SRI/USEPA-GHG-VR-14
                           April 2002
Environmental
Technology Verification
Report


JCH Fuel Solutions, Inc.
JCH Enviro Automated Fuel
Cleaning and Maintenance System
  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/USEP A-GHG-VR-14
                                                                April 2002
      Greenhouse Gas Technology Center
     A U.S. EPA Sponsored Environmental Technology Verification (£|-^ ) Organization
         Environmental Technology Verification Report

                     JCH Fuel Solutions, Inc.
JCH Enviro Automated Fuel Cleaning and Maintenance System
                              Prepared by:
                      Greenhouse Gas Technology Center
                         Southern Research Institute
                              PO Box 13825
                    Research Triangle Park, NC 27709  USA
                          Telephone: 919/806-3456
              Under EPA Cooperative Agreement  CR 826311-01-0
                    U.S. Environmental Protection Agency
                     Office of Research and Development
                National Risk Management Research Laboratory
                 Air Pollution Prevention and Control Division
                  Research Triangle Park, NC 27711  USA

                 EPA Project Officer:  David A. Kirchgessner

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                               TABLE OF CONTENTS
                                                                                   Page
APPENDICES	iii
LIST OF FIGURES	iii
LIST OF TABLES	iii
ACKNOWLEDGMENTS	iv

1.0   INTRODUCTION	1-1
     1.1   BACKGROUND	1-1
     1.2   JCH ENVIRO AUTOMATED FUEL CLEANING AND MAINTENANCE
          SYSTEM DESCRIPTION	1-2
     1.3   TEST FACILITY DESCRIPTION	1-6
     1.4   OVERVIEW OF VERIFICATION PARAMETERS AND EVALUATION
          STRATEGIES	1-8
          1.4.1   Emissions Performance	1-11
          1.4.2   Fuel Properties for Contaminated and Cleaned Fuel	1-15
                 1.4.2.1  Fuel Consumption Rate for Contaminated and Cleaned Fuel	1-15
                 1.4.2.2  Fuel Heating Value and Fuel Quality for Contaminated and
                        Cleaned Fuel	1-16
          1.4.3   Emissions Performance of Contaminated and Cleaned Fuel	1-18
          1.4.4   Fuel Cleaning Performance	1-19

2.0   VERIFICATION RESULTS	2-1
     2.1   OVERVIEW	2-1
     2.2   ENGINE OPERATION AND FUEL CLEANING PROCEDURES	2-2
          2.2.1   Engine Operation	2-2
          2.2.2   Fuel Cleaning Procedures	2-4
     2.3   ENGINE EMISSIONS AND EMISSIONS PERFORMANCE	2-5
          2.3.1   Engine Emissions	2-5
          2.3.2   Emissions Performance	2-8
     2.4   FUEL QUALITY AND FUEL CLEANING PERFORMANCE	2-9
          2.4.1   Fuel Quality	2-9
          2.4.2   Fuel Cleaning Performance	2-12

3.0   DATA QUALITY ASSESSMENT	3-1
     3.1   DATA QUALITY OBJECTIVES	3-1
     3.2   RECONCILIATION OF DQOS AND DQIS	3-2
          3.2.1   Emission Measurements	3-4
                 3.2.1.1  Exhaust Gas Flow Rate and TPM Emissions	3-4
                 3.2.1.2  Gaseous Pollutant Emissions	3-5
                 3.2.1.3  Propagation of Errors for Emission Rate Measurements	3-7
          3.2.2   Fuel Quality Performance	3-8
          3.2.3   Ambient Measurements	3-11
     3.3   AUDITS	3-11

4.0   REFERENCES	4-1

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                                       APPENDICES
                                                                                       Page
APPENDIX A Table A-1.  Analyzer Spans and Calibration Gas Values	A-2
              Table A-2.  Summary of System Bias and Drift Checks	A-2

APPENDIX B Appendix B-l. SwRI Fuel Sample Handling Procedures	B-2
              Appendix B-2. SwRI Fuel Analysis QA/QC Procedures	B-4



                                    LIST OF FIGURES
                                                                                       Page
Figure 1-1     JCH Fuel Treatment and Cleaning Process Flow	1-3
Figure 1-2     JCH Portable Cart-Mounted System	1-4
Figure 1-3     JCH Floor-Mounted System	1-5
Figure 1-4     Test Engine and Fuel Day Tank	1-8
Figure 1-5     Verification Strategy	1-10
Figure 1-6     Schematic of Verification Measurement System	1-11
Figure 1-7     Sampling Location for Contaminated and Treated Fuel	1-17
Figure 2-1     Ambient Temperature and Relative Humidity During Test Periods	2-4
Figure 2-2     Engine Filter after Operation with Contaminated Fuel	2-13



                                     LIST OF TABLES
                                                                                       Page
Table 1-1      Onan/Cummins Model 200DGFC	1-6
Table 1-2      Summary of Emission Testing Methods	1-12
Table 1-3      Fuel Properties Test Methods	1-16
Table 2-1      Average Generator and Engine Operation During Test Periods	2-2
Table 2-2      Generator and Engine Parameters and Permissible Variation During Test Periods	2-3
Table 2-3      Enviro System Fuel Cleaning Activities During Verification Testing	2-4
Table 2-4      Pollutant Concentrations and Emission Rates	2-6
Table 2-5      Engine Emissions Normalized to  Fuel Consumption and Heat Input	2-7
Table 2-6      Genset Fuel Consumption Rates	2-8
Table 2-7      Differences in Emission Rates	2-9
Table 2-8      Fuel Quality for Contaminated and Treated Fuel	2-10
Table 2-9      Differences in Fuel Properties for Contaminated and Treated Fuel	2-10
Table 2-10     Results of Microbial Contamination Tests	2-11
Table 3-1      Verification Parameters  and Data Quality Objectives	3-2
Table 3-2      Summary of Data Quality Goals and Results	3-3
Table 3-3      Results of Additional TPM Emissions Testing QA/QC Checks	3-4
Table 3-4      Exhaust Gas Flow and Particulate Emission Rate Error Propagation	3-5
Table 3-5      Results of Additional Gaseous Pollutant Emissions Testing QA/QC Checks	3-6
Table 3-6      Participate and Gaseous Pollutant Emission  Rate Error Propagation	3-7
Table 3-7      Summary of Fuel Properties Data Quality Indicators	3-9
                                             111

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                                   ACKNOWLEDGMENTS
The Greenhouse Gas Technology Center wishes to thank Mike Myer and Cummins Intermountain for
hosting this verification and providing the genset used to conduct the testing. Additionally, Garry Schaap
and Matt Sanchez, both of Cummins Intermountain, provided assistance to GHG Center staff during the
field testing that was instrumental to the verification. Thanks are also extended to the members of the
GHG Center's Oil and Gas Industry Stakeholder Group for reviewing and providing input on the testing
strategy and this verification report.
                                               IV

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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 goal of the ETV
program is to  further environmental protection by substantially accelerating the acceptance and use of
improved and  innovative environmental technologies.   ETV is funded by  Congress 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.  With performance data developed under ETV, technology buyers,
financiers, and permitters in the United States and abroad will be better  equipped to make  informed
decisions regarding environmental technology purchase and use.

The Greenhouse Gas Technology Center (GHG Center) is one of six verification organizations  operating
under ETV.  The GHG Center  is managed by  the EPA's partner verification organization,  Southern
Research  Institute  (SRI),  which  conducts  verification  testing of promising  GHG mitigation  and
monitoring technologies.  The GHG  Center's verification process  consists of developing verification
protocols, conducting  field tests, collecting  and interpreting field and  other test  data,  obtaining
independent peer review input, and reporting findings.  Performance evaluations are conducted according
to externally reviewed verification Test  and Quality Assurance  Plans (Test Plan) and established
protocols for quality assurance.

The GHG Center is guided by volunteer groups of stakeholders.  These stakeholders offer advice on
specific technologies most appropriate for testing,  help disseminate results, and review Test Plans  and
Verification Reports. The GHG Center's stakeholder groups consist of national and international experts
in the areas  of climate  science and environmental policy, technology, and regulation.  Members include
industry  trade  organizations,  technology  purchasers,  environmental  technology  finance  groups,
governmental organizations, and  other interested  groups.  In certain cases,  industry  specific stakeholder
groups and technical panels are assembled for technology areas where specific expertise is needed.   The
stakeholder technical panel members provide guidance on the verification testing strategy and peer review
key documents that are related to their areas of expertise.

JCH Fuel Solutions, Inc.  (JCH), located in North  Las Vegas, NV, requested the GHG Center to perform
an independent third-party performance verification of a diesel fuel treatment and filtration system. Many
types of facilities operate stationary and mobile equipment powered by diesel-fueled internal combustion
(1C)  engines.  These facilities often maintain their own  diesel fuel  storage tanks at central locations.
Diesel fuel is best used immediately after manufacture, or at least within a  few months from the time it
was manufactured.  In practice, however, a given inventory of fuel can remain  in a storage tank for long
periods.   The  fuel can  become contaminated  during long  storage  periods  in a  clean tank.   This
contamination  decreases  fuel quality and  may increase engine emissions  when the fuel is ultimately
consumed. JCH's technology treats and cleans contaminated fuel.

This Verification  Report  specifically  addresses  the JCH  Enviro  Automated Fuel  Cleaning  and
Maintenance System, Model 4 (Enviro System).  The Enviro System  incorporates the JCH/Algae-X
Model 46-LG-X1500 magnetic fuel conditioner and the JCH/Algae-X Fuel Catalyst AFC-705. Details on
the verification  test design, measurement test  procedures,  and  Quality  Assurance/Quality Control
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(QA/QC) procedures can be found in the Test Plan titled Testing and Quality Assurance Plan for the JCH
Fuel Solutions, Inc. Enviro Automated Fuel Cleaning and Maintenance System (SRI,  2001).  It can be
downloaded from the GHG Center (sri-rtp.com) or ETV (www.epa.gov/etv) Web sites.  The Test Plan
describes the rationale for the experimental design, the planned test methods and instrument calibration
procedures, and specific QA/QC goals and procedures. The Test Plan was reviewed and revised based on
comments received from JCH, selected members of the GHG Center's stakeholder groups, and the EPA
Quality Assurance Team. The Test Plan met the requirements of the GHG Center's Quality Management
Plan (QMP), and thereby satisfied ETV QMP requirements.  In some cases, the verification required
deviations from the Test Plan. These deviations and the alternative procedures used are discussed in this
report.

The remaining discussion in this section describes the Enviro System technology, presents  the operating
schedule of the test  facility,  and lists  the performance verification parameters that were quantified.
Section 2 presents the verification test results, and Section 3 assesses the  quality of the data obtained.

1.2    JCH ENVIRO AUTOMATED FUEL CLEANING AND MAINTENANCE SYSTEM  DESCRIPTION

Facilities using diesel-fired engines often maintain their own diesel fuel storage tanks at central locations.
Stationary engines draw their fuel  supply through direct piping to the central storage tanks, or they may
operate from integral tanks (day tanks) mounted on the engine chassis.  Although diesel fuel is best used
within a few months  from  when it was manufactured, a given inventory of fuel can  often remain in  a
storage tank for long periods.  For  example, a hospital or hotel with a diesel-powered emergency electric
generating plant may  keep the same tank of fuel for a long time before using it up.  Some facilities buy
fuel months or even years in advance of projected needs to take advantage of favorable pricing.

