SRI/USEPA-GHG-QAP-31
                                    June 2004
Test and Quality Assurance
Plan

Universal Cams, LLC
Dynamic Cam™
Diesel Engine Retrofit System

                 Prepared by:
         Greenhouse Gas Technology Center
            Southern Research Institute
           Under a Cooperative Agreement With
        U.S. Environmental Protection Agency

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                                      EPA REVIEW NOTICE

This report has been peer and administratively reviewed by the  U.S. Environmental Protection Agency, and
approved for publication.  Mention of trade names or commercial products does not constitute endorsement or
recommendation for use.

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                                       SRI/USEPA-GHG-QAP-31
                                                 June 2004
 Greenhouse Gas Technology Center
A U.S. EPA Sponsored Environmental Technology Verification ( jj^) Organization
     Test and Quality Assurance Plan
             Universal Cams, LLC
                Dynamic Cam™
       Diesel Engine Retrofit System
                     Prepared By:
              Greenhouse Gas Technology Center
                 Southern Research Institute
                    PO Box 13825
             Research Triangle Park, NC 27709  USA
                 Telephone: 919/806-3456
                     Reviewed By:
       Universal Cams, LLC
       Southwest Research Institute
       U.S. EPA Office of Research and Development

          ^ indicates comments are integrated into Test Plan

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       Greenhouse Gas Technology Center
      A U.S. EPA Sponsored Environmental Technology Verification ( Ef^j Organization
           Test and Quality Assurance Plan
                    Universal Cams, LLC
                        Dynamic Cam™
              Diesel  Engine Retrofit System
This Test and Quality Assurance Plan has been reviewed and approved by the Greenhouse Gas
Technology Center Project Manager and Center Director, the U.S. EPA APPCD Project Officer, and the
U.S. EPA APPCD Quality Assurance Manager.
Stephen Piccot             Date
Center Director
Greenhouse Gas Technology Center
Southern Research Institute
David Kirchgessner
APPCD Project Officer
U.S. EPA
Date
Mark Meech              Date
Project Manager
Greenhouse Gas Technology Center
Southern Research Institute
Robert Wright             Date
APPCD Quality Assurance Manager
U.S. EPA
Test Plan Final: June 2004

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                           DISTRIBUTION LIST
Universal Cams,
      Dave Maxwell
U.S. EPA
      David Kirchgessner
      Bob Wright
Southern Research Institute
      Stephen Piccot
      Mark Meech
      Tim Hansen
      Ashlev Williamson
Southwest Research Institute
       Robert Fanick

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                                        TABLE OF CONTENTS
1.0     INTRODUCTION	1

  1.1     BACKGROUND	1
  1.2     SwRI TESTING QUALIFICATIONS	2
  1.3     ORGANIZATION OF THIS PLAN	3
  1.4     REFERENCED SwRI QUALITY DOCUMENTS	3

2.0     TEST DESCRIPTION AND TEST OBJECTIVES	5

  2.1     TECHNOLOGY DESCRIPTION	5
  2.2     TEST DESCRIPTION	6
    2.2.1   Overview	6
  2.3     TEST ENGINE SELECTION AND SPECIFICATIONS	7
  2.4     BASELINE ENGINE PREPARATION	9
  2.4     BASELINE ENGINE PREPARATION	9
    2.4.1   Fuel-Injector Replacement	9
    2.4.2   Engine Inspection	9
    2.4.3   Engine Oil Change	9
  2.5     ENGINE MODIFICATION WITH UC TECHNOLOGY	10
  2.6     ENGINE TESTING PROCEDURES	10
    2.6.1   Break-in Period	11
    2.6.2   Engine Mapping.	11
    2.6.3   Test Cycle	11
    2.6.4   Engine Preconditioning	12
    2.6.5   Emissions and Fuel Consumption Testing	12
    2.6.6   Evaluation of Maximum Fuel Consumption	13
  2.7     ADDITIONAL TEST CONSIDERATIONS	13
    2.7.1   Test Fuel	13
    2.7.2   Back-Pressure	13
    2.7.3   Durability	14
  2.8     TEST ORGANIZATION AND RESPONSIBILITIES	14
    2.8.1   EPA	15
    2.8.2   Southern Research Institute	16
    2.8.3   SwRI	17
    2.8.4   Universal Cams	17
    2.8.5   EPA-OTAQ	17
  2.9     SCHEDULE AND MILESTONES	17
  2.10   DOCUMENTATION AND RECORDS	18

3.0     DATA QUALITY OBJECTIVES	19

  3.1     CRITICAL MEASUREMENTS	19
  3.2     DATA QUALITY OBJECTIVES	19
    3.2.1   Minimum Number of Test Runs	19
    3.2.2   Confidence Intervals and DQOs	20
    3.2.3   Additional DQO Information	21

4.0     SAMPLING AND ANALYTICAL PROCEDURES	22

  4.1     EXHAUST GAS SAMPLING SYSTEM	22
  4.2     EXHAUST GAS MEASUREMENT SYSTEM SPECIFICATIONS	22
  4.3     FILTER WEIGHING	23
  4.4     GASEOUS ANALYZERS	23

5.0     SAMPLE HANDLING AND CUSTODY	24

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6.0    DATA QUALITY INDICATOR GOALS AND QA/QC CHECKS	25

7.0    INSTRUMENT CALIBRATION AND FREQUENCY	28

8.0    DATA ACQUISITION AND MANAGEMENT	29

9.0    INTERNAL AND EXTERNAL AUDITS	31

  9.1    TECHNICAL SYSTEMS AUDIT	31
  9.2    PERFORMANCE EVALUATION AUDITS	31
  9.3    AUDIT OF DATA QUALITY	31
  9.4    EXTERNAL ASSESSMENTS	32
  9.5    INTERNAL ASSESSMENTS	32

10.0   CORRECTIVE ACTION	33

11.0   DATA REDUCTION, REVIEW, VALIDATION, AND REPORTING	33

12.0   REPORTING OF DATA QUALITY INDICATORS	33

13.0   DEVIATIONS FROM GVP	33

14.0   REFERENCED QUALITY DOCUMENTS	34

  14.1   EPA-ETV	34
  14.2   GHGTC	34
  14.3   SOUTHWEST RESEARCH INSTITUTE	34

Appendix A: Test Log Forms and Checklists
Appendix B: Cummins Shop Manual

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                                   1.0     INTRODUCTION
1.1   BACKGROUND

The U.S. Environmental Protection Agency's Office of Research and Development (EPA-ORD) operates
the Environmental Technology Verification (ETV) program to  facilitate the deployment of innovative
technologies through performance verification and information dissemination.  The ETV program's goal
is to further environmental protection by substantially accelerating the acceptance and use of improved
and innovative environmental technologies. Congress funds ETV in response to the belief that there are
many viable  environmental technologies that  are not being used  for the lack of credible third-party
performance data.  The performance data developed under this  program will  allow technology buyers,
financiers, and permitters  in the United States and abroad to make more informed decisions regarding
environmental technology purchase and use.

The Greenhouse Gas Technology Center (GHG Center) is one of six ETV organizations.  EPA's partner
verification organization, Southern Research Institute (Southern), manages the GHG Center. The GHG
Center conducts verification testing of promising GHG mitigation and monitoring technologies.  It
develops verification protocols, conducts field  tests, collects and interprets field and other data, obtains
independent peer-review input, and reports findings. The GHG Center conducts performance evaluations
according to externally reviewed verification Test and Quality Assurance Plans (TQAPs) and established
protocols for quality assurance (QA).

Volunteer stakeholder groups guide the GHG Center's verification activities.  These stakeholders advise
on specific technologies most appropriate for testing, help disseminate results, and review Test Plans and
technology Verification Reports.  National and  international environmental  policy,  technology, and
regulatory experts participate in the GHG Center's Executive Stakeholder  Group.   The group also
includes  industry trade  organizations,  environmental technology  finance  groups,  governmental
organizations, and other interested parties. Industry-specific stakeholders peer-review key documents
prepared by the GHG Center and provide verification testing strategy guidance in those areas related to
their expertise.

One sector of significant interest to GHG Center stakeholders is transportation - particularly technologies
that result in fuel economy improvements.  The Department of Energy reports that in 2001, "other trucks"
(all trucks other than light-duty trucks)  consuming diesel fuel emitted approximately 72.5 million metric
tons of carbon dioxide (CO2). These emissions  increase to 107.5 million metric tons when considering all
diesel vehicles in the transportation  sector.  Small fuel efficiency or emission rate improvements are
expected to have a significant beneficial impact on nationwide greenhouse gas emissions.

Universal Cams, LLC (UC) of Stuart, Florida, has developed a  technology that is planned for use as a
retrofit device for existing diesel, gasoline, and other engines. This technology can also be installed in
new engines during production.   The Dynamic  Cam™  technology includes a cam-shaft, camshaft
sprocket  gear, and fuel injectors which are installed as one-time replacements of an OEM camshaft,
camshaft sprocket, and fuel injectors. UC states that the technology will produce significant reductions in
fuel consumption and emissions  and will also produce improvements in engine horsepower and torque.
UC wishes to verify performance of its Dynamic Cam™ technology for reductions in fuel consumption
and emissions as a  retrofit  modification to  a heavy-duty  highway diesel  engine. UC  is a suitable
verification candidate considering its potentially significant beneficial environmental quality impacts and
ETV stakeholder interest in verified transportation sector emission reduction technologies.

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This test will be conducted under the Generic  Verification Protocol for Diesel Exhaust Catalysts,
Particulate Filters, and Engine Modification Control Technologies for Highway and Nonroad Use Diesel
Engine because of the parameters to be measured.  This document is an ETV  Generic Verification
Protocol (GVP) developed by the Air Pollution Control Technology Verification Center (APCTVC). This
GVP makes use of the Federal Test Procedure (FTP) as listed in 40 CFR Part 86 for highway engines as a
standard test protocol. Performance will be assessed using the GVP test sequence by comparing the fuel
consumption and emission rates measured on a heavy-duty test engine before and after installation of the
UC Dynamic Cam™ technology.  Verification testing will be directed by the GHG  Center. The tests will
take place at Southwest Research Institute's (SwRI) Department of Engine  and Emissions Research
(DEER) in San Antonio, TX. The test program is described in the following sections.   Any deviations
from the GVP are noted in Section 13 of this TQAP.

This TQAP  specifies verification parameters and the rationale for  their selection.   It contains the
verification approach, data quality objectives (DQOs), and Quality Assurance/Quality Control (QA/QC)
procedures. It will also guide test implementation, document creation, data analysis, and interpretation.

This TQAP prepared by the  GHG  Center  has  been peer-reviewed by the technology  developers
(Universal Cams), SwRI, and the EPA-ETV QA Manager. The EPA-APPCD Project Officer provided
final approval of the TQAP.   The  TQAP  meets the requirements of the GHG  Center's  Quality
Management Plan (QMP) once  approved and signed by the responsible parties listed on the front of this
document.    The TQAP is available on GHG Center internet site  at www.sri-rtp.com  and the ETV
program site at www.epa.gov/etv.

