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Prepared for
U.S. ENVIRONMENTAL PROTECTION AGENCY
ANN ARBOR, MICHIGAN
CONTRACT NUMBER 68-02-3507
EPA Project Officer
John M. Cabaniss
January, 1982
REVIEW OF THE MASSACHUSETTS
VEHICLE EMISSIONS TEST EQUIPMENT
FINAL REPORT
by
BOOZ, ALLEN & HAMILTON Inc
4330 East West Highway
Bethesda, Maryland 20814
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TABLE OF CONTENTS
Page
Number
SUMMARY
APPENDIX A
APPENDIX B
APPENDIX C
Three Technical Memoranda:
Review and Development of Basic
Analyzer Specifications A-l
Development of a Quality
Assurance Testing Program A-17
Schedule for Analyzer Development
and Distribution A-25
Emission Analyzer Technical and
Performance Specifications B-l
Proposal Evaluation Methodology and
Instructions C-l
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DISCLAIMER
This Final Report was furnished to the U.S.
Environmental Protection Agency by Booz'Allen & Hamilton
Inc., Bethesda, Maryland 20814, in fulfillment of Contract
Number 68-02-3507. The opinions, findings, and conclusions
expressed are those of the authors and not necessarily those
those of the Environmental Protection Agency or of cooperat-
ing agencies. Mention of company or product names is not to
be considered as an endorsement by the Environmental
Protection Agency.
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SUMMARY
This document is the final report for a "Review of the
Massachusetts Equipment Specification" performed by
Booz'Allen & Hamilton Inc., for the Environmental
Protection Agency (EPA) under contract number 68-02-3507.
The work was performed in close consultation with the
Massachusetts Department of Environmental Quality
Engineering (DEQE).
The study involved reviewing the Massachusetts draft
computerized emission analyzer specification and then
developing a final equipment specification as well as
specifications for a quality assurance (QA) program, a
recommended procurement schedule and a set of proposal
evaluation criteria. This section of the report provides
an overview of the study objectives, methodology and
results. Three technical appendices contain technical
documentation prepared during the course of the study
(Appendix A), the final equipment specification (Appendix
B) and recommended proposal evaluation procedures
(Appendix C).
1. OBJECTIVES OF THE STUDY
The objectives of this study were to provide
assistance to the Commonwealth of Massachusetts in (1)
developing a request for proposal (RFP) for the State's
computerized emission analyzer and (2) providing a
methodology for evaluating the proposals received in
response to the RFP. Specific objectives were to:
Review the Massachusetts draft emissions analyzer
technical and performance specifications, modify
these specifications as necessary and prepare a
final equipment specification (Task 1)
Develop a manufacturing quality assurance (QA)
program for the emissions analyzers (Task 2)
Develop a schedule for the development and
distribution of the computerized emission
analyzers (Task 3)
Prepare the relevant sections of the RFP (Task 4)
Develop a methodology for use by Massachusetts in
evaluating proposals received in response to the
RFP (Task 5) .
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2. STUDY METHODOLOGY
The general methodology of the study combined (1)
engineering analysis of selected analyzer specifications and
QA procedures, (2) interviews with equipment manufacturers
and industry representatives, (3) an analysis of the
manufacturers' comments and (4) an analysis of the technical
feasibility, costs and lead times for various equipment
options. The specific approach applied in each task area is
described below.
(1) Task-1 - Review the Existing Draft Analyzer
Specification and Prepare a Final Equipment
Specification
The approach to this task was organized in three
steps as follows:
The Massachusetts draft analyzer specification
was compared with the recommended EPA
specification for computerized emissions
analyzers, the New York and California Bureau
of Auto Repair (BAR) '80 specifications, and
the requirements of the EPA promulgated
207 (b) emissions performance warranty
regulation. The purpose of the comparison was
to identify "variances" between the draft
Massachusetts specification and the
aforementioned analyzer specifications/207 (b)
warranty regulations.
Inquiries to the emission analyzer
manufacturing industry were made to determine
the technical feasibility, costs and lead
times for equipment specifications found to be
at variance with the previously bid
specifications. Representatives of four
equipment manufacturers (Sun, Hamilton Test
Systems, FMC and Bear), the Equipment and Tool
Institute (ETI), the State of New York and the
EPA were interviewed on this subject.
The results from the manufacturing industry
interviews and comparisons of the analyzer
specifications were analyzed, and recommenda-
tions for the final Massachusetts equipment
specification developed.
Appendix A contains documentation of these
recommendations.
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(2) Task 2 - Develop a Manufacturing Quality Assurance
Testing Program
The quality assurance (QA) procedures recommended
by the EPA and implemented by the State of New York were
analyzed and used as models for developing the
Massachusetts QA testing program. Representatives of
EPA, the New York Emissions Task Force and the New York
Department of Environmental Conservation were
interviewed regarding the merits and weaknesses of the
respective QA procedures. Comments from the analyzer
manufacturers on alternative QA procedures were also
considered. The comments received from EPA, New York
and the manufacturers were analyzed and a set of
recommendations and action items prepared for
Massachusetts. The final recommended QA procedures were
incorporated into the equipment specification section of
the RFP.
(3) Task 3 - Develop a Schedule for Analyzer
Development and Distribution
A schedule was constructed for the development and
distribution of the computerized emission analyzers.
The schedule was based on discussions with the analyzer
manufacturers and the Equipment and Tool Institute and
on the following analyses:
A review of the manufacturers' lead time
requirements for analyzer development
A review of the time required for analyzer
manufacture and certification
An evaluation of the time requirements for
marketing the analyzers
An analysis of the proper sequencing of the
analyzer development and distribution efforts
Massachusetts DEQE requirements for handling
the procurement.
The final recommended schedule is contained in
Appendix A.
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(4) Task 4 - Prepare the Relevant Sections of the RFP
During Task 4, a chapter of the Massachusetts RFP
addressing the following was finalized:
Analyzer specifications
Manufacturing QA procedures
Analyzer in-use QA/QC procedures.
The chapter was written in a manner consistent in format
with other sections written by the Massachusetts DEQE.
It is reproduced in Appendix B.
(5) Task 5 - Develop a Methodology for Evaluating
Bidders' Responses to the RFP
Proposal evaluation criteria were developed based
on an evaluation of the selection criteria in the draft
Massachusetts RFP and utilized in the New York emission
analyzer procurement, as well as the experience of other
states. Booz, Allen's experience in evaluating manufac-
turers' technical and cost proposals for the U.S.
Departments of Transportation and Energy was useful in
developing the overall proposal evaluation methodology.
Standard government procurement procedures were utilized
as much as possible. Close contact was maintained with
the Massachusetts DEQE throughout the development of the
proposal evaluation methodology. The methodology is
reproduced in Appendix C.
3. STUDY RESULTS
Recommendations for the Massachusetts equipment specifi-
cations and quality assurance provisions were presented
during the study and are reproduced in Appendix A. The
recommendations were based on an analysis of the schedule,
costs and benefits of available options, and with the intent
of attracting as many bidders as possible. This section
briefly summarizes the principal results of the analyses in
each area.
(1) Analyzer Specifications
Based on a detailed review of the existing analyzer
specifications and on an analysis of comments received
from knowledgeable industry and government sources, the
following recommendations were made regarding the
analyzer specifications:
Require the analyzer to have a capability for
(1) automatically recording, storing and
printing out test results, (2) measuring
engine speed, and (3) measuring
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Require the analyzer to have (1) a switch or
selector button that enables the analyzer to
be used for vehicle repair as well as inspec-
tion, (2) anti-tampering features and (3)
system diagnostic features.
Require an automatic read system (i.e. a
system whereby the analyzer averages the gas
samples over a specified time period).
Require fully automatic gas span, leak and HC
hang-up checks.
Use EPA's performance specification for all
parameters except the instrument accuracy
profile and drift requirements. For these two
specifications the BAR '80 provisions were
recommended.
(2) Quality Assurance Procedures
Recommendations on manufacturing quality assurance
(QA) procedures were based on evaluation of the EPA
recommended procedure and comments received from
manufacturers. Recommendations to Massachusetts on
manufacturing QA procedures included the following:
Adopt the revised EPA QA procedure for use in
Massachusetts
Specify in the RFP the government agency which
will be responsible for evaluating the QA test
results and engineering reports.
Allow bidders to suggest alternative QA
procedures that can be performed in a shorter
time frame or at a lower cost than the EPA
procedure, yet provide equivalent QA test data
Do not require certification by the California
BAR in addition to the EPA certification
Require a performance bond from the successful
bidder
Require the contractor to assume responsibil-
ity for the performance and maintenance of the
equipment in the field and to pay a penalty
for excessive analyzer downtime.
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APPENDIX A
THREE TECHNICAL MEMORANDA
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APPENDIX A
THREE TECHNICAL MEMORANDA
This appendix contains three technical memoranda which were
developed to document the results of the first three tasks of the
study. They include the following:
Review and Development of Basic Analyzer Specifications
(Task 1)
Development of a Quality Assurance Testing Program
(Task 2)
Schedule for Analyzer Development and Distribution
(Task 3) .
Parenthetical notations have been included at various places
throughout this appendix in order to more fully explain how the
final equipment specifications evolved from the technical
memoranda in this appendix. These technical memoranda were
deliberative documents which led to further investigation of
certain analyzer issues. In some cases, new information resulted
in changes in some of the positions taken in the technical
memoranda. While such changes were reflected in the final
specifications, they were not otherwise documented.
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TECHNICAL MEMORANDUM ON THE REVIEW AND DEVELOPMENT
OF BASIC ANALYZER SPECIFICATIONS
This technical memorandum summarizes the results of Task 1 of
a study to provide assistance to the Commonwealth of Massachusetts
in developing a request for proposal (RFP) for their I/M
computerized emissions analyzer. The objective of Task 1 was to
review and develop the basic specification for the computerized
emissions analyzer. The methodology used to accomplish this
objective involved three steps as follows:
Step 1; Compare the Massachusetts draft analyzer
specification with the recommended EPA specification for
computerized emissions analyzers, the New York and BAR
'80 analyzer specifications, and the requirements of the
207(b) emissions performance warranty regulation.The
purpose of this comparison was to identify "variances"
between the draft Massachusetts specification and the
aforementioned analyzer specifications/207(b) warranty
regulation requirements.
Step 2; Contact representatives of various manufac-
turers of infra-red exhaust emissions analyzers, the
Equipment and Tool Institute (ETI) and the State of New
York.The purpose of these contacts was to gather
first-hand information on the position of the industry
regarding what would be acceptable specifications and
the experience of that one state (i.e., New York) with a
decentralized I/M program employing computerized
emissions analyzers. In total, representatives of four
equipment manufacturers (Sun, Hamilton Test Systems, FMC
and Bear), the ETI and the State of New York were
interviewed.
Step 3; Analyze the comments received from industry/
state representatives and develop recommendations.
Based on the comments received from industry/state
representatives regarding the technical feasibility,
costs and lead times associated with each of the
variances, combined with our understanding of the
intended purpose/scope and desired operational features
of the Massachusetts I/M program, recommendations were
developed. In developing the recommended analyzer
specification, the EPA specification was used whenever
possible unless supporting justification for not using
it could be established. In those cases, an alternative
specification is proposed.
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The remainder of this technical memorandum describes the
results of this three step methodology. Results are presented
under the following headings:
Comparison of the Massachusetts Draft Analyzer
Specification, the EPA Computerized Analyzer
Specification, the New York and BAR '80 Analyzer
Specification, and the 207(b) Warranty Regulation
Industry/State Comments Regarding What Would Be An
Acceptable/Reasonable Analyzer Specification
Analysis of Industry/State Comments and Recommendations.
COMPARISON OF MASSACHUSETTS DRAFT ANALYZER SPECIFICATION, THE EPA
COMPUTERIZED ANALYZER SPECIFICATION, NEW YORK AND BAR '80 ANALYZER
SPECIFICATIONS, AND THE 207(b) WARRANTY REGULATION
As described above, the first step of this task was to
compare the Massachusetts draft analyzer specification with the
EPA computerized analyzer specification, the New York and BAR '80
analyzer specifications, and the 207(b) warranty regulation. The
results of this comparison are described below.
Comparison of Massachusetts (Draft), EPA, New York and BAR '80
Analyzer Specifications with 207(b) Warranty Regulation
Requirements
Based on analysis of the aforementioned specifications and
the 207(b) warranty regulations, it was observed that the EPA
recommended analyzer specification is the only specification that
fully complies with the requirements of the 207(b) warranty
regulation. The BAR '80 and New York analyzer specifications
comply with all requirements of 207(b) except the leak and span
check frequencies. The 207(b) warranty regulation requires weekly
leak and span checks while BAR '80 and New York require the
following:
BAR '80; Calls for the leak and span checks to be
controlled by the operator, but requires the operator to
maintain a log book that notes the date, time and
results of all checks.
