Environmental Technology Verification
Report
Mobile Source Retrofit Air Pollution Control
Devices
Clean Clear Fuel Technologies, Inc.'s, Universal Fuel Cell
Prepared by
Southwest Research Institute RTI International
HRTI
INTERNATIONAL
Under a Cooperative Agreement with
U.S. Environmental Protection Agency
c/EPA
EW EW ET
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Environmental Technology Verification
Report
Mobile Source Retrofit Air Pollution Control
Devices
Clean Clear Fuel Technologies, Inc.'s,
Universal Fuel Cell
Prepared by
RTI International
Southwest Research Institute
EPA Cooperative Agreement No. CR829434-01-1
EPA Project Manager:
Mike Kosusko
Air Pollution and Control Division
National Risk Management Research Laboratory
Office of Research and Development
Research Triangle Park, NC 27711
February 2005
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Notice
This document was prepared by RTI International (RTI)* and its subcontractor Southwest
Research Institute (SwRI), with partial funding from Cooperative Agreement No. CR829434-01-
1 with the U.S. Environmental Protection Agency (EPA). The document has been submitted to
RTI/EPA's peer and administrative reviews and has been approved for publication. Mention of
corporation names, trade names, or commercial products does not constitute endorsement or
recommendation for use of specific products.
* RTI International is a trade name of Research Triangle Institute.
ii
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Foreword
The Environmental Technology Verification (ETV) Program, established by the U.S.
Environmental Protection Agency (EPA), is designed to accelerate the development and
commercialization of new or improved technologies through third-party verification and
reporting of performance. The goal of the ETV Program is to verify the performance of
commercially ready environmental technologies through the evaluation of objective and quality-
assured data so that potential purchasers and permitters are provided with an independent and
credible assessment of the technology that they are buying or permitting.
The Air Pollution Control Technology (APCT) Center is part of EPA's ETV Program and is
operated as a partnership between RTI International (RTI) and EPA. The Center verifies the
performance of commercially ready air pollution control technologies. Verification tests use
approved protocols, and verified performance is reported in verification statements signed by
EPA. RTI contracts with Southwest Research Institute (SwRI) to perform verification tests on
engine emission control technologies.
Retrofit air pollution control devices used to control emissions from mobile diesel engines are
among the technologies evaluated by the APCT Center. The Center developed (and EPA
approved) the Generic Verification Protocol for Diesel Exhaust Catalysts, Particulate Filters,
and Engine Modification Control Technologies for Highway andNonroad Use Diesel Engines to
provide guidance on the verification testing of specific products that are designed to control
emissions from diesel engines.
The following report reviews the performance of Clean Clear Fuel Technologies, Inc.'s,
Universal Fuel Cell, Model CCFT21061. ETV testing of this technology was conducted during
November 2003 at SwRI. All testing was performed in accordance with an approved test/quality
assurance plan that implements the requirements of the generic verification protocol at the test
laboratory.
in
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Availability of Report
Copies of this verification report are available from:
• RTI International
Engineering and Technology Unit
P.O. Box 12194
Research Triangle Park, NC 27709-2194
• U.S. Environmental Protection Agency
Air Pollution Prevention and Control Division (E343-02)
109 T. W. Alexander Drive
Research Triangle Park, NC 27711
Web sites: http://www.epa.gov/etv/verifications/verification-index.html (electronic copy)
http://www.epa.gov/ncepihom/
IV
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Table of Contents
Notice ii
Foreword iii
Availability of Report iv
List of Figures vi
List of Tables vi
Acronyms/Abbreviations vii
Acknowledgments viii
Section 1.0 Introduction 1
Section 2.0 Description of Products 2
Section 3.0 Test Documentation 4
3.1 Engine Description 4
3.2 Engine Fuel Description 4
3.3 Summary of Emissions Measurement Procedures 5
3.4 Deviations from the Test/QAPlan 6
3.5 Documented Test Conditions 7
Section 4.0 Summary and Discussion of Emission Results 9
4.1 Emissions Test Data 9
4.2 Quality Assurance 11
Section 5.0 References 12
Appendix A Vendor Comments A-l
v
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List of Figures
Figure Page
1. Mounting location of aged Universal Fuel Cell, Model 21061, Serial Number 0642,
in Test Cell 8 3
2. Constant volume sampler setup for emissions measurement 6
List of Tables
Table Page
1. Engine Identification Information 4
2. Selected Fuel Properties and Specifications 5
3. Engine Performance Data 7
4. Magnetic Flux Density Measurements 8
5. Brake Specific Fuel Consumption 8
6. Emissions Test Data 9
7. Composite Weighted Emissions Values (English units) 10
8. Composite Weighted Emissions Values (metric units) 10
9. Summary of Verification Test Emission Values 11
10. Summary of Verification Test Emission Reductions \ \
VI
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Acronyms/Abbreviations
o
F degrees Fahrenheit
°C degrees Celsius
APCT Air Pollution Control Technology
ASTM American Society for Testing and Materials
bhp brake horsepower
bhp-h brake horsepower hour
BSFC brake specific fuel consumption
CCFT Clean Clear Fuel Technologies, Inc.
