Test/QA Plan for ETV Fuel and Lubricant Modifications at SwRI
November 2006
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             TEST/QA PLAN FOR THE VERIFICATION TESTING OF
  ALTERNATIVE OR REFORMULATED LIQUID FUELS, FUEL ADDITIVES, FUEL
                     EMULSIONS, AND LUBRICANTS FOR
  HIGHWAY AND NONROAD USE HEAVY DUTY DIESEL ENGINES AND LIGHT
                 DUTY GASOLINE ENGINES AND VEHICLES
                     EPA Cooperative Agreement No. CR83191101
                                       BRTI
                                       INTERNATIONAL
 Southwest Research Institute

 6220 Culebra Road
 P.O. Drawer 28510
 San Antonio, TX 78228-0510
 Phone:   210-522-2654
 FAX:    210-522-3950
 E-mail:   tullman@swri.org
Research Triangle Institute

3040 Cornwallis Road
P.O. Box 12194
Research Triangle Park, NC 27709-2194
Phone:    919-361-3742
FAX:     919-541-6936
E-mail:    atrenholm@rti.org
                    This plan has been reviewed and approved by:
 Original signed by Terry Ullman
 T. Ullman, Technical Manager, Southwest Research Institute

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

 Original signed by Andrew Trenholm
 A. Trenholm, RTI ETV/APCT Center Director

 Original signed by W. Gary Eaton
 C. Eaton, RTI ETV/APCT Center Quality Manager

 Original signed by Michael Kosusko
 M. Kosusko, EPA ETV/APCT Center Program Manager

 Original signed by Paul W. Grqff
 P. Groff, EPA ETV/APCT Center Quality Manager
                         7/7/06
                           Date

                         7/7/06
                           Date

                       July 7, 2006
                           Date

                       July 7, 2006
                           Date

                    September 22, 2006
                           Date

                         9/22/06
                           Date

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                                A2: Table of Contents
    List of Figures	iv
    List of Tables	iv
    List of Acronyms and Abbreviations	v
    A3: Distribution List	vi
    GROUP A: PROJECT MANAGEMENT	1
    A4: Project/Task Organization	1
        A4.1. Management Responsibilities	2
              A4.1.1. EPA Project Manager	2
              A4.1.2. RTI APCT Center Director	2
              A4.1.3. RTI Task Leader	3
              A4.1.4. SwRI Technical Leader	3
              A4.1.5. SwRI Task Leader	3
        A4.2. Quality Assurance Responsibilities	3
              A4.2.1. EPA Quality Manager	4
              A4.2.2. RTI Quality Manager	4
              A4.2.3. SwRI Quality Manager	4
    A5: Problem Definition/Background	5
    A6: Project/Task Description	5
        A6.1. Description	5
        A6.2. Schedule	6
    A7: Quality Objectives and Criteria	6
    A8: Special Training/Certification	7
    A9: Documents and Records	8
    GROUP B: DATA GENERATION AND ACQUISITION	9
    Bl: Sampling Process Design (Experimental Design)	9
    B2: Sampling Methods	9

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        B2.1.  Exhaust Gas Sampling System	9
        B2.2.  PM Sampling System	10
    B3:  Sample Handling and Custody	10
        B3.1.  Particulate Filters Handling and Custody	10
        B3.2.  Bag Samples Handling and Custody	10
    B4:  Analytical Methods	11
        B4.1 Exhaust Gas Measurement System	11
        B4.2.  Filter Weighing	11
        B4.3.  Gaseous Analyzers	11
    B5:  Quality Control	11
    B6:  Instrument/Equipment Testing, Inspection, and Maintenance	11
    B7:  Instrument/Equipment Calibration andFrequency	11
        B7.1.  Gas Meter Calibrations	12
        B7.2.  Gaseous Analyzer Calibrations	12
              B7.2.1. Hydrocarbon Analyzers	12
              B7.2.2. Carbon Monoxide Analyzers	12
              B7.2.3. Oxides of Nitrogen Analyzers	12
              B7.2.4. Carbon Dioxide Analyzers	12
              B7.2.5. Methane Analyzers	13
        B7.3.  Analyzer Calibration Gases	13
    B8:  Inspection/Acceptance of Supplies and Consumables	13
    B9:  Non-direct Measurements	13
    BIO: Data Management	13
        B10.1 Data Acquisition and Management	13
        B10.2 Reporting	14
    GROUP C: ASSESSMENTS AND OVERSIGHT ELEMENTS	15
    Cl:  Assessments and Response Actions	15
        Cl.l.  Internal Audits	15
        C1.2.  Audits of Data Quality	15

