Test/QA Plan for Diesel Exhaust and Engine Modification Retrofit Technologies at SwRI
March 2011
                              Version 2.0
             TEST/QA PLAN FOR THE VERIFICATION TESTING OF
     DIESEL EXHAUST CATALYSTS, PARTICULATE FILTERS, AND ENGINE
  MODIFICATION CONTROL TECHNOLOGIES FOR HIGHWAY AND NONROAD
                            USE DIESEL ENGINES
                    EPA Cooperative Agreement No. CR83416901-0
                        RTI Sub Agreement No. 2-340-0212320

                                 Prepared by:
                                   K. Spreen
                                       BRTI
                                       INTERNATIONAL
 Southwest Research Institute

 6220 Culebra Road
 P.O. Drawer 28510
 San Antonio, TX 78228-0510
 Phone:   210-522-5012
 FAX:    210-522-3950
 E-mail:   kspreen@swri.org
RTI International

3040 Cornwallis Road
P.O. Box 12194
Research Triangle Park, NC 27709-2194
Phone:   919-541-7443
FAX:    919-541-6936
E-mail:   jhill@rti.org
                    This plan has been reviewed and approved by:
 Original signed by Kent Spreen
 K. Spreen, Technical Leader, Southwest Research Institute

 Original signed by Michael Van Hecke
 M. Van Hecke, Quality Manager, Southwest Research Institute

 Original signed by Jason Hill	
 J. Hill, RTI ETV/APCT Center Director

 Original signed by James Flanagan
 J. Flanagan, RTI ETV/APCT Center Quality Manager

 Original signed by Michael Kosusko
 M. Kosusko, EPA Project Manager

 Original signed by Robert Wright
 R. Wright, EPA Quality Manager
                         4/5/2011
                           Date

                         4/5/2011
                           Date

                         3/4/2011
                           Date

                         3/8/2011
                           Date

                        3/23/2011
                           Date

                        3/23/2011
                                                                  Date

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                                A2: Table of Contents
List of Figures  	v
List of Tables 	v
List of Acronyms and Abbreviations	vi
A3: Distribution List	viii
BACKGROUND 	1
GROUP A: PROJECT MANAGEMENT 	2
A4: Project/Task Organization 	2
A4.1. Management Responsibilities 	3
A4.1.1. EPA Project Manager	3
A4.1.2. RTI APCT Center Director	3
A4.1.3. RTI Task Leader 	4
A4.1.4. SwRI Technical Leader	4
A4.1.5. SwRI Task Leader	4
A4.2. Quality Assurance Responsibilities	4
A4.2.1. EPA Quality Manager	5
A4.2.2. RTI Quality Manager	5
A4.2.3. SwRI Quality Manager 	6
A5: Problem Definition/Background (Verification Approach) 	6
A6: Project/Task Description	6
A6.1. Description 	6
A7: Quality Objectives and Criteria 	7
A8: Special Training Requirement/Certifications  	10
A9: Document and Records	10
GROUP B: DATA GENERATION AND ACQUISITION	11
Bl: Sampling Process Design (Experimental Design)  	11
B2: Sampling Methods  	11
B2.1.  Exhaust Gas Sampling System	12
B2.2.  Particulate Sampling System	12
B2.3.  Corrective Action for Sampling 	12
B3: Sample Handling and Custody	13
B3.1.  Particulate Filter Handling Custody 	13
B3.2.  Raw Data Handling Custody	13

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B4: Analytical Methods 	14
B4.1.  Gaseous Analyzers 	14
B4.2.  Corrective Action for Analyzers 	14
B4.3.  Filter Weighing  	14
B5: Quality Control	15
B6: Instrument/Equipment Testing, Inspection, and Maintenance	15
B7: Instrument/Equipment Calibration and Frequency 	15
B7.1.  Gaseous Analyzer Calibration	16
B7.1.1. Hydrocarbon Analyzer 	16
B7.1.2. Carbon Monoxide Analyzer	16
B7.1.3. Oxides of Nitrogen Analyzer 	16
B7.1.4. Carbon Dioxide Analyzer	16
B7.2.  Constant Volume Sampler (CVS)  	16
B7.3.  Gas Meter Calibration 	17
B7.4.  Miscellaneous Instruments	17
B7.5.  Analyzer Calibration Gases	17
B8: Inspection/Acceptance of Supplies and Consumables	17
B8.1.  Test Fuel	17
B8.2.  Calibration Gases 	17
B8.3.  Paniculate Matter (PM) Filter Media	18
B9: Non-Direct Measurements 	18
BIO: Data Management 	19
GROUP C: ASSESSMENT AND OVERSIGHT ELEMENTS 	20
Cl: Assessments and Response 	20
Cl.l.  Internal Audits	20
C1.2.  External Audits	20
C1.3.  Audits of Data Quality  	20
C1.4.  Corrective Action 	20
C2: Reports to Management 	21
GROUP D: DATA VALIDATION AND USABILITY ELEMENTS 	22
Dl: Date Review, Verification, and Validation	22
D2: Verification and Validation Methods	22
D3: Reconciliation with User Requirements 	22

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APPENDIX A: APPLICABLE DOCUMENTS AND PROCEDURES 	23
1.  EPA Documents	23
2.  APCT Center Documents 	23
3.  SwRI AE Standard Operation Procedures 	23
4.  SwRIEEVRD Test and Inspection Procedures  	24

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                                     List of Figures
Figure 1. Organizational Chart	3
Figure 2. Gaseous and Particulate Emissions Sampling System 	11
Figure 3. Exhaust Gas Sampling and Analytical System  	14
Figure 4. ETV Data Management	19
                                     List of Tables

Table 1.  Test Equipment Specifications andDQIGs 	8
Table 2.  Gas Analysis Equipment Specifications and DQIGs	8
Table 3.  Calibration Gas Specifications andDQIGs 	9
Table 4.  Emission Test Data DQIGs	9

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ADQ
AE
APCT Center
CFO
CFR
CI
CO
CO2
CVS
DOC
DPF
DQIG(s)
DQO(s)
EEVRD
EPA
EPA-ORD
ER&DD
ETIS
ETV
FRIS
FTP(s)
GVP
HC
HD
HFID
in. H2O
kPa
Ib-ft
mm Hg
MSDS
N2
NDIR
NIST
NO
NO2
NOX
02
PDF
PEA(s)
ppm
ppmC
PTFE
QA
             List of Acronyms and Abbreviations

audit of data quality
Automotive Engineering
Air Pollution Control Technology Center
critical flow orifice
Code of Federal Regulations
compression-ignition
carbon monoxide
carbon dioxide
constant volume sampler
diesel oxidation catalyst
diesel particulate filter
data quality indicator goal(s)
data quality objective(s)
Engine, Emissions and Vehicle Research Division
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency's Office of Research and Development
Emissions Research and Development Department
Emissions Test Information System
Environmental Technology Verification
Filter Room Interface Software
Federal Test Procedure(s)
generic verification protocol
hydrocarbons
heavy-duty
heated flame ionization detector
inches of water
kilopascals
pound-feet
millimeters of mercury
material safety data sheet
nitrogen
non-dispersive infrared
National Institute of Standards and Technology
nitric oxide
nitrogen dioxide
nitrogen oxides
oxygen
positive displacement pump
performance evaluation audit(s)PM particulate matter
parts per million
parts per million carbon
polytetrafluoroethylene
quality assurance