New York; Requires leak and span checks to be performed
monthly by the vendor of the analyzers (i.e., Hamilton
Test Systems).
Comparison of Massachusetts (Draft), EPA, New York and BAR '80
Analyzer Specifications
Comparison of these four specifications in terms of technical
content revealed that the most significant difference in the
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specifications was in the area of automation. The EPA recommends
as a "fail safe" measure (i.e., to prevent improper operation of
the analyzer) that a number of analyzer features be automated
(i.e., controlled by an on-board computer/microprocesser). These
features include zero/span check, leak check, HC hang-up, read
system (i.e., sample averaging) and test sequencing. Neither the
BAR '80 specification nor the New York specification require these
automated features.* In addition, as a convenience measure, the
EPA also suggests that the analyzer be capable of collecting and
storing the emissions test results. Only the New York specifica-
tion also requires this feature; the BAR '80 specification does
not.
Other major differences (variances) between these specifica-
tions include the following:
As additional fail safe measures, the EPA recommends
that the analyzer be equipped with (1) a printer, (2) a
switch or selector button that enables the analyzer to
be used for vehicle repair as well as inspection, (3)
anti-tamper ing features and (4) system diagnostic
testing features. The BAR '80 specification doesn't
require any of these features. The New York
specification, however, requires all these features.
To provide more capability, the EPA suggests that the
analyzer be equipped with a C02 analyzer and a
tachometer. Again the BAR '80 specification doesn't
require either of these features while the New York
specification requires both features.**
In the area of analyzer performance, the EPA specifica-
tion is slightly more stringent than the BAR '80/New
York specification in the areas of calibration, drift,
and HC hang-up, and slightly less stringent in the areas
of interferences, leak detection, propane/hexane conver-
sion and analyzer response time. Only very minor or no
differences exist between these three specifications in
other performance areas.
Based on a line-by-line comparison of the specifications, the
Massachusetts draft specification requires all the fail safe/
convenience features suggested by the EPA specification but is
* The New York specification requires test sequencing but not
exactly the same as that specified in the EPA specification.
** The New York specification is essentially the BAR '80
specification with some automated features. The one
exception is that the BAR '80 requirement for on-board gas
was eliminated.
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more closely tied in the area of analyzer performance to the New
York/BAR '80 specification (although variations do exist between
the Massachusetts draft specification and New York/BAR '80
specification). Major deviations between the Massachusetts draft
specification, and the New York, BAR '80 and EPA specifications
are in the areas of analyzer response time and the range of
ambient temperatures in which the analyzer is required to operate.
INDUSTRY/STATE COMMENTS REGARDING WHAT WOULD BE AN ACCEPTABLE/
REASONABLE ANALYZER SPECIFICATION
As indicated in the previous section, the Massachuetts draft
specification primarily deviated from the EPA recommended
specification in the area of analyzer performance. It included
most of EPA's recommendations on the automated/convenience
features. However, because of the limited field experience with
some of the automated/convenience features, discussions were held
with industry/state representatives on both these features, as
well as the differences in the performance specifications. The
comments received by industry/state representatives in these areas
are discussed below.*
Automation
The position of the manufacturing industry with regard to the
EPA analyzer specifications for automation is that certain of the
specifications are beyond current analyzer technology. The
addition of the specified functions is technically feasible but
will require an investment in time and money before they can be
achieved.
The fundamental source of automated analyzer functions is the
microprocessor. Current manufacturing capability includes
companies that already build analyzers equipped with
microprocessors (Sun, Hamilton Test Systems) and those that do not
(Bear, FMC, other U.S. manufacturers). Companies which have not
yet accomplished integration of the microprocessor into the
analyzer must undertake a substantial development effort just to
provide basic microprocessor controlled functions. Such basic
functions specified by EPA include automatic test sequencing and
automatic data collection. Sun and Hamilton Test Systems
currently offer these capabilities.
Data from the New York program which could provide key
answers to the calibration requirements of analyzers in the
decentralized program will not be available for some time.
At some point this data should reveal how the monthly
calibration is working and whether in fact more or less
frequent gas calibrations are necessary.
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Four additional EPA specifications are beyond the technology
currently offered by any manufacturer. These include automatic
gas spanning, automatic leak detection, automatic hang-up
detection and an automatic read system (calculates an integration
test value from several samples rather than giving the value of a
single sample). The addition of these features to Sun and Hamilton
Test's equipment is technically feasible but will require a re-
search and development effort. The other manufacturers must first
integrate microprocessors into their analyzers before they can
even begin the development of these more sophisticated functions.
(Note: Continued research into the feasibility, costs, and time
restraints of these four automated features resulted in subsequent
findings that full automation was both feasible and cost-effective.
Therefore, the final equipment specification contains provisions
for all four of these features.)
Automatic Gas Span
All of the manufacturers interviewed questioned the
cost-effectiveness of equipping the analyzer with a computer
controlled gas spanning feature. While technically feasible, the
manufacturers interviewed indicated that:
The hardware necessary to facilitate automatic gas
spanning is both complicated and costly and thus may add
appreciably to the base cost of the analyzer
Required software programs must be developed and
tested. This task represents the longest estimated lead
time -- from 6 to 18 months depending on the
manufacturer.
Although not a limiting factor, several of the manufacturers also
indicated that the amount of on-board calibration gas storage that
would be required in an automatic spanning program would pose a
potential problem. In addition, several of the manufacturers
also felt that electrical spanning techniques which can be
automated were adequate.
All of the manufacturers felt that a workable and more
cost-effective compromise between a completely automatic gas span
and a manual operation would be a semi-automatic calibration
procedure. In this concept the internal plumbing, valving,
electrical controls and gas storage requirements would be
essentially the same as in the automatic version but the test
would be initiated by the operator (i.e., by pushing a button or
flipping a switch). Software could also be developed that notes
when the operator performed the calibration. Opinions of the
manufacturers vary on the merits of this approach. All agree,
however, that the costs and lead time would be considerably less
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since little or no programming would be required (depending on
whether it was desirable to note when the calibration was
performed). The system would be very similar to the BAR '80
requirements that now exist.
Automatic Leak Check
For essentially the same reasons discussed above for
automatic gas spanning all the manufacturers interviewed felt that
a completely automatic leak check, while technically feasible, was
not cost-effective. All felt that the semi-automatic leak check
procedure recommended in EPA's revised specifications was more
practical for a decentralized program. This procedure requires
that span gas be available on the analyzer and that some
mechanical provision be made for introducing the gas to the probe
in which the operator would be involved (i.e., the operator would
have to push a button or flip a switch).
In a practical sense, this procedure is tied to the gas span
procedure. If the analyzer is designed and equipped for automatic
or semi-automatic gas spanning, it is relatively simple for the
manufacturers to provide an automatic or semi-automatic gas system
leak check. What is needed is additional software. As was
discussed for the semi-automatic span check, software could be
developed that (1) notes every time the leak check is performed,
and (2) stores this information on tape. Depending on the
manufacturer, this can be either a very costly or a relatively
inexpensive development effort. For Hamilton Standard and Sun
whose analyzers are already equipped with microprocessors, this is
a relatively inexpensive development effort. For Bear and FMC
whose analyzers are not equipped with on-board microprocessors, up
to 18 months of effort would be required to develop the software
at a considerable expense.
HC Hang-Up
The possibility of HC hang-up in the internal and external
flow system is a factor that must be considered in the analyzer
design. Not only should design practices and material be
incorporated to minimize the hang-up, but procedures for
evaluating the amount hang-up be developed, these procedures can
be manual or semi-automated. The manufacturer is free to choose
the actual system hardware and approach. The main advantage of
the hang-up check is found in the centralized system where the
purge time between the completion of one test and the beginning of
another must be minimized. In this instance the ideal system
would be automatic and include a lock out feature that would
prevent the next test from beginning until the HC hang-up was
below the prescribed limit. In a decentralized inspection
program, the manufacturers feel that the frequency of testing
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minimizes the need for automatic testing if not the hang-up test
itself. New York State does not require the test or the equipment
to do it. (Note: In a decentralized I/M program, the analyzer
will not only be used for emissions inspections but also for
diagnosing and repairing failed vehicles and for tune-up
adjustments. In these repair modes, the analyzer may be subjected
to extended exposure to potentially high concentrations of
hydrocarbon emissions, thus increasing the likelihood of a
hydrocarbon hang-up problem. The final Massachusetts equipment
specifications include provisions for this check to be performed
automatically.)
Automatic Read System
The EPA computerized analyzer equipment specification calls
for a system whereby continuous samples are taken by the analyzer
and averaged over a 15 second time interval. Neither the BAR '80
nor New York analyzer specifications require this feature. The
advantage of the feature is that it enhances the accuracy of the
test results and reduces the errors of omission and commission.
It accomplishes this by minimizing the influence of "outlier"
samples on the test outcome, i.e., if a single gas sample is taken
as the sole determining measure of the "cleanliness" of a vehicle,
and if this single sample happens to be an "outlier," it may cause
a vehicle which should have failed the inspection to pass or vice
versa.
The primary disadvantage of this feature is that it increases
the base cost of the analyzer (although not significantly
according to the manufacturers interviewed). Another considera-
tion, however, is that while there are variations in HC and CO
readings while the vehicle is idling, only in rare cases will the
readings vary enough so that a car which should have failed the
inspection will be passed or vice versa. Thus, the added benefit
of this feature must be questioned in light of the fact that it
serves to protect only a small percentage of the vehicles
subjected to the mandatory inspection program.
Other Fail Safe/Convenience Features
Most of the fail safe/convenience features (i.e., printer,
vehicle diagnosis capability, anti-tampering feature, self
diagnostic capability, C02 analyzer and tachometer) recommended
by the EPA are features which are either presently offered by
analyzer manufacturers or could be readily offered with minor
development effort. For example, Hamilton Test Systems and Sun
offer all of the features identified above, while FMC and Bear
only offer the printer as an option.
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In discussing the necessity of these features, all agreed
that the printer was needed from a public relations standpoint,
while Hamilton and Sun (since they already have a microprocessor
capability) saw the need for anti-tampering provisions and system
self diagnostic features. All four manufacturers also saw the
benefit of incorporating a vehicle diagnostic capability within
the analyzer (i.e., adding a switch or selector button that
enables the analyzer to be used for vehicle repair as well as
inspection) since this capability enhances the marketability of
the analyzer. Those features questioned by the manufacturers in
terms of costs and benefits were the C02 analyzer and
tachometer. Each is discussed below.
Tachometer
All four manufacturers were found to offer an engine speed
readout capability with their analyzer, however, their approach to
the display mode varied. For example, given an analyzer that is
used solely for vehicle conformance evaluation (i.e., to determine
that the vehicle is idling properly), three of the four
manufacturers (Hamilton, FMC and Bear) preferred a digital
tachometer as opposed to an analog tachometer. The primary
reasons cited for this preference was the ease in which the output
can be read. The other manufacturer (Sun) preferred an analog
tachometer because, according to Sun, it facilitates engine
diagnostic work when the analyzer is switched to the vehicle
repair mode.
Vehicle Exhaust Leak Detection
All of the analyzer specifications require the analyzer to be
equipped with a CC>2 monitor to detect dilution in the gas
sample. The acceptable range for CC>2 dilution is from +2
percent to +3 percent. At issue is the EPA recommendation that
the C02 monitor be available to the inspector to test for
exhaust system integrity (leaks). The manufacturers assert that
evidence of CC>2 in the exhaust is not a conclusive indication of
a faulty exhaust system. Thus, in New York, analyzers are
equipped with C02 monitors, but they are not used to test for
faulty exhaust systems.
The position of the manufacturers is that the general
condition of the vehicle exhaust should be ascertained by the
inspector in a private garage system. This can be done by briefly
blocking the tailpipe while the engine is running and listening
for leaks. A preliminary inspection for exhaust leaks would also
permit the inspector to avoid testing cars with a known failed
system.
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Performance
The New York performance specification is essentially the
same as the BAR '80 specification with some automated features.
On a line-by-line comparison, the EPA specification is slightly
more stringent than New York/BAR '80 in the areas of calibration,
drift and HC hang-up; and slightly less stringent in the areas of
interferences, leak detection, propane/hexane conversion and
analyzer response time. Other performance specifications include
operating environment, operating temperature and operating time.