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        C1.3. External Audits	15

        C1.4. Corrective Action	15

    C2:  Reports to Management	15

    GROUP D: DATA VALIDATION AND USABILITY ELEMENTS	16

    Dl:  Data Review, Verification, and Validation	16

    D2:  Verification and Validation Methods	16

    D3:  Reconciliation with User Requirements	16

    APPENDIX A:  APPLICABLE DOCUMENTS AND PROCEDURES	1

    1. EPA Documents	1

    2. APCT Center Documents	1

    3. SwRIOAE Standard Operating Procedures	2

    4. SwRI DER Standard Operating Procedures	2

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                                     List of Figures

Figure 1. Organizational chart	2
Figure 2. Example of schedule	6
Figure 3. Gaseous and particulate emissions sampling system	9
Figure 4. Exhaust gas sampling and analytical train	10
Figure 5. ETV data management system	14

                                     List of Tables

1   Data Quality Indicator Goals (DQIG)	7

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                          List of Acronyms and Abbreviations

ADQ        audit of data quality
APCT Center Air Pollution Control Technology Verification Center
CFR         Code of Federal Regulations
CO          carbon monoxide
CC>2         carbon dioxide
CVS         constant volume sampler
DER        Department of Emissions Research at SwRI
DQIG       data quality indicator goals
DQO        data quality objective
EPA         U.S. Environmental Protection Agency
ETV         Environmental Technology Verification
FID         flame ionization detector
FTP         federal test procedure
GVP         generic verification protocol
HC          hydrocarbon
HFID        heated flame ionization detector
ISO         International Standards Organization
NOx         nitrogen oxides
OAE        Office of Automotive Engineering
PEA         performance evaluation audit
PM          particulate matter
QA          quality assurance
QC          quality control
QM         quality manager
QMP        quality management plan
QSM        Quality System Manual
RTI         Research Triangle Institute
SOP         standard operating procedure
SOW        statement of work
SwRI        Southwest Research Institute
TSA         technical systems audit
VR          verification report

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A3:  Distribution List

U.S. EPA
Michael Kosusko
Paul Groff

Research Triangle Institute
Andrew Trenholm
Jenni Elion
Gary Eaton

Southwest Research Institute
Terry Ullman
Michael Van Hecke

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                       GROUP A: PROJECT MANAGEMENT

A4: Project/Task Organization

The U.S. Environmental Protection Agency (EPA) has overall responsibility for the
Environmental Technology Verification (ETV) Program for the Air Pollution Control
Technology Verification Center (APCT Center).  Research Triangle Institute (RTI) is EPA's
verification partner in this effort. Southwest Research Institute (SwRI) is the technology-
specific testing organization for mobile sources within the APCT Center.

Management and testing of fuel and lubricant modifications 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 Determination of Emissions
       Reductions Obtained by Use of Alternative or Reformulated Liquid Fuels, Fuel Additives,
       Fuel Emulsions, and Lubricants for Highway andNonroad Use Diesel Engines and Light
       Duty Gasoline Engines and Vehicles
   •   SwRI's Office of Automotive Engineering (OAE) Standard Operating Procedures (SOPs)
   •   SwRI's Department of Emissions Research (DER) SOPs
   •   This test/quality assurance (QA) plan.
Appendix A lists full citations for these documents. This test/QA plan 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 the APCT Center qualified testing organization, SwRI will verify the emissions reductions of
alternative or reformulated liquid fuels, fuel additives, fuel emulsions, and lubricants intended
for highway and nonroad use diesel engines and light duty gasoline engines and vehicles.  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 the verification statements. The
various QA and management responsibilities are divided among SwRI, RTI, and EPA key
project 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
                          Paul Groff
                        RTIAPCT Center Director
                           Andrew Trenholm
                      RTI Quality Manager
                         Gary Eaton
  Technology Vendor
RTI Task Leader
  Jenni Elion
                                                   Quality Manager
                                                    Mike VanHecke
                                                                         -SwRI Organization
                                              Office of Automotive
                                                 Engineering
                                                                        Engine, Emissions, and
                                                                           Vehicle Research
                                                                         Engine and Emissions
                                                                              Research
                                                                           Bruce B. Bykowski
                                                                          Diesel Technology
                                                                             Terry Ullman
                                  Denotes normal lines of communication and responsibility
                                  Denotes informal communication
                                  Denotes organizational independence
                                                 Task Leaders
                                                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, test/QA plans, 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 Andrew Trenholm. 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 in technology-specific verification tests.  He will
assign technology verification task leaders; oversee verifications; review technical panel

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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.

