installed arrestor
to verify that it is sealed in the duct. For tests
with no arrestor, install the empty frame.
11.1.1.6 Visually confirm the manometer
zero and level. Adjust as needed.
11.1.2 Clean Efficiency Test.
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15032 Federal Register/Vol. 63, No. 59/Friday, March 27, 1998/Rules and Regulations
11.1.2.1 Record the date and time upon
beginning this section.
11.1.2.2 Optical Particle Counter.
11.1.2.2.1 General: Operate the OPC per
the manufacturer's instructions allowing a
minimum of 20 minutes warm up before
making any measurements.
11.1.2.2.2 Overload: The OPC will yield
inaccurate data if the aerosol concentration it
is attempting to measure exceeds its
operating limit. To ensure reliable
measurements, the maximum aerosol
concentration will not exceed 10 percent of
the manufacturer's claimed upper
concentration limit corresponding to a 10
percent count error. If this value is exceeded,
reduce the aerosol concentration until the
acceptable conditions are met.
11.1.2.2.3 Zero Count: Connect a HEP A
capsule to the inlet of the OPC and obtain
printouts for three samples (each a minimum
of 1 -minute each). Record maximum
cumulative zero count. If the count rate
exceeds 50 counts per minute, the OPC
requires servicing before continuing.
11.1.2.2.4 PSL Check of OPC Calibration:
Confirm the calibration of the OPC by
sampling a known size PSL aerosol.
Aerosolize the PSL using an appropriate
nebulizer. Record whether the peak count is
observed in the proper channel. If the peak
is not seen in the appropriate channel, have
the OPC recalibrated.
11.1.2.3 Test Conditions:
11.1.2.3.1 Airflow: The test airflow
corresponds to a nominal face velocity of 120
FPM through the arrestor. For arrestors
having nominal 20 in. x 20 in. face
dimensions, this measurement corresponds
to an airflow of 333 cfm. For arrestors having
nominal face dimensions of 24 in. x 24 in.,
this measurement corresponds to an airflow
of 480 cfm.
11.1.2.3.2 Temperature and Relative
Humidity: The temperature and relative
humidity of the challenge air stream will be
measured to within an accuracy of +/ 2°F
and +/ 10 percent RH. To protect the probe
from fouling, it may be removed during
periods of aerosol generation.
11.1.2.3.3 Barometric Pressure: Use a
mercury barometer. Record the atmospheric
pressure.
11.1.2.4 Upstream and Downstream
Background Counts.
11.1.2.4.1 With the arrestor installed in
the test duct and the airflow set at the proper
value, turn on the data acquisition computer
and bring up the data acquisition program.
11.1.2.4.2 Set the OPC settings for the
appropriate test sample duration with output
for both printer and computer data
collection.
11.1.2.4.3 Obtain one set of upstream-
downstream background measurements.
11.1.2.4.4 After obtaining the upstream-
downstream measurements, stop data
acquisition.
11.1.2.5 Efficiency Measurements:
11.1.2.5.1 Record the arrestor pressure
drop.
11.1.2.5.2 Turn on the Aerosol Generator.
Begin aerosol generation and record the
operating parameters.
11.1.2.5.3 Monitor the particle counts.
Allow a minimum of 5 minutes for the
generator to stabilize.
11.1.2.5.4 Confirm that the total particle
count does not exceed the predetermined
upper limit. Adjust generator as needed.
11.1.2.5.5 Confirm that a minimum of 50
particle counts are measured in the upstream
sample in each of the OPC channels per
sample. (A minimum of 50 counts per
channel per sample will yield the required
minimum 500 counts per channel total for
the 10 upstream samples as specified in
Table 319-1.) Adjust generator or sample
time as needed.
11.1.2.5.6 If you are unable to obtain a
stable concentration within the concentration
limit and with the 50 count minimum per
channel, adjust the aerosol generator.
11.1.2.5.7 When the counts are stable,
perform repeated upstream-downstream
sampling until 10 upstream-downstream
measurements are obtained.
11.1.2.5.8 After collection of the 10
upstream-downstream samples, stop data
acquisition and allow 2 more minutes for
final purging of generator.
11.1.2.5.9 Obtain one additional set of
upstream-downstream background samples.
11.1.2.5.10 After obtaining the upstream-
downstream background samples, stop data
acquisition.
11.1.2.5.11 Record the arrestor pressure
drop.
11.1.2.5.12 Turn off blower.
11.1.2.5.13 Remove the paint arrestor
assembly from the test duct. Note any signs
of physical deterioration.
11.1.2.5.14 Remove the arrestor from the
frame and place the arrestor in an
appropriate storage bag.
11.2 Control Test: 100 Percent
Penetration Test. A 100 percent penetration
test must be performed immediately before
each individual paint arrestor test using the
same challenge aerosol substance (i.e., oleic
acid or KC1) as to be used in the arrestor test.