The manufacturers say that they can meet the specifications
in the areas where the EPA requirements are more stringent.
However, whether the expected minor improvements in test accuracy
can justify the required equipment development effort is
questioned.
Response Time
The response times recommended by the various analyzer
specifications vary considerably as follows:
EPA: 14 seconds to 95% of reading
BAR '80: 8 seconds to 90% of reading
N.Y.: 10 seconds to 95% of reading
Massachusetts: 5 seconds to 95% of reading.
According to the manufacturers interviewed, the EPA requirement is
the most realistic for a decentralized program.
Shorter response times are technically feasible and are in
fact a requirement of most centralized inspection programs.
However, these programs are concerned with high throughput whereas
decentralized programs are not. All of the manufacturers can
provide quicker response times but at an added cost which does not
appear to be justified.
Operating Environment
The EPA, BAR '80 and New York analyzer specifications require
that the unit be able to meet all system specifications within the
ambient temperatures of 35° F and 110° F. The draft
Massachusetts specification, on the other hand, calls for the unit
to meet all system specifications between 20° F and 110° F.
According to the manufacturers interviewed, broadening the
temperature range as specified in the draft Massachusetts speci-
fication will require the addition of a heater in the analyzer
cabinet -- again increasing the base cost of the analyzer. While
Massachusetts is known for its harsh winters, garages that perform
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repairs/inspections are generally equipped with space heaters.
Thus, the temperature in these garages will generally not fall
below 35° F to 40° F even on the coldest days. Hence, it is
again questionable whether this added feature is actually needed.
As an alternative to requiring this feature, the garage
performing the inspection can be required to maintain a minimum
ambient temperature or in the case of a prolonged cold soak, it
can be required to keep the analyzer turned on (see "warm-up time"
below).
Warm-Up Time
The EPA does not specify a precise warm-up time for the
analyzer. Rather, it specifies that the analyzer will not be
operable until all circuits in the unit are functional to within
specified limits. The BAR '80 and New York specifications, on the
other hand, specify a warm-up time of 15 minutes.
In theory all of the manufacturers claim that they can meet
the New York/BAR '80 warm-up time of 15 minutes. In practice,
however, this requirement has not always been met. Situations
have occurred in the New York program where, due to extreme cold
soak, the equipment has not been able to perform without
auxilliary heat.
In the Massachusetts specification, it may be necessary to
require heating elements in the analzyer or require that the
garage performing the inspection leave the analyzer turned on when
an extended cold soak is anticipated (such as over a weekend).
New York State has used this latter approach successfully to meet
the warm up time criteria.
Calibration Curve Accuracy
The New York, California BAR and Massachusetts specifications
for calibration curve accuracy vary to a small degree from the EPA
specification -- the EPA specification is slightly more
stringent. Thus, existing gas benches meet the New York/BAR '80
requirements, while there is currently no bench which meets the
EPA specification. All the manufacturers who were contacted agree
that they can meet the EPA specification with additional
development effort. However, given the time remaining before the
Massachusetts I/M implementation date, the wisdom of requiring a
major development effort to achieve slight improvements in
accuracy is questioned.
A-ll
-------
Meter Drift
There are two areas of difference between the EPA meter drift
specifications and those of BAR '80, New York and Massachusetts.
First, the EPA recommends a maximum meter drift of +_ 2 percent
full scale, while the New York and BAR '80 specifications permit a
less stringent + 3 percent full scale drift. Second, the EPA and
New York permit the specified drift to a period of two hours.
Massachusetts on the other hand specifies its standard in terms of
ppm HC and percent CO. (Note: The full New York/BAR '80
specification for meter drift is:
zero drift - +3% full scale low range for one hour
meter drift - _+3% full scale low range for the first hour of
operation and +2% full scale low range in any succeeding
hour.
This same comment applies to the meter drift specification in
Table 1 on page A-16. The correct New York/BAR '80 meter drift
specification was incorporated into the final Massachusetts
specifications.)
In the opinion of the manufacturers, these differences are
minor. However, again, no optical bench system presently exists
that meets the EPA specification. Thus, the question again is
whether it is worth the added cost and time to achieve this slight
improvement in accuracy.
HC Hang Up
The New York/BAR '80 specifications require the analyzer to
retain less than 200 ppm of hang-up in the system within 15
seconds after a two-minute sample. The EPA specification, on the
other hand, calls for less than 20 ppm hang-up prior to testing a
vehicle, with no specific time limitation except that an
excessively long time (five to ten minutes) to reduce the hang-up
to the standard should indicate a need for maintenance. (Note:
The full New York/BAR '80 specification for hydrocarbon hang-up is
less than 200 ppm after 15 seconds and less than 60 ppm after 30
seconds. The EPA specification for hydrocarbon hang-up was
incorporated into the final Massachusetts specifications.)
Due to the more extended time period between tests in a
garage environment as compared with a centralized lane, the
manufacturers believe the analyzers will easily be able to
eliminate hang-up before each test. However, they feel that a
machine check for hang-up prior to every test, as required by EPA,
is excessively stringent and unnecessary. The New York/BAR '80
specifications have no requirement for a similar hang-up check
A-12
-------
prior to each test. (Note: Subsequent investigation led to the
determination that the hydrocarbon hang-up feature could be easily
incorporated into a fully automatic analyzer.)
Interferences
The BAR '80, New York and Massachusetts specifications give
limitations on either five or six interference gases. In
contrast, the EPA requirement specifies limitation of only three
gases. Thus, the EPA specification on interference gases is
attainable in the opinion of the manufacturers.
Propane/Hexane Factor
The variation in limits of the propane/hexane conversion
factor is not an issue with the analyzer manufacturers at this
time. All the probable respondents to the Massachusetts analyzer
procurement are likely to purchase optical benches from the same
manufacturer. The narrower the conversion factor range, the fewer
the number of benches that will be acceptable for installation in
the individual analyzers. The BAR '80 specification in this case
is more stringent than the EPA specification.
ANALYSIS OF INDUSTRY/STATE COMMENTS AND RECOMMENDATIONS
Based on review of the aforementioned specifications and
analysis of the industry/state comments, the following
recommendations are made for the Massachusetts RFP:
Require that the analyzer include a capability for (1)
automatically recording, storing and printing out tes"t
results, (2) measuring engine speed, and (3) measuring
CO_2 • For at least two manufacturers (Hamilton and
Sun), these features can be readily added. In fact,
both already offer these features. For other
manufacturers, some development will be required, but
the effort will not be overwhelming. The automatic data
collection feature is important from a data quality
standpoint, while including a printer is important from
a public relations standpoint in that the motorist
receives a hard copy of the test results. The engine
speed and C02 features are important from the
standpoint that they minimize ways in which an operator
can tamper with the test results (i.e., the test will
not be run if the engine speed is set too high or if
there are insufficient amounts of CC>2 detected) .
A-13
-------
Require that the analyzer include (1) a switch or
selector button that enables the analyzer to be used for
vehicle repair as well as inspection, (2) anti-tampering
features and (3) system diagnostic features.The
inclusion of these features pose little problem for Sun
and Hamilton (again, these two manufacturers already
offer these features as options) and represent only
minor additions for those manufacturers which need to
develop a microprocessor capability. The requirement
for these features is felt to be important for the
following reasons:
A switch or selector button that enables the
analyzer to be used for vehicle repair as well as
inspection will enhance the marketability of the
analyzer to the private garage.
The inclusion of anti-tampering and system
diagnostic features serve to make the analyzer more
"fool proof."
Do not require an automatic read system (i.e., a system
whereby the analyzer averages the gas samples over a
specified time period). Based on our analysis of this
feature, it provides little benefit and is a feature
which will involve some development effort by all
manufacturers. (Note: Continued investigation
subsequent to this technical memorandum led to the
determination that this feature was both feasible and
cost-effective.)
Do not require fully automatic gas span, leak, and HC
hang-up checks. To require these checks to be fully
automated will appreciably add to the base cost of the
analyzer and will require a significant amount of
development by manufacturers. In fact, it is
questionable whether the manufacturers can complete the
necessary development and produce the required number of
analyzers in time to implement the program in April 1983
(see technical memorandum on the schedule). Thus, it is
recommended that the gas span, leak and HC hang-up
checks be semi-automated with the necessary software
added to note when the check was made (as described
earlier). The manufacturers can more readily comply
with this requirement. Additionally, the 207(b)
requirement for weekly span and leak checks can be more
easily complied with if these checks were
semi-automated. (Note: Continued investigation
subsequent to this technical memorandum led to the
determination that these features were both feasible and
cost-effective.)
A-14
-------
Use EPA's performance specifications for all
except gas calibration, and drift. No optical bench
system presently exists that meets EPA's specification
for calibration and drift. Thus, to require these
specifications would involve some development and
testing by bench manufacturers. Furthermore, comparison
of the BAR '80/New York and EPA specifications for each
of these items indicate very minor differences. (EPA is
only slightly more stringent). Given this finding and
the already tight schedule (see Technical Memorandum on
the schedule), it does not appear justified to require
this added accuracy.
A summary of EPA's performance specification recommendations
for major items is shown in Table 1. Also shown in the table are
alternative specifications for each item in which we do not
recommend the EPA specification. Note that we recommend using
EPAs specification in the operating temperature range (i.e., 25°
to 110° F) instead of that required in the Massachusetts draft
specification (i.e., 20° to 110° F). In evaluating the trade-
offs, we feel that it would be more cost-effective to require the
licensed inspection station to maintain minimum ambient tempera-
tures as is done in New York then to require the manufacturers to
certify their equipment to 20° F.
In addition to the above, we also recommend that the New York
probe design be used instead of the EPA design. The New York
design is a twelve-inch flexible probe system with positive
retention and a thermally insulated handle. By 1983 this probe
will be compatible with almost every vehicle on the road. With
its required sixteen-inch length the EPA design is too long for
most cars. Furthermore, the specified anti-dilution device will
be applicable only in a few isolated cases such as vehicles
equipped with flame arresters at the end of the tailpipe.
The above recommendations were made (1) with the intent of
attracting as many bidders as possible, and (2) based on analysis
of the schedule, costs and benefits. Based on discussions with
the equipment manufacturers, it is our opinion that even given the
above recommendations for the specifications (which are somewhat
relaxed compared to EPA's recommended specification for a comput-
erzied analyzer) only two manufacturers -- Sun and Hamilton --
could respond (i.e., design and produce the number of analyzers
required by Massachusetts) within the allotted time frame. Thus,
if the specification is made much more stringent than our recom-
mendation, Massachusetts runs the risk of either having one or no
bidders, or not meeting their April 1983 start up date.
A-15
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TABLE 1
RECOMMENDED PERFORMANCE SPECIFICATIONS
ITEM
Accuracy of
Calibration
Curve
Accuracy of
Audit Gases
Accuracy of
Span Gases
Meter Drift*
HC Hang-Up
Interferences
- Gaseous
- Electrical
Leaks
Operating
Environment
- Tempera-
ture
- Relative
Humidity
Propane/
Hexane
Conversion
Factor
Response
Time
EPA
SPECIFICATION
Not
Recommended
1% Traceable to
NBS Standard
Reference Material
2% Traceable to
NBS
Not
Recommended
Less than 20 PPM
Before Each Test
3 Items @ 1% each
6 Items @ 1% each
3% of Comparative
gas readings
35 to 110°F
0% to 99%
.48 - .56
@ 90% Confidence
Level
14 seconds to
95% of Reading
OTHER
HS ±30 PPM ( 400-1000 Range)
HC ±60 PPM (1000-2000 Range)
LS ±12 PPM ( 0-400 Range)
HS ±0.15% (2- 5% Range)
CO ±0.3 % (5-10% Range)
LS ±0.06% (0- 2% Range)
"
—
± 3% f.s. Is for 1 hour
—
—
—
~
—
Note: See parenthetical comment on page A-12 in the section entitled
"Meter Drift".
A-16
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TECHNICAL MEMORANDUM ON THE DEVELOPMENT OF A QUALITY
ASSURANCE TESTING PROGRAM
This technical memorandum documents our findings and
recommendations on the development of a quality assurance
program for Massachusetts (Task 2). The results are based
on discussions with members of the New York Emissions Task
Force; employees of the New York Department of Environmen-
tal Conservation; and selected equipment manufacturers.
Reports documenting the EPA and New York quality assurance
procedures were also reviewed. The memorandum is
organized in the following sections:
Summary of New York and EPA Quality Assurance
Procedures
Comments from Equipment Manufacturers regarding
the EPA Quality Assurance Procedures
Recommendations for the Massachusetts RFP
Action Items for Massachusetts.