The GHG Center will prepare a Verification Report (VR) and Verification Statement (VS) upon field test
completion.  The  same organizations listed above will review the report, followed by EPA-ORD technical
review.  The GHG Center Director and EPA-ORD Laboratory Director will sign the VS when this review
is complete and the GHG Center will post the final documents as described above.

1.2   SWRI TESTING QUALIFICATIONS

The GHG Center has selected SwRI to conduct the testing for this verification. The following describes
the accreditations and registrations of SwRI relevant to this TQAP.

The SwRI DEER is  registered to International Organization for Standardization (ISO) 9002 "Model for
Quality Assurance in Production and Installation." This independently assessed quality system provides
the basis for quality procedures that  are applied  to every project conducted in the DEER. DEER is
accredited to ISO/IEC Guide 25 "General Requirements for the Competency of Calibration and Testing
Laboratories" and EN 45001, "General Criteria for the Operation of Test Laboratories."  The American
Association  for  Laboratory  Accreditation  (A2LA) Certificate  Number  0702-01  accredits DEER to
perform evaluations of automotive fluids, fuel 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 DEER to use specific standards
and procedures,  including dynamometer procedures for hydrocarbons,  carbon  monoxide, oxides of
nitrogen, and particulate matter.    DEER has also:  (1)  achieved Ford  Tier  1  status for providing
engineering services, (2) received the Ford Ql  Quality Award and the Ford  Customer-Driven  Quality
Award, and (3) maintains its status as a Caterpillar-certified supplier.

SwRI has conducted testing for one previous GHG Center technology verification program. Testing was

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conducted on a light-duty gasoline-fueled vehicle. SwRI has also conducted the testing for several heavy-
duty diesel verification tests for another ETV Center.   The EPA has reviewed the TQAP for these tests
and the DEER quality system and verified that the information conforms to the specific required elements
of the [EPA Requirements for  Quality Assurance  Project Plans], the ETV QMP, and the general
requirements of the GVP.

1.3   ORGANIZATION OF THIS PLAN

This plan addresses ETV technology testing at  SwRI under the  applicable  GVP. It is deliberately
organized to parallel the structure of EPA QA/R-5.  Since all laboratory data will be generated by SwRI,
much of this plan also parallels  the SwRI Test/QA Plan for the Verification Testing of Diesel Exhaust
Catalysts, Paniculate Filters, and Engine Modification Control Technologies for Highway and Nonroad
Use Diesel Engines (Version 1.0, April 8, 2002; SwRI QPP ) which was developed based on the  GVP.
This should aid SwRI project personnel as well as the reviewer familiar with verification testing under the
referenced documents. The referenced SwRI QPP was developed for ETV testing under the current GVP
and  is posted on the  ETV website.   Differences between  the  SwRI QPP  and this  plan  reflect
organizational differences and the specific role of the GHG center as the verification organization on this
test.  This plan  also  contains  test-specific  details  of the   UC  Dynamic  Cam™ technology,  its
implementation, verification parameters, schedule, and test design. These details are generally inserted in
the appropriate sections of the main text rather than in a test-specific attachment to the existing  SwRI
QPP.

This plan also describes testing under the framework of the GVP and the relevant Federal Test Procedures
(FTP) (from 40 CFR 86 Subpart N for highway engines), and both documents will be cited as applicable
by reference where such citation is clear.  This plan also describes how the FTP will be  specifically
implemented for this verification.
1.4   REFERENCED SWRI QUALITY DOCUMENTS

Several relevant internal SwRI documents will be incorporated by reference in this TQAP, including the
(1) DEER Quality System Manual (QSM), (2) Quality Policy and Procedures (QPPs), and (3) Standard
Operating Procedures (SOPs).  These internal quality documents, unlike the GVP and FTP references, are
considered proprietary to SwRI and are not publicly available. However, they will be made available for
review during the on-site assessment of the DEER technical and quality systems, and for test-specific on-
site audits by the GHG or EPA QA personnel. Several of the referenced SOPs were previously reviewed
by GHG Center staff as part of a previous verification test and found  adequate by the GHG Center QA
manager as discussed in the TSA report for that test. The following sections of this document reference
specific  SwRI  quality documents that  describe DEER's conformance  with specific  QPP-required
elements. These references  do  not supersede the applicable GVP and  FTP citations, but are  included to
document the specific implementations of these directions by SwRI staff.

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                    2.0     TEST DESCRIPTION AND TEST OBJECTIVES
2.1   TECHNOLOGY DESCRIPTION

The camshaft in an internal combustion engine is composed of lobes (called cams) and the shaft upon
which the cams are mounted. It is tied to the engine's crankshaft by a chain, gears, or a belt. The camshaft
lobes push against the valves in the engine as the camshaft rotates. The valves let the air/fuel mixture into
the engine and allow the exhaust out of the engine. The camshaft and its lobes  control the opening and
closing of the valves in the cylinder heads ~ when they open; when they close; how fast they open; how
fast they close;  and how high (lift) they open. Most engines have  one camshaft.  However, some engines
have two camshafts or more. Springs on the valves return them to their closed position. There is a direct
relationship between the shape of the lobes and the way the engine performs at different speed ranges.

The Universal Cams technology consists of three modified components of an internal combustion engine:
(1) the camshaft, (2) cam sprocket, and (3) fuel injectors. These three proprietary products are referred to
as the "Dynamic Cam™" technology.  They are  a suite of products complementing each other that UC
claims can apply to all internal combustion engines using camshafts.  UC  also claims that every engine
modified with this technology  requires  less fuel and more air, thereby reducing emissions and improving
fuel economy.

The UC technology can be installed in  either new engines (during production)  or in used or rebuilt
engines  (in retrofit applications).  UC states that the installation of this technology is identical  to the
installation process for any OEM camshaft, sprocket, and fuel injection system. No special installation
procedures are required.

The three components of the UC Dynamic Cam™ technology to be verified are:

(1) Sprockey™ - This  is an overhead camshaft sprocket or cam gear replacement.  It is designed to be a
replacement sprocket for the OEM camshaft sprocket or cam gear on all kinds of engines.  UC claims that
the modified sprocket changes the camshaft configuration, thereby improving the effectiveness  of the
camshaft. Sprockey™ can  be installed  by any competent mechanic using normal OEM installation
procedures. The design was originally  intended for heavy-duty diesel engines, but can also be applied to
other types of engines. UC currently considers the Sprockey™ degree modifications and algorithmic
differences proprietary.

(2) DynaCam™ -  This is a camshaft replacement with new lobe configuration.  Camshafts can be
enhanced by modifying their lobe  shape and configuration.  The UC design was originally intended for
heavy-duty diesel  engines.    UC can replace any camshaft arrangement - single overhead,  double
overhead, etc. The  DynaCam™ differs from typical  camshaft and lobe configurations by modifying the
position, or degree, and shape of the camshaft lobes. UC states that the design  creates a more efficient
lobe shape for opening and closing valves. Lobe shapes will vary between engines and the position of the
lobes is  critical.  UC considers the lobe positions and shapes proprietary at this time.  Additional details
will be disclosed after completion of successful verification testing.

(3) Leanjector™ - This is  a fuel injector (reduced-fuel flow) replacement.   Many engine manufacturers
have adopted a "starve-the-engine" approach to meet emission reduction standards.   This  approach
severely limits the amount of air that can be mixed with fuel in the combustion chamber. Universal Cams
has observed that modifying an engine with just the Sprockey™ device alone  or the Sprockey™ and
DynaCam™ devices together  makes the  engine  run leaner. The modified engines run with  the same
                                             5

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amount of air (or more), but with far less fuel. The computer-controlled fuel injectors will adjust to
providing less  fuel but the reduced fuel flow can  be  made much more  effective  by installing  the
Leanjector™ injectors.

UC states that this technology will provide the following benefits:

    •   Increase fuel efficiency in both diesel and gasoline engines;
    •   Lower emissions in both diesel and gasoline engines, especially PM and NOX;
    •   Significantly increase horsepower and torque in all engines;
    •   Save operating costs with lower fuel costs and increased vehicle mileage;
    •   Be applicable to compression ignition (diesel) and spark-ignition (gasoline) and four- and two-
        stroke engines;
    •   Be applicable to diesel, gasoline, natural  gas,  alternative fuels, bio-fuels, blended bio-fuels,
        hydrogen, and multi-fuel engines; and
    •   Retrofit into any existing internal combustion engine that uses camshafts - including automobiles,
        light and heavy trucks, buses, heavy construction  equipment, tractors and combines, locomotives,
        yachts,  ships, generators, and compressors.

UC claims that normal  OEM installation  procedures are used for installation of the  Dynamic Cam™
technology. Cummins camshaft installation procedures are included in Appendix B of this TP.  A local
Cummins technician will be responsible for removal of the existing camshaft, cam sprocket, fuel injectors
(and ancillary equipment) and subsequent installation of the  Dynamic Cam™ technology.

2.2   TEST DESCRIPTION
2.2.1    Overview

This TQAP describes testing of the Universal Cams Dynamic Cam™ technology under the GVP.  The
general test sequence described in GVP Sections 5.2.2 and 5.4.2 is applicable to this test. Testing is being
completed to verify the performance of the Universal Cams Dynamic Cam™ system in reducing exhaust
emissions and improving fuel economy of a heavy-duty diesel engine. The exhaust from the engine will
be analyzed for emissions of NOX, PM, THC,  CO,  CO2,  and CIL,.  Additional measurements and
calculation procedures will be used to determine fuel economy of the engine over a specified test cycle.

The general sequence of test events  follows.   Detailed descriptions of each test phase are provided in
Sections 2.2 through 2.4:

    1.  Obtain a representative test engine and inspect the engine;
    2.  Install new OEM fuel injectors;
    3.  Change the engine oil and filter;
    4.  Break-in the fuel injectors and lubricant;
    5.  Map the baseline engine (develop torque curve);
    6.  Precondition the baseline engine  ;
    7.  Soak the baseline engine;
    8.  Perform baseline engine testing for emissions and fuel consumption;
    9.  Install the Universal Cams Dynamic Cam™ system;
    10. Break-in the UC system;
    11. Map the modified engine;
    12. Precondition the modified engine;
    13. Soak the modified engine;

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    14. Perform modified engine testing for emissions and fuel consumption;
    15. Evaluate the test data for data quality; and
    16. Complete additional testing as necessary to achieve data quality objectives.

The verification test generally requires operation of a test engine on an engine dynamometer. The engine
dynamometer simulates operating conditions of the engine by applying loads to the engine and measuring
the amount  of power that the engine  can  produce against the  load. The engine is  operated on the
dynamometer over a simulated duty cycle that mimics a typical on-road heavy-duty vehicle.  This is the
"transient" cycle heavy-duty FTP specified in 40 CFR 86.1333.