CFR Code of Federal Regulations
CO carbon monoxide
CO2 carbon dioxide
DDC Detroit Diesel Corporation
EPA U.S. Environmental Protection Agency
ETV Environmental Technology Verification
FTP Federal Test Procedure
ft foot (feet)
g gram(s)
HC hydrocarbon(s)
HD heavy duty
Hg mercury
kW kilowatt(s)
kWh kilowatt hour(s)
kPa kilopascal(s)
Ib pound(s)
Ibf/ft pound force foot (feet)
LSD low-sulfur diesel
mm millimeter(s)
N newton(s)
N*m newton-meter
NOX nitrogen oxide(s)
OTAQ Office of Transportation and Air Quality
Pa pascal(s)
PDF Positive Displacement Pump
PM particulate matter
ppm parts per million by volume
QA quality assurance
QC quality control
rpm revolutions per minute
RTI RTI International
SwRI Southwest Research Institute
vn
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Acknowledgments
The authors acknowledge the support of all those who helped plan and conduct the verification
activities. In particular, we would like to thank Mike Kosusko, the U.S. Environmental
Protection Agency's (EPA's) Project Manager, and Paul Groff, EPA's Quality Assurance
Manager, both of whom are with EPA's National Risk Management Research Laboratory in
Research Triangle Park, NC. We would also like to acknowledge the assistance and
participation of Clean Clear Fuel Technologies personnel who supported the test effort.
For more information on the Clean Clear Fuel Technologies, Inc., Universal Fuel Cell, contact:
Mr. John Montgomery
Clean Clear Fuel Technologies, Inc.
2999 E. Dublin Granville Rd., Suite 101
Columbus, OH 43231
Telephone: (614) 882-0019
Fax: (614) 882-0849
Email: thodge@ee.net
Web site: http://www.cleanclearfuel.com
For more information on verification testing of mobile sources air pollution control devices,
contact
Ms. Jenni Elion
RTI International
P.O. Box 12194
Research Triangle Park, NC 27709-2194
Telephone: (919) 541-6253
Email: jme@rti.org
Web site: http://etv.rti.org/apct/index.html
Vlll
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Section 1.0
Introduction
This report reviews the performance of the Clean Clear Fuel Technologies, Inc.'s (CCFT's)
Universal Fuel Cell, Model CCFT21061. Environmental Technology Verification (ETV)
Program testing of this technology was conducted during a series of tests in November 2003 by
Southwest Research Institute (SwRI) under contract with RTI International's (RTFs) Air
Pollution Control Technology (APCT) Center. The objective of the APCT Center and the ETV
Program is to verify, with high data quality, the performance of air pollution control
technologies. Control of air emissions from diesel engines is within the scope of the APCT
Center. An APCT Center program area was designed by RTI and a technical panel of experts to
evaluate the performance of diesel exhaust catalysts, particulate filters, and engine modification
control technologies for mobile diesel engines. Based on the activities of this technical panel,
the Generic Verification Protocol for Diesel Exhaust Catalysts, Paniculate Filters, and Engine
Modification Control Technologies for Highway andNonroad Use Diesel Engines1 was
developed. The specific test/quality assurance (QA) plan addendum for the ETV test of the
technology submitted by CCFT was developed and approved on August 27, 2003.2 The goal of
the test was to measure the emissions control performance of the technology system and its
emissions reduction relative to an uncontrolled engine.
A description of the Universal Fuel Cell is presented in Section 2. Section 3 documents the
procedures and methods used for the verification test and the conditions under which the test was
conducted. The results of the test are summarized and discussed in Section 4, and references are
presented in Section 5.
This report contains only summary information and data as well as the verification statement.
Vendor comments are included in Appendix A. Complete documentation of the test results is
provided in a separate test report3 and audit of data quality (ADQ) report.4 These reports include
the raw test data from product testing and supplemental testing, equipment calibration results,
and QA and quality control (QC) activities and results. Complete documentation of QA/QC
activities and results, raw test data, and equipment calibration results are retained in SwRI's files
for 7 years.
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Section 2.0
Description of Products
The APCT Center conducted verification testing for CCFT's system described below
(descriptions provided by CCFT). The system consisted of CCFT's Universal Fuel Cell, Model
CCFT21061. The technology was provided directly to the APCT Center's test organization,
SwRI, as:
• one degreened Universal Fuel Cell, Model CCFT21061 (Serial Number 0963), and
• one aged Universal Fuel Cell, Model CCFT21061 (Serial Number 0642).