A4.1.3.  RTI Task Leader

The RTI task leader is Jenni Elion.  She 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.
Ms. Elion 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 Terry Ullman. 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 fuel and lubricant modifications,
   •   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.
Ullman 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.
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), Paul Groff, will conduct audits of RTFs 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 test/QA plan 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 test/QA plan, the EPA QM (or his designee) will perform
the following specific activities associated with the verification tests:
   •   Review and approve the GVP for this technology,
   •   Review and approve this SwRI-specific test/QA plan and each test-specific addendum,
   •   Review and approve each verification report and each verification statement, and
   •   Perform a PEA of the verification test of SwRFs ETV testing operations.
A4.2.2.  RTI Quality Manager

The RTI APCT Center quality manager (RTI QM), Gary Eaton,  is organizationally independent
of the RTI APCT Center director and is responsible for ensuring that QA/quality control (QC)
procedures described in this test/QA plan are followed. In addition, Eaton 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, test/QA plans, test/QA plan  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.
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 SwRFs DER.  He fulfills the role as
quality management representative for the department and conducts audits of all pertinent quality
standards to ensure compliance. He is organizationally independent of the unit generating the
data. He will:

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    •   maintain the official, approved version of this document,
    •   review and approve test-specific addenda to this document, and
    •   reconcile test results with DQOs via data quality indicator goals (DQIG) attainment.
The SwRI QM will document the test-specific ADQ as described in Element C1.2.

A5: Problem Definition/Background

This ETV test/QA plan for heavy-duty diesel engine testing at the SwRI's DER describes how
the Federal Test Procedure (FTP), as listed in 40 CFR Part 86 for highway engines and 40 CFR
Part 89 for nonroad engines, will be specifically implemented for this testing program. The
phrase "without deviation" is used when the FTP is followed exactly. When the FTP allows
flexibility (e.g., "alternate methods ... may be used"), the specific implementation will be
described if such flexibility is used.

A6: Project/Task Description

A6.1. Description

This ETV test/QA plan describes the test and QA procedures that will satisfy the specifications
of the Generic Verification Protocol (GVP) for Determination of Emissions Reductions Obtained
by Use of Alternative or Reformulated Liquid Fuels, Fuel Additives, Fuel Emulsions, and
Lubricants for Highway and Nonroad Use Diesel Engines and Light Duty Gasoline Engines and
Vehicles developed under the authority of the APCT Center at RTI.  This document is written to
conform to all specifications of EPA Requirements for Quality Assurance Project Plans,  EPA
QA/R-5, the EPA ETV QMP, and the APCT Center QMP.  It describes the quality system of
SwRI and the procedures applicable to meeting EPA quality requirements that are common to all
ETV tests.  Test-specific addenda, noted below, will be reviewed and approved by EPA prior to
testing.

This testing, based on the FTP, is to quantify the effectiveness of "commercially ready" fuel and
lubricant modifications for oxides of nitrogen (NOX), hydrocarbons (HCs), particulate matter
(PM), and carbon monoxide (CO) that are intended for use on diesel and light duty gasoline
engines considered mobile sources of air pollution.  For a specific technology, the number and
type of FTP tests may  differ (see GVP, Section 5.1) from certification requirements  in order to
satisfy the DQOs (see  GVP, Section 2.4).

A description of a specific technology, engine to be tested, and test-specific details will be
documented as a test-specific addendum to this document that will be prepared by the  RTI task
leader and submitted for EPA review and approval prior to the  start of testing.  The test-specific
addendum will provide additional information needed to conform to required elements A5
(Problem Definition/Background) and A6 (Project/Task Description) of EPA QA/R-5.

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A6.2. Schedule

Figure 2 shows an example schedule for completion of a first draft verification report and
statement. The test-specific schedule is expected to vary from technology to technology based
on the scheduling needs of the applicant,  SwRI, and the APCT Center.
tM O N T H
1

Applicant accepts SUW, signs terms & Conditions
EPA approves applicant-specific test/QA plan addendum
SwRI receives test items from applicant
SwRI conducts testing
SwRI delivers test report to APCT Center
APCT Center completes first draft verification report and
statement
4
<




2


>
+



3




^^H

4





4

5





>
<
                            Figure 2.  Example of schedule.
A7:  Quality Objectives and Criteria

The DQOs of this testing focus on the measurements of NOx, HC, PM, and CO.  Test
requirements are those found in 40 CFR 86 and 40 CFR 89 FTP test methods, with the number
of tests being determined by:
   1.  A minimum of three tests,
   2.  Additional tests indicated (see GVP, Section 5), and
   3.  Additional tests desired by the applicant.
The rationale for the number of FTP test cycles will be included in the test-specific addenda to
this document, which will conform to required element Bl of EPA QA/R-5.