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QC           quality control
QM          quality manager
QMP         quality management plan
QSA         quality system audit
RTI          Research Triangle Institute
SET          supplemental emissions test
SOP(s)       standard operating procedure(s)
SOW(s)       statement(s) of work
SwRI         Southwest Research Institute
TIP(s)        test and inspection procedure(s)
TO           test organization
TQAP        test/quality assurance plan
TSA(s)       technical systems audit(s)VR verification report
|j,g            microgram

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A3:  Distribution List

U.S. EPA
Michael Kosusko
Robert Wright

RTI International
Jason Hill
James Flanagan

Southwest Research Institute
Jeff White
Kent Spreen
Michael Van Hecke
Mike Ross

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                                   BACKGROUND

The U.S. Environmental Protection Agency's Office of Research and Development (EPA-ORD)
directs the Environmental Technology Verification (ETV) program to verify performance of
innovative technologies that have the potential to improve protection of the environment. The
ETV program's goal  is to supplement environmental protection by  accelerating the entrance of
new  technologies  into marketplaces.  ETV  is  a voluntary  program  that makes objective
performance information available to support assessment by potential users.  From performance
data generated under  ETV, technology buyers,  financiers, and permitters in the U.S. and abroad
will be better informed to make decisions regarding environmental  technology purchases. The
ETV verification provides actual performance of a technology under specific, pre-determined
criteria or protocols and a strong quality management system. ETV  does not endorse, certify, or
approve technologies.

The Air Pollution Control Technology Center (APCT Center) is one of six ETV centers.  EPA's
partner verification organization, RTI International  (RTI), manages the APCT  Center.  The
APCT Center conducts verification testing of potential air pollution control technologies. The
APCT Center  conducts performance evaluations according to  externally reviewed verification
Test/Quality Assurance Plans (TQAPs), technology specific Test Plan addenda or  Statements of
Work (SOWs), and established protocols for quality assurance.

Emissions testing for air pollution  control technologies to be used  on mobile sources (on-
highway or nonroad vehicles with diesel engines) and some stationary source diesel  engines is
conducted at Southwest Research  Institute (SwRI), an independent, not-for-profit, applied and
developmental research organization. Southwest Research Institute's  Emissions  Research and
Development Department (ER&DD) has had significant experience with automotive emissions
testing.   ER&DD has worked with the EPA  to  develop  automotive  emissions  sampling and
analytical techniques, and to develop test  procedures used for regulatory purposes.  ER&DD
maintains ISO 9001:  2008 certification and ISO 17025: 2005 accreditation.  The  APCT Center
has selected SwRI as  a test organization to perform ETV testing  for mobile sources.

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                       GROUP A: PROJECT MANAGEMENT

A4: Project/Task Organization

The EPA has overall responsibility for the ETV program for the APCT Center.  The APCT
Center is managed by RTI International. SwRI is a test organization performing ETV for mobile
source technologies for the APCT Center.

Management and testing of diesel oxidation catalyst (DOC), diesel particulate filter (DPF), and
engine modification  control  technologies for mobile sources within the  APCT Center  are
performed in  accordance with procedures  and  protocols  defined  by  a  series  of quality
management documents.  The primary source for  the APCT Center  quality  system is EPA's
Policy and Program Requirements for the Mandatory Agency-wide Quality System, EPA Order
5360.1 A2 (May 2000).  The quality system is in compliance with the following:

       •   EPA Requirements for Quality Management Plans (EPA QA/R-2)
       •   EPA's Environmental Technology Verification Program, Quality Management Plan
          (EPA ETV QMP) for the overall ETV program
       •   APCT Center's Verification Testing of Air Pollution Control Technology - Quality
          Management Plan (APCT Center QMP)
       •   APCT Center's Generic  Verification Protocol (GVP)for Diesel Exhaust Catalysts,
          Particulate Filters, and Engine Modification Control Technologies for Highway and
          Nonroad Use Diesel Engines
          SwRI's Automotive Engineering (AE) Standard Operating Procedures (SOPs)
       •   SwRI's EEVRD test and inspection  procedures (TIPs)
       •   This test/quality assurance plan (TQAP).

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

As an APCT Center qualified test organization (TO), SwRI will verify the emissions reductions
for DOC, DPF,  or engine modification technologies intended for on-highway and nonroad diesel
engines.  SwRI will perform the testing, evaluate the data,  and submit a report documenting the
results to RTI.  RTI will use  the  data to prepare  the  verification  reports and verification
statements.  The various QA and management responsibilities are divided among SwRI, RTI,
and EPA key personnel as defined below.  The lines of authority among key personnel for this
project are shown on the project organization chart in Figure 1.

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                           EPA Project Manager
                             Michael Kosusko
                      EPA Quality Manager
                         RobertWright
                          RTI APCT Center Director
                                Jason Hill
                      RTI Quality Manager
                        James Flanagan
     Technology Vendor
RTI Task Leader
   Jason Hill
                                                                          SwRI Organization
                                                   AE Quality Manager
                                                     Mike Van Hecke
                          — Normal lines of communication and responsibility
                          	 Informal communication
                          	 Organizational Independence
                                               Automotive
                                               Engineering
                                                                       Engine, Emissions, and
                                                                          Vehicle Research
                                                                          Emissions R&D
                                                                             Jeff White
                                                                               _L
                                                                          Technical Leader
                                                                            KentSpreen
                                                                           Task Leader
                                                                           Technical Staff
                         FIGURE 1.  ORGANIZATIONAL CHART

A4.1.  Management Responsibilities

Project management responsibilities  are divided  among the  SwRI,  RTI,  and  EPA staff as
described below.

A4.1.1. EPA Project Manager

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

A4.1.2. RTI APCT Center Director
The RTI APCT Center director is Jason Hill.  He has overall responsibility for liaison with the
EPA project manager, technical and administrative oversight of the APCT Center and the QA
program in the APCT Center  and for technology-specific verification tests.  He will assign
technology verification task leaders; oversee verifications;  review technical panel makeup; and
review generic verification protocol and test-specific quality documents.  These responsibilities
are described in greater detail in Section 2 of the APCT Center's QMP.

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A4.1.3. RTI Task Leader

The RTI task leader is Jason Hill.  He will:

       •   Define task objectives,
       •   Develop a detailed test scope,
       •   Work with vendors and stakeholders,
       •   Prepare test-specific addenda to this document,
       •   Review work progress to ensure that task budgets and schedules are met, and
       •   Prepare verification reports and verification statements.

Hill has overall responsibility for coordinating verification of technologies between applicants
and the APCT Center qualified testing organization.

A4.1.4. SwRI Technical Leader

The SwRI technical leader is Kent Spreen. He will:

       •   Assist the RTI task leader with the test scope,
       •   Review/prepare operating procedures applicable to the testing,
       •   Review test apparatus and procedures prior to commencement of testing,
       •   Oversee testing of the DOC, DPF, or engine modification technologies,
       •   Review test data/results for attainment of data quality objectives (DQOs) and
          reasonableness,
       •   Initiate corrective actions when needed,
       •   Review test results, and
          Submit test results to the RTI task leader.