Exhaust emissions from the  engine  are routed through a constant volume sampling (CVS) system to
determine emission concentrations. An adjustable-speed turbine blower dilutes the exhaust with ambient
air while the vehicle operates on the dynamometer. This dilution prevents the exhaust moisture from
condensing  and  provides controllable  sampling conditions.   A  sample pump and a control system
transfers  diluted exhaust to emission analyzers,  sample bags, or particulate sampling systems (filters).
Samples are  collected at constant sampling rates.
2.3   TEST ENGINE SELECTION AND SPECIFICATIONS

UC was responsible for selecting a representative test engine for the current verification based on their
intended  market.   The diesel engine used in this  test program  will be  a  Cummins N-14 350-HP
(turbocharged) engine manufactured in 1997.  The Cummins N-14 series engine was manufactured from
1988 to 2002.  This engine was selected for testing because it represents a large segment of heavy-duty
diesel engines currently on the road for which the UC technology is intended.  UC is responsible for
locating and procuring the test engine and delivering it to the SwRI DEER.  UC is also responsible for
verifying that the engine  has not been rebuilt or modified, and is operating reasonably within original
OEM specifications.   UC will provide documentation (such as operating and maintenance records)
verifying the original certification, purchase, use, and history of this engine.

Cummins states that there were over 150,000 N-14 engines on the road in 2003. More than 100,000
additional units were supplied to the military for a variety of logistical and special-purpose equipment
applications.  The engine has an advanced electric control module (ECM) that provides improved engine
controls.   The specifications  for a Cummins N-14 350 are provided in Table  2-1.  The N-14 series of
engines includes engines in a 330 - 525 HP range.   The specifications provided in Table  2-1 are for a
350-HP engine, but many of these parameters apply to the entire HP range of N-14 by Cummins engines.
Parameters that may vary from engine to engine with varying horsepower are  horsepower, peak torque,
compression ratio, weight-to-power ratio, and, in some cases, governed speed.

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Table 2-2 lists maximum performance data for Cummins N-14 350-HP engine operating parameters.
Table 2-1. Cummins N-14 350 HP Specifications
Parameter

Advertised HP
Peak Torque
Governed Speed
Clutch Engagement Torque
Number of Cylinders
Bore and Stroke
Engine Displacement
Compression Ratio
Operating Cycles
Oil System Capacity*
Coolant Capacity (engine only)
Net Weight with Standard
Accessories, Dry
Weight per Power
Value
(SI units)

350bhp
1400 Ib.-ft
1800/2100 rpm
900 Ib. -ft
6
5.5X6.0 in
855 cu. in.
18.5:1
4
11.0 U.S. gallons
20 U.S. qts.
2805 Ibs.
8.01 Ibs/HP
Value
(Metric units)

261 kW
1898 N-m
1800/2100 rpm
1220 N-m
6
(140 X 152 mm)
14 L
18.5:1
4
42 L
21 L
1272 kg
4.87 kg/kW
*with combination lube filter
Table 2-2. Cummins N-14 350 Hp Maximum Rated Performance Data
Parameter

Engine speed, RPM
Output, BHP (kW)
Torque, lb-ft (N-m)
Inlet air flow, CFM (litre/sec)
Charge air flow, Ib/min (kg/min)
Exhaust gas flow, CFM (litre/sec)
Exhaust gas temperature, °F (°C)
Engine coolant heat rejection, BTU/min (kW)
Radiator coolant flow, U.S. gpm (litre/mm)
Turbo compressor outlet pressure, in hg (mm hg)
Turbo compressor outlet temperature, °F (°C)
Nominal fuel consumption, Ib/hr (kg/hr)
Maximum fuel flow to pump, Ib/hr (kg/hr)
Brake mean effective pressure, PSI (kPa)
Governed
Speed

2100
350 (261)
875(1187)
1212 (572)
84 (38)
2254 (1064)
606(319)
6100 (107)
98(371)
50 (1274)
319(159)
121.2(55.0)
550 (249)
154 (1064)
Peak
Power

1600
368 (274)
1208 (1638)
983 (464)
68(31)
2067 (975)
727 (386)
6100 (107)
75 (284)
46(1170)
308 (153)
117(53.3)
450 (204)
213 (1469)
Peak
Torque

1200
308 (230)
1350(1831)
678 (320)
48 (22)
1642 (775)
846 (452)
5600 (99)
56 (212)
34 (867)
257 (125)
98 (44.4)
350(159)
238 (1639)

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2.4   BASELINE ENGINE PREPARATION
2.4.1    Fuel-Injector Replacement

The engine will have new OEM replacement fuel injectors installed prior to beginning the testing of the
baseline engine.  Fuel injectors will be replaced to ensure that the baseline injectors are operating properly
for comparison to the modified engine (which includes new Leanjector™ fuel injectors).  The injectors
will be replaced using procedures specified in the engine maintenance manual. All equipment installation
and  engine mechanical  work on  the  Cummins  engine will be  performed  by  a  local  Cummins
representative  (Cummins  Southern  Plains).  The technician will  document all  work completed, parts
replaced, specific part numbers, and modifications to the engine.

2.4.2    Engine  Inspection

The Cummins representative will visually inspect the visible parts of the engine during installation of the
baseline OEM fuel injectors to ensure that:

    •   the engine is in good operating condition,
    •   there is not any excessive wear on visible parts,
    •   there are no damaged or broken parts, and
    •   there is not any excessive buildup on visible engine parts.

The Cummins representative will document  any potential problems noted during the inspection and
present these to the GHG Center field team leader.  The field team  leader will determine whether the test
engine is acceptable, needs parts replaced, or should not be used for testing based on the results of the
inspection.  The  field team leader will also document the engine condition. All repairs to the baseline
engine will be documented by the Cummins representative and field team leader.

2.4.3    Engine  Oil Change

The test engine's oil will  be  changed prior to baseline testing.  Technicians will change the engine oil
using the standard manufacturer oil change procedure.  This ensures that the engine oil will not impact the
performance of the engine  from the baseline to modified engine test. A suitable grade of engine oil will be
used based on manufacturer specifications.

The technicians performing the engine oil change will document the oil change,  including the quantity
and type of oil used.  Documentation will be signed by the technicians and copies provided to the field
team leader.

The engine lubricant will not be changed again as significant wear of the lubricant will not occur during
the test period.  Therefore, the same engine  oil will  be  used throughout the entire test  (baseline and
modified engine).

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2.5   ENGINE MODIFICATION WITH UC TECHNOLOGY

The test engine will be modified by installing the Universal Cams Dynamic Cam™ system after baseline
engine testing is complete. A local Cummins representative (Cummins Southern Plains) will perform all
equipment installation and engine mechanical work on the Cummins engine.

The  GVP requires that  UC  provide written descriptions of the procedures for  installation and post-
installation engine adjustments  required for optimum operation [GVP, Section 2.2.3]. UC states that the
Cummins technician will be  present and will be directed by UC regarding the installation of modified
parts and subsequent tuning of the engine.  UC personnel will be present for oversight and consultation
during the  installation of the  Dynamic  Cam™ technology.     UC  considers any other  tuning steps
proprietary.   The Cummins  representative will be required to sign a nondisclosure agreement with UC
prior to commencing work on this engine.

The ETV verification process typically presents information necessary for anyone to duplicate the testing
process. This UC TQAP indicates that some aspects of post-installation engine adjustment are considered
proprietary by UC and will not  be presented  in  this TQAP.  The GHG Center cautions that users will not
have access to certain technology tuning procedures unless provided by UC or their designated installers.
Therefore, the user may not be able to duplicate the test procedures and results presented in the VR.

The Cummins technician, specifically certified by Cummins to work on N-14 engines, will remove the
existing camshaft, cam sprocket, and fuel injectors  (and any other auxiliary parts associated with this
equipment). These will  be replaced with the UC Dynamic Cam™ technology, consisting of camshaft
(DynaCam™), cam sprocket (Sprockey™), and fuel injectors (Leanjector™) as  well as any auxiliary
parts. The technician will complete the installation based on:

    •  the Cummins Shop Manual for Camshafts (001-008 - included in Appendix B of this TQAP),
    •  Cummins Bulletin No. 3666142, Troubleshooting and Repair Manual, and
    •  any other Cummins written instructions for removal of this equipment and work with any other
       part of the N-14 engine  during this process.

UC representatives will not physically touch the engine or Dynamic Cam™ technology unless assistance
is  requested by Cummins. Any "hands-on" interaction by UC will be documented by the field team
leader and reported in the VR.  Any alterations in the installation procedure will also be documented and
reported in the VR.

UC will need to adjust the fuel/air mixture to optimize the effect  of the Dynamic Cam™ operation after
installation.  These procedures  are currently considered proprietary by UC.  These procedures will be
revealed after testing has been  completed.  The Cummins technician will  follow the verbal instructions
from UC for engine adjustment. The GHG Center will document all adjustments made to the engine after
installation of the UC Dynamic Cam™ system. Such adjustments will be  reported in the VR.   UC will
approve the installation and modified engine testing will commence once  installation and adjustment is
complete.

2.6   ENGINE TESTING PROCEDURES

The baseline engine will be installed on the engine dynamometer after engine preparations are completed.
Engine installation is completed and SOPs 07-001 (Power  Validation for Heavy-Duty Diesel Engines)
and 07-002 (Power Mapping for Heavy-Duty Diesel Engines) are addressed.   The engine test procedure
is described in the following sections.

                                              10

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2.6.1    Break-in Period

The baseline and modified engine must go through a break-in period to ensure proper break-in of new
parts and the engine oil.  This allows the engine to stabilize  and eliminates any effects of break-in on
engine performance.  The GVP (Section 5.2.6) specifies a range of 25 -125 hours.

Break-in is completed by operating  the engine at specified conditions  for a specified time period. The
cycle operates at various engine conditions, including idle, peak torque, rated speed, and high idles.
2.6.1.1    Baseline Engine Break-in

The  baseline engine will undergo  break-in for the new engine lubricant and the new baseline fuel
injectors.  This verification test will  have the baseline engine operate under the Cummins break-in cycle
for a period  of 25 hours.  This will ensure that the engine oil and fuel injectors are broken in. The actual
break-in time, operating conditions, and test cycle will be documented by SwPJ.
2.6.1.2    Modified Engine Break-in
The modified engine will undergo break-in for the UC Dynamic Cam™ system. UC does not specify any
required break-in period, but this period will be used to ensure that the technology is functioning properly
and has been operated for the same amount of time as the new baseline engine parts  prior to  testing.
Therefore, for this verification test, the modified engine will also be operated under the conditions of the
Cummins break-in cycle for a period of 25 hours. The actual break-in time, operating conditions, and test
cycle will be documented by SwPJ.

2.6.2    Engine Mapping

Engine mapping is a procedure that is completed to generate  a torque curve for the test engine. It is
generated by running the engine  at  full throttle  at increasing engine speed from curb idle through the
manufacturer's rated speed.  The  engine  torque  is measured at each speed.   The torque  curve is
subsequently used to generate data for the transient test  cycle  for that specific engine.  The engine
mapping procedure follows the procedure specified at 40 CFR 86 Subpart N, Sections 86.1332 and 86-
1333.