The DQIG for individual measurements will conform to those specified in relevant sections of
the FTP, as shown in Table 1. Test-specific DQIG will be documented in the test-specific
addenda to this document.

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                     Table 1: Data Quality Indicator Goals (DQIG)
Param
NOx
NOx


NOx
NOx
NOx
NOx
NOx
NOx
NOx
Sampling
Sampling
Sampling
Sampling
Sampling
Weighing
Weighing
Weighing
Weighing
Bag Cart
Bag Cart
Bag Cart
Bag Cart
Testing
DER SOP
06-002
06-002
06-003
06-003
06-025
06-025
06-025
06-041
06-041
06-041
06-041
07-003
07-009, 07-038
07-009, 07-038
07-009
07-009
07-020
07-020
07-020
07-020
07-023, 07-038
07-023, 07-038
07-023, 07-038
07-023
07-028
40CFR
86.1323-84(a)(4)
86.1323-84(a)(7)























Acceptance Criteria
N02 content < 5% of NO concentration
Converter efficiency >90% (SwRI: 95%)
Gas divider linearity: |known - observed! - 2.0%
Gas divider linearity, full-scale: |known - observed! - 0-5%
Analyzer initial zero = 0.0 ± 0.5 meter division
Analyzer initial span: |known - observed! - 0-5 meter division
Analyzer post-check zero and span: drift < 1 .0 meter division
Carbon dioxide (C02) quench, pre-test zero: 0.0 ± 0.5% full scale
C02 quench, pre-test span: |known - observed! - 0-5% full-scale meter
C02 quench, post-test zero and span: drift < 2% full-scale meter
C02 quench: < 3% full scale meter
20 °C < CVS (constant volume sampler) dilution air temp < 30 °C
Background of CVS and tunnel: < 10 ppmC (carbon)
Background: |CVS tunnel - bag| < 2 ppmC
NOx post-test zero and span drift < 2% full scale meter
HC post-test zero and span drift < 3% full scale meter
Chamber: 19 °C< temperatures 25 °C
Chamber: 37% < relative humidity < 53%
Reference filter weight change < 20 micrograms
Reference mass weight change < 10 micrograms
Pre-test zero: 0.0 ± 0.5% full-scale meter
Pre-test span: |known - observed! - 0-5% full-scale meter
Pre-test zero and span check: |known - observed! - 1% full-scale meter
Post-test zero and span: drift < 2% full scale
Gas meter #2 (secondary flow) counts > 373 counts/min
A8:  Special Training/Certification

The DER is certified to International Organization for Standardization (ISO) 9001:2000 "Model
for Quality Management Systems."  This independently-assessed quality system provides the
basis for quality procedures that are applied to every project conducted in the DER.

DER is accredited to ISO/LEG 17025 "General Requirements for the Competency of Calibration
and Testing Laboratories." Under American Association for Laboratory Accreditation
Certificate Number 0702-01, DER has been accredited to perform evaluations of automotive
fluids, fuels emissions, automotive components, engine and power-train performance and
durability using stationary engine dynamometer test stands (light-duty, nonroad, and heavy duty)
and vehicle dynamometer facilities, and automotive fleets (see
http://www.a21a2.net/scopepdf/0702-01.pdf). The certificate accredits DER to use specific
standards and procedures, including dynamometer procedures for HCs, CO, NOx, and PM.

DER has also achieved and has maintained Ford Tier 1 status for providing engineering services,
received the Ford Ql Quality Award and the Ford Customer-Driven Quality Award, and
maintains its status as a Caterpillar-Certified Supplier.

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All SwRI personnel supporting the project will be qualified as prescribed by OAE SOP 4.18
(Training).

A9:  Documents and Records

Test-specific documentation and records will be processed as specified in OAE SOP 4.5
(Document Control), OAE SOP 4.16 (Quality Records), and OAE SOP 4.10.2 (Test Conduct and
Recording of Test and Calibration Data).  See Element BIO for details of test data acquisition
and management.