Spreen has  overall  responsibility for technical and  administrative  activities, and  exercises
technical leadership to promote quality in project performance.  He will also function as liaison
for clients in specific technical areas and supervise the activities of project leaders.

A4.1.5. SwRI Task Leader

Task leaders assigned by the SwRI technical leader will:

       •   Review the statement of work,
       •   Develop specific instruction for test work,
       •   Interface between test operations and vendor, and
       •   Review and communicate results to RTI.

A4.2. Quality Assurance Responsibilities

QA responsibilities are divided among the EPA, RTI,  and SwRI personnel as listed below.

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A4.2.1. EPA Quality Manager

The EPA quality manager (EPA QM), Robert Wright, will conduct audits of RTI's QA system
and of specific technical activities on the project. He will be available to resolve any QA issues
relating to performance and EPA's QA requirements.  Specific functions and duties of the EPA
QM include approving the contents of this TQAP and subsequent revisions and reviewing  QA
reports prepared by RTI, including QA evaluations and audits.  In addition, the EPA QM will:

       •   Communicate quality systems requirements, quality procedures, and quality issues to
          the EPA project manager and the RTI project manager,
       •   Review and approve APCT Center quality systems documents to verify conformance
          with the quality provisions of the ETV quality systems documents,
       •   Perform technical systems audits (TSAs) and performance evaluation audits (PEAs)
          of verification tests, as appropriate, and
       •   Provide assistance to APCT Center personnel in resolving QA issues.

For each technology tested  under this TQAP,  the EPA QM (or his designee) will perform the
following specific activities  associated with the verification tests:

       •   Review and approve the GVP for diesel  exhaust and  engine modification retrofit
          technologies,
       •   Review and approve this SwRI-specific TQAP and each test-specific addendum,
       •   Review and approve each verification report and each verification statement, and
       •   Perform a PEA of the verification test of SwRI's ETV testing operations.

A4.2.2. RTI Quality Manager

The  RTI APCT  Center quality manager (RTI QM),  James Flanagan,  is organizationally
independent of the RTI  APCT Center director and is responsible for ensuring that QA/quality
control (QC) procedures  described in this TQAP are followed.  In addition, Flanagan will:

       •   Maintain regular communication with the EPA QM and APCT Center staff regarding
          QA issues,
       •   Report on the adequacy,  status, and effectiveness of the QA program  on a regular
          basis to the task leader and the APCT Center director,
       •   Conduct audits of lab activities as necessary and prepare audit reports,
       •   Ensure that corrective action, if necessary, is properly implemented and documented,
       •   Review and approve GVPs, TQAPs, TQAP addenda, and SOPs,
       •   Review the audit of data quality  (ADQ) report of the SwRI quality manager (SwRI
          QM),
       •   Review and approve test (including QC) reports, and
       •   Prepare the QA section of each verification statement and verification report.

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A4.2.3. SwRI Quality Manager

The SwRI QM, Mike Van Hecke, plays a central role in the introduction, implementation, and
consistent application of continuous quality improvement at SwRI's AE.  He fulfills the role as
quality management representative for the department and is organizationally independent of the
unit generating the data. He will:

       •   ensure the official, approved version of this document is maintained,
       •   review and approve test-specific addenda to this document,
       •   reconcile  test results with DQOs  via attainment of data quality  indicator goals
          (DQIGs),
       •   conduct audits of all pertinent quality standards to ensure compliance, and
       •   conduct the  test-specific  ADQ as described in Element C1.3 and prepare the ADQ
          report.

A5: Problem Definition/Background (Verification Approach)

The objective for ETV testing of air pollution control technologies is to  quantify emissions
reduction  capability  and determine effectiveness  for "commercial ready"  technologies.   Air
pollution control technologies for mobile sources are  effectively used to reduce emissions from
older diesel engines.  This use of engine  pollution control technologies as diesel retrofit requires
proper integration with an engine or group of engines to decrease emissions, but integration is
not necessarily intended to bring the engine to current or any prior emission regulation levels.
Performance  of a  diesel retrofit technology  to  decrease emissions is  verified with ETV.
Verification of diesel retrofit technologies is in the spirit of introducing innovative technologies
that have potential to improve environmental protection. Verified technologies are performance-
proven by independent  and objective  testing using test  procedures used for air  pollution
regulation,  established  protocols, and an EPA-approved  quality management system.   This
TQAP is specific to the DOC and DPF retrofit technologies that reduce PM emissions, along
with HC and CO, or engine modification retrofit technologies that reduce HC, CO, NOX, and PM
emissions.  A test-specific addendum (Test Plan SOW) will provide additional information to
this TQAP to conform to Element A5 of EPA QA/R-5.

A6: Project/Task Description

A6.1. Description

The diesel retrofit technologies covered by this ETV TQAP are intended for use on on-highway
heavy-duty (HD) diesel engines and nonroad compression-ignition (CI) engines.  Emissions test
procedures for the candidate technology devices will  use procedures for emission regulation of
on-highway HD and nonroad CI engines.  Federal Test Procedures (FTPs) are documented in
CFR Title 40 Part 86, Subpart N for on-highway HD engines and 40 CFR Part 89 for nonroad CI
engines.  Procedures in 40 CFR Part 86, Subpart N  include the transient FTP for heavy-duty
diesel engines and the  supplemental emissions test (SET).  It is important to state that as of
January 2010 these test procedures are obsolete and replaced by revised procedures.  It is
assumed that candidate technology devices are intended for engines manufactured before 2010;
therefore, appropriate test procedures will come from 40 CFR Parts 86 and 89.  The use of 40

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CFR Part 1065 emission test procedures will be specifically stated in a test-specific addendum to
this TQAP document, also known as the Test Plan SOW.

Primary  measurement  will include regulated  emissions  of total  hydrocarbons (HC), carbon
monoxide (CO), oxides of nitrogen (NOX), and  total particulate matter (PM).  Based on the
specific technology,  the type of FTP and number of tests are  determined to conform to the
Generic  Verification Protocol for Diesel Exhaust Catalysts,  Particulate Filters, and Engine
Modification Control Technologies for Highway and Nonroad Use Diesel Engines., Sections 5.1
and 2.3,  to satisfy test design requirement and data quality objectives.   These sections of the
GVP  give  information on test design and objectives to determine confidence intervals that
differences in mean emission levels are measured.

A description of the specific technology, test engine, and test-specific details will be documented
as a test-specific addendum to this TQAP that will be prepared by RTI task leader, reviewed by
the SwRI technical leader, and submitted for EPA review and approval prior to beginning of the
ETV test program. The test-specific addendum will provide additional information to this TQAP
to conform to Element A6 of EPA QA/R-5.

A7: Quality Objectives and Criteria

In order to determine the emissions performance of a diesel retrofit technology, test quality must
be assured. Emissions testing by FTP must follow a large number of quality requirements given
in 40 CFR Part 86 (on-highway engine tests) or Part 89 (nonroad engine tests) to deem the data
as valid.  All emissions sampling  and measurement equipment along with  ambient condition
measurements and engine  parameter measurements have requirements in 40 CFR for accuracy
and traceability to standards.