Engine mapping will be completed  after the break-in procedure is completed for both the baseline and
modified engines.  The baseline engine map obtained will be compared to the manufacturer-specified
engine map.  Significant differences identified between the two maps will lead to  an investigation of the
cause of this discrepancy.  Corrective actions will be reviewed once the cause is identified.  The required
corrective action will be addressed and considered prior to accepting the engine for further testing. The
engine may be labeled as unacceptable for the test if fundamental problems with the engine are  identified
based on the engine map. A new test engine would then be located.

Mapping results will be reported for  both the baseline and modified test  engine. Results will be compared
to evaluate  changes in engine  performance as a result of  the  installation of the Dynamic  Cam™
technology.

2.6.3    Test Cycle

The test engine is operated on the dynamometer over a transient driving cycle that simulates the  operation
of a typical on-road heavy-duty vehicle.  This test cycle is the  heavy-duty FTP specified in 40 CFR
86.1333. It  is typically used for emissions  testing of heavy-duty on-road engines.  The FTP cycle takes
into account the  operation of a variety of heavy-duty trucks and buses,  and includes simulation of traffic
on roads and expressways in and around cities. The average speed is about 30 km/h and the equivalent

                                               11

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distance traveled is  10.3 km.  The  cycle lasts  1200 s [dieselnet: http://www.dieselnet.com/standards
/cycles/ftp_trans.html].

The test cycle is specified as a normalized cycle.  The data points specified in the FTP are the percent of
maximum torque and speed over time. The specific transient cycle for the test engine is calculated based
on these values and the engine mapping values for test engine torque  vs. engine speed.  One complete
FTP cycle consists of two test segments. The first is a "cold-start test" completed after the engine has
been "soaked" (not operating) for a specified time period (overnight).  The second period is a "hot-start"
test.  This is the same cycle as the cold start test,  begun 20 minutes after the completion of the cold-start
test, while the engine is still "hot".

The  specific FTP cycle used for both the baseline and modified engines will be calculated for this
verification test using the baseline engine mapping results even though engine mapping is completed for
both the baseline and modified engines.

Testing of each engine  configuration will consist of a single cold-start test, followed by the required 20-
minute soak period, and a minimum of three hot-start tests.  A 20-minute soak period is required between
each hot-start test.

2.6.4   Engine Preconditioning

The test engine will be  preconditioned after engine mapping is completed.  Preconditioning  is completed
by running the engine through the FTP test cycle that it will be seeing for the actual test procedure.  Both
the baseline and modified engine will be preconditioned for this test by running the engine through the
transient FTP cycle three times. The transient cycles, each 20 minutes long, are run concurrently without
any soak period. The prep period is completed after this one-hour period.  The preconditioning runs are
completed and then the engine is turned off and allowed to "soak" overnight.   The length of the soak
period between the end of preconditioning and beginning of test runs will be approximately the same for
both the baseline and modified test engine.

2.6.5   Emissions and Fuel Consumption Testing

The  emissions  and fuel consumption tests will  be completed after the  overnight soak following the
preconditioning runs. The test runs will consist of operating the test engine over the  specified FTP test
cycle for one cold-start test, and a minimum of three hot-start tests for both the baseline and modified
engine. Additional hot-start tests may be added depending on the data quality of the initial test runs as
well as reaching agreement between all parties and funding  agencies involved in the test campaign. Total
minimum test duration  is two hours and twenty minutes, consisting of one cold-start test, three hot-start
tests, and three soak periods, each twenty minutes long.

The brake-specific fuel consumption  (BSFC) evaluated during the test  is a measure of engine efficiency
and is  a primary verification parameter for this test series during the FTP  transient cycles.  BSFC is the
ratio of the  engine  fuel consumption to the engine power output  and has units of grams of fuel per
kilowatt-hour (g/kWh) or pounds mass of fuel per brake horsepower-hour (Ib/bhp-hr).  The calculation of
BSFC is shown at 40 CFR 86.1342-90. The equation and supporting parameters are:

                              BSFC =  l/7flVU + 6/7 flVU                         Eqn. 1
                                     l/7(BHP-hrc) + 6/7 (BHP-hrh)
                                               12

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where:        BSFC = brake-specific fuel consumption in pounds of fuel per brake horsepower-hour,
                      Ibs/BHP-hr
               Mc  = mass of fuel used by the engine during the cold start test, Ibs
               M h  = mass of fuel used by the engine during the hot start test, Ibs
               BHP-hrc = total brake horsepower-hours (brake horsepower integrated with  respect to
               time) for the cold start test
               BHP-hrh = total brake horsepower-hours (brake horsepower integrated with  respect to
               time) for the hot start test

The mass of fuel, M, used during each test is calculated via a carbon balance method using the emission
rates and fuel properties determined during testing. These calculations are specified in 40 CFR 86.1342-
90.

Exhaust emissions will be analyzed for NOX, PM, THC, CO, CO2, and CH4 during the test period. Engine
and dynamometer operating conditions will  be recorded. Sampling system, emission analyzer, and test
cell operations will also be monitored.

Each test run  will be followed by evaluation of data quality in  accordance with  the requirements  of
Section 3. Achievement of all data quality indicator goals and FTP requirements will allow the field team
leader to declare a run valid.  A test run where required data quality indicator goals are not met will cause
the test run to be invalidated and repeated immediately (if a hot-start).

2.6.6    Evaluation of Maximum Fuel Consumption

In addition to the FTP cycle fuel consumption, the GVP also specifies measurement of fuel consumption
at maximum power (rated conditions)  and at peak torque at intermediate speed [GVP, Section 5.2.12].
These measurements will be made for both the baseline and modified engine after completion of the FTP
cycle tests. Fuel consumption will be  measured for three five-minute steady-state tests with the  engine
operating at the specified conditions, based on the engine map. The tests will alternate between the two
conditions.  Fuel consumption of the engine will be monitored at maximum power at rated speed for five
minutes,  then peak torque (at intermediate speed) for five minutes, and this cycle is repeated two more
times.  The carbon balance or direct-fuel measurement calculation of modal BSFC may be used (see 40
CFR 86  Subpart N  for both calculations), depending  on available equipment.   The maximum fuel
consumption will be reported as the mean and standard deviation of the three runs.
2.7   ADDITIONAL TEST CONSIDERATIONS
2.7.1    Test Fuel

Testing will use standard diesel test fuel (40 CFR 86.1313-98) with sulfur in the range of 300-500 ppm.
The GHG Center will review fuel analyses and verify the fuel to be within specifications before the start
of engine testing.  The reference for test fuel requirements in the GVP is Section 5.2.10.

2.7.2    Back-Pressure

Baseline  engine back-pressure will  be set to the value required by the applicable FTP (highway  or
nonroad) within the test cell.  The back-pressure of the retrofit control technology may be greater than
the FTP requirement once it has been installed for the ETV test. The ETV test would then be conducted
without adding additional  back-pressure; if not,  the  test cell  will  be  adjusted  to  meet the  FTP

                                              13

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requirements.  Back-pressure of a retrofit control technology may affect the performance of an engine, so
the ETV test will measure and report back-pressure with the control device at full load and rated speed.
Back-pressure will be measured and reported for both the baseline engine (as set for the FTP test without
the technology installed) and the engine with the de-greened control technology installed.

2.7.3    Durability

The aged technology test  described in the GVP will not be part of this verification test due to time and
budgetary constraints [GVP, Section 5.2.9]. Durability testing may be completed in a subsequent testing
phase if this verification test program is successful.  This is mentioned in Section 13 as a deviation from
the GVP.

2.8   TEST ORGANIZATION AND RESPONSIBILITIES

The EPA has  overall responsibility for the  ETV Program  for the  GHG Center. Southern is EPA's
verification partner in this effort. SwRI is the testing organization selected for this test. Management and
testing are performed  in accordance with procedures and protocols defined by a series  of quality
management documents. These include (see Section 19), in order of precedence:

  • EPA Requirements for Quality Assurance Project Plans (EPA QA/R-5);
  • EPA's Quality and Management Plan for the overall ETV program (EPA QMP);
  • QMP for the GHG Center;
  • SwRI's Quality System Manual - 2000 (QSM);
  • DEER's Quality System Manual (QSM);
  • The Generic Verification Protocol (GVP) for Verification Testing of Diesel Exhaust Catalysts,
    Particulate Filters, and Engine Modification Control Technologies for Highway and Nonroad Use
    Diesel Engines; and
  • This TQAP.

SwRI will conduct  field verification and analyze data. Southern will prepare a Verification Report  (VR)
and Verification Statement (VS). The various management and quality assurance (QA)  responsibilities
are divided  between EPA, Southern, and SwRI key project personnel as defined below. The lines of
authority between key personnel for this project are shown on the project organization chart in Figure 2.1.
                                              14

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      U.S. EPA
   APPCD Project Officer


     David Kirchgessner
        U.S. EPA
 APPCD Quality Assurance
          Manager

       Robert Wright
     Southern Research Institute
     Quality Assurance Manager

       Ashley Williamson
Southern Research Institute
 GHG Center Director

    Stephen Piccot
Southern Research Institute
    GHG Center
    Project Manager

    Mark Meech
Southern Research Institute
      GHG Center
    Field Team Leader
      Tim Hansen
                                   Fuel Ec<
                                         moniy Testing
                                  Southwest Research Institute

                                      Robert Fanick
            Universal Cams

            David Maxwell
         U.S. EPA
Office of Transportation Air Quality

        Dennis Johnson
                                   Southwest Research Institute
                                   Quality Assurance Manager

                                  	Mike Van Hecke	
Figure 2-1.    Project Organization
Project management responsibilities are divided among the EPA, Southern, and SwPJ staff as described
below.

2.8.1    EPA
2.8.1.1     Project Management
The EPA Project Manager, David Kirchgessner, has overall EPA responsibility for the GHG Center. He is
responsible for obtaining EPA's final approval of project TQAPs and reports.
2.8.1.2     Quality Manager
The EPA Quality Manager for the GHG Center is Robert Wright of EPA's Air Pollution Prevention and
Control Division (APPCD). His responsibilities include:

    •   Communicate quality systems requirements, quality procedures, and quality issues to the EPA
        Project Manager and the  GHG Project Manager;
    •   Review and approve GHG Center quality systems documents  to  verify conformance with the
        quality provisions of the  ETV quality systems documents;
    •   Conduct performance evaluations (PEs) of verification tests, as appropriate;
    •   Provide assistance to GHG Center personnel in resolving QA issues;
    •   Review and approve this TQAP;
    •   Review and approve the VR and VS for each technology tested under this TQAP; and
                                                 15

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2.8.2    Southern Research Institute
2.8.2.1    GHG Center Director
Southern's GHG Center has overall planning responsibility and will ensure successful verification test
implementation. The GHG Center will:

    •  coordinate all activities;
    •  develop, monitor, and manage schedules; and
    •  ensure the achievement of high-quality independent testing and reporting.