The degreened unit was labeled to have run 139 hours, and the aged unit was labeled to have run
3,187 hours.
The Universal Fuel Cell is a high-density magnet with a field strength of at least 1000 gauss.
The strength of the tested device ranged from 1,300 to 1,600 gauss (see Section 3.5). Fuel lines
were fabricated by SwRI and approved by CCFT to mount the fuel cells along the fuel line after
the engine's secondary fuel filter and before the fuel injector gallery. Figure 1 shows the aged
Universal Fuel Cell mounted in the fuel system of the Detroit Diesel Corporation (DDC) engine
in Test Cell 8.
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Aged universal
Fuel Cell
Figure 1. Mounting location of aged Universal Fuel Cell, Model 21061, Serial Number
0642, in Test Cell 8.
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Section 3.0
Test Documentation
The ETV testing took place at SwRI under contract to the APCT Center. Testing was performed
in accordance with:
• Generic Verification Protocol for Diesel Exhaust Catalysts, Paniculate Filters, and Engine
Modification Control Technologies for Highway andNonroad Use Diesel Engines;1
• Test/QA Plan for the Verification Testing of Diesel Exhaust Catalysts, Paniculate Filters,
and Engine Modification Control Technologies for Highway andNonroad Use Diesel
Engines;5 and
• Test-Specific Addendum to ETV Mobile Source Test/QA Plan for Clean Clear Fuel
Technology Universal Fuel Cell; and
The generic verification protocol and the test/QA plan were available to the applicant prior to
testing.
3.1 Engine Description
The ETV testing was performed using an inline, 6-cylinder, 12.7-liter, 1998 model year Detroit
DDC, heavy-duty (HD), on-highway diesel engine. It was turbocharged and used a laboratory
water-to-air heat exchanger for a charge air intercooler. The engine was owned by SwRI and has
been used on various research programs. Table 1 provides the engine's identification details.
Table 1. Engine Identification Information
Engine serial number
Date of manufacture
Make
Model year
Model
Engine displacement and configuration
Service class
EPA engine family identification
Rated power
Rated torque
Certified emission control system
Aspiration
Fuel system
06R0422316
April 1998
Detroit Diesel Corporation
1998
Series 60
12.7-L, in-line 6-cylinder
On-highway, heavy-duty (HD) diesel engine
WDDXH12.7EGD
298 kW (400 bhp) at 1,800 rpm
2130 N»m (1550 Ibf/ft) at 1,200 rpm
Electronic control
Turbocharged, air-to-air intercooled
Direct injection, electronically controlled unit
injectors
3.2 Engine Fuel Description
The diesel fuel used during all test runs for this verification test was a conventional No. 2 low-
sulfur diesel (LSD) fuel, with a sulfur level of 386 ppm. The LSD fuel meets EPA current diesel
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fuel specifications given in 40 CFR 86.1313-98, Table N98-26. Selected fuel properties from
suppliers' analyses are summarized in Table 2.
Table 2. Selected Fuel Properties and Specifications
Item
Cetane number
Cetane index
Distillation range:
Initial boiling point, °C (°F)
10% Point, °C(°F)
50% Point, °C(°F)
90% Point, °C(°F)
End point, °C (°F)
Gravity (American Petroleum
Institute)
Specific gravity
Total sulfur, ppm
Hydrocarbon composition:
Aromatics (minimum), %
Paraffins, naphthenes, and olefins,
%
Flash point (minimum), °C (°F)
Viscosity, centistokes @ 40 °C
Code of Federal Regulations (CFR)
Specification"
ASTM
D613
D976
D86
D86
D86
D86
D86
D287
D2622
D1319
D1319
D93
D445
Type-2D
40-50
40-50
171-204 (340-400)
204-238 (400-460)
243-282 (470-540)
293-332 (560-630)
321-366 (610-690)
32-37
-
(300-500)b
27
C
54 (130)
2.0-3.2
Test Fuel
Low-Sulfur Diesel
EM-4991-F
47.3
46.7
177 (350)
207 (404)
258 (496)
302 (575)
328 (642)
35.9
0.8453
386
30.6
69.4
67(153)
2.3
Note: ASTM = American Society for Testing and Materials.
a Diesel fuel specification as in 40 CFR 86.1313-98(b)(2)6 for the year 1998 and beyond for heavy-duty diesel
engines.
b 1998 sulfur range specification.
0 Remainder of the hydrocarbons.
3.3 Summary of Emissions Measurement Procedures
The ETV tests consisted of baseline uncontrolled tests and tests with the control system installed.