SUMMARY OF THE NEW YORK AND EPA QUALITY ASSURANCE
PROCEDURES
New York's quality assurance procedures were reviewed
to identify those procedures which are applicable to the
Massachusetts RFP. The EPA recommended quality assurance
procedure was also reviewed and then discussed with
selected analyzer manufacturers. The following sections
summarize the New York quality assurance procedures and
the procedure recommended by EPA.
New York State Quality Assurance Procedures
In the recent New York emission analyzer procurement
the schedule was extremely tight and there was little time
for formal quality assurance during the prototype and pro-
duction stages. New York required the basic analyzer to
be certified against the California BAR '80 specifica-
tions; the State then worked closely with the contractor
to further develop the top half (interactive) part of the
unit. This process started with a rough engineering
mock-up which, together, the State and the contractor
improved. When advanced hand-made units were available,
tests were conducted on approximately 35 cars in the
laboratory and a few cars in a private garage.
A-17
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During procurement, New York was primarily concerned
about the operation of the printer and the interface be-
tween the inspector and the unit. The correct operation
of the gas analyzer was guaranteed, in the opinion of New
York representatives, by the requirement for BAR '80 cer-
tification of the analyzer; a hefty performance bond sub-
mitted by the contractor; and strict contractual language
requiring the contractor to assume responsibility for the
equipment's performance in the field. The most pertinent
contract requirements included the following:
California Quality Assurance Accreditation. The
New York equipment was required to meet the
California BAR '80 quality assurance provisions.
Performance Bond. New York required the con-
tractor to submit a $500,000 performance bond.
These funds are held by the State to be used in
the event damages are suffered due to non-
performance or default.
Equipment Operation and Maintenance Agreement.
The New York contractor was required to sign a
maintenance agreement to ensure that the analy-
zers are kept properly maintained and calibrated
in the field. The contractor inspects, cali-
brates and maintains the emission analyzers
monthly at the premises of the licensed station
and is responsible to the State for the correct
functioning of the equipment. The contractor
also provides service or equipment replacement
when malfunctions are reported. To verify that
the contractor is fulfilling this agreement, the
State conducts unannounced periodic checks as
well as concealed identity investigations of the
inspection stations. The contractor also agreed
to pay a penalty to the equipment purchaser,
(i.e., licensed inspection station) if an analy-
zer remains inoperable for 8 hours during one
scheduled work day.
EPA Recommended Quality Assurance Procedure
The EPA recommended quality assurance procedure is
intended to be applied to a random sample of the first
batch of production analyzers. The procedure is defined
in two parts; the production sampling procedure and the
quality assurance evaluation procedure. Each is discussed
below.
A-18
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Production Sampling Procedure. The sampling pro-
cedure recommended by EPA requires the random
selection of 3 of the first 20 production units;
the three are then subjected to the evaluation
tests. If two of the three units pass all the
tests then EPA will award full accreditation valid
for three years from the date the first unit was
produced. If two or more units fail the evalua-
tion tests, corrections to the design and/or pro-
duction must be made, and three additional units
randomly selected from a new or current produc-
tion run. Two of these three must pass all evalua-
tion tests.
Quality Assurance Evaluation Procedure. According
to a review by the New York Department of Environ-
mental Conservation,* the EPA-recommended quality
assurance evaluation procedure is essentially the
same as the California BAR '80 procedure, except
that acceptance criteria differ where the EPA
analyzer specifications differ from the BAR '80
analyzer specifications. The EPA procedure in-
cludes a list of procedures for which California
BAR '80 test results may be substituted.
The initial EPA procedure was distributed to
manufacturers for comment, and many of the manu-
facturer's recommendations were included in the
revised version. Thus, equipment manufacturers
have had an opportunity to review the procedure
and become familiar with its requirements. One
of the most significant requirements is that the
evaluation must be conducted by a 3rd party, i.e.,
an authorized testing laboratory. (Note: The
EPA procedure does not require, although it does
recommend, a third party evaluation. The final
Massachusetts specifications allow the QA testing
procedures to be performed at the contractor's own
facilities or at a third party testing laboratory.)
"A Comparative Review of EPA and NYS Exhaust Emissions
Analyzer Specifications," Walter J. Pienta, New York
Department of Environmental Conservation, March 25, 1981,
A-19
-------
COMMENTS FROM THE EQUIPMENT MANUFACTURERS REGARDING THE
EPA QUALITY ASSURANCE PROCEDURE
Booz, Allen contacted selected manufacturers to obtain
their comments regarding the use of the EPA recommended
quality assurance procedure in the Massachusetts procure-
ment. Most of the manufacturers felt that the EPA recom-
mended procedure was technically sound and generally could
be accommodated. Specific comments and/or criticisms
arose in the following six areas:
Identification of the Reviewing Agency
Redundancy of the EPA and BAR procedures.
Requirement to Test Production vs. Prototype Units
Leadtime and Cost Requirements of a 3rd party
Evaluation
Definition of Re-certification Procedures.
Acceptance of Alternative Q.A. Procedures.
Comments received from the manufacturers in each of these
areas are discussed below.
Identification of the Reviewing Agency. EPA has
not identified the agency which will take res-
ponsibility for accepting and evaluating the
quality assurance test results. Either Massachu-
setts or the EPA will need to assume this res-
ponsibility and assign it to a qualified techni-
cian capable of fairly analyzing the results.
The same is true for accepting and evaluating
engineering reports on infant mortality failures
and the repair of random failures in production
units.
Redundancy of the EPA and BAR '80 (California)
Quality Assurance Procedures. Some manufacturers
feel that the EPA and California (BAR) certifi-
cation procedures are redundant, and that one or
the other should be required for the basic analy-
zer bench, but not both. The time required for
certification testing (1 to 2 months) is a criti-
cal element in the manufacturer's schedule for
delivery of the equipment and delays could jeo-
pardize timely delivery of the units. Unique
aspects of the analyzer other than the basic
bench, such as the interactive unit, could be
tested according to a procedure developed jointly
by the State and the manufacturer.
A-20
-------
Requirement to Test Production Versus Prototype
Units. There is a feeling among some manufac-
turers that functional tests could be performed
as effectively on prototype units identical to :
the planned production units as on the production
units themselves. Prototype testing can verify
whether the design does what it's supposed to in
time to adjust costly production machinery before
it is brought on line. EPA allows preliminary
accreditation on pre-production units but is firm
on its commitment to require that production
units be tested for compliance with the analyzer
specifications.
Lead Time and Cost Requirements of a 3rd Party
Evaluation. The requirement for a 3rd party
evaluation raises critical questions about lead
time and cost. First, adequate lead time must be
built into the manufacturing schedule for deliv-
ery of the equipment to the laboratory and per-
formance of the tests by the lab. If infant mor-
tality or random failures occur during testing
they must be documented by engineering reports
justifying that the failures are not design fail-
ures. Then, in the event of random failures in
production units, a plan must be developed (and
documented) to prevent the specific type of fail-
ure in future production units. Furthermore,
after repair of the random failures in the pro-
duction units, those tests that might be affected
by the repairs must be rerun. All of this activ-
ity may consume weeks out of the manufacturing
and production schedules and could delay delivery
of the units. Second, an unofficial estimate
quoted by Bear for a 3rd party quality assurance
evaluation according to the EPA procedure was
$22,000. It is expected that this cost will be
included as part of the manufacturer's contract
and will be reflected in the price of the ana-
lyzer and the inspection fee. In the event that
multiple awards are made in a single State, the
expense of 3rd party evaluations could be re-
quired for two or more similar analyzers built
by different manufacturers. (Note: Considering
that Massachusetts intends to award a single con-
tract for 3000 to 4000 analyzers, the cost of a
third party evaluation represents only a small
cost per analyzer which is negligible when com-
pared to the expected unit cost of the analyzer.
However, the final Massachusetts specifications
do not require a third party evaluation.)
A-21
-------
Definition of Re-Certification Procedures. EPA
has defined a procedure for mandatory re-
certification of the emission analyzer design.
The current (revised) procedure calls for re-
certification testing on new production units
every three years after the initial certifica-
tion. The re-certification testing is limited
to certain key parameters which, according to
the manufacturers, need to be more clearly de- ..
fined. The basic issue here is that the require-
ment for subsequent testing is too vague and that
more specific language needs to be developed.
Acceptance of Alternative QA Procedures. The
manufacturers would like to have the opportunity
to propose alternative quality assurance proce-
dures in their bids without being considered non-
compliant. Allowing the manufacturers to suggest
options for QA could potentially benefit both the
manufacturer and the State.
RECOMMENDATIONS FOR THE MASSACHUSETTS RFP
Based on evaluation of the EPA quality assurance pro-
cedure and review of comments made by manufacturers the
following recommendations are made for the Massachusetts
RFP:
Adopt the EPA Quality Assurance Procedure. All
of the manufacturers have had an opportunity to
review and submit comments on the EPA QA proce-
dure, and the revised version incorporates many
of the manufacturer's recommendations. It ap-
pears that most of the manufacturers can accommo-
date the revised procedure in their bids.
Specify the Reviewing Agency in the RFP. The
government agency and/or department which will be
responsible for evaluating the QA test results
and engineering reports should be identified in
the RFP. Any planned arrangements for supple-
menting an existing technical capability with
assistance from, for example, EPA in Ann Arbor,
should be described.
Permit the Bidders to Suggest Alternative QA
Procedures. The manufacturers may be able to
suggest alternative QA procedures that can be
performed in a shorter timeframe or at a lower
cost than the EPA procedure yet provide equiva-
lent QA test data. Massachusetts could poten-
tially benefit by allowing the bidders to propose
A-22
-------
options in the quality assurance procedure. The
proposed options should be limited by Massachu-
setts to modifications of the EPA'procedure
rather than, for example, elimination of some of
the EPA requirements.
Do Not Require Certification by California BAR in
Addition to the EPA Certification. The EPA cer-
tification requirement is an independent and com-
plete analyzer certification procedure. Requiring
both California BAR and EPA certification is re-
dundant and unnecessary.
Request a More Detailed Specification of the Re-
certification QA Procedure from EPA, and If Pos-
sible, Include it in the RFP. The EPA re-
certification requirement needs more specific
definition before the manufacturers can fully
understand their long-term obligations under the
procedure. If possible, a more detailed explana-
tion of the re-certification requirements should
be included in the Massachusetts RFP. (Note:
Since Massachusetts is only concerned with a one-
time production of analyzers for its I/M program,
a re-certification procedure was not included in
the final specifications.)
Require a Performance Bond. The $500,000 per-
formance bond submitted by Hamilton Test Systems
in New York is a strong incentive for the con-
tractor to meet all performance requirements of
the contract. It also provides a contingency for
the State in the event of non-performance or
default. It is recommended that Massachusetts
require a performance bond from the successful
bidder. The amount should be determined by the
State.
Require the Contractor to Assume Responsibility
for the Performance and Maintenance of the Equip-
ment in the Field and to Pay a Penalty for Ex-
cessive Analyzer Downtime. The contractor should
be held responsible for the correct functioning
of the analyzers in the field. This responsibility
includes providing service or equipment replace-
ment when malfunctions are reported. To protect
the inspection station operators from loss of in-
come due to a malfunctioning analyzer, the con-
tractor should be required to pay a penalty when
the analyzer or associated hardware remains inoperable
for an extended period. The maximum allowable down-
time and the amount of the penalty should be deter-
mined by Massachusetts.
A-23
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ACTION ITEMS FOR MASSACHUSETTS
Recommended action items for Massachusetts include the
following:
Identify the organization and individuals who
will be responsible for evaluating test results
and engineering reports on the emission analyzers.
Request EPA to provide a more detailed explana-
tion of the analyzer re-certification QA procedure.
This material should be received in time to be in-
cluded in the RFP.
Determine the amount of the performance bond to be
submitted by the successful bidder.
Determine the maximum allowable downtime for
emission analyzers in the field and the penalty to
be paid by the contractor for exceeding this time
period.
A-24
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TECHNICAL MEMORANDUM ON SCHEDULE FOR
ANALYZER DEVELOPMENT AND DISTRIBUTION
This technical memorandum documents our findings and
recommendations on an appropriate schedule for the develop-
ment and distribution of computerized emissions analyzers
for Massachusetts I/M program (Task 3). The findings are
based on discussions with representatives of four analyzer
manufacturers (Sun, Hamilton, FMC and Bear) and the Equip-
ment and Tool Institute (ETI). The memorandum is divided
into the following three sections:
Summary of Manufacturer Responses
Analysis of Manufacturer Responses
Recommendations.