Mr. Stephen Piccot is the GHG Center Director. He will ensure that staff and resources are sufficient and
available to complete this verification.   He will review the TQAP  to ensure  consistency with ETV
operating principles.  He will oversee GHG Center staff activities and provide management support where
needed. Mr. Piccot will sign the VS along with the EPA-ORD Laboratory Director.


2.8.2.2    GHG Center Project Manager

Mr. Mark Meech will serve as the Project Manager for the GHG Center. His responsibilities include:

    •  drafting the TQAP and VR;
    •  overseeing the field team leader's data collection activities, and
    •  ensuring data quality objectives (DQOs) are met prior to completion of testing.

The project manager will have full authority to suspend testing should a situation arise that could affect
the health or safety  of any personnel.  He will also have the authority to suspend testing if the DQIGs
described in Section 3.0 are not being met. He may resume testing when problems are resolved in both
cases. He will be responsible for maintaining communication with UC, SwRI, EPA, and stakeholders.

2.8.2.3    GHG Center Field Team Leader

Mr. Tim Hansen will serve as the Field Team Leader and  will supervise all SwRI activities to ensure
conformance with the TQAP.  Mr. Hansen will  assess test data quality and will have the authority to
repeat tests as determined necessary to ensure achievement of data quality goals. He will perform on-site
activities required for data quality audits under the direction of the GHG Center QA Manager and perform
other QA/QC procedures as described in Section 3.0. He will also communicate with the SwRI Program
and Quality Managers to coordinate the internal audit activities of the SwRI Quality Manager with those
of the GHG Center.  Mr. Hansen will communicate test results to the project manager at the completion of
each test run.  The field team leader and project manager will then determine if sufficient test runs have
been conducted to report statistically valid fuel economy improvements.
2.8.2.4    GHG Center Quality Manager
Southern's QA Manager, Dr. Ashley Williamson,  is responsible for ensuring that all verification tests are
performed in compliance with the QA requirements  of the GHG Center QMP, GVPs, and TQAP. He will
review this TQAP. He has reviewed the applicable elements of the SwRI Quality System and approved
quality requirements for implementation by SwRI technical and quality staff on the coming test. He will
also  review the verification test results and ensure that applicable internal assessments are conducted as
described  in  Section 9.5.  Dr.  Williamson will  report all  internal audit and corrective  action results
directly to the GHG Center Director who will provide copies to the project manager for corrective action
as applicable and citation in the final verification report. He will review and approve the final verification
report and statement. He is administratively independent from the GHG Center Director.

                                               16

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2.8.3    SwRI
2.8.3.1    SwRI Program Manager
Mr. Bob Fanick is the SwRI Program Manager for this test program.  He will be the primary contact for
SwRI and will be responsible for set-up and testing of the vehicle.  He will also review the TQAP and
VR.
2.8.3.2    SwRI Quality Manager
Mr. Mike Van Hecke plays a central role in the introduction, implementation, and consistent application
of continuous  quality  improvement at the  DEER. He fulfills  the  role  as quality  management
representative for SwRI and conducts audits of all pertinent quality standards to ensure compliance. He is
administratively independent of the unit generating the data. He will conduct an internal PEA and ADQ
of SwRI data collection activities on this test as described in  Section 9 and  report results to the GHG
Center QA Manager.

2.8.3.3    Support Personnel
All persons  supporting the project will be qualified as  prescribed by SwRI  QPP 10 (Training  and
Motivation).

2.8.4    Universal Cams

Mr. David Maxwell will serve as Universal Cams' primary contact person.  Mr. Maxwell will provide
technical support in accurately representing the UC technology.  Mr. Maxwell will review the TQAP and
VR and provide written comments. Mr. Maxwell may be present during the verification testing.  UC will
be responsible for procuring the engine and sending it to  SwRI.  UC will be responsible for contacting
and directing the local Cummins technician.

2.8.5    EPA-OTAQ

Mr. Dennis  lohnson  will be the Project Engineer for EPA's OTAQ.  He was provided a copy  of the
TQAP for consistency review with OTAQ requirements and test protocols.


2.9   SCHEDULE AND MILESTONES

An independent quality  system and technical system assessment will be performed following submittal of
the TQAP.

The tentative schedule of activities for testing the Universal Cams technology is as follows:

Verification Test Plan Development                               Dates
       GHG Center Internal Draft Development               October 15, 2003 - lanuary 16, 2004
       UC Review/Revision                                 lanuary 16 - February 13, 2004
       Industry Peer-Review/Revision                       February 20 - March 5, 2004
       EPA Plan Review                                   March 9 - April 5, 2004
       Final Plan Revision and EPA Approval                April 6 - April 19, 2004
       Final Document Posted                               April 28, 2004
                                              17

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Verification Testing and Analysis
       Preliminary Meeting and review at SwRI
       Testing
       Data Validation and Analysis

Verification Report Development
       GHG Center Internal Draft Development
       UC Review and Report Revision
       EPA and Industry Peer-Review
       Final Report Revision and EPA Approval
       Final Report Posted

2.10  DOCUMENTATION AND RECORDS
       Dates
May 24, 2004
May 25 - June 4, 2004
June 7-June 18,2004

       Dates
June 21-July 23, 2004
July 26- August 6, 2004
August 2-August 11 2004
August 23 - September 10, 2004
September 24, 2004
Test-specific documentation and records generated by SwRI will be processed as specified in:

    •   SwRI QPP 03 (Document Preparation and Control);
    •   SwRI QPP 07 (Testing and Sample Analysis); and
    •   SwRI QPP 14 (Quality Records).

Copies of results and supporting data will be transferred to the GHG Center and managed according to the
GHG  Center  QMP.    See  Section 8 for details of test data acquisition and management. SwRI, in
accordance with Part A, Sections 5.1 and 5.3 of EPA's QMP, will retain all test-specific documentation
and records for seven years after the final payment of the agreement between SwRI and the GHG ETV
Center. Southern will retain all verification reports and statements for seven years after final payment of
the agreement between Southern and EPA.
                                             18

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                           3.0    DATA QUALITY OBJECTIVES
3.1   CRITICAL MEASUREMENTS

Critical measurements are for the exhaust gas concentrations of CO2, NOX, PM, HC, and CO \_GVP,
Section 2.3].    CO2 is  listed as a required  secondary measurement under the  GVP.  However, CO2
emissions and the related quantity BSFC are  primary measurements for this and other GHG Center
verifications because of the economic and GHG implications of improved fuel economy.

3.2   DATA QUALITY OBJECTIVES

DQOs are  statements about the planned overall accuracy of the BSFC  improvements  and pollutant
reductions. Two documents provide the basis  for this subsection:  (1) the [GFP] and (2) the Test and
Quality Assurance Plan — ConocoPhillips Fuel-Efficient High-Performance SAE 75W90 Rear Axle  Gear
Lubricant published  by the GHG  Center ("Lubricant TP").  The  references  contain more detailed
discussion than can be provided here.

3.2.1    Minimum Number of Test Runs

More test runs generally provide a more precise characterization.   The first DQO development step
involves determining the minimum number of test runs that will achieve the required data quality.

The BSFC improvement, for example, is the difference between the baseline engine and the same engine
with the UC modifications in place.  The difference is also known as "delta" (or A). The estimate for the
minimum number of test runs required to show a statistically significant A depends on:

    •  the expected mean BSFC value for each test condition,
    •  the absolute value of A, and the resulting relative value expressed as a percentage,
    •  allowable statistical uncertainty, and
    •  the test data's relative  standard deviation, expressed as a percentage (also known as the
       coefficient of variation, or COV).

The  following equation for the minimum number of test runs is derived from the GVP  (Appendix B,
Equation B-l):
                                       /  \ *COV2
                                           j  ctyi/2
                                                    }-                  Eqn.2
                                       o
       where:
              n  =   number of test runs, rounded up to the next integer
              Za =   1 .645, or normal distribution value for upper-tail probability when 1-a is 0.95
              Zp =   1 .282, or normal distribution value for upper-tail probability when l-(3 is 0.90
              COVi = coefficient of variation (sample standard deviation divided by the mean,
                expressed as a percentage) of the baseline engine BSFC
              COV2 = coefficient of variation of the modified engine BSFC
              5  =   relative BSFC change between the as-received engine and the modified engine,
                     expressed as - * 100
                                 BSFC,
                                      ' baseline
                                              19

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Table 3-1 shows the estimated number of test runs for each verification parameter. An estimated 20%
improvement in BSFC provided by UC is the source for the assumption of a 20-percent improvement for
each verification parameter identified in the table. Previous engine dynamometer tests of baseline and
modified 275-hp Cummins and 400-hp Detroit diesel engines conducted by SwRI form the basis for the
Table 3-1 entries.  SwRI performed the engine dynamometer tests  as part of past ETV verifications of
diesel retrofit technologies.  A total of nine test series was considered for the BSFC COV estimates and
six for each of the pollutant COV estimates.  Each test series consisted of three test runs.  The engines,
test equipment,  and test conditions  are expected to be similar to those experienced in this verification.
Note that the GVP adopts n = 3 as the minimum number of test runs, even though the table shows that the
equation yields n < 1 for most parameters.
Table 3-1. GVP Test Run Estimate"
Parameter
BSFC
C02
PM
NOX
THC
CO
Value A*,
Ib/Bhp-hr
0.412
592
0.072
3.970
0.174
1.020
c « c
Vl,A> sn-l,B
Ib/Bhp-hr
0.005
7.000
0.002
0.060
0.035
0.060
COVA,
%
0.7
0.8
2.2
1.2
7.3
2.5
Value B*
Ib/Bhp-hr
0.330
473
0.058
3.176
0.139
0.816
COVB,
%
0.9
1.0
2.8
1.4
9.1
3.1
nEqn. 2
0.02
0.03
0.21
0.06
2.52
0.26
^rounded
3
3
3
3
3d
3d
"Assumes 20-percent improvement for each parameter
*Value A is the mean for the as-received engine; Value B is the mean for the UC-modified engine.
csn-i is sample standard deviation. The table assumes the same absolute sample standard deviation for the
as-received and UC-modified engine.
dTHC and CO are not a primary focus of this verification.
The primary verification parameters are BSFC (as derived from CO2), NOX, and PM.  The tests will
include THC and CO, but no DQOs will apply because they are not the primary focus of this verification.
These emissions tend to be much lower than any applicable standards, and their higher measurement
variability (because of low absolute values) lead to large A determination errors.

3.2.2    Confidence Intervals and DQOs

Fuel consumption improvement or pollutant reductions will be expressed as the mean  A between the
baseline and modified engine combined with an accuracy statement.  The accuracy statement will be the
95-percent confidence interval, expressed in relative terms.  An example would be "BSFC mean A was 20
± 2.9 percent."   The confidence interval  depends on the  sample standard deviation  (sn-i) for each
parameter as found during the tests. The mean A for each parameter must be greater than sn-i [Lubricant
TP, Section 2.3].  If it is not, the 95-percent confidence interval is wider than the change itself, and it
cannot be deemed statistically significant [Lubricant TP, Section 2.2, 2.4].