The fuel can become contaminated during long storage periods even when it is  stored in  a clean tank.
This contamination decreases fuel quality and may  increase engine emissions when it  is ultimately
consumed.

During storage, diesel fuel may:

       •   acquire water from atmospheric condensation and separation
       •   grow colonies of algae  and fungi
       •   form clouds and gels
       •   oxidize into gums and resins
       •   accumulate other particles (e.g., ambient dust, rust, other fines)

Each  of these contaminants can alter diesel fuel  properties and thereby potentially harm  the precision
mechanisms of a diesel engine, increase wear, clog filters, and reduce combustion quality.  Contaminated
fuel may therefore increase fuel consumption and emissions.

JCH's Enviro  System technology treats and cleans contaminated fuel.   It also maintains the treated fuel
while in storage. Figure 1-1  depicts the process flow of the Enviro System.
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                   Figure 1-1. JCH Fuel Treatment and Cleaning Process Flow
                                             JCH Fuel Treatment,
                                               Installation, and
                                                Operation of
                                               Enviro Cleaning
                                                Technology
When an operator requires a solution to a fuel contamination problem, JCH initially collects a fuel sample
for field testing and laboratory classification of contaminants.  The field test equipment yields a quick
qualitative evaluation of the fuel for sediment and water, microorganisms, appearance, clarity/brightness,
and debris/contamination. The JCH representative rates the fuel for each of these factors on a qualitative
scale  from 1 to 10: 1 is no observable contamination, and 10 indicates heavy contamination.  The field
tests  roughly correspond to  standard  laboratory  [ASTM  International  (ASTM)]  methods,  and  are
sufficient for most customers' applications.  JCH then develops a prescription of care for fuel treatment
and filtration.

The first step of treatment consists of the application of the proper amount of Algae-X AFC-705 fuel
catalyst.   The AFC-705 solution  contains detergents, lubricity enhancers, a corrosion inhibitor, and  a
demulsifier  to  drop out entrained water.  The solution also provides a preservative and dispersant to
stabilize fuel in storage by retarding gum formation.  The tank owner adds the fuel treatment directly to
the stored fuel. One gallon of AFC-705 solution treats approximately 5,000 gallons  of fuel.
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JCH then installs an Enviro  System  at  or  near the  storage tank.  JCH  manufactures and  markets
approximately 12 Enviro models in various  sizes and capacities.  Figure 1-2 shows a schematic of a
portable cart-mounted system that can be moved from tank to tank.  Figure 1-3 depicts a larger capacity
system intended to be permanently floor- or wall-mounted at a single storage tank.
                         Figure 1-2. JCH Portable Cart-Mounted System
Inlet Screen
Water Filter
md
Each  system consists of several components.  An electric pump moves fuel  from the tank through an
Algae-X magnetic fuel conditioner, a multistage filter train, and then back to the tank.  The Algae-X fuel
conditioner is designed to eliminate and prevent problems related to fuel deterioration, repolymerization,
stratification, and organic debris and acid buildup.  Most portable Enviro models (Figure  1-2) employ
two-stage filtration.  The first stage is a cartridge-type coarse particulate screen and bulk water separator.
The second stage is a 2-um particulate filter that also removes emulsified water. Depending on pumping
capacity, atypical portable unit is 49 x 21 x 19  in. (height/width/depth) and weighs about 175 pounds.

The larger,  permanently mounted units  (Figure 1-3) are housed in an  enclosure and use three-stage
filtration.  Stage 1  is a 150-um  particulate and bulk water separator cartridge.   Stage 2 is  a  10-um
particulate filter which removes 95 percent of entrained water.  Stage 3 is a 2-um particulate filter which
removes emulsified water.  The stage 2 and 3  filters are spin-on canister-type elements.  These systems
are plumbed directly into the tanks which they  serve. Inlet piping conveys the fuel from the lowest point
of the tank to the inlet screen and water filter. The electric pump circulates the fuel through the final filter
train and back to the storage tank.
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                             Figure 1-3. JCH Floor-Mounted System
                    Fuel Storage Tank
                   Fuel Return
            I
             Fuel Supply
The system size and pumping capacity is selected based on the size of the tank to be served. The Enviro 2
is intended for use on tanks up to 2,000 gallons and has a 3 gallons per minute (GPM) pump.  Its wall-
mounted enclosure is 24 x 24 x 10 in. (h/w/d), and the entire unit weighs 150 pounds. The largest model,
the Enviro 9, monitors and maintains tanks up to 80,000 gallons with a 40 GPM pump.  It is in a 40 x 54 x
26 in. (h/w/d) floor-mounted enclosure and weighs 750 pounds.

During this verification, a Model 4 was specified based on the capacity of the day tank used to store fuel
for the  test engine (275 gallons).   During initial treatment and cleaning activities, JCH qualitatively
monitors the fuel  quality using  field test equipment to determine when to end a treatment.  Once a
contaminated lot of fuel is satisfactorily treated, its quality must be maintained by regular operation of the
Enviro System.  JCH  recommends that  at least one tank volume per week be circulated through the
Enviro System.  Portable systems are operated manually:  the operator moves the cart to the tank to be
treated,  installs the inlet and outlet hoses through the tank fill cap, and runs the system for the time
required.

For wall-mounted  systems,  a programmable logic controller (PLC) provides for unattended operation.
The operator programs the PLC according to the pumping capacity  of the Enviro System and the  size of
the tank.
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The PLC also monitors vacuum and pressure gauge readings.  A vacuum gauge alarm alerts the operator
of the need to  clean or replace the  inlet screen and filter.  A differential pressure (DP) gauge alarm
indicates the need to change the final filter elements.  The PLC shuts the system off during overpressure
conditions (e.g., final filter becoming clogged). It also monitors  the leak sump and pump motor, shutting
the system down or triggering alarms as appropriate.

System maintenance includes draining water and sludge from the inlet screen and filter into an adsorbent
to stabilize it. The 10- and 2-um filter canisters must be changed periodically.  Enviro System users must
transfer the used canisters and spent adsorbent media to a Class I  landfill for ultimate waste disposal.

1.3    TEST  FACILITY DESCRIPTION

This verification was hosted by the Cummins Intermountain (CI) facility located in North Las Vegas, NV.
CI is a full-service Cummins engine dealer that maintains  a large inventory of  diesel-driven generator
(genset) rental equipment.  The unit selected for testing was an Onan Model 200DGFC 200 kilowatt (kW)
trailer-mounted genset, with a Cummins  Model 6CTAA8.3-G1  6-cylinder, direct injected, turbocharged
engine (Onan, 2001).  The genset was connected to  a Loadtec  Model  OTT3-1505.1 Portable Resistive
Load Bank to provide a controlled electrical load.  Table 1-1  shows  factory  performance and emissions
data for the test engine.  The emissions  data in the  table are manufacturer  rated values and served as
starting estimates for the field determinations.
Table 1-1. Onan/Cummins Model 200DGFC
(Engine/Generator Emissions Data: Prime Power Service)
Description
Brake Horsepower (Bhp) (a), 1800 rpm (60 Hz)
* Carbon Dioxide (CO^) Emissions
Carbon Monoxide (CO) Emissions
Fuel Consumption
Nitrogen Oxides (NOx) Emissions
Prime Power Generating Capacity (480 VAC)
* Sulfur Dioxide (802) Emissions
Total Unburned Hydrocarbons, as Methane (CH/0
Predicted Value
285 Bhp
*285.8 Ib/hr
5.341b/hr
13.3 gal/hr
4.341b/hr
180 kW
*0.50 Ib/hr
0.63 Ib/hr
* Factory data unavailable; estimate based on AP-42 "Emission Factors of Uncontrolled Gasoline and Diesel
Industrial Engines" (U.S. EPA, 1995)
During  test development  and planning, the GHG Center  reviewed this engine's size and generation
capacity with representatives from Cummins, Inc., Caterpillar, Inc., International Truck and Engine Co.,
John Deere & Co., and several  diesel fuel experts, including the chairman of the ASTM D-975 fuels
committee.  The consensus was that this engine/generator  combination is a good selection for the test
campaign for several reasons.   First, diesel engines  of all sizes must achieve EPA Tier I  emissions
requirements. More restrictive Tier II regulations are phasing in from 2001 to 2006. Most manufacturers
are using similar technologies (e.g., direct injection, turbocharging, computerized engine control) to meet
the requirements.   The increasingly stringent emissions regulations are forcing a convergence in engine
design and operation across all manufacturers, regardless of size.  Emissions from engines of different
manufacturers are reported to be very similar for a given horsepower (hp) range.
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Second, the  180 kW  engine/generator combination is representative  of a large  number of installed
gensets. In the fourth quarter of 2000 alone, the Electrical Generating Systems Association reported sales
of 4461 gensets of between 150 and 4000 kW capacity (EGSA, 2001). Of these, 60 percent were between
150 and 750 kW.

Third,  a generator with  a resistive load provides a consistent,  predictable load for the engine.  The
constant 100 percent prime-power load cycle represents normal operating conditions for genset engines.
The  only differences which arise when compared with other service classes are the load rating of the
engine and the operating time  allowed at that  load. For example, this genset can supply 200  kW of
emergency power for the duration of a normal power interruption.  Net emissions per hour at the higher
rating will  be greater because  the engine is working harder and burning more fuel.   The normalized
emission rates at both power ratings (Ibpoiiutant/lbfuei), however, will  be virtually the same.

Finally, this genset represented  a good compromise between a large engine which would have required a
large amount of test fuel, and a small engine which would have presented emissions testing and fuel flow
measuring difficulties.  Figure 1-4 is a photograph of the fuel day tank and the test engine.

To help maintain steady  engine  operations  during the verification,  an adjustable load bank  (Loadtec
Portable Resistive Load Bank,  Model OTT3-1505.1) was used to provide a steady state, pure resistive
load for the genset at a target load of 100 ± 5 percent of the prime power capacity (180 kW). In the load
bank, fan-cooled resistor arrays convert electrical energy into heat.  Various resistors can be switched in-
to and out of the circuit to provide the appropriate load for each generator phase.

The  engine was also fitted with a custom fabricated test duct installed on the engine exhaust to facilitate
proper emissions measurements.  The temporary test duct was a  6-inch diameter stainless steel tube,  10
feet  long, with an  adaptor  for the genset's rain cap.   Appropriate ports for gaseous and particulate
emissions sampling were installed on the stack.