SUMMARY OF MANUFACTURER RESPONSES
Tables 1 and 2 on'the following page summarize the
manufacturers' responses regarding the amount of time that
would be required to develop and manufacture two types of
analyzers:
Table 1 assumes the development of an analyzer
with those features recommended by Booz, Allen
in the technical memorandum on basic analyzer
specifications (i.e., includes automatic data
collection and storage, C02 analyzer, tachometer,
semi-automatic gas span, leak and HC hang-up
checks, EPA performance specifications except
for gas span and meter drift, etc.).
Table 2 assumes the development of a computerized
analyzer that fully complies with EPA's recom-
mended specifications for computerized analyzers
(i.e., includes a fully automatic gas span, semi-
automatic leak check, automatic HC hang-up check,
etc.) .
As shown by the tables, the time required to develop
and manufacture these analyzers varies considerably by
manufacturer. Those manufacturers (i.e., Sun and Hamilton)
that already offer analyzers with a microprocessor capa-
bility require much less lead time than those manufacturers
(i.e., FMC and Bear) that don't have such analyzers. FMC
and Bear indicated it would take them a minimum of 12 months
to develop a microprocessor capability. As also shown in the
tables, the manufacturing capability of manufacturers also
varies significantly.
A-25
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TABLE 1
Development and Manufacturing Time Estimates
For Analyzer Built to
Booz, Allen Recommended Specifications
SCHEDULE
ITEM
Development
Manufacture
(4,000
units)
MANUFACTURER
SUN
6 mos.
6 to 9
mos.
HAMILTON
6 to 9
mos.
6 mos.
FMC
12 mos.
12 to 18
mos.
BEAR
12 to 18
mos.
16 mos.
TABLE 2
Development and Manufacturing Time Estimates
For Analyzer Built to
EPA Specification
SCHEDULE
ITEM
Development
Manufacture
(4,000
units)
MANUFACTURER
SUN
12
mos.
6 to 9
mos.
HAMILTON
9 to 12
mos.
6 mos.
FMC
15 mos.
12 to 18
mos.
BEAR
18 mos.
16 mos.
A-26
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ANALYSIS OF MANUFACTURER RESPONSES
Given the results presented in Tables 1 and 2 and
assuming the milestones shown in Figure 1 are realistic,
the following can be concluded:
Even given the somewhat relaxed specifications
(compared to EPA) recommended by Booz, Allen, it
is doubtful that any manufacturer without a micro-
processor capability at present will be able to
meet Massachusetts' timetable to develop and manu-
facture analyzers by April 1, 1983. Assuming a 12-
month development effort, the earliest any manu-
facturer (without a microprocessor capability)
could have a prototype ready for certification
testing would be January 1983.
Both Hamilton and Sun (it appears) could
comply with Massachusetts' timetable given the
Booz, Allen recommended analyzer specifications
and could possibly comply with EPA's timetable
(i.e., develop .and manufacture analyzers by
January 1, 1983), assuming that (1) the analyzer
certification process goes smoothly and takes no
longer than one month, and (2) there are no signif-
icant schedule slippages early in the program. It
also assumes that the manufacturers receive firm
commitments by garages to purchase the analyzers by
August 1, 1982 and that there are no major problems
encountered in the analyzer development effort.
Even if there are no problems, meeting the EPA sched-
ule would still be tight since (a) the manufacturers
would still have to train garagemen in the operation
of the analyzer, and (b) there is a lag time between
manufacture of the analyzers and delivery of the
analyzers to garages. Given the EPA-recommended
specification for computerized emissions analyzers,
it does not appear that either Hamilton or Sun could
comply with Massachusetts' timetable.
RFP's Distributed September 11, 1981
Proposal Received by Massachusetts November 1, 1981
Contract Award December 1, 1981
Contract Negotiations Completed December 15, 1981
Analyzer Development Effort Begins January 1, 1982
FIGURE 1
Milestones for RFP Distribution,
Contract Award and Contract Negotiation
A-27
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RECOMMENDATIONS
Based on the above analysis, it appears that the extra
three months requested by Massachusetts is justified, given
the various schedule uncertainties. Thus it is recommended
that the implementation date be moved from January 1, 1983 to
April 1, 1983. If after contract award, the selected manufac-
turer finds it can meet the EPA January 1, 1983 start up date,
this extra three-month period can be used for public awareness
and "debugging" purposes prior to full implementation.
A-28
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APPENDIX B
EMISSION ANALYZER TECHNICAL AND
PERFORMANCE SPECIFICATIONS
-------
EMISSIONS ANALYZER TECHNICAL AND
PERFORMANCE SPECIFICATIONS
This section provides the technical and performance
specifications for the exhaust emissions analyzer required
by the Commonwealth of Massachusetts. The specifications
detailed herein are those recommended by the U.S. EPA
(Document Numbers EPA-AAA-IMS-80-5-B and EPA-AAA-IMS-
80-5-C) with the exception that the BAR '80 gas cali-
bration accuracy and meter drift performance specifi-
cations have been substituted for the EPA's recommended
specifications. Automatic features required by the
specifications described herein include automatic gas
spanning, automatic leak checking, automatic HC hang-up,
automatic test averaging (i.e., automatic read system),
automatic test sequencing and automatic data collection.
Additionally, the specifications also require that the
analyzer possesses a vehicle diagnostic capability, an
anti-dilution capability and an engine speed monitoring
capability.
The remainder of this section is divided into the
following parts:
4.A General Requirements
4.B Construction/Materials
4.C Hardware/Design Requirements
4.D Environmental Requirements
4.E Performance Specifications
4.F Manuals
4.G Quality Assurance.
References to the U.S. EPA and BAR '80 analyzer
specifications are made throughout each remaining part of
this section. The reader is encouraged to use these
references in responding to this specification. (Note:
All references to EPA-AA-IMS-80-5-B in the text
automatically include any revisions in EPA-AA-IMS-80-5-C
unless specifically stated otherwise. Specifications in
EPA-AA-IMS-80-5-C supersede those in EPA-AA-IMS-80-5-B).
4.A GENERAL REQUIREMENTS
4.A.I Design Goals
The emissions analyzer shall be designed for maximum
operational simplicity with a minimum number of opera-
tional decisions required in the performance of a complete
exhaust emissions analysis. The analyzer shall be
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unaffected by ambient conditions in a typical repair
facility environment and its use shall be primarily for
compliance inspection purposes. It shall however be
capable of vehicle diagnostic work as well.
4.A.2 Useful Life
The useful life of the analyzer shall be a minimum of
five years. (Ref: EPA-AA-IMS-80-5-B, Section VII.D.I,
page 23) .
4.A..3 Name Plate Data
A nameplate with provisions for and including the
following data shall be permanently affixed to the housing
of the analyzer:
Name and address of manufacturer
Model description
Serial number
Date of assembly
Date of analyzer system assembly
Blank space(s) for rebuild certification.
The serial number shall also be stamped or engraved on the
chassis of the analyzer housing. After installation, the
manufacturer shall affix a stick-on type label to the
analyzer which contains a telephone number for customer
service.
4.B CONSTRUCTION/MATERIALS
4.B.I Materials
All materials used in the fabrication of the analyzer
and the appropriate housing assembly shall be new and of
industrial quality and durability. Contact between non-
ferrous and ferrous metals shall be avoided where pos-
sible. Suitable protective coatings shall be applied
where galvanic action is likely. All mechanical fasteners
shall have appropriate locking features. Use of self tap-
ping screws shall be avoided. All parts subject to ad-
justment or removal and reinstallation shall not be per-
manently deformed by the adjustment or removal/reinstal-
lation process and this process shall not cause defor-
mations to adjoining parts of the equipment. Only
materials that are not susceptible to deterioration when
in contact with automobile exhaust gases shall be used.
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4.B.2 Construction
The analyzer shall be complete and all necessary parts
and equipment required for satisfactoy operation shall be
furnished. A suitable means of storing the probes and
sample hose shall be provided. All parts shall be manu-
factured and assembled to permit the replacement and/or
adjustment of components and parts without requiring the
modification of any parts or the basic equipment design.
Where practical components and/or subassemblies shall be
modularized. The analyzer cabinet finish shall be baked
enamel or equivalent.
4.B.3 Mobility
The analyzer unit shall be designed for easy and safe
movement over hard and/or graded surfaces. The center of
gravity and wheel design shall be such that the analyzer
can negotiate a vertical grade separation of 1/2 inch
without overturning when being moved in a prescribed man-
ner. Industrial grade, swivel casters shall be used to
permit 360° rotation of the unit. The caster wheels
shall be equipped with oil resistant tires and foot
operated brakes.
4.B.4 Electrical Materials/Construction
Unless otherwise specified, all electrical components
including motors, starters, switches and wiring shall con-
form to provisions established by the Underwriters Labora-
tories, National Electrical Code and applicable state and
local electrical codes.
4.B.4.1 Connections
Connections to conductors and terminal parts shall be
of the screw pressure (i.e., mechanically fastened) or
solder type. When screw pressure type connections are
used, the conductors and terminal parts shall be
mechanically secured with a means to prevent loss of
tightness.
Interconnecting cables terminating at the control
panels shall be constructed with connectors staked to
withstand shock and vibration during operation and
movement.
4.B.4.2 Power Supply
The analyzer shall operate from unregulated 120 volt,
60 Hertz supply. An input voltage variation of from 100
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to 130 volts and a +1 Hz frequency variation shall not
change analyzer performance more than 1% of full scale.
The power cable shall be equipped with a standard three
prong connector at the inlet. It shall be 30 feet in
length and be extremely durable and water resistant^
(Ref:EPA-AA-IMS-80-5-B, Section VII.E.8b, page 33).
4.B.4.3 Fault Protection
Each analytical system and the entire emissions ana-
lyzer shall incorporate safety devices to prevent condi-
tions hazardous to personnel or detrimental to equipment.
Circuit breakers shall be used to protect individual cir-
cuits and the analyzer. All such devices shall be readily
accessible and clearly marked as to functions affected.
Fuses shall not be used. The system shall be grounded to
prevent electrical shock.
)
4.C HARDWARE/DESIGN REQUIREMENTS
4.C.I Readout Display Control Panel
The console shall contain numerical HC (Hexane), CO,
and C02 displays, a pass/fail display and a vehicle
control group selector.
4.C.1.1 Numerical HC, CO and CO2 Displays
The numerical displays shall be of a digital format.
The resolution of the displays shall be as follows:
HC: XXXX ppm (Hexane)
CO: X.XX%
C02: XX.X%
The display increments shall be 0.01% CO, 1 ppm HC and
0.1% C02- The displays shall be capable of maximum
readings of 9.99% CO, and at least 2000 ppm HC (Hexane)
and 16% C02. See EPA-AA-IMS-80-5-B, Section VII.D.8,
page 29 for negative readings.
4.C.I.2 Pass/Fail Display
Readily visible lights shall be provided to indicate
pass (green) and fail (red) for HC, CO or both. An addi-
tional indicator light is to be employed for an exhaust
system leak check. This light will signal excess dilution
in the exhaust system based upon measurement of CO2
emissions. The accuracy of the pass/fail set points must
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be +2% of the indicated value. The failure lights must
accommodate the failure points of each potential
standard. An exhaust system leak will automatically yield
an invalid test, and such indication will appear on the
printout and data recorder.
4.C.1.4 Vehicle Control Group Selector
The analyzer shall be capable of selecting outpoints
based, on vehicle model year* for five vehicle control groups:.
Control group selection, shall be accomplished by opera-tor*
entry into the data acquisition analyzer storage system of
the vehicle model yearv Once entered•> the failure points
(cutpoints) for each test must then be automatically selee-
ted front the analytical console. Provisions- shall be made
for: five (5) vehicle year control groups with additional
provision for future adjustment
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3. Exhaust leak analysis, pass or fail
4. HC & CO analysis, pass or fail
5. Unit in purge mode.
4.C.3 Sampling System
The sampling system consists of two subsystems:
(1) external sampling system; and (2) internal sampling
system. The external subsystem shall include an insulated
sample probe, tailpipe extender and a 20-foot hose. The
internal subsystem shall include, but not necessarily be
limited to, a water trap, filtration system, sample pump,
and bypass pump. Specific references to the EPA reports
are identified in the following subsections.
4.C.3.1 Sample Probe
The sample probe shall incorporate a positive means of
retention to prevent it from slipping out of the tailpipe
when in use. A thermally insulated, securely attached
hand grip shall be provided on the probe in such a manner
that easy probe insertion using one hand is insured.