For this ETV testing, achieving data quality objectives (DQOs)  requires that test methods and
procedures adhere strictly to 40 CFR Part 86, Subpart N or 40 CFR Part 89. Test DQOs given in
Section 2.3  of the GVP  give  reference to the  number of individual emissions tests to  be
conducted to achieve desired confidence intervals that differences  in mean emission levels are
detected. At a minimum, three repeated tests using a specific test cycle (Part  86 or Part 89) are
conducted.   The number and  type  of emission tests will  be specified in the test-specific
addendum to this TQAP.

Each individual measurement within an emissions test has specific data quality indicators that
must be met to  ensure  project DQOs.  The  data quality indicator goals (DQIGs) for individual
measurements are listed in Tables 1 through 4.

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           TABLE 1.  TEST EQUIPMENT SPECIFICATIONS AND DQIGs
Measurement
Variable
Speed
Torque
CVS Volumetric Flow Rate
Propane analysis
Mass flow verification using a
critical flow orifice (CFO)
PM Double Dilution Flow Rate
Dilution meter
Sample meter
System Pressures
System Temperatures
Accuracy
Specification
±2% of absolute
standard
±3% of true torque3
Measured mass ± 2% of
injected propane mass
± 1% of total flow
through PM filter
± 2% of point /± l%full
scale
±0.4 kPa
(± 3 mm Hg)
(± 1.6 in. H2O)
± 1.9°C(±3.4°F)
Frequency
Monthly
Weekly
Weekly
When replaced
Annually
Semi-annually
Semi-annually
Semi-annually
Semi-annually
40CFR
86.1308-84
86.1318-84
86.1316-94
86.1319-90
86.1316-94
86.1320-90
86.1309-90
86.1309-90
a Torque accuracy also defined as ± 2.5 Ib-ft for full-scale values up to and including 550 Ib-ft, ± 5 Ib-ft
for full-scale values up to and including 1050 Ib-ft, and ± 10 Ib-ft for full-scale values over 1050 Ib-ft.
      TABLE 2.  GAS ANALYSIS EQUIPMENT SPECIFICATIONS AND DQIGs
Measurement
Variable
HC
CO
CO2
NOX
NOX Converter Efficiency
NOX/CO2 Quench
CO/CO2 Interference
Accuracy or Result
Specification
±2% of point
and
± 0.3% of full scale at zero3
> 90%
<2%
< 3 ppm (Range 0-300 ppm)
< 1% full scale (Range > 300
ppm)
Frequency
Monthly
Monthly
Annually
Annually
40CFR
86.1321-94
86.1322-84
86.1324-84
86.1323-2007
86.1323-2007
86.1323-2007
86.1322-84
a Emission measurement accuracies in 86.1338-2007 also apply.

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           TABLE 3.  CALIBRATION GAS SPECIFICATIONS AND DQIGs
Gas
HC
CO
CO2
NOX
Zero Air
HFID Fuel
Specification
Named to ± 1% of NIST Value
andNO2<5%ofNO
< 1 ppmC HC
< 1 ppm CO
< 0.04% CO2
<0.1ppmNOx
18 to 21% O2
remainder N2
40 ± 2% H2
< 1 ppmC HC
remainder helium
40CFR
86.1314-94
86.1314-94
86.1314-94
                     TABLE 4. EMISSION TEST DATA DQIGs
Variable
CVS sample zone temperature
PM filter face temperature
Primary dilution temperature
HC (HFID) sample train temperature
Engine intake air temperature
Post-test span & zero drift
Transient cycle validation
Cold-Start soak temperature (transient)
PM weigh chamber
Conditioning temperature
Conditioning humidity
Sample filter checkout time
Reference filter weight change
Specification
191°Cmax.
52 °C max.
25 °C ± 5 °C
191 °C± 11°C
25 °C ± 5 °C
± 2% full scale (CO, CO2, NOX)
± 3% full scale (HC) of initial
per 40 CFR 86. 1341
>20°C
22 °C ± 3 °C
Dew point 9.4 °C ± 3 °C and
relative humidity 45% ± 8%
< 1 hour
< 40 (ig change
40 CFR
86.1310-903
86.1330-90
86.1340-94
86.1341-98
86.1330-90
86.1312-88b
86.1339-90
a Exhaust gas sampling and analytical system for gaseous and particulate emissions can follow methods in
40 CFR 86.1310-2007 if stated in test-specific addenda.
b PM filters can be high efficiency membrane media if specified in test-specific addenda; filter
conditioning and weighing facility will conform to 40 CFR 86. 13 12-2007.

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A8: Special Training Requirement/Certifications

The  ER&DD is certified to  International Organization for  Standardization  (ISO) 9001:2008
"Model for Quality Management  Systems."  This independently assessed system provides the
basis for quality management procedures that are applied to all emissions tests processes at
ER&DD.

ER&DD is accredited  to  ISO/IEC  17025  "General Requirements  for  the Competency  of
Calibration  and  Testing  Laboratories."   Under  American  Association  for Laboratory
Accreditation Certificate Number 0702-01, ER&DD has been accredited to perform evaluations
of automotive  fluids; fuels;  emissions;  and automotive component, engine and  powertrain
performance and durability using stationary engine dynamometer test stands (light-duty, heavy-
duty,  and   nonroad)   vehicle  dynamometer   facilities,   and   automotive  fleets   (see
http://www.a21a.org/scopepdf/0702-01.pdf).  The certificate accredits ER&DD to use specific
standards and procedures, including dynamometer procedures for regulated emissions testing.

All ER&DD personnel supporting the project will be qualified as described by AE SOP 4.18.

A9: Document and Records

The  scope of test documents and records  to be maintained by SwRI is given in Part A, Section
5.3 of the ETV  program QMP. Section 3.6 of the APCT QMP states that project documentation
will be retained by SwRI or APCT for 7  years.  These documents include: TQAP, SwRI  SOPs
and TIPs, calibration data and certificates of standards, raw test data, emission results, and final
project reports.

Test plan documentation such as this TQAP and test-specific addenda will  be maintained by the
SwRI quality manager.  SOPs and TIPs are  maintained and accessible at the EEVRD website.
Calibration records will  be maintained in central  storage locations at ER&DD.  Records of
traceability to standards  and  certificates  of  standards will be maintained in  the  same storage
locations.  Each individual test's data are  recorded manually on pre-formatted data sheets  at the
facility as the test is conducted. Test data will be assembled into a data packet and transferred to
a central location for entry into a database. Emissions  calculations are conducted using compiled
software within the database.  The database information  and test  results  will be archived
electronically and  the paper  data packets  will be stored in central storage locations.   The
procedure for storage of test data forms and calibration records is documented in AE  SOP 4.16.
The  subagreement, subagreement  modifications, correspondence between  SwRI and  RTI,  final
reports and billing information will be maintained in central storage locations.