The  test engine was equipped with a standard fuel cleaning system that included a two-stage fuel filter.
Both stages were rated  at 20-um nominal filtration; the primary stage included a water separator element.
This compares with the 10- and 2-um filters in the Enviro equipment described in Section 1.2.
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                          Figure 1-4.  Test Engine and Fuel Day Tank
                       Fuel Hoses and Supports
1.4    OVERVIEW OF VERIFICATION PARAMETERS AND EVALUATION STRATEGIES

This verification was designed to evaluate the following fuel and engine performance characteristics:

       •   Mass emission rates of criteria air pollutants and greenhouse gases (GHGs) from the
           engine while combusting contaminated and treated fuel:
               Carbon Dioxide (CO2), Ib/hr
               Carbon Monoxide (CO), Ib/hr
               Methane (CH4), Ib/hr
               Nitrogen Oxides (NOX), Ib/hr
               Sulfur Dioxide (SO2), Ib/hr
               Total Hydrocarbons (THCs), quantified as CH4, Ib/hr
               Total Particulate Matter (TPM), Ib/hr
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           Fuel properties for contaminated and treated fuel:
               - Fuel consumption rate, Ib/hr
               - Fuel lower heating value (LFfV), Btu/lb
               - Fuel quality properties:
                      API Gravity
                      Ash, vol %
                      Cetane Number
                      Flash Point, °C
                      Gums and Resins, mg/L
                      Lubricity
                      Microbial Contamination
                      Particulate Matter, mg/L
                      Water and Sediment, vol  %

           Emissions  performance in terms  of the percent change  in  mass emission  rates
           between contaminated and treated fuel.  Emission rates were normalized as pounds of
           pollutant per pound of fuel (Ibpoiiutant/lbfuei) and as pounds of pollutant per  million Btu
           of heat input (lbponutant/106Btu).

           Fuel cleaning performance: Percent  change resulting from fuel treatment for each
           fuel property.
Figure 1-5 is a schematic of the verification strategy.  This verification strategy was to conduct a set of
tests for emissions, fuel quality, and fuel consumption while operating the engine on the contaminated
fuel, and then to repeat the tests after treating the same lot of fuel using the Enviro System and running
the engine on the treated fuel.  During each test period, engine load was maintained at near- steady state
using the  load bank.  The emissions tests conformed to well-documented EPA reference methods, and
fuel measurements were  conducted according  to  ASTM test  specifications and other  protocols  as
described  in following sections.  The results of these measurements allowed emissions performance and
cleaning performance comparisons between the two fuel conditions.
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                                Figure 1-5. Verification Strategy
                Deliver Contaminated
                Fuel to Test Facility
                     I
                 Transfer Fuel to
                 Test Day Tank
                    Purge Engine
                  Fuel System and
                 Stabilize Operation
                     I
                 Contaminated Fuel
                 Test Runs; Collect
                   Fuel Samples
                 Evaluate, Treat,
                 and Clean Fuel
                    Purge Engine
                  Fuel System and
                 Stabilize Operation
                   Cleaned Fuel
                 Test Runs; Collect
                   Fuel Samples
Determine Pollutant Mass
Emission Rates, Fuel Mass
   Consumption Rates

Determine Fuel Properties
    Compute and Report
 Emission Performance and
 Fuel Cleaning Performance
JCH provided a contaminated lot of fuel for this test, provided the test day tank which contained the test
fuel, and performed all fuel transfers.  The fuel in the test day tank was agitated before and during all
testing to prevent stratification and to ensure that the mixed fuel supplied to the engine during testing was
representative of the contaminated fuel.

GHG Center personnel obtained fuel samples from the as-received test fuel prior to the first test run. The
Field Team Leader transferred the as-received sample from the test day tank into two 2.5 liter aluminum
sample bottles with a suction pump while the fuel was being agitated.  The suction pump inlet hose used
to collect  this sample was placed  adjacent to  the  fuel hose  to obtain a  sample  which would  be
representative of the fuel that the engine would consume.
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The engine's fuel hoses and the circulation pump hoses were positioned such that they would not have
contact with the tank walls or floor, thereby causing weight fluctuations (the genset's integral fuel tank
was disconnected from the engine).  The fuel return hose had a tee fitting and a ball valve connected to a
short length of hose for fuel sample collection.

Verification testing  commenced after collection of the as-received fuel sample and installation of the fuel
delivery and sampling system.  A series of tests were conducted for each of the verification parameters
listed above while combusting the contaminated fuel.  The fuel was then treated using the Enviro System,
and the tests  were  repeated while  combusting the treated fuel.   Figure  1-6  is  a  schematic of the
measurement system used during the testing. Specific procedures used to document test conditions and to
determine each  of  the parameters  are presented in Sections  1.4.1  through 1.4.4.  Additional details
regarding these procedures can be found in the Test Plan.
                   Figure 1-6. Schematic of Verification Measurement System
                  Ambient Sensors
                  (temp, and RH)
             Engine Exhaust
                    Fuel Return T .ine
                    Fuel Supply T .ine
  Test Day Tank
                                                                  Emissions Testing Laboratory
                                                                 (CH,, CO, CO2, NOx, THCs, TPM)
                                   Engine Fuel Filter
                                                          Fuel Pump and
                                                            Manifold
                                               Test Genset
             _L
                                                                           Fuel Sampling Port
                                                                        (Fuel Properties Analyses)
          Fuel Scale [Fuel
        Consumption (GPH)
      Genset Operations
    (amps, volts, kW, Hz,
and oil, water, and exhaust temps.
Engine and generator operations were monitored during each of the test periods.  Parameters recorded
included engine oil  temperature, water temperature, exhaust temperature,  generator amperes (amps),
volts, and hertz (Hz).  In addition to these engine/generator parameters, ambient temperature and relative
humidity (RH) were also monitored.  These data were used to document stable engine operation and test
conditions  during  the test periods by  comparing the variability  in  the  measurements  to allowable
variations specified in  the test engine  Operation and Maintenance  and Troubleshooting and  Repair
Manuals (Cummins, 1991a and 1991b).
1.4.1
        Emissions Performance
Determination of the  emissions  performance of the  engine  is  a primary verification parameter for
evaluation  of the performance of the  Enviro  System.   Pollutant  concentration and emission rate
measurements for CH4 CO, CO2, NOX, SO2, THCs, and TPM were conducted on the engine exhaust stack
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during each test period.  All of the test procedures used in the verification are EPA Reference Methods,
which are contained in the Code of Federal Regulations. The Reference Methods include procedures for
selecting measurement system performance specifications and test procedures, quality control procedures,
and emission calculations (U.S. EPA,  1999). Table 1-2 summarizes the standard Test Methods that were
followed.
Table 1-2. Summary of Emission Testing Methods
Pollutant/
Parameter
CH4
CO
C09
NOX
09
S09
THCs
TPM
Reference
Method
18
10
3A
7E
3A
6
25A
5/202
Principle of Detection
GC/FID
NDIR - Gas Filter Correlation
NDIR
Chemiluminescence
Fuel Cell
Barium-thorin Titration
Flame lonization
Isokinetic Sampling/Gravimetric
Analytical
Range (Span)
0 to 500 ppmv
0 to 408 ppmv
0 to!4 %
0 to 2,500 ppmv
0 to 25 %
Oto 1,500 ppmv
0 to 500 ppmv
not applicable
The emissions testing was conducted by Cubix Corporation of Albuquerque, New Mexico, under the on-
site supervision of the GHG Center Field Team Leader.

A mobile laboratory was used to house the instruments and record emissions data throughout the testing
periods.  A detailed description of the sampling system used to determine the concentrations  of criteria
pollutants, GHGs,  and O2 is provided  in  the Test Plan and  is not repeated in this  report.  A brief
description of key features is provided below.

Sampling for gaseous pollutants (CH4,  CO, CO2, NOX, O2, and THCs) was  conducted by extracting a
continuous stream of engine exhaust gas from a single point in the 4.75-inch diameter stack and directing
the gas to the mobile laboratory. In order for the CO, CO2, NOx, and O2 instruments used to operate
properly  and reliably, the flue gas must  be  conditioned prior to introduction into  the analyzers. The gas
conditioning system used for this test was  designed to remove water vapor and/or particulate from the
sample.   Gas was extracted from the exhaust gas stream through a stainless steel probe and heated sample
line, and transported to two ice-bath condensers, one on each side of a sample pump.  The condensers
removed moisture from the gas stream. The clean, dry sample was then transported to a flow distribution
manifold where sample flow to each analyzer was controlled.  Calibration gases were routed through this
manifold and to the sample probe to perform bias and linearity  checks.

For CO2 and O2  determination, a continuous sample was extracted from the emission source and passed
through a Servomex Model 1400 analyzer.  For determination of CO2 concentrations, the  Model 1400
was equipped with a nondispersive infrared  spectrometer (NDIR). The CO2 analyzer range was set at 0 to
14 percent.  The same Model 1400 is  also equipped with a micro-fuel-cell  O2 sensor.  The fuel cell
technology used  by this instrument  determines levels of O2 based on partial pressures.  The O2 analyzer
range was set at 0 to 25 percent.

NOX concentrations were determined utilizing a Thermo Environmental Model 10AR chemiluminescence
analyzer. This analyzer catalytically reduces NOX in the sample gas to nitrogen oxide (NO). The gas is
                                             1-12

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then converted to excited nitrogen dioxide  (NO2) molecules by oxidation  with ozone (O3) (normally
generated by ultraviolet light).  The intensity of the emitted energy from the excited NO2 is proportional
to the concentration of NO2 in the sample.  The efficiency of the catalytic converter for converting NO to
NO2 is checked as an element of instrument setup and checkout.  The NOX analyzer was operated with a
range of 0 to 2,500 parts per million (ppm).

A Thermo  Environmental Model 48H gas filter correlation analyzer with an optical filter  arrangement
was  used to determine CO concentrations.   This method provides  high specificity  for  CO.  Gas filter
correlation  uses a constantly rotating filter with two separate 180-degree sections (much like a pinwheel).
One section of the filter contains a known concentration of CO, and the other section contains an inert gas
without CO. Based upon the known concentrations of CO in the filter, these two values are  correlated to
determine the concentration of CO in the sample gas.  The CO analyzer was operated within a range of 0
to 408 ppm.

THC concentrations in the exhaust gas were measured using  a JUM Model 3-300  flame  ionization
detector (FID).  This detector analyzes gases on a wet, unconditioned basis.  Therefore, a second heated
sample  line was used to  deliver unconditioned exhaust  gases directly  to the THC analyzer.  All
combustible hydrocarbons were being analyzed and reported,  and the emission value was calculated on a
CH4 basis.  The THC analyzer was operated within a range of 0 to 500 ppm.

Concentrations of CH4  in the exhaust gas stream were measured using a gas chromatograph (GC) with a
VICI 6-port gas loop injection system and a FID that was calibrated  with appropriate certified calibration
gases.   Integrated gas samples  were  collected in Tedlar bags and returned  to the  emission  testing
contractor's laboratory for analysis.   In  the laboratory,  samples were  directed to  a GC/FID  after
calibration  of the FID.

Concentrations of SO2 were determined following EPA Reference Method 6.  This method was selected
in lieu of the planned instrumental method (Method 6C) because it  has the potential to provide a lower
detection limit, and SO2 concentrations were expected to be very low.  The principle of Method 6  is to
extract a gas stream from the stack at a known flow rate and pass the gas through impingers  containing 3
percent hydrogen peroxide (H2O2) solution to absorb any SO2 in the gas stream.   After collecting the
samples, the solutions are returned to  the laboratory where analyses are conducted using barium-thorin
titration procedures.  Test results reported by the laboratory indicated that SO2  concentrations were not
detectable,  but laboratory  results for the fuel samples indicate that small levels of sulfur were found in the
fuel.  This indicates that some SO2 (approximately 15 ppm) should have been detected in the exhaust gas.
For this reason, the SO2 results reported in Section 2.3 are based on fuel sulfur analyses and  calculations.
This is discussed in more  detail in Section 2.3.