The probe shall be flexible enough to extend into a
iy diameter tailpipe having a 3" radius 90° bend, 4"
from the end of the pipe. .The probe insertion depth shall
be at least 16 inches from the end of tailpipe or tailpipe
extender. All flexible materials used in the probe con-
struction shall be of a sealed construction to prevent
sample dilution. The probe assembly shall be replaceable
as a unit separate from the sample line.
The probe shall also have a smooth surface near the
probe tip before the flexible portion of the probe to be
used for sealing of the span gas adaptor necessary for
field or on-board leak checking (gas comparison) or re-
sponse time checking equipment. For standardization it is
recommended that the sealing surface be 1/2 inch in out-
side diameter and 1/2 to 1 inch long.
A probe tip cap or some other means of introducing
calibration gas into the analyzer shall be provided for
the sample system check described in Section 4.C.9.
(Ref: EPA-AA-IMS-80-5-B, Section VII.D.5, pages 24-25).
4.C.3.2 Tailpipe Extender
In addition to the sample probe, a tailpipe extender
capable of being attached to the vehicle within 60 seconds
shall be provided. The tailpipe extender shall be de-
signed to allow the attachment of standard service center
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building exhaust evacuation systems without affecting the
vehicle or measurement process. The pressure at the end
of the tailpipe or extender shall be within +2 inches of
water of the ambient barometric pressure.
The tailpipe extender shall not alter the sample and
the material shall conform to all requirements described
earlier. The probe and tailpipe extender shall have suf-
ficient hardware (insulated handles, etc.) that will allow
the user to insert, attach, or remove the probe or the
dilution adapter safely and conveniently. The probe or
tailpipe extender shall be designed in a manner that will
prevent the probe or extender from being removed from the
vehicle unintentionally. (Ref: EPA-AA-IMS-80-5-B,
Section VII.D.5, page 25) ~
4.C.3.3 Sample Hose
The interconnecting hose shall be of such design and
weight that it can easily be handled by the inspector.
The hose shall not be longer than 25 feet nor shorter than
15 feet (excluding the probe). For standardization, a 20
foot length is preferred. The hose shall be of
non-kinking construction and fabricated of materials that
will not be affected by nor react with the exhaust
gases. Molecular hydrocarbon hang-up shall be
minimized. The hose connection to the analyzer shall be
reinforced at the point of maximum bending. (Ref:
EPA-AA-IMS-80-5-B, Section VII.D.6, pages 25-26).
4.C.3.4 Water Trap
The system shall be designed with a water trap in the
bypass sample stream. The water trap shall be continually
self-draining through a bypass pump. The trap bowl shall
be constructed of a durable transparent material. The
water trap and bypass pump should be located as low as
possible on the analyzer so that condensed water in the
sample hose will drain, by gravity, into them. However,
the trap must be placed in a position readily visible to
the operator. The sample for the analyzer shall be ob-
tained from the top of the water trap. (Ref:
EPA-AA-IMS-80-5-B, Section VII.D.3 d, pages 23-24 and
EPA-AA-IMS-80-5-C, Section III.D.1, page 10) .
4.C.3.5 Filtration
The sampling system shall be equipped with a 5 micron
particulate filter upstream of the optical bench. A sec-
ondary filter upstream of the sample pump is optional.
This filter must have sufficient capacity to filter the
samples obtained during the routine testing of at least
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500 vehicles in the inspection station. (Ref: EPA-AA-
IMS-80-5-B, Section VII. D.3 e, page 24 and EPA-AA-IMS-80-
5-C, Section III. D.2, page 10).
4.C.3.6 Sample & Bypass Pumps
The sample and bypass pumps shall be the positive dis-
placement diaphragm type, with corrosion resistant inter-
nal surfaces. The pumps shall have a minimum operational
life of 2,000 hours with no mechanical or electrical
failure (or equivalent).
The pumps may be either a single pump, multiple pumps
for the sample and bypass streams, or a dual pump for
bypass flow and sample flow. The sample pump shall have
integral motor overload protection and permanently
lubricated, sealed ball bearings. The bypass pump shall
be connected in the sample system so that any water
condensed in the water trap is removed by the pump and
dumped outside the system. The bypass stream does not
pass through the particulate filter.
The bypass and sample pumps shall be deactivated by a
test standby switch. The flow rate from the pumps shall
be sufficient to obtain an overall response time of less
than 14 seconds for 95 percent response to a step input of
gas having either or both contaminants.
4.C.4 System Vents
No restrictions such as flowmeters may be placed
downstream of any analyzer vent (a series analyzer flow
path is permitted) unless the system can detect potential
changes in restriction (i.e. sticking flowmeter), and
Alert the operator of the problem which would
require a new gas span and/or repair of the
component causing the restriction, or
Use automatic compensation of the analyzer
readout device for the change in restriction.
A change in restriction that will cause a 3 percent of
point change in the analyzer response shall activate the
alert system. (Ref: EPA-AA-IMS-80-5-B, Section VII.D.10,
page 30.)
4.C.5 Analytical System
The analytical system shall include carbon monoxide,
carbon dioxide, and hydrocarbon analyzers. These ana-
lyzers shall be the nondispersive infrared type.
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4.C.6 Fail Safe Features
4.C.6.1 Operating Temperature Lockout
Functional operation of the unit shall remain disabled
through a system lockout until the instrument meets the
warm-up requirements specified in section 4.E.3. (Ref:
EPA-AA-IMS-80-5-C, Section III.H.1, page 19).
4.C.6.2 Low Flow Indicator
A low flow indicator shall be provided which will ac-
tivate when the sample flow rate is decreased to a point
which would not allow the analyzer system to meet the re-
sponse time specificiations indicated in Section 4.E.4.
(Ref: EPA-AA-IMS-80-5-B, Section VII. H. 2, page 37) .
4.C-7 Automatic Data Collection
The analyzer shall be supplied with provisions for
data entry and storage. (Ref: EPA-AA-IMS-80-5-B, Section
IX. A, page 50) .
4.C.7.1 Data Entry System
An alphanumeric keyboard shall be used for data entry
and control ofT the analyzer shall be via a small com-
puter* The test mode shall be selected by using an
"auto-test1* key. This shall cause the preset inspection
station identification number to be entered into the test
record. The date may be set automatically or on a daily
basis. If set daily, it need only be verified for each
vehicle.
The following information will then be entered on the
keyboard:
Vehicle license plate number
VIN
Vehicle type (LDV, LOT, HDG, etc.)
Vehicle make
Vehicle model
Vehicle model year
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Odometer reading
Fuel type (gasoline, gasohol, methanol, ethanol,
propane, hydrogen, spare channel, etc.)
Inspector identification number
Type of test (initial, first retest, second
retest, etc.)
This action will key appropriate HC and CO limits for a
pass/fail decision. After the probe is inserted into the
vehicle tailpipe, the test shall be initiated by using a
"start-test" key. The emission test will be conducted
automatically with no further operator action, i.e. the
sample will be validated (dilution check), readings will
be taken, values will be compared to limits and a
pass/fail determination will be made. (See Section
4.C.15.) The HC and CO readings and a pass/fail
determination will then be supplied by the printer and
entered on the data storage unit.
4.C.7.2 Data Storage System
The data collection device shall be compatible with
the data storage system. The format of the data shall be
in machine readable form. Included in this data shall be
the date, inspection number, vehicle license plate number,
inspection station identification number, inspector
identification number, vehicle classr year, make/model of
vehicle, vehicle type, odometer reading, fuel type, type
of test (i.e, initial, first retest, second retest, etc),
anti- dilution test criteria (i.e., air pump, no air
pump), CO and HC emissions readings and overall pass/fail
determination. The data storage system shall have
sufficent capacity to store safety inspection-related data
at a future date.
4.C.8 Printer
The analysis system shall have a printer that provides
the consumer and the inspector a receipt with the fol-
lowing information:
a) Date (the printer may use manually input values
for the date) .
b) Inspection Facility Number or Instrument Serial
Numbe r.
c) Inspection Test Number (may be sequenced by ini-
tiation of Automatic Test Sequence).
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d) Applicable outpoints or standards for HC and CO
for each test mode.
e) Integrated vehicle test values for HC and CO for
each test mode.
f) An overall pass or fail indication for each test.
Space on the form (back or front) shall provide for
safety item check off boxes and repair information based
upon HC and CO emissions levels. The printer shall allow
for two copies of the printed material.
4.C.9 Automatic Gas Span Check
The analyzer shall be designed for automatic gas
calibration plus automatic electrical spanning. The
frequency of calibration shall be every 180 hours. If the
system is not calibrated or the system fails the
calibration, an error message shall be displayed and the
printer shall be prevented from printing. Appropriate
valves, switches and electrical controls shall be
installed to permit this operation. The reader is
referred to EPA-AA-IMS-80-5-B, Section VIII.A, pages 41
and 42 and EPA-AA-IMS-80-5-C, Section IV.Bf pages 21 for a
listing of the detailed requirements associated with this
feature.
4»C. 10 Automatic Leak-Check
An automatic leak checking system shall be provided
that will allow the vacuum side of the system to be
checked for leakage using span gas. Appropriate valves,
lines, and switches shall be installed to permit this op-
eration. Minimal activity by the operator, such as set-
ting the probe in a holder or capping the probe, is per-
mitted, provided errors resulting from improper operator
action would be identified by the computer and would
require corrective action or improper operator action
would tend to cause the system to fail a leak check.
The leak check shall be accomplished by comparing the
span gas response when the gas is introduced through the
span network (calibration port) to the response of the
same gas introduced through the probe and sample line.
Leakage in the vacuum portion of the sampling system shall
not exceed a variation of 3 % in the reading of the gas
value, when the flow through the probe and hose is
compared with the flow through the calibration port.
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The analyzer shall be equipped with a timer that will
allow the analyzer to operate for 180 calendar hours (once
per week) between leak checks. If the system is not leak
checked, or the system fails a leak check, an error
message shall be displayed, and the printer shall be
prevented from printing. (Ref: EPA-AA-IMS-80-5-B,
Section VIII.B, page 43 arid EPA-AA-IMS-80-5-C,- Section
IV.C, page 22) .
4.C.11 Automatic Hang-Up Check
The analyzer shall be designed for automatic HC
hang-up checks of the sampling system using room air. The
analyzer shall have a selector switch or button with indi-
cator light labeled "Hang-up Check.* Activation of the
"Hang-up" switch shall cause the analyzer to automatically
sample room air through the sample line and probe. The
check system shall continue to sample room air until the
HC response is below the value specified in Section
4.E.8. When the HC level stabilizes below this value, an
indication that testing may begin shall be displayed. The
analyzer shall be precluded from operating and the printer
prevented from printing until the HC level is met.
A receptacle shall be provided on the analyzer with a
suitable interlock that will prevent the probe from sam-
pling air in close proximity to the floor. The analyzer
shall also be locked out unless a successful hang-up check
has been performed since the last activation of the test
sequence or the HC analyzer has not experienced an HC
level greater than that specified in section 4.E.8.
(Ref: EPA-AA-IMS-80-5-B, Section VIII.C, page 44).
4.C.12 Vehicle Diagnosis
For the purpose of vehicle diagnosis and/or repairs,
the analyzer shall have a selector switch or button with
indicator light labeled "Vehicle Diagnosis" or "Vehicle
Repair." Activation of the "Vehicle Diagnosis" switch
shall allow the analyzer to continuously monitor the ve-
hicle exhaust regardless of inspection status (e.g., sys-
tem needs weekly span check, leak check, warm-up con-
dition,- etc.)
The printer, or any automatic data collection system,
shall be prevented from operating anytime the analysis
system is in a "Vehicle Diagnosis" status. For excep-
tions, see EPA-AA-IMS-80-5-B, Section VIII, Introduction,
page 41 and EPA-AA-IMS-80-5-C, Section IV, Introduction,
page 20. Auxilliary analog trend meters may be used
provided that they are decictivated for inspections.
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4.C.13 Anti-Tampering
The analyzer shall be equipped with anti-tampering
features to prevent intentional tampering with the analy-
sis system.
All switches or entry access for automatic zero/ span
check adjustments, anti-dilution limits, span gas concen-
tration values, diagnostic switches, etc. shall be con-
tained in a box or other tamper-proof mechanism with
provisions for an inspector's seal. Span gas concentra-
tion switches shall be accessible to the user and the
switch values shall be stored and printed for each test.