This implies  that  sn-i could  serve as  each parameter's DQO  because it  is directly related  to the
determinations' overall accuracy. More generally, the  COV (a normalized expression of sn_i) will be the
DQO.  The COVs for the historical SwRI  data set for similar diesel engine retrofit technology  engine
dynamometer tests  provide the DQO goals for this  test.   Based on  this historical data and  testing
similarities, the DQOs, stated as COVs, should be achievable for the UC test if the test personnel  adhere
to the test procedures and methods specified in this TQAP.  Table 3-2  summarizes each DQO.   It also
shows the smallest quantifiable mean  A based on the COV for the historical data set, for which the UC
test should be similar.
                                              20

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Table 3-2. Data Quality Objectives
Parameter
BSFC
C02
PM
NOX
Expected
Baseline Value,
Ib/Bhp-hr
0.412
592
0.072
3.970
Sn-l,
g/Bhp-hr
0.003
4.961
0.002
0.046
cov, %,
DQO
0.7
0.8
2.2
1.2
95%-Confidence Interval
(Smallest Quantifiable
Mean A), Ib/Bhp-hr
+ 0.007
+ 11.2
+ 0.004
+ 0.104
Smallest Quantifiable
Mean A, % (relative to
baseline)
+ 1.6
+ 1.9
+ 5.0
+ 2.7
As an example, the BSFC shown in Table 3-2 indicates that the baseline engine is expected to use about
0.412 Ib/Bhp-hr of fuel, based on historical data. Testers can expect the sample standard deviation for the
baseline BSFC to be ± 0.003 Ib/Bhp-hr, or a 0.7 percent COV.  Completion of three test runs yielding this
or a lower COV would meet the specified DQO for BSFC. The 95% confidence interval corresponding to
the standard deviation and COV for the baseline BSFC data set is ± 0.007 Ib/Bhp-hr.  To be statistically
significant, the mean A  must be greater than the 95%  confidence interval  of either the  baseline  or
candidate data sets (assumed to be indentical in this case). Therefore, the smallest statistically significant
quantifiable mean A is equivalent to the 95% confidence interval.  This is ± 1.6 percent of the expected
baseline BSFC value.

3.2.3    Additional DQO Information

SwRI's historical data are based on twenty test runs. This test campaign will use three  and it is possible
that the observed COVs may be greater than the DQO goals listed in  Table 3-2.  This situation would
result in the field team leader, GHG Center project manager, UC personnel, and other funding agencies
possibly  opting to  conduct more  test runs  to  better  characterize  the  COVs  and  the  technology
performance.

It is also possible that the mean A for any parameter could be less than the standard deviation for either
data set, even though the tests meet the DQOs for the associated  COVs. The report will, therefore, note
that the mean A is not statistically significant.
                                               21

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                    4.0     SAMPLING AND ANALYTICAL PROCEDURES


The sampling  system is comprised primarily of the exhaust sampling system  to  which  continuous
measurement devices and particulate filters are attached.


4.1   EXHAUST GAS SAMPLING SYSTEM


The exhaust gas sampling system conforms to 40 CFR 86.1310 and 89.308, respectively. The  system that
will be used at SwRI is depicted in Figure 4-1.
                              Optional for
                              Paniculate
                           Background Reading
                              Zero Air
                                LJ
                                         HC Span Gas
                                                              Integrator
                           Counters
                                   ¥
                   Read Background Bag
                           Dillution Tunnel
                              Heated Probe
                           Particulate Probe
                           Mixing Orifice
Heat Exchanger
   LEGEND
-£>l<3- Flow Control Valve

Wfel Selection Valve

F^ Particulate Filter

-f»4- Pump

 \p/  Flowmeter

 ("^  Pressure Gauge

I  R  I Recorder

 C*J  Temperature Sensor
                      Vehicle Exhaust Inlet
Primary Filter (Phase 1 and 3)
Back-up Filter (Phase 1 and

Note: Three filter holders
    (one for each phase)
    are also acceptable.
          or
                                                                                rib Formaldehyde
                                                                                Sample Collection
  Supply Air

Primary Filter (Phase 2)
 Back-up Filter(Phase 2)
  ,To Pump Bolometer
    and Gas Meter
     as Diagramed
     Immediately
       Below
                                                        Gas\ Discharge
                                                       .Meterj
                              *• To Methanol Sample
                                Collection
                                                                                  Manometer
                                                                                    Revolution Counter
                                                                                        Pick Up

                                                                                  Manometer

                                                                                 Discharge
   Fisure 4-1. Gaseous and Particular Emissions Sampling System (PDP-CVS) fSwRIl
4.2   EXHAUST GAS MEASUREMENT SYSTEM SPECIFICATIONS


The exhaust gas measurement system conforms to 40 CFR 86.1310 and 40 CFR 89.309. Table 4-2 lists
the major equipment to be used during the test campaign, expected values, and instrument spans.  Typical
manufacturers and model numbers are listed for reference only.
                                                22

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Table 4-2. Exhaust Gas Measurement System Specifications
Parameter or
Subsystem
Dynamometer
speed
Dynamometer
load
CVS pressure
CVS
temperature
CVS
volumetric
flow rate
CO
C02
CH4
NOX
THC
PM
Expected
Operating
Range
0-2100RPM
0 - 368 hp,
0 - 1350 Ib.ft
950-1050
millibar
0 to 191 °C
2000 ftj / min
(nominal)
0 - 300 ppmv
0 - 10000
ppmv
0 - 10 ppmv
0-100 ppm
0 - 300 ppmv
0-100 ppmv
0- 5mg
Manufacturer,
Model / Operating
Principle
Varies with test cell
Varies with test cell
SwRI-built constant
volume sampler
HoribaOPE-135/
NDIR
HoribaOPE-135/
NDIR
GC/FID
Rosemount 955 /
Chemiluminescence
Rosemount 402 /
HFID
Gravimetric
Span
Varies with
test cell up to
6000 RPM
Varies; up to
600 hp, 2600
Ib.ft
0 - 1500
millibar
0 - 200 °C
1 800-2200 fir"
/ min; Varies
with test cell
0-100 ppmv
100 ppm
0 - 10000
ppmv
10 ppmv
100 ppmv
0 - 300 ppmv
0-100 ppmv
0 - 1000 mg
Measurement
Frequency
10 Hz (10/s)
10 Hz (10/s)
10 Hz (10/s)
1 analysis per
bag, 2 bags (1
dilute exhaust,
1 ambient air)
per each cold-
start. Similar
set of 2 bags
for each hot-
start
10 Hz (10/s)
(Note: online
gas analysis
through
sampling
probe)
1 per each
cold- and hot-
start
4.3   FILTER WEIGHING

Participate filters are stored, conditioned, and weighed in a dedicated facility which conforms to 40 CFR
86.1312. The chamber in which the participate filters are conditioned and weighed conforms to 40 CFR
86.112 without deviation.

4.4   GASEOUS ANALYZERS

Gaseous analyzers  conform to §86.309, §86.1311, and §89,  Subpart  D, App B, Figure 1 without
deviation. Their operation is specified in SwRI SOP# 07-009, which conforms to required elements B4
(Analytical  Methods), B5 (Quality Control), and B6  (Instrument/Equipment Testing, Inspection, and
Maintenance) of EPA QA/R-5.
                                             23

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                       5.0    SAMPLE HANDLING AND CUSTODY

Only participate matter (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.

The PM filters are prepared and processed according to SwRI SOP# 07-020 which specifies a method of
conditioning and weighing filters used to collect particulate samples during exhaust emission testing. This
SwRI SOP conforms to required element B3 (Sample Handling and Custody) of EPA QA/R-5.

Samples are handled  according to  SwRI SOP 07-023.  This  SOP conforms to required element B3
(Sample Handling and Custody) of EPA QA/R-5.
                                            24

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            6.0    DATA QUALITY INDICATOR GOALS AND QA/QC CHECKS
Test measurements that contribute to a verification parameter's determination have specific data quality
indicator goals (DQIGs) that, if met, imply achievement of the  parameter's DQOs.  For this test,
completion of the QA/QC checks and achievement of the DQI goals ensures that the specified test
methods have been completed in accordance with the TQAP and CFRtest method requirements.  Based
on historical data, when testing is properly completed, the specified DQOs should be achievable.

Table 6-1 lists the individual analyzer and system DQIGs in terms of accuracy. A variety of calibrations,
QA/QC checks, and other procedures ensure the achievement of each DQIG. The table summarizes those
QA/QC checks for each of the major test systems.
TABLE 6-1. Data Quality Indicator Goals and QA/QC Checks
System or Parameter
Dynamometer
CVS System
Speed
Load
(torque
sensor)
Pressure
Temperature
Volumetric
flow rate
DataC
Accuracy
+ 2.0%
+0.5%
+ 2.0% of
reading
+ 2.0% of
reading
+ 0.5 % of
reading
Juality Indicator Goal
How
Verified
60-tooth
wheel
combined
with
frequency
counter
NIST-
traceable
weights and
torque arm
Calibration
of sensors
with NIST-
traceable
standard
Calibration
of sensors
with NIST-
traceable
standard
CVS and
propane
critical
orifice
calibration
Frequency
At initial
installation
or after
major
repairs
Weekly
At initial
installation
or after
major
repairs
At initial
installation
or after
major
repairs
At initial
installation
or after
major
repairs
QA/QC Check
Description
Inspect
calibration
certificate
Inspect
calibration
certificate
Torque trace
acceptance
test
Inspect
calibration
certificates
Inspect
calibration
certificates
Inspect
calibration
data
Propane
composition
verification
via analysis
with FID
Frequency
Prior to test
Prior to test
and after
new
calibration
Each test
run
Prior to test
Prior to test
Prior to test
Prior to
placing new
propane
tank in
service
Allowable
Result
Current
calibration
meeting DQI
goal
Current
calibration
meeting DQI
goal
+ 2.5 Ib.ft Re-
values < 550
lb.fl,
+ 5.0 Ib.ft for
values < 1050
Ib.ft,
+ 10 Ib.ft for
values < 1550
Ib.ft
Current
calibration
meeting DQI
goal
Current
calibration
meeting DQI
goal
Current
calibration
meeting DQI
goal
< 0.35 %
difference from
previously used
and verified
tank
                                            25

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TABLE 6-1. Data Quality Indicator Goals and QA/QC Checks
System or ]
Instrumental
Analyzers
'arameter
CO
CO2
NOX
THC
DataC
Accuracy

+ 1.0%FS
or + 2.0%
for each
calibration
gas
luality Indicator Goal
How
Verified

11-point
calibration
(including
zero) with
gas divider;
protocol
calibration
gases
Frequency