The testing for all of the gaseous pollutants (CH4, CO, CO2, NOx, SO2, and  THCs) yielded concentrations
in units of parts  per million by volume (ppmv).  Engine exhaust gas volumetric flow rates (determined
using EPA Methods 2 through 4 as described below) were used to convert the concentration values into
exhaust gas emission rates in units of pounds per hour (Ib/hr) using Equation 1.
               Epoii,i ~ C poiijK poiiQstack,std,i                                          (Eqn. 1)

       Where:
                                              1-13

-------
        Ep0ii! = Emission rate for test run i, Ib/hr
        Cpoii.i = Average analyzer concentration for test run i (where i=l to 3), ppmv
        Kpoii = ppmv to Ib/dscf conversion factor
        Qstack,std,i = Stack dry volumetric flow rate, dscf/hr (dscfm*60), corrected to standard conditions
        (60 °F, 29.92 in. Hg) for test run i
Emissions of TPM were determined in accordance with EPA Method 5/202 using an isokinetic sampling
system. Stack gas velocity, temperature, and moisture content determinations were included in the TPM
testing following Methods 2, 3, and 4.  A standard-type pitot tube and thermocouple were located at the
center of the 4.75-inch diameter stack to record DP and gas temperature throughout each test.  These data
were  used to calculate the average stack gas velocity.  Moisture  was determined gravimetrically by
withdrawing a measured stack gas sample through a probe and passing it through a chilled impinger train
to condense the water.  Oxygen (O2) and CO2 concentrations required to calculate the stack gas molecular
weight were obtained using Method 3A as described above.  These data,  along with the physical
measurement of the test duct area, were used to  determine the average dry volumetric flow  rate at
standard conditions (dscfm) for each test run.  These values were correlated with measured pollutant
concentrations to calculate pollutant emission rates.

For TPM  determination, the stack gas and its entrained particulate matter pass through the heated, glass-
lined  probe and through a  filter  maintained at  250 ±  25  °F.  The filter  collected particulate (usually
inorganic  matter) which condensed above that  temperature; the  rest of the stack gas  and condensible
particulate passed through the filter. The weights of particulate collected on the filter and deposited in the
probe and nozzle were correlated with the total volume of stack gas collected and comprised the front half
particulate concentration.

The stack gas then passed into a chilled impinger train charged with distilled water.  Stack gas moisture
and condensible particulate (usually organic matter) dropped out in the impinger train for recovery at the
end of the test run.  Test operators forwarded the recovered samples to the  laboratory for extraction with
methylene chloride and gravimetric  analyses. The condensed impinger particulate was correlated with the
total volume of stack gas collected and comprised the back half particulate concentration.

TPM  results were reported  as the  sum of the front half and  back half concentrations in units of grains per
dry standard cubic foot (gr/dscf), as  shown in Equation 2.
                „         filter    conenSan                                    _    „.
                CTPM =	                          ( qa  }
                JTPM
                                     I/ /!/.
                                        - std
       Where:

       CTPM= Particulate mass concentration, gr/dscf
       mfllter= Mass of particulate collected on the filter, mg
       nicondens = Mass of particulate collected in impingers, mg
       mbiank= Total mass of filter, probe rinse, back half, and extraction reagent blanks, mg
       VMstd = Volume of collected stack gas, corrected to dry standard conditions
                (68 °F, 29.92 in. Hg), dscf
       64.799 = conversion factor, mg/gr
                                               1-14

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Total particulate emission rates are reported as shown in Equation 3.

               ETpM .  = CTPM Qstack std,.  * 1.429 x 10'4                                 (Eqn. 3)

       Where:

       ETPM.I = Particulate emission rate, Ib/hr
       CTPM.I  = Mass concentration of particulate matter for run i (where i = 1 to 3), gr/dscf
       Qstack std i = Stack dry volumetric flow rate, dscf/hr (dscf»60) corrected to standard conditions
                 (60 °F, 29.92 in. Hg)
       1.429 x 10"4 = conversion factor, gr/lb


1.4.2    Fuel Properties for Contaminated and Cleaned Fuel

This verification included determination of fuel consumption rates, heating values, and fuel quality for
contaminated and cleaned fuel as burned  in the engine. These measurements were used to evaluate the
quality of fuel combusted in the engine and  to correlate the data with the engine emissions for the two
fuel conditions.  The fuel  properties evaluation included  examination of engine fuel  consumption rate,
fuel heating value, and fuel  quality while operating the engine on contaminated and cleaned fuel.  The
testing was designed to evaluate the quality of the fuel as combusted in the engine.

1.4.2.1    Fuel Consumption Rate for Contaminated and Cleaned Fuel

Diesel engines use their fuel for cooling and lubrication  of fuel system components.  Engine-operated
pumps constantly circulate fuel from the storage tank, through the engine galleries and past the injectors,
and back to the storage tank.  The Cummins test engine circulates  approximately 55 gallons per hour
(gal/hr) under normal conditions. The  injectors actually use only a portion of the total flow depending on
the engine load and revolutions per minute (rpm).  For this engine, fuel consumption was expected to be
about 13 gal/hr at 100 percent of prime power load (180 kW).

Gravimetric determination was selected as the optimum way to monitor the fuel consumed.   The 275-
gallon polyethylene day tank was placed  on a Fairbanks platform scale (Model IQ-5900C, 2000 pound
capacity,  serial number B39991) to obtain fuel mass consumption data. The engine pulled its  fuel  from
the day tank, and the return fuel was circulated back to the same tank. For each test run conducted, the
GHG Center personnel recorded fuel starting  and ending weights on field data forms.

At the beginning  of each test run, test operators recorded the time, the weight of the tank and fuel, and
initial fuel temperature.  At least three scale readings were collected at 15-minute  intervals during each
test run. The total fuel used during the run is  shown in Equation 4.
               FuelRate = (W^ - Wt2 )(--)                                   (Eqn. 4)
                                        elapse
       Where:
                                              1-15

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       FuelRate = Mass fuel consumption rate, Ib/hr
       Wti = Initial tank/fuel weight at the beginning of the test run, Ib
       Wt2 = Final tank/fuel weight at the end of the test run, Ib
       TeiapSe = Run elapsed time, as recorded by the instrumental analyzer operator, min
I A.2.2    Fuel Heating Value and Fuel Quality for Contaminated and Cleaned Fuel
To  determine the  fuel cleaning performance of the Enviro System,  fuel samples were collected and
submitted to a  laboratory for analysis  of fuel quality properties.   These  data were  used to form
comparisons  between the  contaminated and cleaned fuel combusted in the engine.  The samples were
collected in conjunction with the emissions testing.  As specified in the Test Plan,  all samples were
collected downstream of the engine fuel filtering system so that evaluation of the fuel  actually being
introduced to the engine could be examined.

The selection of fuel quality properties was based on input from engine manufacturing representatives
(i.e., Association of Engine Manufacturers, Cummins, Caterpillar, International Truck  and Engine, John
Deere), fuel biological contamination experts, the chairman of the ASTM D-975 fuels committee, and
several testing laboratories.

JCH's treatment and filtration  technology  was expected to affect properties such as water, sediment,
particulate, API gravity,  and microbial contamination.  There was also interest in determining if the
technology might affect other properties such as LHV, flash point, gums and resins, cetane number, or
lubricity.

ASTM D-975, "Standard Specification for Diesel Fuel Oils" specifies  some of these properties and lists
the  associated test methods (ASTM, 1999). Other  properties  of interest  were analyzed with additional
ASTM test methods not specified in D-975.  Table 1-3 outlines the consensus selection of fuel properties
evaluated, the D-975 specifications and test methods  where applicable, and other methods used.
Table 1-3. Fuel Properties Test Methods
Description
API Gravity
Ash
Bacterial and Fungal
Contamination
Cetane Number
Flash Point
Gums and Resins
LHV
Lubricity
Particulate Matter
Water and Sediment
D-975
Method
—
D-482
—
D-613
D-93
—
—
—
—
D-2709
Test Plan
Method
D-4052
D-482
LiquiCult
D-613
D-93
D-381
D-4809
D-6079
D-6217
D-2709
Principle of Detection
Density by densitometer
Gravimetric after incineration
Colorimetric evaluation of fuel culture
on agar
Audible knock in test engine
Closed-cup heating with ignition
source
Gravimetric after evaporation of
volatile compounds
Calorimetric
Reciprocating scuffing pad
Gravimetric after filtering
Volumetric after centrifugal separation
Method Accuracy
±0.22% of reading
±21 % of reading
± 1 log] o of reading
±5.2% of reading
± 5 % of reading
±6mg/100mL
±97.1 Btu/lb
±2 1.3% of reading
varies; ±25.3 % at
10mg/l
varies; ± 9.4 % at
3 % vol. cone.
                                              1-16

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All fuel samples  were collected from the fuel  return hose downstream of the  engine (and the engine
filtering system).  This sampling location had a tee fitting and a ball valve connected to a short length of
hose. Figure 1-7 illustrates the fuel return connections at the engine and the collection of a sample.  When
the valve was in  the  closed position, all return fuel was routed back to the test day tank.  When test
personnel opened the  valve, part of the return was diverted into the fuel sample hose.  The Field Team
Leader regulated the valve such that approximately 10 minutes was required to fill each sample bottle.
               Figure 1-7. Sampling Location for Contaminated and Treated Fuel
                        Fuel Return Hose to Test Day Tank
Procedures detailed in the Test Plan were followed during all of the fuel sampling.  The Field Team
Leader first filled  a 2.5-liter sample container with fuel.  A 5.0-mL  syringe was then filled from the
sample remaining  in the hose, and the contents were injected into a LiquiCult™ vial for bacterial and
fungal microbial contamination analysis.  The Field Team Leader then filled a second 2.5-liter container
to complete the sample collection for Runs 1 and 3 for cleaned, and contaminated fuel. The Field Team
Leader subsequently filled a third  2.5-liter container for Run 2 for each fuel condition so that the
laboratory would have sufficient sample volume to conduct duplicate analyses on those samples.  After
filling, the Field Team  Leader immediately sealed and  labeled each sample container and entered the
proper information on the Fuel Sample Collection Log form.  Samples were forwarded to  Southwest
Research Institute's Petroleum Products Research Department (SwRI) for analysis.   Standard chain of
custody procedures were followed in the field and at the analytical laboratory  operated by SwRI.  After
each sample collection,  filled sample bottles were tagged with numbers, placed into  shipping containers
(four per container) and, before the containers were sealed, a signed chain of custody form, complete with
laboratory  handling instructions,  was  included.  At the SwRI  laboratory,  the technician   combined
appropriate samples into a single container from which  aliquots were drawn for analysis for each run.
The technician handled each  group of samples individually, so that all the containers were not open at one
                                              1-17

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time,  but only those containers for the current sample group.  Laboratory identification numbers were
applied to  the combined sample containers, providing traceability to their original containers shipped
from the field.

At the laboratory, samples were analyzed for each of the fuel quality parameters listed in Table 1-3.  The
Field  Team Leader retained the LiquiCult samples for analysis at the proper times. These analyses were
conducted  at 30 ± 3  hours and 72 ±  3 hours after the  sample was collected for bacterial and  fungal
contamination, respectively.  Additional details regarding each of the fuel analyses are presented in the
Test Plan and are not repeated here.

