APCT CENTER VENDOR GUIDE FOR VERIFICATION OF
               MOBILE SOURCE RETROFIT EMISSIONS CONTROLS
1.      INTRODUCTION
This guide is intended to help applicants to the Air Pollution Control Technologies Verification
Center (APCT Center), a center under the EPA's Environmental Technology Verification (ETV)
Program, understand the verification process and  their role and  responsibilities.  The guide
addresses manufacturers'  use of ETV data to  list  their technologies on  EPA's Office  of
Transportation  &  Air  Quality's  National Clean  Diesel  Campaign (NCDC)  verified  retrofit
technologies list.  ETV and NCDC are separate but complementary programs run by separate
offices within the EPA.

1.1     APCT Verification Center Background

EPA's  ETV Program (http://www.epa.gov/etv/), funded  by  EPA's Office  of  Research  and
Development (ORD), verifies the performance of commercially available, innovative or improved
technologies as an independent third party.  Verification tests generate credible performance
information with quality-assured data approved by EPA. The ETV Program addresses problems
that threaten human health or the environment; it was designed to accelerate the entrance of
new environmental  technologies  into  the domestic and international  marketplace.   RTI
International1  is  partnering  with  EPA  for  the  ETV APCT  Center.   The  APCT  Center
(http://www.epa.gov/etv/centers/center5.html)  addresses control  technologies  for  both
stationary and mobile air pollution sources.  For mobile source retrofit technologies,  the APCT
Center worked with EPA's Office of Transportation  and  Air Quality (OTAQ) and  interested
stakeholders representing manufacturers and end users to develop verification test protocols.

1.2     NCDC Background
The  objective of OTAQ's NCDC (http://www.epa.gov/diesel/) is to evaluate the  emissions
reduction effectiveness of retrofit technologies and provide stakeholders with  confidence that
these technologies will achieve quantifiable emissions  reductions. This verification process will
evaluate  the emission reduction performance of retrofit technologies, including their durability,
and identify engine operating criteria and conditions that must exist for these technologies to
achieve those reductions.

1.3     Relationship between the ETV APCT Center and NCDC
ETV measures the performance of a given technology using  a specified fuel on a specified
engine tested under specified loading cycles and issues verification reports and statements on
the  results of that unique configuration.  NCDC evaluates the data generated by ETV to apply
emissions reductions from the single verified configuration to  a broader sector, such  as the
engine family that includes the make and model  used for verification.  Data generated outside
the  ETV  program may be submitted to OTAQ to support applying emissions reductions  to a
broader engine definition;  however, ETV verification reports and statements are generated only
for testing conducted under the ETV program.  The table below identifies the roles of these two
separate  and independent organizations when they work together to verify technologies.
 RTI International is a trade name of Research Triangle Institute

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              APCT CENTER VENDOR GUIDE FOR VERIFICATION OF
               MOBILE SOURCE RETROFIT EMISSIONS CONTROLS
 Environmental Technology Verification Program (ETV)
 	EPA Office of Research and Development	
  National Clean Diesel Campaign (NCDC)
  EPA Office of Transportation & Air Quality
     Coordinates testing with EPA-OTAQ
     Audits ETV testing organizations
     Prepares test/QA plan
     Estimates costs of verification tests
     Conducts ETV tests
     Issues ETV verification reports and statements
Evaluates  technologies  to  understand  in-use
performance and applicability to different engine
and vehicle technologies.
Evaluates total application package
Interprets emissions reductions data from ETV
Sets emissions reductions  for technologies and
posts on NCDC website
Extends applicability to other engines (and adds
requirements for additional data)
Requires in-use testing of technologies.	
1.4    Applying to the APCT Center/NCDC

The  NCDC  application is available as an  Excel  spreadsheet on the EPA OTAQ website at
http://www.epa.gov/otaq/retrofit/retrofittech.htm.     The  application   requires  detailed
descriptions of the product, components, and test  results, as well as contact information for the
manufacturer's designated technical authority. For simplicity, the same application may be used
for the ETV program.

OTAQ requires a thorough technical understanding of how the technology works before it will be
considered  for verification.   To ensure  OTAQ  acceptance of the data,  its  requests for
information must be fulfilled before a test plan can be finalized and verification can proceed.

1.5    Protocols and Test Plans
Stakeholders representing federal, state, and local government agencies;  manufacturers; end
users; trade associations;  and testing  organizations  developed  three  protocols  to cover
technologies in the mobile  sources area. The Devices protocol provides the  requirements for
verification of the  performance of diesel exhaust catalysts,  particulate matter filters, and engine
modifications applied to highway and nonroad diesel engines.  The selective catalytic reduction
(SCR) protocol provides  the requirements for verification of SCR systems applied to highway
and  nonroad diesel engines and some categories of stationary engines.  The Fuels protocol
provides the requirements for verification of emissions reductions achieved by fuel modifications
and  reformulations, alternative fuels,  and lubricants applied  to  highway and nonroad diesel
engines and light-duty gasoline engines.  All three protocols are available on the EPA  ETV
website (http://www.epa.gov/etv/verifications/protocols-index.html)  in  portable document
file (pdf) format. The protocol sets the requirements for testing. The verification tests are based
on Federal Test  Procedures detailed in the Code of Federal Regulations.   Highway engine
testing is based on 40 CFR 86, Subpart N (40 CFR 86.1301).  Nonroad engine testing is based
on 40 CFR 89, Subpart E (40  CFR 89.401). Test/QA plans are developed that document how
the protocol will  be implemented by  a testing organization.  These documents are in place
before verification testing may begin  in  a technology area.  A technology-specific addendum
documents the vendor, the technology, how many  tests are required to distinguish the expected
emissions reductions from normal test variability, and decisions on optional measurements.