In accordance with Part A, Sections 5.1 and 5.3 of EPA's QMP, SwRI will retain all test-specific
documentation and records for seven years after the final payment of the agreement between
SwRI and the APCT Center. RTI will retain all verification reports and statements for seven
years after final payment of the agreement between RTI and EPA.

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                  GROUP B: DATA GENERATION AND ACQUISITION


Bl:  Sampling Process Design (Experimental Design)

The test design follows the FTP, 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 addenda to this document, which will
conform to required element Bl  of EPA QA/R-5.
B2:  Sampling Methods

The sampling system is comprised primarily of the exhaust sampling system to which continuous
measurement devices and paniculate filters are attached, as depicted in Figure 3.


B2.1.  Exhaust Gas Sampling System


The exhaust gas sampling system conforms to 40 CFR 86.1310-90 and 40 CFR 89.419. The
system that will be used at SwRI is depicted in Figure 3.
                            Optional for
                            Participate
                         Background Reading
                             Zero Air
    Discharge
    Dilution Air Filter
    Sampling Train
Ambient
Air Inlet
LEGEND
                                        HC Span Gas
                                                             Integrator
                                                                             Counters
                                 1
                 Read Background BagV—/
  Dillution Tunnel
     Heated Probe
   Particulate Probe
|  Mixing Orifice
Flow Control Valve

Selection Valve

Particulate Filter

Pump

Flowmeter

Pressure Gauge
 V
 0
                                                                      To Background Sample Bag
                          To Exhaust \o/
                          Sample Bag V
                         Heated Sample Line
                             Heat Exchanger


                               4-f-f-f-Tf Coolant
                                                                           Positive
                                                                         Displacement
                                                                            Pump
                           Primary Filter (Phase 2)
                            Back-up Filter(Phase 2)
                             .To Pump Rotometer
                               and Gas Meter
                                as Diagramed
                                Immediately
                                   Below
                                                                                   rTo Formaldehyde
                                                                                   Sample Collection
                                                                                 *• To Methanol Sample
                     Vehicle Exhaust Inlet
Primary Filter (Phase 1 and 3)
Back-up Filter (Phase 1 and 3)

Note: Three filter holders
    (one for each phase)
    are also acceptable.
                                                                                    Revolution Counter
                                                                                        Pick Up

                                                                                  Manometer

                                                                                 Discharge
      Recorder

      Temperature Sensor

                Figure 3. Gaseous and particulate emissions sampling system.

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B2.2. PM Sampling System

Particulate samples are collected on a pair of 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 constant volume sampler (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.
(See Element B4.2 for specific filter weighing procedures.)
B3:  Sample Handling and Custody

Only PM filter measurements and bag samples involve manual handling, since gaseous emission
measurements are made and recorded by the computer-controlled data system associated with
the continuous sampling system shown in Figures 3 and 4.
                                                             Optional
                              FL5
                                                                        LEGEND
                                   NOx
                                    CL
                             ! Span and  Span and ,,
                             I Zero Gases Zero Gases MhLn
P10 WT1
—J—D
                                           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
                                           Plug Valve or Equivalent
                                           (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 4. Exhaust gas sampling and analytical train.

B3.1. Particulate Filters Handling and Custody

The PM filters are prepared and processed according to DER SOP 07-020 (Particulate Filter
Conditioning and Weighing), which specifies sample handling and custody procedures as well as
a method of conditioning and weighing filters used to collect particulate samples during exhaust
emission testing. This DER SOP conforms to required element B3 (Sample Handling and
Custody) of EPA QA/R-5.

B3.2. Bag Samples Handling and Custody

Samples are handled according to DER SOP 07-023 (Operation of Bag  Cart).  This SOP
conforms to required element B3 (Sample Handling  and Custody) of EPA QA/R-5.

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B4: Analytical Methods

B4.1 Exhaust Gas Measurement System

The exhaust gas measurement system conforms to 40 CFR 86.1310-90, 40 CFR 89.419, and 40
CFR 89.421. The configuration that is used at SwRI is shown in Figure 4.

B4.2. Filter Weighing

Particulate filters are stored, conditioned, and weighed in a room at SwRI that conforms to 40
CFR 86.1312-88 according to DER SOP 07-020 (Particulate Filter Conditioning and Weighing).
 The weighing process conforms to 40 CFR 86.1339-90.  The balances that will be used are
listed in the SwRI DER "Recall Database."