1.4.3    Emissions Performance of Contaminated and Cleaned Fuel

Emission rate measurements  described above were  used to report emissions performance as the percent
change in emission rates for  each pollutant between contaminated and treated fuel.  To accomplish this,
pollutant mass emissions were normalized using average diesel fuel mass consumption rates and LHVs.
Results were  computed in two forms:

        •   Percent change of mass of pollutant emitted per mass of fuel consumed (percent
           change, Ibp0uutant/lbfuei)
•   Percent change of mass of pollutant emitted per million  Btu heat input (percent  change,
    Ibpollutant/lO'Btu)
The calculation  of emissions in terms of lbpoiiutant/lbfuei requires  the emission rate for  each pollutant
(Section 1.4.1) and  the fuel consumption  rate (Section 1.4.2).    Equation  5  was used to determine
normalized emissions.
                                                                                 (Eqa5)
       Where:
        Enorm,i = Normalized emission rate of the given pollutant or greenhouse gas for run i, Ib/lb
                of fuel
        E; = Emission rate of the given pollutant or greenhouse gas, for run i (where i = 1  to 3), Ib/hr
        FuelRatCj = Fuel consumption rate for run i, Ib/hr
The calculation of emissions in terms of pounds of a pollutant per million Btu of fuel heat input requires
the emission rate for each pollutant (Section 1.4.1), the fuel consumption rate (Section 1.4.2), and the
LFfV (Section 1.4.2) of the fuel according to Equation 6.

                                      E.
                 "°rme     (FuelRate  ,. *ZffKi. 71,000,000)

       Where:
                                               1-18

-------
        Enormheati = Normalized emission rate of the given pollutant or greenhouse gas for run i,
                  lb/106Btu
        E! = Emission rate of the given pollutant or greenhouse gas, for run i (where i = 1 to 3),
            Ib/hr
        FuelRate; = Fuel consumption rate for run i, Ib/hr
        LHVj = Fuel net heating value for run i, Btu/lb
        1,000,000 = Conversion factor, Btu/106Btu
To report the emissions performance  (i.e., the percent change  in emissions between contaminated and
cleaned fuel) a statistically significant  difference in emissions must exist.  Analysts computed t-statistics
according to the procedure described in the following section.

1.4.4    Fuel Cleaning Performance

Fuel cleaning performance of the Enviro System was defined in the Test Plan as the percent change in
fuel parameters between contaminated fuel and the same fuel when it has been treated and cleaned.  The
laboratory results for contaminated and cleaned fuel properties (Section 1.4.2) were used to develop the
fuel quality comparisons.  As described in Section 1.4.2, all of the fuel quality samples were collected
downstream of the engine filtering system so that the results would represent the quality of fuel being
combusted (Figure 1-6).  However, this approach did not allow a quantitative evaluation of the quality of
the fuel in the fuel tank before and after treatment.  Therefore, this verification does not include a true
evaluation of the Enviro System performance regarding the quality of fuel in the tank before and after
treatment.  Instead, this study reports only the quality of the fuel as combusted. More details regarding
the Enviro System's fuel cleaning ability is provided in Section 2.4.

Fuel quality results were evaluated for statistically significant differences for each fuel quality parameter
to allow a meaningful computation of the percent change between cleaned and contaminated fuel.  The
GHG Center tested the hypothesis that average fuel properties for the two fuel conditions were different
by computing the following test statistic, as shown in Equations 7 and 8.

                      (X     — X
                , 	    \   cleaned     contai
                             1         1
                            	1	
                           cleaned    contam y
                      (n cleaned ~ O5  X,cleaned + (^COHtom ~ !)•? X,contam
                                   cleaned    contam
        Where:
        t = Test statistic
        X = Average laboratory value for the fuel property (LFfV, "API, etc.; see Section 2.4)
        sp = Pooled sample standard deviation
        s = Sample standard deviation for cleaned and contaminated fuel conditions
        n = Number of available results (3)
                                               1-19

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For parameters where the test statistic (t) was  > 2.776 (assuming a 95 percent confidence level and 4
degrees of freedom), it was accepted that the average values were different.  The data determined to be
statistically different were then processed to calculate the percent change.

The percent change in each fuel property is as shown in Equation 9.

                              (X      -X     ~\
               %Changex =    clemed	c-SSiss.  * 100                             (Eqn. 9)
                              V        contam     j
       Where:

       % Changex = Percent change of fuel property, X
       Xdeaned = Average laboratory value of property, X (LHV, "API, etc.) for cleaned fuel
       Xoontam = Average laboratory value of property, X for contaminated fuel
                                               1-20

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                                  2.0  VERIFICATION RESULTS
2.1    OVERVIEW

The verification testing was conducted at the CI facility in North Las Vegas, NV, on July 17 and 18,
2001.  During this period, engine  emissions, fuel  consumption, and fuel quality were  evaluated  with
contaminated and cleaned fuel.

To facilitate this verification, JCH representatives obtained the contaminated fuel from a Nortel facility in
Laughlin, NV, while servicing a storage tank. An independent hauler transferred the fuel from the service
location to a 275-gallon polyethylene storage tank and a  55-gallon drum located at JCH's South Las
Vegas facility.  Total fuel available  for the tests was approximately 300 gallons;  approximately 250
gallons in the polyethylene tank and 50 gallons in the drum.  JCH transferred the fuel to a new 275-gallon
polyethylene tank which was placed  in a trailer.  JCH cleaned the original polyethylene storage  tank
because it was to be used as the test day tank at the CI test site.  The Field Team Leader and JCH noted
that both tanks were clean before any fuel was transferred into them. At the test site the test day tank was
placed on a scale, and the fuel was  transferred into  it.   It was  anticipated that some fuel  would be
consumed during test preparations.  The fuel in the drum was kept in reserve to top up the test day tank
immediately prior to the start of testing.

The Test Plan specified that  a propeller-type stirrer would agitate the fuel during testing.  This was to
prevent stratification  and to ensure  that the mixed fuel  supplied to  the  engine during  testing was
representative of the contaminated fuel.  At the test site, however, JCH and Cummins personnel became
concerned that a propeller could breach the walls of the test day  tank and suggested using a recirculating
pump for this purpose instead. GHG Center personnel concurred  and, for both sets of tests, JCH installed
a 10-GPM recirculating pump.  When the pump was switched on,  the Field Team Leader observed
vigorous rolling circulation at the surface of the fuel.  Once the fuel delivery system was in place and the
fuel agitation pump was running, the GHG Center began testing activities.

At least three valid test runs were  conducted for engine  emissions for each fuel condition.  The first
particulate and instrumental analyzer run for contaminated fuel lasted 60 minutes, but the particulate
sample volume was slightly less than that specified in the Test Plan (i.e.,  31.45 instead of 31.8 dscf).  The
remaining particulate/instrumental  analyzer test runs  were 70  minutes  each to ensure collection  of
sufficient particulate sample volume.

The NOX analyzer had  excessive  drift during  Run  3 for contaminated fuel; the THC analyzer had
excessive drift during Run 2 for contaminated fuel  and Run 5 for  cleaned fuel.  Testers conducted
additional instrumental analyzer runs  (designated  3a and 6a for contaminated and  cleaned fuels,
respectively).  Each of these runs was 30 minutes in duration.

Fuel quality sampling and fuel consumption determinations were conducted in conjunction with each test
run.  After completing the  contaminated fuel testing, JCH  personnel conducted fuel treatment activities
using the Enviro System. The testing was then repeated the following day while combusting the cleaned
fuel.  Details regarding engine operation during testing activities, fuel cleaning activities, and test results
are presented in the following subsections:
                                               2-1

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        Section 2.1 - Engine Operation and Fuel Cleaning Procedures
        Section 2.2 - Engine Emissions and Emissions Performance
        Section 2.3 - Fuel Quality and Fuel Cleaning Performance

An assessment of the quality of data collected throughout all verification testing is provided in Section
3.0.  The data quality assessment is used to demonstrate whether the data quality objectives (DQOs)
introduced in the Test Plan were met.
2.2
      ENGINE OPERATION AND FUEL CLEANING PROCEDURES
2.2.1
        Engine Operation
To  purge the  engine of fuel from previous  activities  prior to beginning both sets  of tests, Cummins
personnel started the genset and operated the engine at 50 to 80 percent of prime power capacity while
placing the  engine's fuel return line in a waste container.  A 10-minute run purged approximately 5
gallons of fuel through the engine, which was deemed  sufficient because the engine's fuel system holds
approximately 1  gallon of fuel.

The engine fuel  return line was then connected to the test day tank, and the engine was operated at 100
percent prime  power during all test periods.   As had been anticipated in the Test Plan, the engine's fuel
filters tended to bind and clog while the engine combusted the contaminated fuel.  Prior to the start of the
first test run, the engine ran for approximately 2.5 hours at full load on contaminated fuel when the engine
fuel filter clogged, and the engine stalled.  Cummins personnel installed a new set of engine fuel filters,
and the contaminated fuel test runs were started.  According to the Test Plan, the filters were changed
between every test run to prevent engine shutdowns or damage to the engine.

To  ensure stable operations during all test periods, the GHG Center logged generator amperage, voltage,
frequency, engine oil, water,  and exhaust temperatures.  Table 2-1 summarizes engine operations during
the  test periods and indicates stable operation throughout the test periods.
Table 2-1. Average Generator and Engine Operation During Test Periods

Run ID
Contaminated 1
Contaminated 2
Contaminated 3
Contaminated 3 a
Cleaned 1
Cleaned 2
Cleaned 3
Cleaned 3 a
Generator Parameters
Current,
amps
499.8
501.1
497.7
497.6
500.1
496.0
500.9
495.8
Voltage
208.0
208.0
208.0
208.0
208.0
208.0
208.0
208.0
Power,
kW
180.0
180.6
179.3
179.3
180.2
178.7
180.5
178.6
Frequency,
Hz
60.0
60.0
60.0
60.0
59.9
59.9
60.0
60.0
Engine Parameters
Oil
Temp,°F
205
208
215
218
205
212
216
212
Water
Temp,°F
189
192
195
197
190
193
196
198
Exhaust
Temp,°F
889
881
898
902
874
895
903
902
The Test Plan specified expected values and permissible variations for each of these generator and engine
parameters based on preliminary information.  For example, the Test Plan assumed that generator nominal
                                               2-2

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voltage and current were 483 volts alternating current (VAC) and 215 amps, respectively.  The Test Plan
allowed a 2.5 percent permissible variation for each of these parameters.  Actual generator voltage was
208 VAC. For the generator to supply 180 kW at 208 VAC, the current must be 499.6 amps.

Similarly, the oil temperature, water temperature, exhaust temperature, and their permissible variation
observed in the field were different from those specified in the Test Plan.  GHG Center personnel revised
the expected values and their permissible variations  based  on specifications in the engine operating and
troubleshooting manuals (Cummins,  1991a and 1991b). Table 2-2 presents the revised values.
Table 2-2. Generator and Engine Parameters and
Permissible Variation During Test Periods
Description
Generator Ammeter, Each Phase
Generator Voltmeter, Each Phase
Generator Frequency Meter
Engine Oil Temperature
Engine Water Temperature
* Engine Exhaust Temperature
Expected Value
499.6 amps
208.0 VAC
60.0 Hz
260 °F
212 °F
925 °F
Permissible Variation During
Test Period
± 12.5 amps
± 5.2 VAC
±1.2 Hz
+0, -50 °F
+0, -54 °F
n/a
* This instrument was not a standard engine accessory. The engine's manuals did not specify a permissible range for this
parameter.
Data  acquired  during  all tests conformed to these permissible  variations  except  for  lubricating oil
temperatures  during Runs 1 and 2 for contaminated fuel and Run 1 for cleaned fuel.   The Cummins
technician on site stated that this is normal for engines operating under the conditions found during the
tests, and would not materially affect the engine's performance.