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                 GROUP B: DATA GENERATION AND ACQUISITION

Bl: Sampling Process Design (Experimental Design)

The experimental design follows the FTP for the respective on-highway  or nonroad application
with the number of separate FTP tests for a specific technology determined by the algorithm
specified in Section 5.1 of the  GVP.  The rationale for the number of FTP test cycles will be
included in the test-specific addendum to this document, which will conform to required Element
Bl of EPA QA/R-5.  Primary measurements will include brake specific  emissions of HC, CO,
NOX,  and PM. Noncritical emission measurements include nitrogen dioxide (NO2).  Additional
emissions  measurements and  methods  will  be specified  in  the   test-specific  addendum.
Implementation of procedures from 40 CFR Parts 86 or 89 are documented in EEVRD Test and
Inspection  Procedures (TIPs) listed in Elements B3 through BIO.

B2: Sampling Methods

The emissions sampling system is a constant volume sampler  (CVS) system, described in 40
CFR 86.1310-90 for on-highway applications and 40 CFR 89.419 for nonroad applications, onto
which gaseous and particulate emission measurement systems are attached. An illustration of the
sampling system is given in  Figure 2.  This is a typical design with  some variation at individual
test cells due to their instrumentation configuration.
                            Optional for
                            Particulate
                         Background Reading
                            Zero Air
     Discharge
                                      HC Span Gas
                                                                  To Background Sample Bag
     Dilution Air Filter
     Sampling Train
                                A
                 Read Background Bag**	S~

LEGEND
     Flow Control Valve
     Selection Valve
     Particulate Filter
     Pump
     Flowmeter
     Pressure Gauge
     Recorder
     Temperature Sensor
Dillution Tunnel
   Heated Probe
 Particulate Probe
Mixing Orifice
                     Exhaust Inlet
 V
 0
                                                  Supply Air
                                           Primary Filter
                                            Back-up Filter
                                                        Dilute Emission Bench
                                                         (HC, CO, CO 2, NOX|
                                                Heat Exchanger

                                                  4-444
                                                  ,To Pump Rotometer
                                                    and Gas Meter
                                                    as Diagramed
                                                     Immediately
                                                      Below
                                 Discharge
                                                                              To Formaldehyde
                                                                              Sample Collection
                                                                              To Methanol Sample
                                                                              Collection
                                                                             Manometer
                                                                               Revolution Counter
                                                                                   Pick Up
                                                                             Manometer
                                                                             Discharge
    FIGURE 2. GASEOUS AND PARTICULATE EMISSIONS SAMPLING SYSTEM

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B2.1. Exhaust Gas Sampling System

The  exhaust  gas  sampling system conforms to  40 CFR  86.1310-90 or 40 CFR  89.419 in
construction,  performance, and calibration requirements.  CVS systems at SwRI use a positive
displacement pump (PDF) with heat exchanger. The CVS flow is sufficient to maintain a dilute
exhaust stream below 191 °C  and above temperatures  that would allow water condensation.
Sample probes are placed in the CVS at a position where dilution air and exhaust are well mixed
(at least ten tunnel diameters downstream from where the exhaust enters the CVS).  A heated
sample probe, sample system, and analyzer for continuous HC measurement are maintained at
191 °C ± 11 °C.  Continuous measurement of CO, CC>2, and NOX is sampled from one common
heated sample probe and pump. The NOX sample system is maintained at 191 °C ± 11 °C up to
the NO2/NO converter. A separate probe leads to a double dilution system for PM measurement.

B2.2. Particulate Sampling System

PM emission mass is determined by filtration of a portion of the dilute exhaust.  Particulate
samples are collected on a pair of polytetrafluoroethylene (PTFE)- or Teflon-coated glass fiber
filters using a double dilution technique  as outlined in 40 CFR 86.1310-90.  A portion of the
diluted exhaust from the primary CVS tunnel is routed  into a secondary dilution system, where it
is further diluted in order to control the temperature of the sample stream  to 52 °C or less.
Particulate sample filters are conditioned and weighed according to procedures  described in 40
CFR  86.1312-88  and  86.1339-90 (see  Element B4.3  for  specific  sample  filter weighing
procedures).   Sample filter  weighing is conducted  at a central location  separate from  the
engine/dynamometer emissions test facility.

The double dilution technique as  outlined in 40 CFR 86.1310-2007 can be used if it is stated in
the  test-specific addenda.   With this  2007  technique, a  single PTFE-  or Teflon-coated
borosilicate glass fiber high efficiency filter or PTFE or  Teflon high efficiency membrane filter
is used.

Particulate sampling for nonroad applications is specified in 40 CFR 89.112 which references the
California Code of Regulations for new 1996 and later heavy-duty off-road diesel cycle engines.
There is  a reference from the  California Air Resources Board that particulate sampling uses
procedures from ISO  8178.  ISO procedures agree with 40 CFR Part  86 with  an  additional
requirement for sampling gas face velocity through the filter to be between 35  and 80 cm/s and a
recommended pressure drop increase less  than 25 kPa, between the beginning and end of the test.

B2.3. Corrective Action for Sampling

Any deviation of emissions  sampling from requirements of the CFR that include equipment
malfunctions, nonconformances,  and/or  testing problems are reported by the test  personnel
(technical staff) to the technical leader or task leader as  per AE SOP 4.10.2.  Corrective action
from any deviations to CFR procedures is conducted according to AE SOP 4.13.

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B3: Sample Handling and Custody

Collection of emissions  data is performed within one building at ER&DD.  Therefore, sample
handling and custody are  straightforward. No data or samples are transferred to/from outside
locations. The PM sample filters and raw test data forms involve manual handling from test
facilities (test cells) to central processing locations.

B3.1. Particulate Filter Handling Custody

The PM sample filters are  prepared and processed according to EEVRD TIP 07-020 (Particulate
Filter Conditioning and Weighing in Accordance with CFR Title 40 Parts 86 and 89).  The TIP
specifies sample  handling and custody procedures  as well as a method of conditioning and
weighing filters used for  PM sampling  during  emissions tests.  The handling and custody
procedures  in TIP 07-020  include:  A pair of sample filters are placed into a petri dish with a
cover.  Using the Filter Room Interface Software (FRIS),  a unique bar code number is generated
for the petri dish  and the dish with the filter set is placed inside the  conditioning chamber (see
Element B4.3) for at least one hour prior to taking a tare weight. FRIS is used to record the time,
tare weight,  temperature, dew point, humidity, and barometric pressure associated with the filter
set's bar code. The petri dish is returned to the conditioning chamber until the filter set is needed
for a test. When a dish is removed from the chamber for testing, FRIS is used to record the time.
The sample  filter  set is removed from the petri dish at  the test cell and  immediately placed into
the sampling system (see  Element  B2.2).  A used filter  set is  replaced into the petri dish and
returned to the conditioning chamber  within one hour of the removal time using FRIS to record
the check-in time. Filter sets not used within one hour  are returned to the conditioning chamber
for a new tare weight unless the filters are  kept in a sealed container. The filter set will remain in
the conditioning chamber for one hour prior to taking gross weight.  FRIS is used to record the
time, gross weight, temperature, dew point, humidity, and  barometric pressure.