The chamber in which the PM filters are conditioned and weighed conforms to 40 CFR 86.1312-
88 without deviation.

B4.3. Gaseous Analyzers

Gaseous analyzers depicted in Figure 4 conform to 40 CFR 89.309, 40 CFR 86.1310-90, and 40
CFR 86.1311-94 without deviation. The specific instruments to be used in this test will be
selected from those listed in the master list of calibration equipment maintained in the SwRI
DER "Recall Database." Their operation is specified in DER SOP 07-009 (Emissions Testing
During Heavy-Duty Diesel Engine Transient Cycle), which conforms to required elements B4
(Analytical Methods), B5 (Quality Control), and B6 (Instrument/Equipment Testing, Inspection,
and Maintenance) of EPA QA/R-5.

B5: Quality Control

Activities are specified in OAE SOP 4.15.2 (Data Control and Reporting) for assessing the
quality of data from each test event. These SOPs conform to required elements B5 (Quality
Control) and D3 (Reconciliation with User Requirements) of EPA QA/R-5.

B6: Instrument/Equipment Testing, Inspection, and Maintenance

Gaseous analyzers depicted in Figure 4 conform to 40 CFR 89.309, 40 CFR 86.1310-90, and 40
CFR 86.1311-94 without deviation. DER SOP 07-009 (Emissions Testing During Heavy-Duty
Diesel Engine Transient Cycle) includes and conforms to required element B6
(Instrument/Equipment Testing, Inspection, and Maintenance) of EPA QA/R-5.

B7: Instrument/Equipment Calibration and Frequency

Calibration and frequency of instruments and equipment are specified in OAE SOP 4.11.1
(Calibration and Maintenance) and OAE SOP 4.11.2 (Calibration Recall), which conform to
required element B7 (Instrument/Equipment Calibration  and Frequency) of EPA QA/R-5.

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B7.1. Gas Meter Calibrations

As specified in DER SOP 06-003 (Linearity Verification of Gas Dividers), all gas meters,
selected from the list of routinely used instruments listed in the DER Recall Database, are
calibrated to conform to 40 CFR 86.1320-90 and 40 CFR 89.319. Any necessary correction is
made by mechanically adjusting the meter and recalibrating.

B7.2. Gaseous Analyzer Calibrations

B7.2.1.  Hydrocarbon Analyzers

The hydrocarbon analyzers used in this testing program, listed in the DER Recall Database, are
calibrated in conformance with 40 CFR 86.1321 and 40 CFR 89.319, using the procedures
specified by the applicable flame ionization detector [FID/heated flame ionization detector
(HFID)] manufacturer. Their operation is specified by DER SOPs 06-012 (Monthly Calibration
of Analyzers for Continuous Dilute Gaseous Exhaust), 06-021 (FID Response for Methane), 06-
024 (Hydrocarbon Analyzer and Systems Response Checks), and 06-044 (Hydrocarbon Analyzer
Optimization), which conform to required element B7 (Instrument/Equipment Calibration and
Frequency) of EPA QA/R-5.

B7.2.2.  Carbon Monoxide Analyzers

The CO analyzers used in this testing program, listed in the DER Recall Database, are calibrated
in conformance with 40 CFR 86.1322 and 40 CFR 89.320, using zero-grade air. Their operation
is specified by DER SOPs 06-016 (Wet CO2 Interference Check for CO Analyzers) and 06-023
(Calibration of Analyzers Using Digital Readout), which conform to required element B7
(Instrument/Equipment Calibration and Frequency) of EPA QA/R-5.

B7.2.3.  Oxides of Nitrogen Analyzers

The NOx analyzers used in this testing program, listed in the DER Recall Database, are
calibrated in conformance with 40 CFR 86.1323 and 40 CFR 89.321, using zero-grade air.  Their
operation is specified by DER SOPs  06-002 (NOx Converter Efficiency Determination), 06-012
(Monthly Calibration of Analyzers for Continuous Dilute Gaseous Exhaust), 06-025 (NOx
Analyzer and System Response Checks), and 06-041 (NOx Analyzer CO2 Quench Check),
which conform to required element B7 (Instrument/Equipment Calibration and Frequency) of
EPA QA/R-5.

B7.2.4.  Carbon Dioxide Analyzers

The carbon dioxide (CO2) analyzers used in this testing program, listed in the DER Recall
Database, are calibrated in conformance with 40 CFR 86.1324 and 40 CFR 89.322, using zero-
grade air. Their operation is specified by DER SOP 06-023 (Calibration of Analyzers Using
Digital Readout), which conforms to required element B7 (Instrument/Equipment Calibration
and Frequency) of EPA QA/R-5. These measurements are ancillary for this testing program.