A gummed label with the inspectors initials and date which
must be torn to gain access, or a braided wire and crimped
lead seal (or similar device) would be sufficient for
sealing.
The tamper-proof system must allow convenient access
by an inspector or authorized service personnel. (Ref:
EPA-AA-IMS-80-5-B, Section VIII.I, page 48 and EPA-AA-IMS-
80-5-C, Section IV.F, page 25.)
4.C.14 Automatic Read System
The analyzer shall have a selector switch or button
(with indicator light) labeled "start-test". Activation
of the "start-test1* switch shall cause the analyzer system
to begin the sequence specified in Section 4.C.7.I. The
sample validation can occur prior to or simultaneously
with the HC and CO sampling. Integrating or averaging the
analyzer response shall begin 17 seconds after the switch
is activated, and continue integrating the analyzer
response to a flowing sample for the next 15 seconds for
HC and CO (5 seconds for C02)~- If validation occurs
before HC and CO sampling7 emissions sampling may occur
immediately after validation. The sample and hold
circuits can be either analog or digital. Digital sample
rates shall be at least 10 hertz. If the manufacturer
identifies that the response time to 99 percent of a step
change is less than 17 seconds, the manufacturer may
select anytime between the 99 percent time and 17 seconds
to begin the integration. If the manufacturer elects this
option, the integration start time must be boldly visable
on the front of the analy2;er. Failure to meet this new
reponse time during field audit checks will constitute a
failure of the audit.
The analyzer read-out device shall display the inte-
grated value, and hold the display until reset. An
indicator light shall signal the operator when the
integrated value is displayed. The automatic test
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sequence (see section 4.C.15) may interact with the
automatic read system to reset the display at appropriate
times or within the test sequence.
The analyzer shall be prevented from printing the
integrated value until the "start-test" switch is
activated and the "testing" cycle is completed. See
Section 4.C.7.I. (Ref: EPA-AA-IMS-80-5-B, Section VII.D,
page 45.)
4.C.15 Automatic Test Sequence
The analyzer must be capable of being programmed for
standard sequences and must be capable of storing the
cutpoints for each mode of the test sequence used. The
operator may only use State accepted criteria for selectng
cutpoints. It is recommended that the following criteria
by usedt
Vehicle Model Year
Type of Vehicle
- Light-Duty Vehicle
Light-Duty Truck
- Heavy-Duty Gas Truck
Spare Channel (fuel type)
Spare Channel (Catalyst-non-catalyst,
California-non-California)
Access to the test sequence programmingr and cutpoint
values and applications shall be limited to a State
Auditor by means of the anti-tampering provisions dis-
cussed in Section 4.C.13. The system must identify the
integrated value for each mode, make a pass or fail
decision on that mode, and either immediately print the
results of store the results until the completion of the
test sequence. If the test sequence includes more than
one mode, the system shall use the pass or fail decision
from all applicable modes to determine an overall pass/
fail determination. (Reft EPA-AA-IMS-80-5-B, Section
VIII.F, page 46-47) .
4.C.16 Anti-Dilution
The analyzer shall be equipped with an anti-dilution
feature to identify vehicle exhaust system leaks and
sample dilution. The preferred technique for identifying
leaks is monitoring the CC>2 levels in the exhaust.
Other techniques that can demonstrate improved sensitivity
to leaks may be used.
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At least three lower-limit C02 values shall be capa-
ble of being used:
Vehicle equipped with air pump
Vehicle without air pump
Spare channel.
The analyzer shall be prevented from reading the sample
until a lower CC>2 limit is selected.
If the C02 reading is less than the lower limit, the
analyzer output shall indicate an error message. The
printer shall be prevented from printing and an indication
of exhaust system dilution shall be displayed. (Ref:
EPA-AA-IMS-80-5-B, Section IX.C, page 53 and
EPA-AA-IMS-80-5-C, Section V.B, page 27) .
4.C.17 Engine Tachometer
A digital tachometer shall be integrated with the con-
sole for the purposes of measuring engine speed. The
hook-up to the engine shall be by means of an inductive
pick-up.
A lock-out feature shall be provided in the tachometer
that will cause an error message to be displayed if the
test idle speed range is exceeded or if the speed fluctu-
ates^ in excess of 10% of the reading. The printer shall
be prevented from printing until the idle speed conditions
are met. (Ref: EPA-AA-D1S-80-5-B, Section IX.Er page 55).
4.D ENVIRONMENTAL REQUIREMENTS
(Ref: EPA-AA-IMS-80-5-B, Section VII.Gr page 36 and
EPA-AA-IMS-80-5-C, Section III.Gr page 18.)
4.D.1 Storage Temperature
While in storage, the analyzer and all components
thereof shall be undamaged from ambient air temperatures
ranging from -20°F to 130°F.
4.D.2 Operating Temperature
The analyzer and all components shall operate without
damage and within calibration limits to ambient air tem-
peratures ranging from +35° to 110°F.
4.D.3 Humidity Conditions
The analyzer shall be designed for use inside a
building or semi-protective shelter that is vented or open
to outside ambient humidity. The analyzer shall be
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designed for use in such locations when the outside
relative humidity ranges between 0% to 100% condensing
(i.e., raining or dense fog).
4.D.4 Temperature Control
Analyzer components which affect sensitivity and cali-
bration shall have their internal temperature controlled
to design temperatures when exposed to the prevailing
ambient conditions of any inspection station. These in-
clude the conditions noted in the sections titled Operat-
ing Temperature and Humidity Conditions.
4.E PERFORMANCE SPECIFICATIONS
4.E.I Overall Accuracy
Each analyzer shall have an overall accuracy which
limits the maximum error to + 3% of each range or portion
thereof as followst
HC: 0 to 400 ppm HC = + 12 ppm
400 to 1000 ppm HC = +_ 30 ppm
1000 to 2000 ppm HC = +_ 60 ppm
CO: 0 to 2% CO == + 0.06%
2 to 5% CO « ±0.15%
5 to 10% CO = +_ 0.3%
This error shall include, but not be limited to, the reso-
lution limitations incurred when reading the equivalent
instrument meters and/or other readout devices by eye at
the distance of fifteen (15) feet. (Ref: BAR '80
Technical Specifications, Section 3.1.2, pages 1-2).
4.E.2 Meter Drift
For span and zero drift the instrument shall not ex-
ceed +12 ppm HC and +0.06% CO for the first hour of opera-
tion and shall not exceed +_8 ppm HC and +_0.04% CO for each
succeeding hour of operation. Both electrical corrections
shall be automatically activated at start-up each day and
before every test. (Ref: BAR '80 Technical
Specifications, Section 3.1.8, pages 3-4).
4.E.3 Warm-up
The analyzer shall reach stabilized operation in a
garage environment within 15 minutes from power on. The
lock out feature shall stay engaged until zero drift is
stabilized.
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4.E.4 Response
In response to a step change input concentration at
the sample probe inlet, the analyzer shall reach 95
percent of final reading within 14 seconds at low flow
conditions. (Ref: EPA-AA-IMS-80-5-B, Section VII.F.4,
page 34.)
4.E.5 Optical Correction Factor
4.E.5.1 Range
The hexane/propane conversion factor shall be limited
to values between 0*480 and 0.560. Factor confirmation
shall be made on each assembled analyzer by measuring both
N-hexane and propane on assembly line quality checks.
(Ref: EPA-AA-IMS-80-5-B, Section VII.E.9, page 33.)
4.E.5.2 Labeling
Each instrument shall be permanently labeled with its
correction factor, carried to two places (within the gas
accuracy limits).
4.E.6 interference
The effect of extraneous gas interference and elec-
tronic interference on the CO and HC analyzers shall be
limited. The limit values are indicated below. (Ref:
EPA-AA-IMS-80-5-B, Section VII.E.8, page 32 and EPA-AA-.
IMS-80-5-C, Section E.4, pages 14 and 15.)
4.E.6.1 Gas Interference
The indicated interference shall not exceed 8 ppm HC
or 0.02% CO for the following components:
14% C02
Saturated H2O at 100°F
100 ppm NO2-
4.E.6.2 Electronic Interference
interference from various sources of electrical and
electronic devices and/or circuits shall be limited to
5 ppm on the HC analyzer and 0.02% on the CO analyzer.
The following sources shall be considered.
High Energy Ignition (HEI) system
Variable and fixed speed electric tools and motors
110/220/440 line interference
RFI and VHI radio bands
Line voltage and frequency variations.
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4.E.7 Sampling System Leakage
The pressure side of the sample system shall be leak
free. (Ref: EPA-AA-IMS-80-5-B, Section VII.F.5 page 34
and EPA-AA-IMS-80-5-C, Section III.F.3-F.4, page 16 and
17.)
4.E.8 Hydrocarbon Hang-Up
The HC hang-up in the sampling system shall not exceed
20 ppm hexane as measured by the analyzer zeroed on room
air. (Ref: EPA-AA-IMS-8CI-5-B, Section VII.F.6, page 35
and EPA-AA-IMS-80-5-C, Section III.F.5, page 17.)
4.E.9 Antidilution Limits
The (X>2 analyzer shall meet all the analyzer
accuracy specifications between CC>2 values of 6% and
14%. Exceptions are (1) the C02 interference
specification does not apply and (2) the uncertainty of
the calibration curve shall be +0.90% CC>2 in the range
of 5-10% C02 and +0.5% CO2 in tEe range of 10 to 14%
C02.
4.F MANUALS .
Each analyzer shall be delivered with one each of the
following manuals:
a) Easy Reference Operating instructions
b) Operation Instruction Manual
c) Maintenance Instruction Manual
d) Initial Start-up, instructions.
The manuals shall be constructed of durable materials,
and shall not deteriorate as a result of normal use over a
five year period. Each mamual shall be attached to the
analyzer in a manner that will:
a) Allow convenient storage
b) Allow easy use
c) Prevent accidental loss or destruction.
The contents of the manuals are documented in
EPA-AA-IMS-80-5-B, Section VII.J.1-J.7, pages 39-40.
4.G QUALITY ASSURANCE
4.G.I Performance Bond
A performance bond in the amount of $ 500,000 will be
required. These funds will be held by the State and used,
in part or whole, in the event damages are suffered due to
non-performance or default.
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4.G.2 Prime Contractor Responsibilities
The contractor must assume total responsibility for
all equipment until such time as the State has formally
accepted this equipment. If any bidder's proposal in-
cludes equipment supplied by other manufacturers it will
be mandatory for each bidder to assume responsibility for
the maintenance of such equipment as prime contractor to
the Department. These responsibilities will include pro-
curement f delivery, installation, operator training and
maintenance of all equipment and support services offered
in the proposal whether or not the contractor is the manu-
facturer or producer of them. The Department will con-
sider the prime contractor to be the sole point of contact
with regard to contractual procurement of the entire
equipment system.
4.G.3 Responsibility for Equipment Maintenance
The contractor will be responsible for inspecting and
maintaining the emission equipment at least once per month
at the premises of the licensed station. The contractor
will include with his services a maintenance agreement to
ensure that the analyzers are kept properly maintained.
4.G.3.1 Maintenance Agreement
As part of the maintenance agreement the contractor
will provide service on demand for the equipment owned or
leased by licensed stations. This service will include
replacement if necessary. The maintenance agreement is
transferable to another licensed inspection station and
will continue for the length of the contract. The con-
tractor agrees to pay penalties to the licensed stations
according to the terms outlined in Paragraph 4.G.3.3 below.
4.G.3.2 Maintenance Schedule
The contractor is required to propose a preventive
maintenance schedule designed to meet the needs of this
program. The maintenance schedule must describe each item
of maintenance, its frequency, cost and who shall perform
it. Maintenance items which are more appropriately per-
formed by the station's personnel shall be identified.
4.G.3.3 Penalty for Equipment Downtime
When the analyzer or associated hardware remains
inoperable for a cumulative total of eight (8) hours or
more during a month, the contractor shall grant a credit
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to the station for each such hour of failure. The credit
shall be a percentage of the basic monthly lease charge.
The specific credit amount for each hour of failure will
be defined in the contract. Downtime for each incident
shall commence from the time the station places the work
request and shall terminate whenever the equipment is re-
turned to operating condition.
4.G.4 Quality Assurance Testing
The contractor must test a random sample of the first
batch of production units according to the quality
assurance procedures outlined in the following EPA
publicationst
Recommended Specifications for Emission
Inspection Analyzers, EPA Report No.
EPA-AA-IMS80-5-B, Chapter XI and Table VII-1.
Change Notice No. 1 to Recommended Speci-
fications for Emission Inspection Analyzers, EPA
Report No. EPA-AA-IMS-80-5-C, Revisions to
Chapter XI and Table VII-1.