The baseline engine and the installed Universal Fuel Cell were tested on conventional LSD fuel.
The standard HD Transient Federal Test Procedure7 (FTP) for exhaust emissions testing was
performed. The engine and control system were conditioned before the official tests with three
hot-start transient cycles conducted in accordance with the test/QA plan.5 Individual exhaust gas
and particulate matter (PM) samples were taken during the official tests for each cycle.
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Emissions Test Procedures
Exhaust emissions were measured using HD Transient FTP7 and the experimental setup shown
in Figure 2. Dilute exhaust emissions measured during tests over the transient FTP operating
conditions included total hydrocarbons (HC), carbon monoxide (CO), carbon dioxide (CO2),
nitrogen oxides (NOX), and exhaust PM. The CO and CO2 levels were determined using
nondispersive infrared instruments. Total HC were measured using continuous sampling
techniques employing a heated flame ionization detector. The NOX was measured continuously
using a chemiluminescent analyzer.
NOx
Analyzer
Positive Displacement
Pump (POP)
CO, CO2, HC, and NOx
Background Bag
CO, C02
Sample Bag
Sample PM
Gas Meter
Pump
Bag Sample
Gas Analyzer
Sample Line
Heated Line
90mm PM Filters
Figure 2. Constant volume sampler setup for emissions measurement.
The exhaust PM level for each test was determined using dilute sampling techniques that
collected PM on a pair of 90-mm diameter Pallflex T60A20 filter media used in series. The
particulate filter pair unit was weighed together both before and after each test to establish
exhaust PM emissions for the test.
3.4 Deviations from the Test/QA Plan
The original test plan incorporated the use of a 1998 rebuilt Cummins ISM 370 ESP (Serial
Number 34936044), FID diesel engine supplied by CCFT. Baseline emission tests with this
engine resulted in a PM weighted composite average of 0.142 g/hph. This level exceeded the
applicable certification standard (0.10 g/hph) by more than the allowable 10%. Upon further
investigation, a water leak was found in the engine's head and five pistons were noted to have
the incorrect part number for the engine's CPL.
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After reviewing the situation, SwRI was instructed by CCFT to remove the Cummins engine and
install a 1998 DDC Series 60 HD engine supplied by SwRI. During initial cold-start runs of the
Series 60, cold-start HC levels were excessive. New rebuilt fuel injectors were installed, and
baseline tests of the DDC engine showed that the engine did not exceed the applicable emission
standards by more than 10%.
On November 21, 2003, a new battery charger was installed in Test Cell 8 to replace an older
unit. Battery chargers are periodically replaced with new models to maintain equipment
reliability. The charger maintains the charge on a 12-V battery, which powers the engine control
module. The DDC Series 60 engine control module is very sensitive to low battery voltage.
During hot-start tests 112103-H2 and 112103-H3, the DDC engine misfired, coinciding with HC
concentration spikes that peaked out of the measurable range of 0-100 ppm. The HC spikes
caused the tests to be voided as specified in the Code of Federal Regulations (CFR), Title 40,
Part 86, Subpart N. Low battery voltage was determined to be the cause of the erratic engine
behavior. The malfunctioning battery charger was replaced with a functional unit, a preparatory
hot-start cycle was run, and two additional hot-start tests were conducted to complete the data
set. No erratic behavior of the engine or HC concentration spikes were noted after the charger
was replaced.
3.5 Documented Test Conditions
Engine Performance
Table 3 gives the observed engine performance while power validating the DDC engine for the
baseline and the controlled configurations. The performance was similar for all configurations.
Performance curves were generated by operating the engine at full load while increasing its
speed by 8 rpm per second for both the baseline and controlled configurations.
Table 3. Engine Performance Data
Fuel
LSD
LSD
LSD
Test Date
11/18/2003
11/19/2003
11/20/2003
Test Type
Baseline
Controlled
Controlled
Rated Power"
bhp (kW)
422(315)
419(312)
420(312)
Peak Torqueb
Ibf/ft (N«m)
1633 (2214)
1630 (2210)
1658 (2248)
Engine Exhaust Backpressure
The engine backpressure was set to 2.4 in Hg (8.1 kPa) at rated speed and load in accordance
with the engine manufacturer specifications.
Universal Fuel Cell Magnetic Flux Density
An AlphaLab, Inc., DC Magnetometer, Serial Number 1187, was supplied by CCFT to measure
the magnetic flux density of each fuel cell both before and after the cells were emission tested.
Triplicate readings were recorded for each measurement and are given in Table 4.
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Table 4.