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B7.2.5.  Methane Analyzers

The methane analyzers used in this testing program, listed in the DER Recall Database, are
calibrated in conformance with 40 CFR 86.1325  and 40 CFR 89.324, without deviation. These
measurements are ancillary for this testing program.

B7.3. Analyzer Calibration Gases

The gases used for instrument calibration conform to 40 CFR 86.1314-94 and 40 CFR 89.312
without deviation.

B8:  Inspection/Acceptance of Supplies and Consumables

Inspection and acceptance criteria for client-supplied or SwRI purchased materials and
equipment are coordinated by the SwRI task leader. This process is conducted in accordance
with OAE SOP 4.10.1 (Receiving Inspection). Upon receipt and processing by SwRI shipping
and receiving, the shipment is delivered to the test facility.  The inventory clerk of the test
facility checks the shipment against the packing slip and notifies the appropriate task leader or
supervisor, who then inventories and inspects the items received.

B9:  Non-direct Measurements

All data used in this project will be generated by this project. No non-measurement sources,
such as computer databases, programs, literature files, and historical databases, will be used.

BIO:  Data Management

B10.1 Data Acquisition and Management

Data acquisition and data management are performed according to OAE SOP 4.10.2 (Test
Conduct and Recording of Test and Calibration Data) and OAE SOP 4.15.2 (Data Control and
Reporting), which conform to required element BIO (Data Management) of EPA QA/R-5. The
planned data streams, with responsibilities of the SwRI technical leader and SwRI QM, are
depicted in Figure 5. The SwRI technical leader is operationally responsible for all aspects  of a
test.  The SwRI QM is operationally responsible  for all data quality aspects of a test, with
primary focus, but not exclusive focus, on the areas indicated in the figure.

Qualitative data regarding the technology to be tested, per 40 CFR 86.1344 and 40 CFR 89.405,
are manually recorded on the data sheets specified in DER SOP 07-003 (Transient Test for
Heavy-Duty  Diesel Engines). Operating and emissions data are captured by the data
management system, described schematically in Figure 5.

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November 2006
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                          Page 14
                     Technical Leader: Test Oversight and Data Production
                       Quality Manager:  Quality System and Data Integrity
                Engine Information from
                   Manufacturer
                Pre-test Filter Weights
                Post-test Filter Weights
Technology Information
   from Supplier
                                                         Test Cell Instrument Data
                                                              QC Data
                                       Assemble Data
                                           T
                                      Calculations and
                                        Data Analysis
                                        QA Review
                                          Report
                 Data Flow
                         Figure 5.  ETV data management system.
B10.2  Reporting
The test report must be sufficiently detailed with background information to allow complete
description of the verification testing in the verification report (VR). Each of the elements
identified in the GVP, section 6.1 must be addressed in the test report.  OAE SOP 4.15.2 (Data
Control and Reporting) conforms to these requirements.

The VR, which will be prepared by the APCT Center, includes the verification statement and a
detailed discussion of the verification testing. An outline of the VR is provided in the GVP,
section 6.1, and the VR includes each of the elements listed. The description of the verification
testing will be based on the test report.  The APCT Center will conduct the data analysis and
verification based on the equations in the GVP, section 5.1.

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             GROUP C: ASSESSMENTS AND OVERSIGHT ELEMENTS

Cl:  Assessments and Response Actions

Cl.l. Internal Audits

Internal audits by SwRI are conducted as specified in OAE SOP 4.17 (Internal Quality Audits),
which conforms to required element Cl (Assessments and Response Actions) and C2 (Reports to
Management) of EPA QA/R-5.

C1.2. Audits of Data Quality

In accordance with Table 9.1 of the EPA ETV QMP, the SwRI QM will conduct an ADQ of at
least 10 percent of all of the verification data. The ADQ will be conducted in accordance with
EPA's Guidance on Technical Audits and Related Assessments for Environmental Data
Operations, EPA QA/G-7, including:

   •   a written report detailing the results of custody tracing,
   •   a study of data transfer and intermediate calculations,
   •   a review of QA and QC data, including reconciliation to user requirements (e.g., DQOs
       and DQIGs),  and
   •   a study of project incidents that resulted in lost data, and a review of study statistics.

The ADQ report ends with conclusions about the quality of the data from the project and their
fitness for their intended use.