The contractor may propose alternative Q.A. testing
procedures so long as the intent of the EPA recommended
procedure is satisfied. If an alternative procedure is
proposed, the advantages of this procedure (i.e., cost,
time, etc.) must be clearly delineated. The procedure may
be performed at the contractor's own facilities or in a
third party testing laboratory. The testing staff must
have experience in performance evaluation of automotive
emission testing equipment.
4.G.4.1 Pre-Production Accreditation
As stated in the EPA recommended specifications, the
manufacturer may receive a preliminary accreditation,
valid for 6 months, by providing a publicly released re-
port which demonstrates that at least one pre-production
unit has passed.all evaluation tests.
4.G.4.2 Initial Production Quality Assurance
As specified by the EPA, the manufacturer shall
select, in a random manner, three of the first 20 produc-
tion units, and all three shall receive all evaluation
tests. If two of the three units pass all evaluation
tests, the instrument shall receive full accreditation for
the production authorized under the terms of the original
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contract. If two or more units fail the evaluation tests,
corrections to the design and/or production must be made,
and three additional units selected from a new or current
production run. Two of these three must pass all evalua-
tion tests. All units covered by a preliminary accredita-
tion and produced prior to the production run in which
full accreditation is received shall be required to incor-
porate the necessary design and/or production fixes.
4.G.4.3 Quality Assurance Testing Criteria
As specified by EPA, two of the three production units
must pass with no design failures. A design failure is
defined as a failure to meet the evaluation procedure
criteria.
Random failures must have sufficient documentation
(i.e., published report available to the DEQE) to justify
why the failure can be attributed as a random failure and
not to minor design failure. Random failures may be re-
paired on all units. A condition to allow the repair of
production analyzers is the development of a plan (where
necessary) to prevent the specific type of failure in fu-
ture production units.. After repairs, those tests that
might be affected by the repairs should be rerun.
An infant mortality is defined as the total failure of
a part (usually a computer chip or related components)
within a short period of time after the unit first re-
ceives any electrical power. Infant mortality failures
must have sufficient documentation (i.e., published report
available to regulatory bodies) to justify why the failure
can be attributed as infant mortality and not minor design
failure. Infant mortality failure is not classified as an
analyzer failure if the failure would be obvious in the
field. After repairs, those tests that might be affected
by the repairs must be rerun.
4.G.4.4 Quality Assurance Testing Procedure
The test procedure for the pre-production, initial and
subsequent production quality assurance testing is
specified in Chapter XI of EPA Document No. EPA-AA-IMS-80-
5-B and Chapter VI of EPA Document No. EPA-AA-IMS-80-5-C.
Optional testing procedures suggested by bidders will be
considered; however the bidder must submit a bid based an
the EPA recommended procedure. If the bidder chooses to
propose an optional procedure, the benefits of this
optional procedure in terms of cost savings and time must
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be clearly delineated. The bidder must also clearly demon-
strate how the optional procedure satisfies the intent of the
EPA-recommended procedure.
4.G.4.5. Reviewing Agency
The Massachusetts DEQE will be responsible for eval-
uating the quality assurance test results and related engi-
neering reports.
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APPENDIX C
PROPOSAL EVALUATION METHODOLOGY
AND INSTRUCTIONS
-------
/EVALUATION METHODOLOGY AND INSTRUCTIONS
METHODOLOGY OVERVIEW
Evaluation of the bidder's proposals will be accomplished in
two parts. First, a technical and management evaluation will be
performed. This evaluation will be conducted by a team of evalua-
tors and will be performed as follows:
Each evaluator will score each bidder's proposal
based on predetermined criteria and scoring
techniques described herein.
A composite technical and management score will
then be developed for each bidder's proposal by
totaling the scores assigned to each bidder's
proposal by each evaluator.
Following the completion of the technical and management
evaluation, a cost evaluation will be performed. This evaluation
will be performed by a single individual (e.g., Chairman of the
evaluation team) rather than a team. The following methodology
will be employed:
Bidder's financial bids will be opened, and
the bids will be rank ordered from lowest to
highest. Separate rankings will be prepared
for purchase price bids, lease bids and main-
tenance.
Each bidder will then be assigned a score
depending on its position in the ranking with
the lowest bidder receiving the highest score.
Separate scores will be prepared for purchase
price, lease and maintenance.
Finally, a composite financial score will be
assigned to each bidder by totaling the indi-
vidual scores received by the bidder for purchase
price, lease and maintenance.
Award of the contract will be made to that bidder who has the
highest financial score and who has completely satisfied all
technical and management requirements (Note: This bidder may not
have the highest technical and management score). In the event
that two or more bidders have equal financial scores, the award
will be made to that bidder with the highest technical and manage-
ment score.
The remainder of this document presents specific instructions
and techniques for conducting the technical/management and cost
evaluations.
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TECHNICAL AND MANAGEMENT EVALUATION INSTRUCTIONS
In evaluating each bidder's proposal, use the following
scoring system:
Score Interpretation
1 Non-responsive
2 Lacking in some way but with
additional information could
be responsive
3 Satisfies requirements
4 Exceeds requirements in
some ways
5 Exceeds requirements in
many ways
Criteria No. 1; Conformance With Equipment Specifications
Score each of the following factors from 1 to 5. The section
number of the proposal associated with each factor is provided
for your reference. The comments column is provided for you to
note reasons for the score given.
Section Number
of Specification Factor Score Comments
4.A.I Design Goals
4.A.2 Useful Life
4.A.3 Name Plate Data
4.B.I Materials
4.B.2 . Construction
4.B.3 Mobility
4.B.4 Electrical Materials/
Construction
4.C.I Readout Display Con-
trol Panel
4.C.2 Process Control
System
4.C.3 Sampling System
4.C.4 System Vents
4.C.5 Analytical System
4.C.6 Fail Safe Features
4.C.7 Automatic Data
Collection
4.C.8 Printer
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Section Number
of Specification Factor Score Comments
4.C.9 Automatic Gas Span
4.C.10 Automatic Leak
Check
4.C.11 Automatic Hang-Up
Check
4.C.12 Vehicle Diagnosis
4.C.I3 Anti-Tampering
4.C.I4 Automatic Read
System
4.C.I5 Automatic Test
Sequence
4.C.16 Anti-Dilution
4.C.I7 Engine Tachometer
4.D.I Storage Temperature
4.D.2 Operating Temper-
ature
4.D.3 Humidity Conditions
4.D.4 Temperature Control
4.E.I Overall Accuracy
4.E.2 Meter Draft
4.E.3 Warm-Up
4.E.4 Response
4.E.5 Optical Correction
Factor
4.E.6 Interference
4.E.7 Sampling System
Leakage
4.E.8 Hydrocarbon Hang- .
Up
4.E.9 Anti-Dilution
Limits
4.F. Manuals
4.G.I Performance Bond
4.G.2 Prime Contractor
Responsibilities
4.G.3 Equipment Mainten-
ance
4.G.4 Quality Assurance
Testing
Computation Of Overall Score For Criteria No.l:
If any individual score is less than 3, the overall score is
the minimum individual score assigned multiplied by 7. If
all individual scores are 3 or greater, the overall score is
the average of all scores multiplied by 7.
Overall score for criteria No.l =
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Criteria No.2; Conformance With Data Collection, Conversion And
Transfer Requirements
Rate the bidder's proposed data collection plan from 1 to 5
based on your analysis of the following factors:
Factor Comment
Is the bidder proposing
to collect the data recor-
ded on the device, replace
the recording medium on
the equipment, and convert
the data into a form
acceptable to the Depart-
ment on a monthly basis
as required in the RFP?
Has the contractor proposed
to provide management and
work maintenance reports on
the maintenance, data collec-
tion and training schedules
on a quarterly basis as
specified in the RFP?
Are there any unique aspects
•to the contractor's data
collection and processing
plan that would be advanta-
geous to the Department?
For example, does the
contractor propose to pro-
vide data more frequently
than on a monthly basis?
Computation Of Overall Score For Criteria No.2;
Overall score is the score you assigned .
Overall Score For Criteria No.2 =
Criteria No.3: Evaluation Of Proposed Equipment From The Stand-
point Of Operational Simplicity And As A Tool For Emissions System
Repair
Rate the bidder's proposed equipment from 1 to 5 based on the
following:
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Factor Comment
How much operator training
is required?
What skill level is required
to operate the equipment?
Can the equipment be used for
emissions system repair as
well as inspection?
Are there any equipment features
that will facilitate or hamper
diagnosis and repair?
Computation Of Overall Score For Criteria No.3
Overall score is the score you assigned.
Overall score for Criteria No.3 =
Criteria No.4; Bidders' Experience, Financial Ability And Organi-
zational Structure
Rate the bidders' experience, financial ability and organi-
zational structure from 1 to 5i based on the following factors:
Factor Comment
Does the bidder have prior
experience in dealing with
emissions testing equipment
or systems?
How directly related is this
experience to the proposed
program in Massachusetts?
Does the bidder have exper-
ience in the development and
manufacturing of emissions
testing equipment?
How long has the bidder been
in business?
Does the bidder have experience
in equipment training?
Does the bidder have experience
in servicing emissions testing
equipment?
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Factor Comment
Does the bidder have the
resources to execute the
terms of the contract?
Is the bidder's proposed
organization sound?
reasonable?
What are the strengths
and experience of proposed
personnel?
Are there a proper mix of
skills represented in the
organizational structure
proposed by the bidder?
Has the bidder committed
sufficient manpower to the
program for it to be
successful?
How does the bidder propose
to manage subcontractors (if
subcontractors are proposed?)
Has the bidder presented a
plan for communicating
progress to the Department?
Has the bidder presented
a schedule for equipment
development and delivery?
Will the bidder meet the
April 1, 1983 start-up date?
Has the bidder incorporated
sufficient time in the
schedule to allow Massachusetts
to review/test the prototype
units and make changes to the
units if necessary?
Has the bidder identified
key milestones from which
Massachusetts can monitor
schedule performance?
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Factor Comment
Overall, is the schedule
realistic and justifiable?
Are there any unique aspects
to the schedule? For example,
is the bidder proposing an
accelerated schedule so that
the additional time before
program start-up can be used
for public awareness and
familiarization?
Computation Of Overall Score For Criteria No.4
Overall score is the score you assigned.
Overall score for Criteria No.4 =
Criteria No.5: Bidder's Recruiting Plans, Maintenance/Repair/
Calibration Plans And Schedule
Rate the bidders' proposed recruiting plans, maintenance/repair/
calibration plans and schedule from 1 to 5 based on your analysis
of the following factors:
Factor Comment
Has the bidder proposed a
plan for recruiting service
representatives including
minimum qualifications and
salary levels for these
individuals?
Is the plan reasonable?
Has the bidder proposed a plan
for establishing a servicing/
repair network which includes:
Response time to a call
for service.
. - Repairs to be performed
at the bidder's facilities
and expected downtown for
repair.
The general location of such
facilities?
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Factor Comment
Is the plan reasonable?
Computation Of Overall Score For Criteria No.5:
Overall score is the score you assigned.
Overall score for Criteria No. 5 =
COST EVALUATION INSTRUCTIONS
The financial bid will be evaluated by the following means
following the ranking of proposal bids as discussed in the
OVERVIEW:
For Purchase Price - 20 points for the lowest
purchase bid; 0 points for a purchase bid equal
to or greater than twice the lowest purchase
bid; and purchasse bids falling between these
two values will receive equal single point
increments assigned on a pro rata basis.
For Lease Price - 20 points for the lowest lease
bid; 0 points for a lease bid equal to or
greater than twice the lowest purchase bid;
and lease bids valuing between these two values
will receive equal single point increments
assigned on a pro rata basis.
For Maintenance Contract Price - 5 points for the
lowest maintenance contract bid; 0 points for a
maintenance contract bid equal to or greater than
twice the lowest maintenance contract bid; and
maintenance bids falling between these two values
will receive equal single point increments assigned
on a pro rata basis.
The total points possible for financial bids will be 45.
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EVALUATION SUMMARY
EVALUATORS NAME:
BIDDER:
TECHNICAL SCORE;
Criteria No.l =
Criteria No.2 =
Criteria No.3 =
Total Technical Score
MANAGEMENT SCORE;
Criteria No.4 =
Criteria No.5.=
Total Management Score
Total Technical &
Management Score
FINANCIAL SCORE;
Purchase Price =
Lease =
Maintenance =
Total Financial Score
Evaluator's Signature:
Date:
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