Magnetic Flux Density Measurements
Unit
Degreened Cell (SN 0963)
Degreened Cell (SN 0963)
Aged Cell (SN 0642)
Aged Cell (SN 0642)
Test Stage
Pre-test
Post-test
Pre-test
Post-test
Test Date
11/19/2003
11/20/2003
11/20/2003
11/26/2003
Reading #1,
gauss
1500
1434
1420
1413
Reading #2,
gauss
1600
1585
1540
1307
Reading #3,
gauss
1600
1523
1370
1495
Fuel Consumption
Table 5 presents the brake specific fuel consumption (BSFC) for all baseline and control
configurations.
Table 5. Brake Specific Fuel Consumption
Test Number
Test Type
Test Date
BSFC,
Ib/bhp-h
BSFC,
kg/kWh
Weighted
BSFC,
Ib/bhp-h
Weighted
BSFC,
kg/kWh
Engine Baseline
111903-C1
111903-H1
111903-H2
111903-H3
Cold-start
Hot-start
Hot-start
Hot-start
11/19/2003
11/19/2003
11/19/2003
11/19/2003
0.424
0.401
0.404
0.401
0.257
0.243
0.244
0.243
0.404
0.407
0.404
0.245
0.246
0.245
Engine with Degreened Fuel Cell
112003-C1
112003 -HI
1 12003 -H2
1 12003 -H3
Cold-start
Hot-start
Hot-start
Hot-start
11/20/2003
11/20/2003
11/20/2003
11/20/2003
0.42
0.405
0.404
0.402
0.254
0.245
0.244
0.243
0.407
0.406
0.405
0.246
0.246
0.245
Engine with Aged Fuel Cell
112103-C1
112103-H1
112103-H4
112103-H5
Cold-start
Hot-start
Hot-start
Hot-start
11/21/2003
11/21/2003
11/21/2003
11/21/2003
0.423
0.406
0.399
0.399
0.256
0.246
0.241
0.241
0.408
0.402
0.402
0.247
0.243
0.243
Note: BSFC = brake specific fuel consumption.
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Section 4.0
Summary and Discussion of Emission Results
4.1 Emissions Test Data
The baseline and controlled emissions data are summarized in Tables 6, 7, and 8. The emissions
were measured at each test point for HC, CO, NOX, and PM. Table 6 also provides data on CC>2
emissions and work. For each pollutant/hot-start test combination, the transient composite-
weighted emissions per work (bhp-h) were then calculated following the fractional calculation
for highway engines as follows:
— • ECOLD H --
(EcoMp)m =
— • WCOLD -\ -- • \WHOT\
1 1 ^ !
(Eq. 1)
where
ECOMP = composite emissions rate, g/bhp-h
m = one, two, or three hot-start tests
ECOLD = cold-start mass emissions level, g
EHOT = hot-start mass emissions level, g
= cold-start brake horsepower hour, bhp-h
= hot-start brake horsepower hour, bhp-h.
These composite-weighted emissions rates are shown in Tables 7 and 8 and were used to
calculate the mean and standard deviations for the baseline and controlled emissions rates. These
data were in turn used to calculate mean emissions reductions and 95% confidence limits. These
calculations are based on the generic verification protocol1 and test/QA plan.5
Table 6.
Emissions Test Data
Test
Number
Test
Type
Test
Date
g
Exhaust
PM
NOX
HC
CO
C02
Work,
KWh
(bhp-h)
Engine Baseline
111903-C1
111903-H1
111903-H2
111903-H3
Cold-start
Hot-start
Hot-start
Hot-start
11/19/03
11/19/03
11/19/03
11/19/03
3.09
2.22
2.22
2.26
128
121
125
126
13.2
4.74
3.28
3.18
66.9
36.8
35.2
35.5
18.5
17.5
17.7
17.5
22.8 (30.5)
22.6 (30.3)
22.6 (30.3)
22.6 (30.3)
Engine Controlled with Degreened Fuel Cell
112003-C1
112003-H1
112003-H2
1 12003-H3
Cold-start
Hot-start
Hot-start
Hot-start
11/20/03
11/20/03
11/20/03
11/20/03
4.02
2.26
2.21
2.21
130
124
123
129
18.5
3.96
3.14
2.45
68.2
37.3
37.1
36.3
18.3
17.7
17.6
17.5
22.8 (30.5)
22.6 (30.3)
22.6 (30.3)
22.6 (30.3)
Engine Controlled with Aged Fuel Cell
112103-C1
112103-H1
112103-H4
112103-H5
Cold-start
Hot-start
Hot-start
Hot-start
11/21/03
11/21/03
11/21/03
11/21/03
4.91
2.47
2.31
2.37
128
124
123
124
23.1
4.44
3.94
5.22
70.5
40.4
37.4
38.6
18.4
17.7
17.4
17.5
22.7 (30.4)
22.6 (30.3)
22.7 (30.4)
22.7 (30.4)
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Table 7. Composite Weighted Emissions Values (English units)
Test
Number
Test
Date
g/bhp-h
Exhaust
PM
NOx
HC
CO
C02
Engine Baseline
111903-H1
111903-H2
111903-H3
11/19/03
11/19/03
11/19/03
0.0772
0.0772
0.0784
4.00
4.13
4.17
0.196
0.155
0.152
1.35
1.31
1.32
581
585
581
Engine Controlled with Degreened Fuel Cell
112003-H1
112003-H2
112003-H3
11/20/03
11/20/03
11/20/03
0.0828
0.0814
0.0814
4.12
4.09
4.26
0.199
0.176
0.156
1.38
1.37
1.35
585
584
581
Engine Controlled with Aged Fuel Cell
112103-H1
112103-H4
112103-H5
11/21/03
11/21/03
11/21/03
0.0931
0.0883
0.0898
4.11
4.09
4.09
0.235
0.220
0.256
1.48
1.39
1.42
587
579
578
Note: PM = participate matter; NOX = nitrogen oxide; HC = hydrocarbon(s); CO = carbon monoxide; CO2 = carbon dioxide.