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              APCT CENTER VENDOR GUIDE FOR VERIFICATION OF
               MOBILE SOURCE RETROFIT EMISSIONS CONTROLS


1.6    The Verification Process:  Step by Step
The verification process follows the steps listed below:

   •   The vendor initiates the verification process by submitting an application to the APCT
       Center and OTAQ.  The application form is posted as an Excel spreadsheet on the
       OTAQ NCDC website (http://www.epa.gov/otaq/retrofit/retrofittech.htm).  It is listed
       under Specific  Verification  Documents as part of the Retrofit Technology Application
       Packet.  The APCT Center uses the same application to reduce the paperwork burden
       on the  applicant and is primarily interested in the technical and contractual contacts,
       identification of the specific technology to  be verified, a  general description of the
       technology and how it works, how it should be installed, and what the claimed emissions
       reductions are.  OTAQ requires  a thorough  and  complete  understanding  of the
       mechanism by which technologies reduce emissions and may require the submission of
       information  that may  be considered by the applicant  to be  confidential  business
       information  (CBI).  EPA  can  maintain CBI in  accordance with applicable regulations.
       Generally, the APCT Center will not need to receive any proprietary information.

   •   The applicant, the  APCT Center, and the testing  organization discuss the intent of the
       test and develop a testing outline.  If the applicant wishes to apply to the NCDC, OTAQ
       is included in the discussions. If the applicant  plans to submit the data to California Air
       Resources Board (CARB), that agency can also be brought into  the discussions.  The
       manufacturer should  have a thorough  understanding  of his  intended  market and
       application  of  the technology to that  market to facilitate  the  discussions.   These
       discussions are usually conducted as a series  of conference calls,  but  may include
       meetings.  During the discussion, OTAQ may bring  up questions about the technology
       and how it operates.  Depending upon how quickly issues are resolved, the discussions
       may require multiple calls and the submission of additional technical information.

   •   After the initial discussions have been completed,  the APCT Center prepares a contract
       outlining Terms & Conditions,  Statement of Work, and Cost.  The Terms and Conditions
       include provisions and guidelines for use of the  ETV logo.

   •   The applicant approves and returns a signed copy of the Terms  & Conditions with full
       payment.

   •   The APCT Center and its testing organization  (with input from the applicant) prepare a
       test plan addendum, to be approved by EPA, by following the applicable protocol.  The
       addendum specifies the number of tests necessary to guarantee a 90% probability of
       detecting the expected emissions reductions.  More  data are needed for low emissions
       reductions.

   •   The applicant  provides degreened and aged devices  and the engine  intended for
       verification testing  to the  testing organization.  The applicant is encouraged to provide
       one degreened device and one aged device. The applicant may choose to suspend the
       verification process after testing  in the degreened condition so the same device can be
       aged.  The delay between testing the device in the  degreened condition and the aged
       condition requires an additional series of baseline tests.

   •   Testing  is  conducted.   The applicant  is  responsible for providing  to  the  testing
       organization the test engine and the system(s) to be  verified as well as installation and
       operation instructions. In  some cases, an inspection and functional test may be required
       to ensure that the unit is operating as it is supposed to before testing begins.

   •   A test report is prepared by the testing organization and submitted  to the APCT Center.

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             APCT CENTER VENDOR GUIDE FOR VERIFICATION OF
               MOBILE SOURCE RETROFIT EMISSIONS CONTROLS
   •   The APCT Center submits a draft verification report and verification statement to EPA.
       The reports are subject to peer, technical, and quality assurance reviews at EPA.  The
       applicant has an opportunity to comment on the report before it is submitted to EPA.

   •   EPA approves and signs the verification report and statement.  Verification  statements
       are signed by the Director of EPA's National  Risk Management Research Laboratory of
       the Office of Research and Development and the Director of the APCT Center.

   •   The APCT Center releases the verification statements and reports.  The EPA ETV
       program administrator posts the verification report and statement on the Center and EPA
       ETV web  site so they are available to the general public and distributes copies to the
       applicant and EPA.  The applicant may use  the ETV reports, statements, and logo for
       marketing as described in the Terms and Conditions in the contract package.
2.      PRETEST ACTIVITIES & DISCUSSION

2.1     Verification Scope
Several key issues addressed during development of the statement of work affect how OTAQ
will extrapolate the emissions reductions to a broader scope.  They include selection of the test
engine, test fuel, and the test cycle. Applicants should make these choices to best match the
verification to their intended market for the technology.
EPA groups engine families into boxes with similar characteristics for current and past model
years.  For highway engines, families are categorized by emissions standards and either urban
bus or non-urban bus.  Each box has 6 subgroupings: stroke technology (2- or 4-stroke) and
engine classification (LHDDE, MHDDE, HHDDE).  The emissions reductions  are verified by
ETV for only the specific engine model and fuel combination tested.  To extend the emissions
reductions to other engines within the same engine box, the  applicant may petition OTAQ and
submit additional  data.   Engine box classifications are posted on OTAQ's website for both
highway engines (http://www.epa.gov/dieselretrofit/documents/engfamoh.pdf) and nonroad
engines (http://www.epa.gov/dieselretrofit/documents/engfamnr.pdf).