B3.2. Raw Data Handling Custody

Quantitative data  as required in  40 CFR 86.1342-94,  86.1343-88 and 86.1344-94 or 40 CFR
89.405 and 89.424 are recorded on formatted forms.  All  raw data forms are prepared according
to EEVRD  TIP 07-009 (Emissions  Testing During Heavy-Duty Diesel Engine Transient Cycle)
and TIP  07-038 (Steady-State Dilute Emissions Testing of Heavy-Duty Engine Using Horiba
MEXA-7200D  Emissions  Bench).    The  forms are given a  unique test number, dated, and
assembled into a test packet according to respective TIPs  07-009 and 07-038. Raw data that are
recorded on the forms include CVS and double dilution  information for calculation of volume
flow rates,  exhaust gas analyzer  concentrations and background levels, engine  air temperature
and dew point, dilution air temperature and wet bulb  temperature, barometric  pressure,  cycle
work or horsepower, and the paniculate filter bar code number. The packet is transferred to a
central location for entry into a database that is used to calculate emission test results.

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     B4: Analytical Methods
Version 2.0
   Page 14
     Gaseous emissions of HC, CO, and NOX are measured by gas analyzers that  sample a dilute
     exhaust stream from the CVS.  Particulate emissions are determined by the net weight gain of
     sample filters.

     B4.1. Gaseous Analyzers

     The gaseous analytical  system,  as illustrated in Figure 3, conforms to 40 CFR 86.1310-90 or 40
     CFR 89.309.  ER&DD test facilities use Horiba MEXA 7200D analyzer benches.  Analyzer
     operation is specified in EEVRD TIP 07-009 (Emissions Testing During Heavy-Duty Diesel
     Engine Transient Cycle) and TIP 07-038  (Steady-State Dilute Emissions Testing of Heavy-Duty
     Engine Using Horiba MEXA-7200D Emissions Bench).
                                                                    Optional
 Vent to f
Atmosphere vi
                                                                                LEGEND
                                                                                    Particulate Filter

                                                                                    Flowmeter
                                                                                    Backpressure Regulator with
                                                                                    Internal Control Loop Shown
                                                                                    Line Pressure Regulator with
                                                                                    Internal Control Loop Shown
                                                                                    Ball Valve or Equivalent
                                                                                    (Darkened Leg Indicates
                                                                                    Common Port)
                                                                                    Flow Control or Needle Valve
                                                                               As— Plug Valve or Equivalent
                                                                              "^fo   (Center Port is Common)

                                                                               I	1  Heated Area
                                                                                CL  Chemiluminescent
                                                                               NDIR Non-dispersive Infra-red
                                                                               HFID Heated Flame lonization
                                                                                    Detector
      V2 F4 F3     V16

              FIGURE 3. EXHAUST GAS SAMPLING AND ANALYTICAL SYSTEM
     B4.2. Corrective Action for Analyzers

     Any  deviation of  gas analysis  from  requirements  of the  CFR  that  include  equipment
     malfunctions,  nonconformances,  and/or testing  problems  is  reported  by the  test personnel
     (technical staff) to the technical leader or task leader as per AE SOP 4.10.2.  Corrective action
     from any deviations to CFR procedure is conducted according to AE SOP 4.13.

     B4.3. Filter Weighing

     Particulate sample filters are conditioned in temperature and humidity controlled chambers that
     conform  to   40  CFR  86.1312-88  according  to  EEVRD  TIP 07-020  (Particulate Filter

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Conditioning and Weighing  in Accordance with CFR Title 40 Parts  86 and 89).   Weighing
process  conforms to 40  CFR 86.1339-90 and the weighing  chamber conforms  to 40 CFR
86.1312-88.  Procedure given in TIP 07-020 for filter weighing is summarized in Element B3.1.

Use of high  efficiency membrane filters for PM will be specified in the test-specific addendum.
These filters are conditioned and weighed in chambers that conform to 40 CFR 86.1312-2007
according to EEVRD TIP 07-045 (Particulate Filter Conditioning and Weighing in  Accordance
with CFR Title 40 Part 1065). The ambient temperature and humidity conditions for stabilizing
and weighing these filters are identical between 40 CFR 86.1312-2007 and 40 CFR  1065.190.
Membrane filter handling custody and weighing procedures are the same as  summarized in
Element B3.1 except one filter is used instead of a pair of filters, conditioning time is 30 minutes
before tare and gross weights are recorded, and the weighed filter is placed into a cassette, while
the filter remains in the clean environment of the conditioning chamber, that holds the filter for
sampling.

B5: Quality Control

Quality control limits in 40 CFR Part 86 (on-highway engine tests) are mostly the same or in a
few cases more stringent than 40  CFR Part 89 limits (nonroad engine tests). Quality control
limits for testing under this  TQAP will adhere  strictly to 40 CFR Part  86.  Quality control
activities for calibrations of the  dynamometer,  CVS, analytical  equipment,  pressures,  and
temperatures are documented in AE SOP 4.11.1  and SOP 4.10.2 and EEVRD TIPs listed in
Appendix A Table 4-1. The control limits from  40 CFR Part 86 and acceptance criteria in the
TIPs listed  in Appendix A are given in Tables  1  through 3 of Element A7. Quality control
activities for individual emissions tests  are documented  in AE SOP 4.10.2 and EEVRD TIP 07-
009 for on-highway engine tests and TIP 07-038 for nonroad  engine tests.  TIP 07-020 includes
QC activities for PM  sample filter handling, conditioning and weighing.   These TIPs include
calibration or test methods, control limits or acceptance criteria, and personnel  responsible for
assessment.  The test control  limits in 40 CFR Part 86 and acceptance criteria in the above TIPs
are given in  Table 4 of Element A7.  QC activities for data entry and reduction are documented
in AE SOP 4.15.2. QC for PM sample filters is assisted by FRIS.  The software will alert the
user to filter conditioning data or reference filter weight changes that exceed CFR requirements.

Procedures   for  corrective  action for calibration or test  equipment  nonconformance are
documented in AE SOP 4.13.

B6: Instrument/Equipment  Testing, Inspection, and Maintenance

Inspection and maintenance activities for the dynamometer, CVS, and analytical  equipment are
documented in EEVRD TIPs listed in Appendix A Table 4-1.  These TIPs include acceptance
criteria and personnel responsible for review.

B7: Instrument/Equipment  Calibration and Frequency

Calibration  frequency of analyzers, instruments,  and equipment  will  conform to  40  CFR
86.1316-94 for on-highway engine tests or 40 CFR 89.305 for nonroad engine  tests.  EEVRD
TIPs listed in Appendix A Table 4-1 include the calibration frequency of emissions sampling and

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measurement equipment,  the applicable  standards to be used and acceptance criteria.   The
calibration frequencies in  these TIPs are given in Tables 1 and 2 of Element A7.  Overall QC
activities for calibrations are documented in AE SOP 4.11.1.

B7.1. Gaseous Analyzer Calibration

Emissions gas analyzers for HC, CO, CO2, and NOX are contained in a Horiba MEXA 7000
Series analyzer bench.