Table 8.
Composite Weighted Emissions Values (metric units)
Test
Number
Test
Date
g/kWh
Exhaust PM
NOX
HC
CO
CO2
Engine Baseline
111903-H1
111903-H2
111903-H3
11/19/03
11/19/03
11/19/03
0.103
0.103
0.105
5.36
5.54
5.59
0.263
0.208
0.204
1.81
1.76
1.77
779
784
779
Engine Controlled with Degreened Fuel Cell
112003-H1
112003-H2
112003-H3
11/20/03
11/20/03
11/20/03
0.111
0.109
0.109
5.52
5.48
5.71
0.267
0.236
0.209
1.85
1.84
1.81
784
783
779
Engine Controlled with Aged Fuel Cell
112103-H1
112103-H4
112103-H5
11/21/03
11/21/03
11/21/03
0.125
0.118
0.120
5.51
5.48
5.48
0.315
0.295
0.343
1.98
1.86
1.90
787
776
775
Note: PM = particulate matter; NOX = nitrogen oxide; HC = hydrocarbon(s); CO = carbon monoxide; CO2 = carbon dioxide.
10
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Table 9 summarizes the mean composite weighted emission values and Table 10 the verified
emissions reductions and their 95% confidence limits. The emissions reductions for CO and
NOX could not be distinguished from zero with 95% confidence for either the degreened or aged
device. HC emissions could not be distinguished from zero with 95% confidence for the
degreened device, but showed a small increase during the test of the aged device compared to
baseline emissions. The PM emissions for both devices showed a small increase during the
controlled tests compared to baseline emissions. However, it was noted that if the 95%
confidence limits are calculated using only the hot-start data, but the same statistical procedures,
the controlled emissions could not be distinguished from zero for any pollutant or device type.
This alternate view of the data should be considered when using the results of this verification.
Table 9. Summary of Verification Test Emission Values
Device
type
Baseline
Degreened
Aged
Fuel
LSD
LSD
LSD
Mean Composite Weighted Emission Value, g/kWh (g/bhp-h)
PM
0.104(0.0776)
0.110(0.0819)
0.121 (0.0904)
NOX
5.50(4.10)
5.58(4.16)
5.50(4.10)
HC
0.225(0.168)
0.237(0.177)
0.318(0.237)
CO
1.78(1.33)
1.82(1.36)
1.92(1.43)
CO2
782 (583)
783 (584)
779(581)
Note: LSD = low-sulfur diesel fuel; PM = particulate matter; NOX = nitrogen oxide; HC = hydrocarbon(s); CO = carbon
monoxide; CO2 = carbon dioxide.
Table 10. Summary of Verification Test Emission Reductions
Device type
Degreened
Aged
Mean Emissions Reduction (%)
PM
-5
-17
NOX
-1
0
HC
-6
-41
CO
-3
-8
95% Confidence Limits on the Emissions Reduction (%)
PM
-3 to -8
-26 to -7
NOX
a
a
HC
a
-75 to -8
CO
a
a
Note: PM = particulate matter; NOX = nitrogen oxide; HC = hydrocarbon(s); CO = carbon monoxide; CO2 = carbon dioxide.
a The emissions reduction can not be distinguished from zero with 95% confidence.
4.2 Quality Assurance
The environmental technology verification of CCFT's Universal Fuel Cell, Model CCFT21061
for HD diesel engines was performed in accordance with the test/QA plan5 (to be completed after
EPA QA review).
11
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Section 5.0
References
1. RTI International (January 2002). Generic Verification Protocol for Diesel Exhaust
Catalysts, P articulate Filters, and Engine Modification Control Technologies for Highway
andNonroad Use Diesel Engines. Research Triangle Park, NC: RTI International.