Because engine performance  and emissions characteristics can vary with changing ambient conditions,
the GHG Center monitored ambient temperature and RH data during each test run with a Vaisala Model
HMP 35C meter connected to a Campbell datalogger.  These data are shown in Figure 2-1 and indicate
similar ambient conditions  during  the 2-day test period.   Temperatures  on July 17 ranged from
approximately 86 to 98 °F, and RH ranged from approximately  18 to 7 percent during the test periods.
On July 18, temperature ranged from approximately 82 to 100 °F (testing  started earlier in the day), and
RH ranged from approximately 24 to 7 percent.
                                               2-3

-------
          Figure 2-1.  Ambient Temperature and Relative Humidity During Test Periods
     110
 .0)
                                                                         ^My^a^^u!
                                                                             ' '" wwjRjrtf
                                            100

                                            90

                                            80

                                            70

                                            60

                                            50  ±
                                                S
                                            40

                                            30

                                            20

                                            10

                                            0
        0600
       07/17/01
                     1200
                                  1800
 0000
07/18/01
                                                             0600
                                                                           1200
                                                 Day and Time
2.2.2    Fuel Cleaning Procedures
                                                                                              £T
                                                                                              |D
                                                                                              I
                                                                                              re
At the conclusion of the contaminated fuel test runs, JCH administered the AFC-705 fuel catalyst (9
ounces in this case) and began operating the Enviro System fuel cleaning equipment.  Table 2-3 shows the
Enviro System fuel cleaning schedule performed by JCH for this verification.
Table 2-3. Enviro System Fuel Cleaning Activities During Verification Testing
Time (Date)
1530 (07-17-01)
1640
1700
1800
1900
1910
1930
0345 (07-18-01)
0400
0600
Process Description
Start Enviro System fuel cleaning equipment
Change 10- and 2-um filters due to pressure alarm;
strainer due to high vacuum
clean water
Restart
Clean water strainer due to high vacuum and restart
Change 10-um filter due to high DP
Restart
Clean water strainer
Stop Enviro System equipment. Purge 5 gallons cleaned
engine fuel system
fuel through
Start genset for 2 hour burnout run by CI technician
Shut down engine, change fuel filters, prepare for
emissions test runs by CI technician
cleaned fuel
                                               2-4

-------
The  water strainer cleaning and filter change procedures conformed generally to JCH's  normal field
practices.  However, the overall treatment and cleaning procedure departed from normal in two respects:

       •   JCH administered approximately twice the normal amount of AFC-705 additive (i.e.,
           dilution was 1:2500 instead of 1:5000).  JCH was concerned that a treated batch of
           fuel  usually has a significant resting time to allow the additive to  work.   They
           recommended the  increased dosage because, for the verification tests, the cleaned
           fuel tests would start immediately after cleaning.  According to the Algae-X additive
           manufacturer, it is  not unusual to administer a double dose of AFC-705 additive to a
           batch of fuel when it is heavily contaminated.  This provides a "shock treatment" to
           quickly control contamination, and is useful when the fuel must be used soon after
           treatment.
       •   After the conclusion of the test campaign, JCH stated that their normal practice is to
           collect the water and sediment fractions from the bottom of the tank with a separate
           probe and suction pump prior to starting the  Enviro System.  This was not  done
           during the verification  testing.  Section 2.4.2 discusses the effect this may have had
           on the test results.

2.3    ENGINE EMISSIONS AND EMISSIONS PERFORMANCE
2.3.1     Engine Emissions

Testing was conducted to determine engine emissions of CH4, CO, CO2, NOX, O2, SO2, THCs, and TPM
while combusting contaminated and cleaned fuel.  Testers conducted three TPM test runs in conjunction
with three  instrumental  analyzer runs for CH4, CO, CO2,  NOX,  O2,  and  THCs for contaminated and
cleaned fuel. Table 2-4 presents results of the emissions testing in concentration units (ppm or %) and
mass emission rates as Ib/hr.  Table 2-5 presents emission rates normalized to  engine fuel consumption
(lbpoiiutant/lbfUei) and heat input (lb/106Btu).

As noted in Tables 2-4 and 2-5, excessive drift in the analyzers invalidated the THC measurements for
Runs 2 and 5, and the NOX measurement for Run 3.  The post-test drift checks exceeded the Reference
Method criteria (3 percent of span).  To make up for the invalidated runs,  additional test runs (Runs 3a
and 6a) were conducted  only for the instrumental measurements.  Fuel sampling  and TPM  emissions
testing was not repeated during Runs 3 a and 6a.

Tables 2-4  and 2-5 also note that SO2 emissions are based on values calculated using the fuel analyses.
The Method 6 tests were  invalidated because the laboratory returned results for each run that were below
the  method detection limit of  approximately  0.5  ppmv, while the fuel analyses clearly  show small
concentrations of sulfur in the fuel.  All of the Method 6 QA/QC criteria were met (Section 3.2.1.2) so the
reason for the non-detectable results is not clear. SO2  emissions were calculated using Equation 10.

               E = Sf*Qf*r                                              (Eqn.  10)

       Where:        E = SO2 emission rate, Ib/hr
                      Sf = sulfur content in fuel, lbsuifur/lbfuei
                      Qf = fuel consumption, Ib/hr
                      r = Ib-mole ratio of SO2:S, 32:16
                                               2-5

-------
Table 2-4. Pollutant Concentrations and Emission Rates
Run ID
1
2
3
3a°
AVG
4
5
6
6a°
AVG
Fuel
Condition
Contam-
inated


Cleaned



Engine
Power, kW
180.0
180.6
179.3
179.3
179 8
180.2
178.7
180.5
178.6
179 5
TPM En
gr/dscf
0.0269
0.0330
0.0399
0 0333
0.0399
0.0290
0.0273
0 0321
: :
Ib/hr
0.113
0.139
0.165
0 139
0.167
0.119
0.112
0 133
NOx En
ppm
1213
1202
b
invalidated
1353
1256
1195
1285
1254
1190
1231
ilssions
Ib/hr
4.25
4.22
b
invalidated
4.67
4 38
4.18
4.40
4.30
4.08
4 24
CO Err
ppm
72.3
80.3
85.1
88.3
81 5
81.9
85.6
92.3
94.7
88 6
issions
Ib/hr
0.154
0.172
0.179
0.186
0 173
0.174
0.179
0.192
0.197
0 186
SO2Em
ppm
15.0
15.3
15.4
15 2
15.6
15.6
15.4
15 5
a
ssions
Ib/hr
0.0732
0.0749
0.0741
0 0741
0.0761
0.0744
0.0733
0 0746
THC Er
ppm
83.8
b
invalidated
94.8
94.2
90 9
61.4
invalidated^
105
102
89 5
: :
Ib/hr
0.102
b
invalidated
0.114
0.113
0 110
0.075
invalidated
0.125
0.122
0 107
CH4 En
ppm
2.30
1.90
1.70
1.90
1 95
2.30
1.80
1.40
1.90
1 85
Isslons
Ib/hr
0.0028
0.0023
0.0020
0.0023
0 0024
0.0028
0.0021
0.0017
0.0023
0 0022
CC-2 En
%
8.83
9.00
9.24
9.25
9 08
8.90
9.06
9.26
9.22
9 11
ilssions
Ib/hr
296
302
305
306
302
298
297
304
302
300
SO2 emission rates calculated based on fuel analyses for sulfur content.
Any tests exceeding the analyzer drift requirements are labelled as invalidated.
Test runs conducted to replace invalidated runs.
                         2-6

-------
Table 2-5.  Engine Emissions Normalized to Fuel Consumption and Heat Input

Run ID
1
2
3
3ac
A\«3
4
5
6
6ac
AVG
Tact nnnHitinn
Fuel
Consump-
tion
(Ibfuei/hr)
88.8
90.9
89.7
88.6
895
89.5
88.2
85.2
88.0
87.7

Fuel LHV
(BtU/lbfuel)
18328
18347
18363
18363
18350
18302
18290
18306
18306
18301


Heat Input
(106Btu/hr)
1.63
1.67
1.65
1.63
1 64
1.64
1.61
1.56
1.61
1.61
TDM Pm

Ibpollutant/
Ibfuel
0.00127
0.00153
0.00184
000155
0.00187
0.00135
0.00131

0.00151
iccinnc

lb/106Btu
0.0694
0.0833
0.100
00843
0.102
0.0738
0.0718

0.0825
NO, Err

Ibpollutant/
Ibfual
0.0479
0.0464
nvalidated
0.0527
00490
0.0467
0.0499
0.0504
0.0463
0.0484
issions

IbMO^tu
2.61
2.53
invalidated
2.87
267
2.55
2.73
2.76
2.53
2.64
rn Pm

Ibpollutant/
Ibfuel
0.00174
0.00189
0.00199
0.00209
000193
0.00195
0.00202
0.00226
0.00224
0.00212
ccinnc

IbMO^tu
0.0947
0.103
0.109
0.114
0105
0.107
0.111
0.123
0.123
0.116
SO? Em

Ibpollutant /
Ibfual
0.000824
0.000824
0.000826
0000825
0.000850
0.000844
0.000860

0.000851
ssions

lb/1 O^tu
0.0450
0.0449
0.0450
0045
0.0464
0.0461
0.0470

0.047
THn Pn

Ibpollutant/
Ibfuel
0.00115
nvalidated
0.00127
0.00128
000123
0.00084
nvalidated
0.00147
0.00138
0.00123
iccinnc

lb/106Btu
0.0627
invalidated
0.0691
0.0695
00671
0.0456
b
invalidated
0.0802
0.0754
0.0671
CHi Em

Ibpollutant / Ibfuel
0.00003
0.00003
0.00002
0.00003
000003
0.00003
0.00002
0.00002
0.00003
0.00003
issions

lb/106Btu
0.0017
0.0014
0.0012
0.0014
00014
0.0017
0.0013
0.0011
0.0014
0.0014
CO? Em

Ibpollutant/ Ibfuel
3.33
3.32
3.40
3.45
338
3.33
3.37
3.56
3.43
3.42
ssions

lb/1 O^tu
182
181
185
188
184
182
184
195
188
187
SO2 emission rates calculated based on fuel analyses for sulfur content.
Any tests exceeding the analyzer drift requirements are labelled as invalidated.
Test runs conducted to replace invalidated runs.
                                2-7

-------
The results in Tables 2-4 and 2-5 indicate that for the majority of pollutants, the fuel cleaning process did
not result in a statistically significant impact on engine emissions.  Average emissions rates for all of the
pollutants were consistent throughout all of the contaminated and cleaned fuel test periods.  As discussed
in  Section  2-4,  the likely  explanation is that after  passing through  the engine's  fuel  filters, the
contaminated fuel's quality was essentially the same as the quality of the cleaned fuel.
2.3.2
        Emissions Performance
In addition to the emission rates, the engine's fueling and  heat  rates are required to determine the
emissions performance in terms of Ibp0iiutant/lbfuei.  Table 2-6 presents the fueling and heat rates for each of
the test runs.
Table 2-6. Genset Fuel Consumption Rates
Fuel Condition
Contaminated Fuel
Treated Fuel
Run ID
1
2
3
3a
Average
4
5
6
6a
Average
Fuel Consumption Rate,
Ib/hr
88.80
90.94
89.66
88.60
89.50 ± 1.25
89.49
88.20
85.20
88.00
87.72 ± 2.13
Heat Rate,
106Btu/hr
1.6275
1.6686
1.6464
1.6269
1.6423 ± 0.0231
1.6378
1.6132
1.5597
1.6109
1.6054 ± 0.0386
Average fuel consumption and heat rates were similar for contaminated and cleaned fuels.  The value
measured during Run 6 (85.2 Ib/hr) is considerably lower than all other tests, but the GHG Center cannot
identify the reason for this difference.  Based on 95 percent confidence intervals of the means, and the
overall measurement uncertainty in the measurements,  the average values presented in the table overlap,
indicating  that  fuel treatment  using  the Enviro  System  did not  significantly affect  engine  fuel
consumption.  Also, the mass of contaminants collected on the engine filters while burning contaminated
fuel may have affected these measurements slightly  because the mass  of contaminated fuel drawn from
the day tank during each test is likely slightly higher than the mass of filtered fuel consumed.

