Test/QA Plan for ETV Fuel and Lubricant Modifications at SwRI
November 2006
Version 0.0
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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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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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