2. RTI International (August 2003). Test-Specific Addendum to ETVMobile Source Test/QA
Plan for Clean Clear Fuel Technology Universal Fuel Cell. Research Triangle Park, NC:
RTI International.
3. Southwest Research Institute (December 2003). Environmental Technology Verification of
a Clean Clear Fuel Technology, Inc. Universal Fuel Cell for Heavy-Duty Diesel Engines.
San Antonio, TX: Southwest Research Institute.
4. Southwest Research Institute (December 2003). Audit of Data Quality for Environmental
Technology Verification of a Clean Clear Fuel Technology, Inc. Universal Fuel Cell for
Heavy-Duty Diesel Engines. San Antonio, TX: Southwest Research Institute.
5. RTI International (April 2002). Test/QA Plan for the Verification Testing of Diesel
Exhaust Catalysts, Paniculate Filters, and Engine Modification Control Technologies for
Highway andNonroad Use Diesel Engines. Research Triangle Park, NC: RTI
International.
6. Fuel Specifications, 40 CFR 86.1313-98, Table N98-2 (updated July 2001).
7. 40 CFR 86, SubpartN, as of July 1, 1999, http://www.epa.gov/epahome/cfr40.htm.
12
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Appendix A
Vendor Comments
Clean Clear Fuel Technology, Inc. has been offered the opportunity to comment on the findings
of this report. Their comments are presented in Appendix A of the report and reflect their
opinions. The Air Pollution Control Technology Center and EPA do not necessarily agree or
disagree with the vendor's comments and opinions.
A-l
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CLEAN CLEAR ™™ TECHNOLOGY. INC.
EXCLUSIVE1DISTRIBUTOR OF THE UNIVERSAL FUEL CELL
February 26,2004
Andrew Trenholm
Air Pollution Control Technology
Verification Center
Research Triangle Institute
P.O. Box 12194
Research Triangle Park, NC 27709-2194
ITnivaraal Fuel Cell
Dear Mr. Trenholm:
Thank you for the opportunity to comment on the Environmental Technology^Verification**
Series 60 Engine provided by SwRI for CCFTs use in testing the Universal Fue CeU ( Fuel
Cd?) wufefeta and d* the appropriate QA/QC procedures were not followed, thus
invalidating the verification test.
Background
The ETV Report recognises that CCFT intended to conduct the verification test on .1998
Qinunins ISM 370 engine. The preparatory testing, however revealed thai fiveof to>s«
pistons in the CummingTenj?ne were of the wrong make and model for the particularCummins
engine. CCFT was capable of providing a replacement engine, but accepted an offer from SwKL
to^e SwRI's enguie in order to expedite the verification process and avoid incurring an
atonal $60,000In testing expenses. CCFT did not know, however, thatSwRTs; enginehad
been in storage for one-year or would exhibit continued malfunctions in the form of hydrocarbon
spikes that remained during 1he verification testing.
•i-
Engine Malfunction
CCFT's December 8, 2003 letter (Exhibit A), explained in detail the malfunctioning of
SwRI's engine and the railed attempts to fix it. During the preparatory tests, the engine misfired
and product significant hydrocarbon spikes. SwRJ reported the misfiring in the Chronology
Report and described SwRI's attempts to fix the misfiring. The Chronology Report explains that
a bore scope found "smsill discoloration on the piston surface, but ^findings were
inconclusive " (ETV Report at p. 3). Previously, however, SwRI advised CCFT that the scope
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SwRI decided to order an instrument to test cylinder compression.
SwRI advised CCFT on October 16, 2003 that a compression
FTwx. not told that SwRI had also decided to replace ihe fuel injectors. Indeed, SwRI
KS?1^
engine problems.
SwRI proceeded with the verification testing after installation of the £builtfi*l mjectorsu
However itbecame evident that the engine was still not in good working order ™***
veSon toJSuto came back showing increasingly high HCs as me tests progress e
^ hTd^arbon spikes were observed during the "aged test" of sufficient *******
SotoruSwL designated as "void" (See Exhibit B). l^™^?**%* *
and voided results were referenced in either of the ETV Report or the Chronology Report
The slight increase in certain parameters as the verification ^ting^oceeded Ion to. F*
Cell is furmer evidence of the defective nature of SwRl's engine. The Fuel Cdl has W
Tremendous success in prior tests and has been proven to be one of to , fc^ £** ^y>
technology that decreases air emissions and increases fuel mileage. CCF T conduced ^exte^we
laboratorlr and on-road testing of the Fuel CeU prior to registering the Fuel Cell for ^ testing
tooSRTl and, in all insiances, had positive results. The first test was conducted on July ^
2000 by EinSn Testing Services in Costa Mesa, California, which is recognized by the
California Air Resources Board as an approved testing facility. A test report zs attached as
Exhibit C and showed the following dramatic emission reductions:
Data File
Weighted Avg. HP
Fuel Consumption, GM/BHPH
Hydrocarbons, GM/BHPH
Carbon Monoxide, GM/BHPH
Nitrogen Oxides, GM/BHPH
-2-
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Particulates, GM/BHPH
an engine in the chassfc, rather than in a substantially more control ed environment. Ttareport
S tesfresults are attached as Exhibit D and also showed the following dramatic results.