B7.1.1. Hydrocarbon Analyzer

The hydrocarbon analyzer is a heated flame ionization detector (HFID) instrument calibrated in
conformance with  40  CFR 86.1321-94  and  40 CFR 89.319.  Calibration and other HFID
operational requirements are conducted according to EERVD TIP 06-012 (Monthly Calibration
of Analyzers for Continuous Gaseous Exhaust Using Horiba Emissions Bench), TIP 06-050 (HC
Analyzer and Sample  System Response Checks of Horiba MEXA 7000  Series Emissions
Benches), and TIP 06-044  (Hydrocarbon Analyzer Optimization).

B7.1.2. Carbon Monoxide Analyzer

The CO analyzer is a non-dispersive infrared (NDIR) instrument calibrated in conformance with
40 CFR  86.1322-84 and  40 CFR 89.320.   Calibration and other  CO  analyzer operational
requirements are conducted according to EEVRD TIP 06-012 (Monthly Calibration of Analyzers
for Continuous Gaseous Exhaust Using Horiba Emissions Bench) and TIP 06-049 (Wet CO2
Interference  Check of CO Analyzer  Integrated  in  Horiba MEXA 7000  Series Emissions
Benches).

B7.1.3. Oxides of Nitrogen Analyzer

The NOX analyzer  is a chemiluminescent instrument calibrated in conformance with 40 CFR
1323-2007 and 89.321.  Calibration and other NOX analyzer operational  requirements are
conducted according to EEVRD TIP 06-012 (Monthly Calibration of Analyzers for Continuous
Gaseous  Exhaust Using Horiba  Emissions Bench),  TIP 06-002  (NOX Converter Efficiency
Determination), TIP 06-051 (NOX Analyzer and Sample System Response Checks of Horiba
MEXA 7000 Series Emissions Benches), and TIP 06-041 (NOX Analyzer CO2 Quench Check).

B7.1.4. Carbon Dioxide Analyzer

The CO2 analyzer is a NDIR instrument calibrated in conformance with 40 CFR 86.1324-84 and
89.322.   Calibration is conducted according to EEVRD TIP 06-012 (Monthly Calibration of
Analyzers for Continuous Gaseous Exhaust Using Horiba Emissions Bench).

B7.2. Constant Volume Sampler (CVS)

The CVS calibration is verified in conformance with 40 CFR 86.1319-90 or 40 CFR 89.422.
CVS calibration is verified according to EEVRD TIP 06-011 (Propane Recovery Check).

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B7.3. Gas Meter Calibration

Particulate sampling requires flow instrumentation or gas meters to determine secondary dilution
and sample flows.  The gas meter calibration is verified in conformance with 40 CFR 86.1320-
90. Calibration verification is conducted according to EEVRD TIP 06-046 (Calibration of Gas
Meter).

B7.4. Miscellaneous Instruments

Engine speed and torque,  signal conditioning, and readouts are calibrated within specifications
given in 40  CFR 86.1308-84, 86.1318-84, and 86.1316-94.   Speed calibration is  verified
according to EEVRD TIP  06-018 (Engine Speed Readout Verification) and torque calibration is
verified according to  EEVRD TIP 06-017 (Torque Meter Calibration Check).  Pressure and
temperature instruments,  signal conditioning and readouts are calibrated within specifications
given in 40 CFR 86.1309-90. Pressure calibration is verified according to EEVRD TIP 06-020
(Pressure  Calibration  and Verification) and temperature  calibration is verified according  to
EEVRD TIP 06-013 (Temperature Calibration and Thermocouple Verification).

B7.5. Analyzer Calibration Gases

The gases used for analyzer calibration conform to 40 CFR  86.1314-94 and 40 CFR 89.312.
Concentrations  of calibration gases are verified according to EEVRD TIP 06-007 (Naming
Monthly Calibration Gases) and zero gases are verified according to TIP 06-036 (Verification of
Zero Gas).

B8: Inspection/Acceptance of Supplies and Consumables

Supplies  and consumables for diesel retrofit ETV include  test fuel, calibration and zero gases,
PM sample filter media, and mechanical and electrical supplies for mounting the test engine in
the emissions facility.

B8.1. Test Fuel

Test fuel is purchased from suppliers  on the EEVRD Approved Supplier List.  Test fuel will
conform to specifications  in 40 CFR 86.1313-2007 unless otherwise stated  in the test-specific
addendum. Batch fuels are stored in underground tanks. Receipt of test fuel is accompanied by
a certificate of  analysis  from the supplier and  a material safety data sheet (MSDS).  The
analytical results are  compared to CFR specifications before the fuel  is used for  emissions
testing.

B8.2. Calibration Gases

Calibration gases are purchased from the EEVRD Approved Supplier List.  Calibration gases are
verified per Element B7.5.

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B8.3. Particulate Matter (PM) Filter Media

PM  sample  media  are  purchased from the EEVRD Approved  Suppliers  List  in  batches.
Individual sample filters are cut from the batch sheet and a pair of filters is placed into a petri
dish with a cover.  The membrane filters are received pre-cut and individual  filters are placed
into a petri dish with a cover.

B9: Non-Direct Measurements

No non-direct measurements are used for diesel retrofit ETV for calculation of emissions results
or the SwRI final report.

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BIO: Data Management
                       Version 2.0
                          Page 19
Quantitative  data as required in 40 CFR 86.1342-94 and 86.1343-88 or 40  CFR 89.424  are
recorded on  formatted forms.   Element B3 gives the chain-of-custody for data forms for an
emissions test.  Raw data forms are  prepared according to EEVRD TIP 07-009 (Emissions
Testing During Heavy-Duty Diesel Engine Transient Cycle) and  07-038 (Steady-State Dilute
Emissions Testing of Heavy-Duty Engine Using Horiba MEXA-7200D Emissions Bench).  The
forms are given a unique test number, dated, and assembled into a test packet.  The packet is
transferred to a central location for entry into the Emissions Test Information System (ETIS)
database that is used to calculate  emission  test results.  Raw data entry  into  the  ETIS is
conducted  by designated personnel according to EEVRD TIP 08-005 (Data  Transfers and
Calculations  of Dilute Steady-State Engine Data) and 08-016 (Heavy-Duty  Transient Test Data
Processing).  Personnel responsible for database entry verification and validation are documented
in AE SOP 4.15.2.  ETIS contains features that will alert the  user  to data that  exceed CFR
requirements or equipment calibration  limits.  PM sample filter data, conditioning  and weights,
are electronically collected using FRIS.  The software will alert the user to filter  conditioning
data or reference filter weight changes that exceed CFR requirements.   Management of test and
equipment QC data is illustrated in Figure 4.
                                Engine Information from
                                   Manufacturer
                                Engine Performance Data
Test Facility Raw Data
                                                          Pre-testPM filter Weight
                                                         Post-test PM filter Weight
                                               Assemble Data
                                               Data Entry and
                                                Calculations
                                                QC Review
                                                Test Report
                                                ADQ Report
                        FIGURE 4. ETV DATA MANAGEMENT

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              GROUP C: ASSESSMENT AND OVERSIGHT ELEMENTS

Cl: Assessments and Response

As  a testing organization to APCT  Center, SwRI's quality and technical  systems  will be
evaluated according to ETV QMP  Part A Section 9.0, APCT Center QMP  Section 3.4, and
retrofit devices GVP Section 11.0.