Monthly
QA/QC Check
Description
Propane
injection
check
Sample bag
leak check
Flow rate
verification
Dilution air
temperature
Review and
verify
analyzer
calibration
Gas divider
linearity
verification
Calibration
gas
certification
or naming
Zero gas
verification
Analyzer zero
and span
Analyzer drift
Frequency
Weekly
Before each
test run
Before each
test run
During each
test run
Once during
test and
upon
completion
of new
calibration
monthly
Prior to
service
Prior to
service
Before and
after each
test run
For each
bag analysis
Allowable
Result
Difference
between
injected and
recovered
propane < +2.0
%
Maintain 10"
Hg for 10
seconds
< + 5 cfm of
nominal test
point
Between 20
and 30 °C
Current
calibration
meeting DQI
goal
All points
within + 2.0%
of linear fit; FS
within + 0.5 %
of known value
Average
concentration
of three
readings must
be within + 1 %
for calibration
gas and NIST-
traceable
reference
material
HC < 1 ppmv
CO < 1 ppmv
CO2 < 400
ppmv
NOX<0.1
ppmv
O2 between 18
and 21%
All values
within + 2.0%
of point of +
1.0%ofFS;
zero point
within + 0.2 %
ofFS
Post-test zero
or span drift
shall not
exceed +2.0%
FS
26

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TABLE 6-1. Data Quality Indicator Goals and QA/QC Checks
System or ]
'arameter
Particulate Matter Analysis
Supplementary instruments and
additional QA/QC checks
DataC
Accuracy

+ 1.0ug
luality Indicator Goal
How
Verified

NIST-
traceable
scale
calibration,
weighing
room
controls,
filter weight
control
Frequency

Daily

QA/QC Check
Description
Frequency
Allowable
Result
CO Analyzer Only
Wet CO2
interference
check
Monthly
CO (0 to 300
ppmv)
interference < 3
ppmv;
CO (> 300
ppmv)
interference < 1
%FS
NOX Analyzer Only
CO2 Quench
Check
Converter
Efficiency
Check
NIST-
traceable
calibration
weight cross-
check
Weight room
temperature
Weight room
relative
humidity
Reference
filter weight
change
Test cell
Wet/dry bulb
thermometer
calibration
Test cell
Barometer
calibration
Test cell
temperature
Test fuel
analysis
Annually
Monthly
Daily
Daily
Daily
Daily
Monthly
Weekly
Each test
run
Prior to
testing
NOX quench <
3.0 %
Converter
Efficiency
>90%
Weight change
<10ug
Between 19
and 25 °C
Between 35
and 53% RH
Weight change
<20ug
Within + 1.0°F
NIST-traceable
standard
Within + 0.1"
Hg of NIST-
traceable
standard
Between 68
and 86 °F
Conforms to 40
CFR§86.1313
specifications
(See Appendix
A-2)
27

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                  7.0     INSTRUMENT CALIBRATION AND FREQUENCY

The calibration schedule for major instruments is included with other QC activities in Table 6-1 above. 40
CFR  86.1316-86.1326  completely  specifies  the methods,  frequency,  and  requirements  of these
calibrations. Specific instruments and the applicable SOPs for implementation are described below. The
general reference is QPP 05 - Measurement and Test Equipment. Records of all calibration activities are
retained at SwRI and will be inspected by the GHG Field Team Leader and/or QA Manager.
                                              28

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                     8.0    DATA ACQUISITION AND MANAGEMENT

This section describes the generation and processing of test data at SwRI and the flow and disposition of
these data from origin to the GHG Center reporting and archiving.  Data acquisition and data management
at SwRI are performed according to QPP  08 -  Data Processing and Reduction, which conforms to
required element  BIO  (Data  Management)  of EPA  QA/R-5. The planned  data streams, with
responsibilities of the project manager and QA Manager, are depicted in Figure 8-1. The project manager
is operationally responsible  for all aspects of a test. The QA Manager is operationally responsible for all
data quality aspects of a test with primary, 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 89.405, are manually
recorded on the data sheets  specified in SwRI #SOP 07-003. Operating and emissions data are captured
by the data system described schematically in Figure 8-1.

SwRI will  submit copies of initial raw and intermediate data  at the  end of each test sequence (setup,
baseline, control) and attest completion. These data include:

    •   documents describing the engine, inspection, and setup activities;
    •   tracking forms for daily test activities and QC check results;
    •   external documents  such as test fuel lot analyses and NIST-traceable calibration gas certificates;
    •   test cell data system printouts showing run summary instrument results for test cell system (dyno,
        CVS, direct and bag cart analysis instruments, etc.); and
    •   QC check summary printouts (zero, span drift, etc.).
SwRI will prepare and submit a letter report in printed and electronic (Microsoft Word) format to the
GHG Center after completion  of the field activities.  The report will describe the test conditions,
document all QA/QC procedures, summarize intermediate data, and present the verification test results.
The SwRI QAO will also submit a QA report documenting the internal data assessment activities of the
test as described in Section 9 below.

The GHG Center Project Manager will incorporate the SwRI material into the final VR and VS and
submit for review according to the GHG Center QMP and ETV Program guidance documents. The GHG
Center QA Manager will incorporate the SwRI QA material into the GHG Center's internal assessment
documentation  for the  test, along with assessment activities of the  Center.   These  will include the
supplemental TSA, performance audit, and ADQ described in Section 14.
                                              29

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Test Manager: Test Oversight and Data Production

QA Officer: Quality System and Data Integrity 1

Engine
Information from —
Manufacturer

Pre-test Filter
Weights """"

Post-test Filter
Weights *******
\



' 1
Assemble
Data
t
Calculations
& Data
Analysis

Technology
— Information from
Supplier

_ Test Cell I
""" Instrument Data 1

_ QC Data |
r

T
QA Review 1
j
Report


NOTE: 1
QAO role focused on indicated areas with regular review of other data sources 1
Figure 8-1. ETV Data Management System
                                       30

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                        9.0    INTERNAL AND EXTERNAL AUDITS

Several assessments are specified for this verification in accordance with the GHG Center QMP and the
ETV Program QMP.

9.1   TECHNICAL SYSTEMS AUDIT

The GHG Center staff has previously conducted a quality and technical systems audits (TSA) of the SwRI
DEER on an earlier related ETV test involving fuel economy and emissions performance on a light-duty
vehicles.  That TSA addressed major test components including documentation and adherence to standard
procedures  for testing, instrument calibration and QC checks, data processing, audits, and reporting. It
also included review of some of the documentation of elements of the SwRI/DEER quality system. In
view of the positive findings of that TSA and the similarity between the  previous verification and the
upcoming test, a second TSA on this technology class is not proposed for the upcoming test.

A tracking checklist of calibrations and QC activities was used as part of the TSA on the previous project.
A version of that checklist will be adapted to the experimental details of the upcoming test.  The field
team leader will verify during the test that the equipment, SOPs, and calibrations are  as described in this
TQAP. The field team leader will complete the items on this checklist during his observation of the test
and return the form to the GHG Center QA manager as part of the QC  documentation of the test. He will
incorporate this material into the ADQ described below.

9.2   PERFORMANCE EVALUATION AUDITS

The GHG  Center specifies  internal  Performance Evaluation Audits  (PEAs), as applicable, on critical
measurements  of every verification test.  The Center will use  the SwRI quality infrastructure for an
internal PEA for this test.   SwRI  maintains a set  of NIST-certified gas standard mixtures in the
concentration ranges applicable to these measurements. The monthly calibration procedure requires that
the DEER challenge the analytical instruments with these standards as a performance check independent
of the calibration gas standards. The GHG Center will use this internal check in lieu of a blind PEA. The
standard mixture challenge from that time will be used as a PEA if a monthly analyzer calibration under
SOP 6-012  has been performed within a week of testing on the test cell used for this study. A separate
challenge, according to the applicable portion of the SOP, will otherwise be conducted during the period
of the test.

9.3   AUDIT OF DATA QUALITY

The GHG Center QA Manager will oversee an audit of data quality (ADQ)  of at least 10 percent of all of
the verification data in accordance  with Table 9-1 of the ETV QMP. The ADQ will be conducted in
accordance  with EPA's [Guidance on Technical Audits and Related Assessments for Environmental Data
Operations}.   The ADQ will include (1)  verification of input data  and  outputs reported by test cell
instrumentation, (2) checks of intermediate calculations, and (3) a review  of study statistics.  The ADQ
will also draw  conclusions about the quality of the data from the  project and their fitness for their
intended use. Effort on this audit will be assigned as follows. The SwRI QAO, in this case, will conduct
an internal  ADQ of results generated by  SwRI covering the areas described above and submit the audit
report to the GHG Center QA Manager. The GHG Center QA Manager will review and incorporate this
into an overall ADQ report, including documentation of subcontractor oversight and review of the final
processing and reporting of the results.
                                              31

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9.4   EXTERNAL ASSESSMENTS

SwRI and GHG Center staff will cooperate with any external assessments by EPA. EPA personnel may
conduct optional assessments (TSA, PEA, or ADQ) during this or any subsequent test. The external
assessments will be conducted as described in EPA QA/G-7.

9.5   INTERNAL ASSESSMENTS

Internal assessment reports will be reviewed by the SwRI QAO and GHG Center QA Manager and they
will respond as noted in Section 11.  The written report of the ADQ will be reviewed by the GHG Center
QA Manager and incorporated into or submitted as separate addenda to the VR.
                                           32

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                               10.0   CORRECTIVE ACTION

A corrective action must occur when the result of an audit or quality control measurement is shown to be
unsatisfactory as defined by the DQOs or by the measurement objectives for each task. The corrective
action process involves the GHG Center project and QA staff as well as subcontractor personnel. A
written corrective action request (CAR)  is required on major corrective actions that deviate from the
TQAP. Corrective action is performed at SwRI according to QPP 11  - Nonconformance and Corrective
Action, which conforms to required elements B5 (Quality Control) and Cl (Assessments and Response
Actions)  of EPA QA/R-5.   Situations requiring corrective action will be communicated to the  GHG
Center field team leader who will, under direction of the GHG Center project manager, assess the incident
and take and document appropriate action on behalf of the center. The project manager is responsible for
and is authorized to halt work if it is determined that a serious problem exists.

           11.0    DATA REDUCTION, REVIEW, VALIDATION, AND REPORTING

The field team leader's primary on-site function will be to monitor SwRI's activities. He will be able to
review, verify, and validate certain data  (test cell file data, QA/QC  check results) during  testing. The
GHG Center project manager will incorporate the SwRI material into the final VR and VS and submit this
information for review according to the GHG Center QMP and ETV program guidance documents. The
GHG Center QA Manager will incorporate the SwRI  QA material into the GHG Center's internal
assessment documentation  for the test along with assessment activities of the Center. These will include
the performance audit and ADQ described in Section 9.0.

                   12.0    REPORTING OF DATA QUALITY INDICATORS

The  SwRI  staff will collect and tabulate the DQIG values specified in Table 6-1 as part of the data
processing steps described above.  These will be reviewed both internally and by the GHG Center project
manager  and QA Manager in  the preparation of their VR and assessment reports. These reports, as
specified in the GHG Center QMP,  are submitted to both the EPA project officer and QA Manager.