These tests are performed with no arrestor
installed in the test housing. This test is a
relatively stringent test of the adequacy of the
overall duct, sampling, measurement, and
aerosol generation system. The test is
performed as a normal penetration test
except the paint arrestor is not used. A
perfect system would yield a measured
penetration of 1 at all particle sizes.
Deviations from 1 can occur due to particle
losses in the duct, differences in the degree
of aerosol uniformity (i.e., mixing) at the
upstream and downstream probes, and
differences in particle transport efficiency in
the upstream and downstream sampling
lines.
11.3 Control Test: 0 Percent Penetration.
One 0 percent penetration test must be
performed at least monthly during testing.
The test is performed by using a HEPA filter
rather than a paint arrestor. This test assesses
the adequacy of the instrument response time
and sample line lag.
12.0 Data Analysis and Calculations.
12.1 Analysis. The analytical procedures
for the fractional penetration and flow
velocity measurements are described in
Section 11. Note that the primary
measurements, those of the upstream and
downstream aerosol concentrations, are
performed with the OPC which acquires the
sample and analyzes it in real time. Because
all the test data are collected in real time,
there are no analytical procedures performed
subsequent to the actual test, only data
analysis.
12.2 Calculations.
12.2.1 Penetration.
Nomenclature
U = Upstream particle count
D = Downstream particle count
Ub = Upstream background count
Db = Downstream background count
Pioo =100 percent penetration value
determined immediately prior to the
arrestor test computed for each channel
as:
P = Penetration of the arrestor corrected for
P100
o = Sample standard deviation
CV = Coefficient of variation = o/mean
E = Efficiency.
Overbar denotes arithmetic mean of
quantity.
Analysis of each test involves the following
quantities:
Pioo value for each sizing channel from
the 100 percent penetration control test,
2 upstream background values,
2 downstream background values,
10 upstream values with aerosol
generator on, and
10 downstream values with aerosol
generator on.
Using the values associated with each
sizing channel, the penetration associated
with each particle-sizing channel is
calculated as:
[(D-Db)l
P=lWr"
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Federal Register/Vol. 63, No. 59/Friday, March 27, 1998/Rules and Regulations 15033
Da, = Dpi,t.,iJPp-"' Cgag^ (Eq. 319-5)
\ Po Aero
Where:
po = unit density of 1 g/cm3.
pparticie = the density of the particle, 0.89 g/
cm3 for oleic acid.
CCFphysicai = the Cunningham Correction
Factor at DphySicai.
CCFAero = the Cunningham Correction Factor
at DAero.
12.4 Presentation of Results. For a given
arrestor, results will be presented for:
Triplicate arrestor tests with the liquid-
phase challenge aerosol,
Triplicate arrestor tests with the solid-
phase challenge aerosol,
Triplicate 100 percent penetration tests
with the liquid-phase challenge aerosol,
Triplicate 100 percent penetration tests
with the solid-phase challenge aerosol, and
One 0 percent filter test (using either the
liquid-phase or solid-phase aerosol and
performed at least monthly).
12.4.1 Results for the paint arrestor test
must be presented in both graphical and
tabular form. The X-axis of the graph will be
a logarithmic scale of aerodynamic diameter
from 0.1 to 100 |im. The Y-axis will be
efficiency (%) on a linear scale from 0 to 100.
Plots for each individual run and a plot of
the average of triplicate solid-phase and of
the average triplicate liquid-phase tests must
be prepared. All plots are to be based on
point-to-point plotting (i.e., no curve fitting
is to be used). The data are to be plotted
based on the geometric mean diameter of
each of the OPC's sizing channels.
12.4.2 Tabulated data from each test must
be provided. The data must include the
upper and lower diameter bound and
geometric mean diameter of each of the OPC
sizing channels, the background particle
counts for each channel for each sample, the
upstream particle counts for each channel for
each sample, the downstream particle counts
for each channel for each sample, the 100
percent penetration values computed for
each channel, and the 0 percent penetration
values computed for each channel.
13.0 Pollution Prevention.
13.1 The quantities of materials to be
aerosolized should be prepared in accord
with the amount needed for the current tests
so as to prevent wasteful excess.
14.0 Waste Management.
14.1 Paint arrestors may be returned to
originator, if requested, or disposed of with
regular laboratory waste.
15.0 References.
1. Hanley, J.T., D.D. Smith and L. Cox.
"Fractional Penetration of Paint Overspray
Arrestors, Draft Final Report," EPA
Cooperative Agreement CR-817083-01-0,
January 1994.
2. Hanley, J.T., D.D. Smith, and D.S. Ensor.
"Define a Fractional Efficiency Test Method
that is Compatible with Particulate Removal
Air Cleaners Used in General Ventilation,"
Final Report, 671-RP, American Society of
Heating, Refrigerating, and Air-Conditioning
Engineers, Inc., December 1993.
3. "Project Work and Quality Assurance
Plan: Fractional Penetration of Paint
Overspray Arrestors, Category II," EPA
Cooperative Agreement No. CR-817083, July
1994.
[FR Doc. 98-6999 Filed 3-26-98; 8:45 am]
BILLING CODE 6560-50-P
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