Average NOx Mass Emission Rate
(gram/far)
Average CO Mass Emission Rate
(gram/hi)
Average Hydrocarbon Mass Emission
Rate
Average Total Particulate Matter Mass
Emission Rate
Baseline Condition
HDDE Exhaust Stack
Average
242.50
149.71
3.12
Universal Fuel Magnet
Condition HDDE
Exhaust Stack AT
213.76
120.70
2.05
Average
Difference
4%)
-11.85
-19.38
Further, on-road uses by CCFTs customers have seen significant decreases in
demonsteated Significant emission reductions in aH tests other than venficaUon test further
demonstrates that the verification test is invalid.
Compliance with OA/OC Procedures
•Die Test/QA Plan for Verification Testing of Diesel Exhaust Catalysts, Particular Filters,
and Engine Modification Control Technologies for Highway and Non-Road Diesel Engines
CTest/QA Plan") prepared by RTI, sets forth the protocol to be used in testing certain emission
conntl te^Tsection 2 of the Test/QA Plan requires • J^^**!"^*
tested to be documented as a test specific addendum to be submitted to U.S EPA for review and
approval prior to the start of testing. CCFT sent ajsignificant amount of information to Kll
ummins engine and, in fact, went back and forth with RTI until CCFT submitted
itted
renge ummn , ,
^entirety of the information requested by RTI on the engine, CCFT recently submitted
additional information for a similar engine that CCFT proposes for use in a re-Jest It, loes not
appear that SwRTs engine was described in any detail to RTI and certainly not to CCFT \ or thai
the engine had been approved for testing by RTI or U.S. EPA in accordance ™* ^ J^£
Mocedures. Even if such information and approval was supplied, the failure to conduct a simple
compression test after several engine misfires, carbon spikes, and observance of scoring and
-3-
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white residue on the valves, did not comply with standard QA/QC procedures or good
mechanical practices.
No Publication of the Verifferfion Report «r Verification Statement
The Draft Generic Verification Protocol for Diesel Exhaust Catalyst, Paniculate Filters, and
Engine Modification Control Technologies for Highway and Non-Road Used Diesel Engines
C'Seric Verification Protocol") states 'tests that meet the E™ ^^V1^™™^?
valid FTP test) are considered valid and suitable for publishing." The test performed by SwRI,
however was not valid or suitable for publishing. The scoring and white residue on the valves,
continued hydrocarbon spikes during testing, the apparent lack of information provided with
respect to SwRI's engine before testing and the test results themselves, all demonstrate a
deviation from the Test/QA Plan and standard mechanical practices. Accordingly, the
verification report and verification statement are not suitable for publishing and should not be
published, and CCFT's Fuel Cell should be tested using an appropriate working and weU-
documented engine.
If RTJ refuses to refrain from publishing the verification report and verification statement,
then, of course, CCFT requests that RTI not issue the verification statement Section 8 of the
Generic Verification Protocol allows a party to request that the verification statement not be
issued if the technology submitted for testing did not meet the applicant's expectation. Whether
the SwRI engine is considered faulty or to have violated the QA/QC procedures, or the
technology is considered not to have performed as expected, RTI should immediately provide for
the re-testing of the Fuel Cell at SwRI on a qualified engine following all applicable QA/QC
procedures. No "improvement" of the Fuel Cell is necessary or warranted as referenced in
Section 8 of the Generic Verification Protocol since the Fuel Cell continues to be m perfect
working order.
Conclusion
The delays caused by the defective engine and testing procedures have resulted in significant
lost sales to CCFT. In order that CCFT, its clients and the environment may enjoy the benefit of
the Fuel Cell, CCFT requests that testing be allowed to proceed in March 2004, which is the time
SwRI has "penciled in" for the purpose of re-testing the Fuel Cell. CCFT looks forward to
working with RTI and SwRI to complete a successful verification test and demonstrate the Fuel
Cell's ability to decrease air pollution and increase fuel efficiency.
If you have any questions with regard to the enclosed or require additional information,
please contact me.
Very truly yours,
, *
Robert Hodge
Manager
Cc: Dennis Johnson, U.S. EPA
.4.
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