2.2     Developing the Statement of Work
What engine will I use?  The engine selected  for  verification testing must be representative of
the intended market.  ETV requires the model year, make, model, engine serial number, date of
manufacture, displacement, service class, EPA engine family, record of service hours or miles,
and  record of  maintenance, repairs, recalls, and  damage.  The applicant  is  responsible for
providing the engine for verification testing.  The testing organization may offer a suitable engine
for a fee but is not obligated to do so.

What fuel will I use? Testing may be conducted using either 2D standard diesel  fuel or ultra low
sulfur diesel fuel (ULSD).  In some cases, the  applicant may choose to use an alternative fuel
specific to its intended market.  The same fuel must be used for both the baseline and  controlled
tests. The testing organization provides the fuel for verification testing.
What test cycle will I use?  Transient  cycles  are used to load highway heavy-duty engines;
verification testing may also include a steady-state Supplemental Emissions Test. Multi-mode
steady-state cycles are used to load nonroad compression ignition (Cl)  engines; verification
testing may also include a nonroad transient cycle.  The cycle generated during the baseline
test is used to load the engine with the degreened and aged technologies installed; new cycles
are not generated. Backpressure and exhaust temperature are monitored.

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             APCT CENTER VENDOR GUIDE FOR VERIFICATION OF
               MOBILE SOURCE RETROFIT EMISSIONS CONTROLS
Do my products meet the requirements for degreening and aging?  Degreened retrofit devices
must have between 25-125 hours of service life;  aged devices must have more than  1000
hours of service life.  Field use is the preferred method for accumulating service hours on the
aged device.   The aging must be appropriate for the test engine and representative of the
intended market.  ETV requires the same engine information on the engines used for aging and
degreening as for the test engine. Documentation of aging and degreening must include the
serial numbers of the control technologies and these serial numbers must match those cited in
the statement of work.
3.      SIGNING A CONTRACT
Upon completion of a satisfactory Statement of Work (SOW), the applicant will sign a contract
with  RTI  to conduct the verification test.  The contract includes Terms and Conditions with
guidelines for proper use of the  ETV Program  name and international logo, the Statement of
Work, and price and payment terms.  The SOW describes the system(s) to be verified, and
outlines the  testing procedure. The price of the verification  covers  the cost of  testing and
reporting.   Applicants are required to  remit payment when  returning the signed  contract
package.
4.      TESTING
Southwest Research Institute is currently the authorized testing organization for verification of
mobile source control technologies under the APCT Center. Testing is conducted at their facility
in San Antonio, TX.  ETV is an open transparent process.  Applicants and their guests can
witness testing of their technology.  Changes to the ETV test/QA plan  are not permitted  once
testing has started.
5.      REPORTING
5.1     Results

Results are reported as the percent mean emissions reductions and 95% confidence limits for
particulate matter (PM), nitrogen oxides (NOx), hydrocarbons (H), and carbon monoxide (CO)
compared to the baseline.

If the confidence interval  includes zero reduction,  then the performance is reported as not
distinguishable from zero.   The vendor can opt for no verification statement under these
circumstances; however, a verification report with the  results is issued and  posted  to the
website.

5.2     Deliverables
The applicant will  receive originals  of the verification report and verification statement.  The
statement will be signed by the director of the National Risk Management Research Laboratory
of EPA's  Office of Research and Development and the director of the APCT Center. Portable
document format (pdf) versions are also posted to the EPA ETV website.

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            APCT CENTER VENDOR GUIDE FOR VERIFICATION OF
              MOBILE SOURCE RETROFIT EMISSIONS CONTROLS
6.     REFERENCES & LINKS
EPA ETV Program website:
http://www.epa.gov/etv/
EPA National Clean Diesel Campaign:
http://www.epa.gov/diesel/

Code of Federal Regulations:
http://www.gpoaccess.gov/cfr/index.html
7.     CONTACT INFORMATION
For more information about RTI or the APCT Center, contact:

Drew Trenholm                           Jenni M. Elion
Director                                  Task Leader - Mobile Sources
APCT Center                             APCT Center
RTI International                           RTI International
Post Office Box 12194                      Post Office Box 12194
Research Triangle Park, NC 27709-2194       Research Triangle Park, NC 27709-2194

Telephone: 919 316-3742                   Telephone: 919 541-6253
Facsimile: 919 541-6936                    Facsimile: 919 541-6936
E-mail: atrenholm@rti.org                   E-mail: jme@rti.org
updated April 2007

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