Cl.l. Internal Audits

Internal audits of AE, EEVRD, and ER&DD are conducted for compliance to ISO 9001 and ISO
17025. Procedure for internal audits is documented in AE SOP 4.17.

C1.2. External Audits

External audits by APCT Center and EPA include quality system audits (QSAs) or technical
system audits (TSAs) as described in retrofit devices GVP Section 11.1.  The APCT Center or an
EPA designate will conduct a QSA before tests begin using this TQAP.  Additional assessments
of SwRFs quality  system will be determined by the APCT Center QM.  The APCT Center or an
EPA designate will conduct a TSA before tests begin under this TQAP.  Subsequent technical
systems audits will be conducted once a year or prior to testing of a candidate technology. QSAs
will be conducted in accordance with EPA QA/G-3 and TSAs will be conducted in accordance to
EPA QA/G-7

C1.3. Audits of Data Quality

In accordance to ETV QMP Part A Section 9.0, APCT Center QMP Section 3.4, and  retrofit
devices GVP Section 11.0,  the  SwRI QM will conduct an ADQ by examining  at  least a 10
percent random sample of all verification test data.  The QM's review of the test data will be
performed after all data are collected and 100 percent are verified by  project personnel.  The
QM's review will include data recording,  transfer,  summarizing,  and reporting.  Because data
calculations  are performed from the emissions database using compiled software,  the QM will
not  be required to perform hand calculations.   Verification of database calculations  can be
forwarded to APCT Center upon request.

The ADQ report will include a detailed review of QA/QC data as required by DQOs and DQIGs.
The  report will summarize  project equipment malfunctions, nonconformances, and/or  testing
problems that resulted in lost data and subsequent corrective actions.

C1.4. Corrective Action

Corrective action that results from an audit or assessment is performed according to AE SOP
4.13.

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C2: Reports to Management

Internal assessment reports will be reviewed by the  SwRI QM, who will respond to APCT
Center.  A written report for the ADQ will be submitted to APCT Center approximately the same
time as the final test report.

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           GROUP D:  DATA VALIDATION AND USABILITY ELEMENTS

Dl: Data Review, Verification, and Validation

Procedures for recording and verifying/validation test and calibration data are given in AE SOP
4.10.2  and SOP 4.15.2.  The EEVRD TIPs listed in  Appendix A Tables 4-1 and 4-2 contain
procedures for data acceptance criteria and personnel responsible for data verification.

D2: Verification and Validation Methods

The majority of test and calibration data are reviewed and verified manually from data forms and
calibration sheets.  Verification of test data that are entered into the ETIS database is a manual
review of transcribed data. Personnel  responsible for data entry verification/validation are given
in AE  SOP 4.15.2.  ETIS contains features that will alert the user to data that exceed CFR
requirements  or  equipment calibration limits.  Data that are determined to be out of limits are
verified for correct entry otherwise the data are a test  nonconformance.  QA for PM  sample
filters is assisted by FRIS.  The software will alert the user to filter conditioning data, checkout
time, or  reference filter  weight changes that exceed  CFR requirements.  Filter  data that are
determined to be out of limits are test nonconformances.

D3: Reconciliation with User Requirements

Emission results for an engine or emission control device are normally accepted as-is provided
that all QA/QC information is reconciled with CFR requirements.   Limits for accuracy or
precision are  not normally set or determined  for emission results.  Test data will be  acceptable
for ETV if all DQOs and DQIGs are met.

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          APPENDIX A: APPLICABLE DOCUMENTS AND PROCEDURES

1. EPA Documents

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

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

EPA.  Environmental Technology Verification Program,  Quality Management Plan.   EPA
Publication No. EPA/600/R-08/009.  http://www.epa.gov/etv/pubs/600r08009.pdf. Office  of
Research and Development, U.S. Environmental Protection Agency.  Cincinnati, OH.  January
2008.

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

EPA.  Guidance for Quality Assurance Project Plans.  EPA QA/G-5,  EPA Publication No.
EPA/240/R-021/009.   Office of Environmental Information, U.S. Environmental Protection
Agency, December 2002.

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

2. APCT Center Documents

APCT Center.  Verification Testing of Air Pollution Control Technology - Quality Management
Plan. RTI International.  Research Triangle Park, NC. March 2010.

APCT  Center.   Generic  Verification Protocol (GVP) for Diesel Exhaust Catalyst, Paniculate
Filters, and Engine Modification Control Technologies for Highway,  Nonroad, and Stationary
Use Diesel Engines.  Research Triangle Institute, Research Triangle Park, NC. January 2002.

3. SwRI AE Standard Operation Procedures

These documents are proprietary but will be made available to APCT Center and EPA staff
during on-site assessments.

QSM              Quality System Manual - Rev. 3, February 2009
AE SOP 4.10.2      Test Conduct and Recording of Test and Calibration Data
AE SOP 4.11.1      Calibration and Maintenance
AE SOP 4.13        Nonconformance, Preventive and Corrective Action, Customer Complaints
AE SOP 4.15.2      Data Control and Reporting

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AE SOP 4.16       Quality Records
AE SOP 4.17       Internal Quality Audits
AESOP 4.18       Training

4. SwRI EEVRD Test and Inspection Procedures

These documents are proprietary but will be made available to APCT Center and EPA staff
during on-site assessments.

                     TABLE 4-1. CALIBRATION PROCEDURES

TIP 06-002   NOX Converter Efficiency Determination
TIP 06-007   Naming Monthly Calibration Gas
TIP 06-011   Propane Recovery Check
TIP 06-012   Monthly Calibration of Analyzers for Continuous Gaseous Exhaust Using Horiba
             Emissions Bench
TIP 06-013   Temperature Calibration and Thermocouple Verification
TIP 06-017   Torque Meter Calibration Check
TIP 06-018   Engine Speed Readout Verification
TIP 06-020   Pressure Calibration and Verification
TIP 06-036   Verification of Zero Gas
TIP 06-041   NOX Analyzer CO2 Quench Check
TIP 06-044   Hydrocarbon Analyzer Optimization
TIP 06-046   Calibration  of Gas Meter
TIP 06-049   Wet  CO2 Interference Check of CO Analyzer Integrated in Horiba MEXA
             7000 Series Emissions Benches
TIP 06-050   HC Analyzer and Sample System Response Checks of Horiba MEXA 7000 Series
             Emissions Benches
TIP 06-051   NOX Analyzer and Sample System Response Check of Horiba MEXA 7000 Series
             Emissions Benches

                          TABLE 4-2. TEST PROCEDURES

TIP 07-009   Emissions Testing During Heavy-Duty Diesel Engine Transient Cycle
TIP 07-020   Particulate Filter Conditioning and Weighing in Accordance with CFR Title 40
             Parts 86 and 89
TIP 07-038   Steady-State Dilute Emissions Testing  of Heavy-Duty Engine Using Horiba
             MEXA-7200D Emissions Bench

                     TABLE 4-3. DATA ENTRY PROCEDURES

TIP 08-005   Data Transfers and Calculations of Dilute Steady-State Engine Data
TIP 08-016   Heavy-Duty Transient Test Data Processing

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