                              13.0   DEVIATIONS FROM GVP

The technical aspects of this plan were constructed to be consistent with the technical requirements and
philosophy of the GVP.  The only planned deviation from the GVP is the omission of the durability test
with an aged technology. No other deviations from the GVP or this document are anticipated. Should this
phase of testing be successful, a second phase of testing is planned that will address durability testing. If
any such deviations are identified in the course of  implementing this test, SwRI staff will consult with
GHG Center staff as soon  as possible to resolve the issues.  Section 2.7 of EPA/QA R-5 states that the
EPA will be notified of any significant deviations and the  QAO will revise this document and submit it to
EPA for review and approval.
                                              33

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                      14.0    REFERENCED QUALITY DOCUMENTS
14.1  EPA-ETV

EPA QA/R-5



EPA ETV QMP
EPA QA/G-5
EPA QA/G-7
GVP
EPA Requirements for Quality Assurance Project Plans, EPA QA/R-5, Office of
Environmental Information, U.S. Environmental Protection Agency, EPA/240/B-
01/003, March 2001.

Environmental Technology Verification Program Quality and Management Plan
for  the Pilot  Period  (1995-2000),  National  Risk  Management  Research
Laboratory, National Exposure Research Laboratory, Office of Research and
Development, U.S. Environmental Protection Agency, EPA/600/R-98/064, May
1998 (or current version).

Guidance  on Quality  Assurance  Project  Plans,  EPA QA/G-5, Office  of
Environmental Information, U.S. Environmental Protection Agency, EPA/600/R-
98/018, February 1998.

Guidance on Technical Audits and Related Assessments, EPA QA/G-7, Office of
Environmental Information, U.S. Environmental Protection Agency, EPA/600/R-
99/080, January 2000.

Generic Verification Protocol for Diesel Exhaust Catalysts, Particulate Filters,
and Engine Modification Control Technologies for Highway and Nonroad Use
Diesel  Engines  (Draft), EPA  Cooperative  Agreement No.  CR826152-01-3,
January 2002.
14.2  GHGTC
GHGTC QMP
SRI/USEPA-GHG-
QAP-28
Greenhouse Gas Technology  Center Quality  Management Plan, Version 1.4,
March, 2003.

Test and Quality Assurance Plan—ConocoPhillips Fuel-Efficient
High-Performance  SAE 75W90 Rear Axle Gear Lubricant, SRI/USEPA-GHG-
QAP-28, March 2003.
14.3  SOUTHWEST RESEARCH INSTITUTE
SwRI QAPP
QSM
QPP-03
QPP-05
Test/QA  Plan for the Verification  Testing  of Diesel Exhaust  Catalysts,
Particulate Filters, and Engine Modification Control Technologies for Highway
and Nonroad Use Diesel Engines (Version 1.0 April 8, 2002).

Quality Policy and Procedures (QPPs)

Quality System Manual - 2000, April 2001
Document Preparation and Control
Measurement and Test Equipment

                       34

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QPP-07               Testing and Sample Analysis
QPP-07-003           Transient Test for Heavy-Duty Diesel Engines
QPP-08               Data Processing and Reduction
QPP-09               Analysis and Reporting
QPP-10               Training and Motivation
QPP-11               Nonconformance and Corrective Actions
QPP-12               Internal Audits
QPP-14               Quality Records

                     Standard Operating Procedures (SOPs)

SOP-06-003           Linearity Verification of Gas Dividers
SOP-06-002           NOX Converter Efficiency Determination
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-06-025           NOX Analyzer and System Response  Checks
SOP-06-041           NOx Analyzer CO2 Quench Check
SOP-06-044           Hydrocarbon Analyzer Optimization
SOP-07-001           Power Validation for Heavy-Duty Diesel Engines
SOP-07-002           Power Mapping for Heavy-Duty Diesel Engines
SOP-07-009           Emissions Testing During Heavy-Duty Diesel Engine Transient Cycle
SOP-07-020           Particulate Filter Conditioning and Weighing
SOP-07-023           Operation of Bag Cart
SOP-12-001           Quality Audits
                                            35

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Appendix A

-------
                        Appendix A-l. Test Results Summary and DQO Checks

    •   Complete after each hot start test run is complete.
    •   After the third hot start test (and any additional tests), calculate the mean, sample standard deviation, and coefficient of
        variation (COV) for each parameter. COV is the sample standard deviation divided by the mean, as a percentage.
    •   Verify that the Data Quality Objectives (DQOs) are met for each parameter.
    •   Signature:	
                                Table A-la:   Baseline Test Results & DQO Check
The value is the weighted value of the single cold start FTP test with the hot start FTP test for each run. See the TQAP for detailed calculations.
                               Table A-lb:   Candidate Test Results & DQO Check
                            Reported Value,
                                g/Bhp-hr*
                                                      A-l

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Audit Date:

Fuel Lot ID:
                              Appendix A-2. Test Fuel Verification

               Obtain a copy of the test fuel lot analysis.
               Review all analysis results and test method documentation.
               Properties and test  methods  must conform to the specifications given in the
               following table.
Signature:
       Date Received:
Table A-2. Test Fuel Specifications
Description
Cetane Number
Cetane Index
Distillation Range:
IBP
10 % point
50 % point
90 % point
Endpoint
Sulfur
Viscosity
Flashpoint
Hydrocarbons:
Olefms
Aromatics
Specific Gravity
ASTM Test
Method No.
D613
D976
D86
D2622
D445
D93
D1319
D5186
D287
Specified
Value
40-50
40-50
340 - 400 °F
400 - 460 °F
470 - 540 °F
560 - 630 °F
610- 690 °F
0.03 - 0.05 %
2.0-3.2
130 °F min.
Balance
27%
32-37 °API
Analysis
Value








Mfg. Certified
Value








Meets
Spec.?








Notes:
                                              A-2

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                                      Appendix A-3
                                     QA/QC Checks
Signature:
Table A3-1: QA/QC Checks
QA/QC
Check
Description
Frequency
Allowable Result
Date Check
Completed
(SwRI)
Date Audit
Completed
(GHG
Center)
OK?
Audit Data
Source
Dynamometer
Dynamometer
Calibration
Certificates
Review
Torque trace
acceptance
test
Prior to
test
Each test
run
Sensor accuracies (speed and load)
meet Table 6-1 specifications
+ 2.5 Ib.ft for values < 550 Ib.ft,
+ 5.0 Ib.ft for values < 1050 Ib.ft,
+ 10 Ib.ft for values < 1550 Ib.ft








CVS System
CVS System
Calibration
Certificates
Review
Propane tank
composition
verification
Propane
injection
check
Sample bag
leak check
Flow rate
verification
Dilution air
temperature
verification
Prior to
test
Prior to
placing
new
propane
tank in
service
Weekly
Before
each test
run
Before
each test
run
During
each test
run
Sensor accuracies (P, T, Q) meet
Table 6-1 specifications
< 0.35 % difference from
previously used and verified tank
Difference between injected and
recovered propane < + 2.0 %
Maintain 10" Hg for 10 seconds
< + 5 cfrn of nominal test point
Between 20 and 30 °C
























Emission Analyzers
Analyzer
calibrations
review
Gas divider
linearity
verification
Calibration
gas
certification or
naming
Once
during test
and upon
completion
of new
calibration
monthly
Prior to
service
All values within + 2.0 % of point
of +1.0% of FS;
All points within + 2.0 % of linear
fit; FS within + 0.5 % of known
value
Average concentration of three
readings must be within + 1 % for
calibration gas and NIST-traceable
reference material












                                          A-3

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Table A3-1: QA/QC Checks
QA/QC
Check
Description
Zero gas
verification
Analyzer zero
and span
Analyzer drift
Wet CO2
interference
check
CO2 Quench
Check
Converter
Efficiency
Check
Frequency
Prior to
service
Before and
after each
test run
For each
bag
analysis
Monthly
Annually
Monthly
Allowable Result
HC < 1 ppmv
CO < 1 ppmv
CO2 < 400 ppmv
NOX < 0. 1 ppmv
O2 between 18 and 21%
All values within + 2.0 % of point
of + 1.0 % of FS; zero point
within + 0.2% of FS
Post-test zero or span drift shall
not exceed + 2.0 % FS
CO (0 to 300 ppmv) interference <
3 ppmv;
CO (> 300 ppmv) interference < 1
%FS
NOX quench < 3.0%
Converter Efficiency >90 %
Date Check
Completed
(SwRI)






Date Audit
Completed
(GHG
Center)






OK?






Audit Data
Source






Particulate Measurement
NIST-
traceable
calibration
weight cross-
check
Weight room
temperature
Weight room
relative
humidity
Reference
filter weight
change
Daily
Daily
Daily
Daily
Weight change < 10 ug
Between 19 and 25 °C
Between 35 and 53 %RH
Weight change < 20 ug
















Ambient Monitoring
Test cell
Wet/dry bulb
thermometer
calibration
Test cell
Barometer
calibration
Test cell
temperature

Monthly
Weekly
Each test
run

+ 1.0 °F NIST-traceable standard
Within + 0.1" Hg of NIST-
traceable standard
Between 68 and 86 °F

















A-4

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                                        Appendix A-4
                          Evaluation of Maximum Fuel Consumption

       Measure  fuel  consumption at maximum power (rated  conditions)  and at peak  torque  at
       intermediate speed.
       Complete for both the baseline and modified engine after completion of the FTP cycle tests.
       Measure fuel consumption during  each of three five-minute steady-state tests with the  engine
       operating at the specified conditions, based on the engine map.
       Alternate between the two conditions during the testing.  Monitor fuel consumption at maximum
       power at rated speed for five minutes, then peak torque at intermediate speed for five minutes.
       Use carbon balance or direct-fuel measurements for calculation of modal BSFC (see 40 CFR 86
       Subpart N for both calculations), depending on available equipment.
Signature:
Date:
                            D  Baseline engine

                            D  Modified engine
           Date
Test ID No.
 Operating
Conditions3
 Brake Specific Fuel
Consumption (BSFC)
     (g/BHP-hr)
                    la
                      MP
                    Ib
                      PT
                    2a
                      MP
                    2b
                      PT
                    3a
                      MP
                    Mean
                    Std. Deviation
                    Mean
                    Std. Deviation
                                            PT
                      MP
                      MP
                      PT
                      PT
               Indicate maximum power (MP) or peak torque (PT)
NOTES:
                                            A-5

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                         Appendix A-5.  Corrective Action Report
Verification Title:
Verification Description:

Description of Problem:_
              Originator:	              Date:
Investigation and Results:,
Corrective Action Taken:
              Investigator:	              Date:
              Originator:	              Date:
              Approver:	              Date:
        Carbon copy: GHG Center Project Manager, GHG Center Director, SRI QA Manager, APPCD Project Officer
                                             A-6

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Appendix B

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