As discussed in the previous section and shown in  Table 2-5,  emission rates were nearly uniform for
combustion of both contaminated and treated fuel.  For each pollutant, a t-statistic  was computed to
determine  if measured differences in emission rates between contaminated  and cleaned  fuel  were
statistically significant.  This t-statistic, compared to a Student's T distribution value for a 95 percent
confidence level, indicates whether or not a statistically valid difference in average emission rates of each
pollutant exists.  The Student's T value depends on the number of test runs (np) for both contaminated and
cleaned fuel. If the t-statistic is less than the corresponding Student's T value, then it is 95 percent certain
that there is no  statistically significant  difference between emission rates for contaminated and cleaned
fuel. Table 2-7 summarizes the t-statistics for each of the pollutants examined.

T-statistics for emission performance in terms  of lbpoiiutant/106Btu are  similar to those in Table 2-7, and are
not presented here.
                                                2-8

-------
Table 2-7. Differences in Emission Rates
Pollutant
CO
CO2
NOX
SO2
THCs
TPM
Average Emission Rate
- Contaminated Fuel,
Ibpollutant/lbfuel
0.00193
3.38
0.0490
0.000825
0.00123
0.00155
Average Emission Rate
- Treated Fuel,
Ibpollutant/lbfuel
0.00212
3.42
0.0484
0.000851
0.00123
0.00151
Average
Difference",
%
-9.6
-1.4
1.3
-3.2
0.1
2.4
<
6
6
5
4
4
4
To.025,np
2.447
2.447
2.571
2.776
2.776
2.776
t-statistic
-1.7
-0.77
0.31
5.7
0.006
0.16
a Average Difference = (contaminated rate - treated rate) / contaminated rate * 100
b np = (number of valid contaminated fuel test runs) + (number of valid cleaned fuel test runs) - 2
Because the t-statistics are less than the Student's T values for all pollutants other than SO2, differences in
emission rates cannot be considered statistically significant.  Because emissions testing results for SO2
emissions were invalidated, the reported rates were calculated from fuel sulfur content. The fuel sulfur
content was approximately 3.4 percent higher after treatment of the fuel.  This difference accounts for the
apparent significance of the increase in calculated SO2 emission rates during the tests conducted  with
treated  fuel.  As described below, the increase in fuel sulfur was likely related  to the AFC-705 fuel
additive used. The small predicted increase  in SO2 emissions is meaningful  only  to the extent that the
fuel sulfur increase is representative.

The data  also indicate a 9.6 percent increase in CO emissions after treatment, but this increase is not
statistically  significant based on  a 95  percent confidence interval (largely  due to variability  in the
individual test run results).  The CO increase is only  statistically valid based on a confidence interval of
85 percent.

2.4    FUEL QUALITY AND FUEL CLEANING  PERFORMANCE
2.4.1
        Fuel Quality
The fuel quality  testing  was  conducted  in conjunction  with the  emissions testing  and  included
determination of fuel properties  and generator fuel consumption  rates.   Documentation  of sample
collection logs, laboratory  results, certifications, and ASTM method control charts is maintained at the
GHG Center.

Fuel quality properties were evaluated by submitting contaminated  and treated fuel samples collected
during each test run to SwRI for analysis.  Table 2-8 summarizes the results of these analyses.
                                                2-9

-------
Table 2-8. Fuel Quality for Contaminated and Treated Fuel3
Test Parameter
Density (° API)
Flash Point (°F)
Sulfur (mass %)
Ash (mass %)
Lubricity (mm
scar)
Cetane Number
Gums and Resins
(me/100 mL)
Water and
Sediment
(volume %)
Particulate Matter
(mg/L)
LHVb(Btu/lb)
Contaminated Fuel Samples
Runl
34.2
163
0.0412
< 0.001
0.410
46.7
46.4
0.023
24.3
18328
Run 2
34.2
163
0.0412
< 0.001
0.345
46.7
39.3
0.025
5.2
18347
Run 3
34.2
165
0.0413
< 0.001
0.370
46.7
47.0
0.045
9.2
18363
Average
34.2
164
0.0412
< 0.001
0.375
46.7
44.2
0.031
12.9
18346
Treated Fuel Samples
Run 4
34.2
165
0.0425
< 0.001
0.375
48.4
72.1
0.130
3.8
18302
Run 5
34.1
165
0.0422
< 0.001
0.355
47.8
75.1
0.075
10.4
18290
Run 6
34.1
167
0.0430
< 0.001
0.370
47.8
63.0
0.028
7.1
18306
Average
34.1
166
0.0426
< 0.001
0.367
48.0
70.1
0.078
7.1
18299
a All samples were collected after fuel filtering by the engine filtering system, and the filters were changed prior to each test
b Values represent the average of duplicate analyses conducted on each sample
Section 1.4.4 described the procedure used by the GHG Center to determine if significant or statistically
valid differences in the physical properties were evident after treatment by the Enviro System.  Using the
results presented in Table 2-8,  this statistical analysis was conducted for each  parameter, and the results
are summarized in Table 2-9.
Table 2-9. Differences in Fuel Properties for Contaminated and Treated Fuel
Test Parameter
Density (° API)
Flash Point (°F)
Sulfur (mass %)
Ash (mass %)
Lubricity (mm scar)
Cetane number
Gums and Resins
(mg/100 mL)
Water and Sediment
(volume %)
Particulate Matter (mg/L)
LHV (Btu/lb)
Average Value -
Contaminated
Fuel
34.2
163.7
0.0412
0
0.375
46.7
44.2
0.031
12.9
18346
Average Value -
Treated Fuel
34.1
165.7
0.0426
0
0.367
48.0
70.1
0.078
7.1
18299
Average
Difference
-0.10
2.00
0.0014
0
-0.008
1.3
25.9
0.047
-5.8
-47
t-statistic
2.000
-2.120
-5.657
0
0.420
-6.500
-5.86
-1.342
0.97
4.16
np
4
4
4
4
4
4
4
4
4
4
Tfl.025, np
2.776
2.776
2.776
2.776
2.776
2.776
2.776
2.776
2.776
2.776
Statistically significant changes in density, flash point, lubricity, water and sediment, and ash were not
evident.  Fuel quality properties including sulfur content, cetane number, and gums and resins all had
                                               2-10

-------
statistically significant changes after treatment.   Each  of these average  values was higher after fuel
cleaning.

The increase in sulfur is possibly related to the 9 ounces of AFC-705 additive with which JCH dosed the
fuel  during  cleaning and  treatment.    Algae-X  International  stated  that the  AFC-705  contains
approximately 1.1 mass percent sulfur.  This means that the additive brought approximately 0.0054 pound
sulfur to the  approximately  1,300 pounds of fuel in the test day tank  at the start of JCH's treatment
schedule.  Based on this rough mass balance calculation,  the AFC-705 increased the fuel sulfur by 0.0004
percent, compared to the 0.0014 percent average shown in Table 2-8. This is about a third of the reported
sulfur increase at the reported level of additive.  No other source  of added sulfur in the fuel was apparent.

The increase in cetane number, although small, is also consistent  with the AFC-705 additive.  Algae-X
International publications state that, at normal treatment levels (0.5 ounce per 20 gallons, or 1:5000), the
additive increases the cetane number by approximately 0.7.  This is consistent with the 1.3 cetane number
increase reported here at a treatment level of approximately 2 times the normal treatment level.

The gums and resins analyses were also higher after treatment.   This may be due to the operations of the
engine's fuel filters as they filter particulate, asphaltines, gums  and resins, and other contaminants from
the fuel.  The GHG Center believes that the unexpected increases in gums and resins are the result of the
samples' being collected downstream of the engine filtering system.

The sampling  protocol used during this verification prevented the GHG Center from  conducting a true
evaluation of fuel properties before  and  after  treatment.  A more detailed discussion of this sampling
problem and the true fuel cleaning performance of the Enviro System is presented in Section 2.4.2.

Microbial contamination of the fuel was evaluated by visual inspection of the Liqui-cult samples after the
required incubation time (30 hours for bacterial growth and 72 hours for fungal growth).  Results of the
tests are summarized in Table 2-10.
Table 2-10. Results of Microbial Contamination Tests
Sample ID
Contaminated 1
Contaminated 2
Contaminated 3
Treated 1
Treated 2
Treated 3
Incubation Time, hrs
Bacterial
36
33
33
31
28
38
Fungal
75
74
72
74
75
75
Visual Condition '
Bacterial
Heavy
Moderate
Slight
Slight
Slight
Slight
Fungal
Heavy
Heavy
Heavy
Slight
Slight
Slight
Corresponding Count
Number
Bacterial
105
104
103
103
103
102
Fungal
106
106
106
10
10
10
a Visual condition is determined by comparison of sample appearance to Liqui-cult reference charts
Test results show that bacterial contamination in the contaminated fuel varied from slight to heavy,  and
that  fungal  contamination was heavy in all  samples.    After  fuel  treatment, bacterial  and  fungal
contaminations were slight in all samples collected, indicating that the Enviro System treatment was
effective in reducing these contaminants.
                                              2-11

-------
2.4.2    Fuel Cleaning Performance

The Test Plan specified  an evaluation  of the  fuel cleaning performance of the Enviro  System by
examining the fuel properties test results before and after treatment, and computing the percent difference
where statistically significant differences were observed. However, to make a sound evaluation of the
effect of fuel cleaning  on engine emissions, the Test  Plan  specified that  all fuel samples would be
collected downstream of the engine fuel filtering system (thereby examining the fuel quality as combusted
by the engine before and after cleaning).  Upon review of the test results, JCH and the GHG Center
determined that a true evaluation of the Enviro System's fuel cleaning performance would have required
that samples be collected upstream of the engine's fuel filter to examine properties of the fuel  in the tank,
prior to being filtered by the engine's filters.  Because samples were not collected upstream of the engine
filters during the test campaign, this  verification parameter could not be evaluated. In fact, for this reason
fuel quality  parameters  appear to be relatively similar, whether dirty or cleaned fuel was present in the
tank (i.e., the engine's filters cleaned the dirty fuel before sampling occurred).

