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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