C1.3. External Audits

SwRI will cooperate with any external assessments by the EPA or the APCT Center.  RTI or
EPA will conduct a single mandatory quality and technical systems assessment of DER before
the start of the first test at DER. They may conduct optional assessments during the first test or
any subsequent test.  The external assessments will  be conducted as described in EPA QA/G-7.

C1.4. Corrective Action

Corrective action that results from any audit or assessment is performed according to OAE SOP
4.13 (Nonconformance, Preventive and Corrective Action, Customer Complaints), which
conforms to required elements B5 (Quality Control) and Cl (Assessments and Response
Actions) of EPA QA/R-5.

C2:  Reports to Management

Internal assessment reports will be reviewed by the SwRI QM, who will respond as noted in
element Cl.  The written report of the ADQ will be submitted to the APCT Center for review as
noted in Element C1.2.

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           GROUP D:  DATA VALIDATION AND USABILITY ELEMENTS

Dl: Data Review, Verification, and Validation

Activities are specified in OAE SOP 4.10.2 (Test Conduct and Recording of Test and Calibration
Data) and OAE SOP 4.15.2 (Data Control and Reporting), which conform to required element
Dl (Data Review, Verification, and Validation) of EPA QA/R-5.

D2: Verification and Validation Methods

Activities are specified in OAE SOP 4.15.2 (Data Control and Reporting), which conforms to
required element D2 (Verification and Validation Methods) of EPA QA/R-5.

D3: Reconciliation with User Requirements

Activities are specified in OAE SOP 4.10.2 (Test Conduct and Recording of Test and Calibration
Data) and OAE SOP 4.15.2 (Data Control and Reporting), which conform to required element
D3 (Reconciliation with User Requirements) of EPA QA/R-5. (See element Cl .2)

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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-03/021. Office of Research and Development, U.S. Environmental
Protection Agency.  Cincinnati, OH. December 2002.

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. EPAQA/G-5, EPA Publication No.
EPA/600/R-98/018. Office of Environmental Information, U.S. Environmental Protection
Agency. February 1998.

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.  Research Triangle Institute. Research Triangle Park, NC.  October 1998.

APCT Center. Generic Verification Protocol (GVP)for Determination of Emissions Reductions
Obtained by Use of Alternative or Reformulated Liquid Fuels, Fuel Additives, Fuel Emulsions,
and Lubricants for Highway andNonroad Use Diesel Engines and Light Duty Gasoline Engines
and Vehicles.  Research Triangle Institute, Research Triangle Park, NC.  September 2003.

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3.  SwRI OAE Standard Operating Procedures

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

    QSM           QUALITY SYSTEM MANUAL - April 2001
 OAE SOP 4.5      Document Control
 OAE SOP 4.10.1   Receiving Inspection
 OAE SOP 4.10.2   Test Conduct and Recording of Test and Calibration Data
 OAE SOP 4.11.1   Calibration and Maintenance
 OAE SOP 4.11.2   Calibration Recall
 OAE SOP 4.13     Nonconformance, Preventive and Corrective Action, Customer Complaints
 OAE SOP 4.15.2   Data Control and Reporting
 OAE SOP 4.16     Quality Records
 OAE SOP 4.17     Internal Quality Audits
 OAE SOP 4.18     Training

4.  SwRI DER Standard Operating Procedures

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

    SOP-06-002   NOx Converter Efficiency Determination
    SOP-06-003   Linearity Verification of Gas Dividers
    SOP-06-012   Monthly Calibration of Analyzers for Continuous Dilute Gaseous Exhaust
    SOP-06-016   Wet CO2 Interference Check for CO Analyzers
    SOP-06-021   FID Response for Methane
    SOP-06-023   Calibration of Analyzers Using Digital Readout
    SOP-06-024   Hydrocarbon Analyzer and Systems Response Checks
    SOP-06-025   NOx Analyzer and System Response Checks
    SOP-06-041   NOx Analyzer CO2 Quench Check
    SOP-06-044   Hydrocarbon Analyzer Optimization
    SOP-07-003   Transient Test for Heavy-Duty Diesel Engines
    SOP-07-009   Emissions Testing During Heavy-Duty Diesel Engine Transient Cycle
    SOP-07-020   Paniculate Filter Conditioning and Weighing
    SOP-07-023   Operation of Bag Cart
    SOP-07-028   Dilute Steady-State Engine Emissions Test
    SOP-07-038   Steady-State Emissions Testing of Heavy-Duty Engines

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