The fuel quality properties analyses discussed in Section 2.4.1 indicated that the gums/resins values for
samples collected in the  return line were higher after treatment with the  Enviro System.   But after
reviewing field notes recorded during the testing and photographs of  the engine filters before and after
fuel  treatment, it is visually  clear that  the Enviro  System does provide significant  fuel cleaning.
Moreover, while combusting contaminated fuel prior to the beginning of testing, the engine  could only
run at full load for about 2.5 hours before the engine filters clogged and stalled the engine.  In anticipation
of this problem, the Test Plan specified that the engine's filters be changed before all test runs.

Results  for water and sediment content in the fuel were very low for both the contaminated and cleaned
fuel runs, and as such, differences between these two cases are not significant.  It is important to address
why some individual cleaned-fuel  test  runs showed  apparent  increases for these parameters.  Three
considerations may explain these increases, as well as the increases in gums and resins.  First,  it is
possible that, as the  test day tank emptied,  small amounts  of water that  had not been collected by the
Enviro System were circulated into the fuel intake hose. After the test campaign  was completed, JCH
personnel stated that their normal field practice  is to collect the water and  sediment that settles to the
bottom  of a fuel tank with a separate probe and  suction pump prior to treating the fuel with the Enviro
System.  This procedure was not followed during the test campaign, and some water may  have remained
in the test day tank during the cleaned fuel test runs.  Thus, as the fuel was consumed and the  level in the
test day tank was drawn down, residual water could have been circulated past the fuel intake hose.

Second, the ASTM  D-2709 test method's uncertainty becomes  very large when water and sediment
concentrations are small.  The method's 0.041  percent  reproduceability is  a significant fraction of the
highest  concentrations  found  (0.130 volume  percent)  and  could completely  obscure  the lower
concentrations (0.005 to 0.025 volume percent).

Third, the Enviro System's fuel cleaning filters have particle size cut  points of 10 and then 2  um,
compared to the genset's 20-um cut point for the fuel cleaning filters.  It stands to reason that the engine
filters would not experience clogging or  even significant caking of material from particulate, gums and
resins, water and  sediment, and other insoluble contaminants after fuel cleaning using the Enviro filters.
Photographs of the filters used during the verification support this  (very little material is visually evident
on the filters after fuel cleaning with the Enviro System).

Conversely, during combustion of contaminated fuel, each engine fuel filter showed significant material
lodged on the filter pleats.  Depending on levels of contamination, eventual clogging of the secondary
                                              2-12

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filter and starvation of the engine's fuel supply could occur. This did occur after approximately 2.5 hours
of run time the day prior to the start of testing.  Additionally, caking of the secondary filter may  reduce
the cut point of the filter, actually increasing its efficiency and accelerating the clogging process.   Figure
2-2 shows one of the filters used during the verification while combusting the contaminated fuel. A large
amount of contaminants is visually apparent on this filter after only approximately 1.5 hours of genset
operation at full load.
                Figure 2-2. Engine Filter after Operation with Contaminated Fuel
Conversations  with the engine  manufacturer,  fuel  testing laboratory,  and  two filter manufacturer
representatives  indicated that this could be an explanation for these data.  It may have been possible for
the filter cake,  which built up very quickly  while filtering the contaminated fuel, to have increased the
filter's efficiency, reduced the cut point, and reduced the amount of contaminants appearing in the fuel
samples.  This  is consistent with research performed  by Hastings Filters, Inc. on a Fleetguard FS-1000
spin-on fuel-filter/water-separator similar to  those used on the test engine.  SAE J905 performance tests
showed a 18.9  percent increase in mass filtering efficiency from beginning to end of life for this filter
(Hastings, 2001).

After cleaning,  the remaining contaminants would have been those which would pass the Enviro System's
2-um filter.   Such contaminants  would also  have easily passed through a new filter's 20-um pores and
been retained in the fuel as it was combusted.
                                               2-13

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                               3.0  DATA QUALITY ASSESSMENT
3.1    DATA QUALITY OBJECTIVES

In verifications  conducted  by the GHG  Center and  EPA-ORD,  measurement  methodologies  and
instruments are selected to ensure that a desired level of data quality exists in the final results.  DQOs are
established for key verification parameters before testing commences.  These objectives must be achieved
in order to  draw  conclusions with the desired level of confidence.  The primary JCH verification
parameters were based on comparisons of engine emissions while combusting contaminated and cleaned
fuel, and the quality of contaminated fuel and fuel cleaned using the Enviro System.

The  process of establishing  DQOs  for  stack  emissions  performance  starts  with  identifying  the
measurement variables that affect the verification parameters.  For example, determination of changes in
NOX emissions in units of lbpoiiutant/lbfuei first requires determination of NOX emissions from cleaned  and
contaminated fuels.

Each of these two determinations requires measurement of three separate variables:  NOX concentrations,
exhaust gas flow rate, and fuel consumption.  The errors associated with each of these measurements must
be accounted for to determine their cumulative effect on emissions performance. The Test Plan did this by
assuming that measurement errors are not random, and that these errors  can be combined to  produce a
worst-case overall error in the verification parameter. For NOX, assuming a  10 percent reduction in stack
gas concentration,  the  resulting emissions performance in terms of lbpoiiutant/lbfuei would be -9.5 ± 5.4
percent.  Note that the accumulated uncertainty is more than half the emissions performance. This shows
how smaller emissions performances resulting from smaller changes in stack gas concentration would be
obscured by the inherent measurement uncertainty.  In this  case, ± 5.4 percent is the DQO for NOX
emissions performance.

For fuel cleaning performance, the DQO is based on the associated ASTM method's uncertainty for each
fuel property.  In the simplest case, the  DQO is twice the method error.  LHV measurement error, for
example, is ± 0.53 percent.  The difference between contaminated and cleaned fuel must be at least twice
that value to achieve the DQO.

Table 3-1 recapitulates the Test Plan's DQOs.
                                              3-1

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Table 3-1. Verification Parameters and Data Quality Objectives
Verification Parameters
Changes in Engine Emissions (DQO represents the
maximum error in propagated measurements, based on a
10 percent reduction in emission rates in units of
Ibpollutant/lbfuel)-
Fuel Cleaning Performance (DQO represents the
minimum percent change in each fuel quality parameter
needed to draw valid conclusions from the results).
CH4
CO
C02
NOX
S02
THCs
TPM
°API
Ash
Cetane Number
Flash Point
Gums and Resins
LHV
Lubricity
Particulate
Water and Sediment
DQO, %
± 7.30
± 7.50
± 7.50
± 5.40
± 7.60
± 7.40
± 4.50
+ 0.44
+ 42.00
+ 15.90
+ 10.00
+ 60.00
+ 1.05
+ 43.00
+ 57.20
+ 23.30
To  determine whether the DQOs listed above were met during the verification testing, data quality
indicator (DQI) goals were established for each key measurement performed in the verification test.  The
DQI goals,  specified in Tables  3-2  (fuel consumption and  emissions) and 3-6 (fuel quality),  contain
accuracy and completeness levels that must be achieved to ensure that DQOs were met.  Reconciliation of
DQIs is  conducted by performing independent performance checks  in the field and/or laboratory, by
following reference method QA/QC procedures, and factory-calibrating the instruments  prior to use
where applicable. The following discussion illustrates that most DQI goals were achieved and, therefore,
the  measurements data are reliable.   A true reconciliation with the DQOs could not be made, however,
because the DQOs were based on changes in emissions and fuel quality. Verification results presented in
Section 2.0 showed that changes in these values were either statistically insignificant, or lower than the
thresholds specified in  Table 3-1.  Further discussion of this and other data quality results is provided
below.

3.2    RECONCILIATION OF DQOS  AND DQIS

Tables 3-2 and 3-7 summarize the range of measurements observed in the field and the completeness
goals.  Completeness is defined as the number of valid determinations expressed as a percent of the total
tests or readings conducted.  The completeness goals were to obtain 1 hour of valid emissions data for a
total of three test runs with contaminated and cleaned fuel,  and to collect one fuel properties sample
during each test run.  Table 3-2 also includes accuracy goals of measurement instruments that are used to
compute DQOs for key verification parameters.   Measurement accuracy was evaluated using instrument
calibrations  conducted  by manufacturers, field calibrations,  reasonableness checks,  and/or independent
performance  checks with  a second instrument.   The accuracy results for each  measurement, and their
effects on the DQOs, are detailed in the following subsections.

The following  discussion illustrates  that the accuracy goals were met  or exceeded  for each of the
measurement variables.   However,  changes in emissions and  fuel properties  were very small  and,
therefore, the data quality objectives  were not met,  even though the measurement accuracy goals were
met.
                                               3-2

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Table 3-2. Summary of Data Quality Goals and Results
Measurement Variable
Fuel
Consumption
Ambient
Conditions
Genset
Emissions
Fuel Tank
Weight
Ambient
Temperature
RH
NOX Levels
CO Levels
CO2 Levels
Oi Levels
CH4 Levels
THC Levels
Stack Gas Flow
TPM Levels
SOi Levels
Instrument Type
or Principle of
Detection
Fairbanks Model IQ-
5900C Platform
Scale
RTD / Vaisala Model
HMP35A
Vaisala Model HMP
35A
Chemiluminescent/
Monitor Labs 8840
NDIR/ Monitor Labs
8830
NDIR / Nova Model
372WP
Paramagnetic /
California Analytical
100P
GC/FID
FID/California
Analytical 300M
Pilot and
thermocouple
Gravimetric
Barium-thorin
titration
Instrument
Range
2,000 Ib
-50 to 150 °F
0 to 100 % RH
0 to 5,000 ppmvd
0 to 500 ppmvd
0 to 20 %
0 to 25 %
0 to 160 ppmvd
0 to 500 ppmvd
not specified
not specified
Detection limit of
0.5 ppmv
Range
Observed in
Field
600 to 2,000 Ib
82to 100° F
7 to 24 % RH
1,150 to 1,275
ppmvd
70 to 95
ppmvd
8. 80 to 9. 93%
8. 50 to 9. 20%
0 to 3 ppmvd
60 to 110
ppmvd
28706 to
29410 scfm
0.026 to 0.040
gr/dscf
< 0.05 ppmv
Accuracy
Goal
± 0.1 %of
reading
±0.2 °F
± 2 % (0 to 90 %
RH)
± 5 % FSa
± 5 % FS
± 5 % FS
± 5 % FS
± 2 % of reading
± 5 % FS
± 5 % of reading
± 5 % of reading
± 5 % of reading
Actual
± 0.1 %of
reading
±.0.2 °F
± 2 % (0 to 90 %
RH)
< ± 4.9 % FSb
< ± 0.54 % FS
< ± 0.71 % FS
< 0.0 % FS
± 1.8% of
reading
± 1.0%FS
±3.88 %of
reading0
± 4.38 % of
reading0
± 2.0 % of
reading0
How Verified /
Determined
Field verification with
NIST-traceable standard
Instrument calibration from
manufacturer
Calculated following EPA
Reference Method
calibrations (before and
after each test run)
Completeness
Goal
100 % for
each
emissions test
1 -minute
readings for
all runs
3 valid runs
per condition
Actual
100 %
1 -minute
readings for
all runs
4 valid runs
per
condition
3 valid runs
per
condition
all runs
invalidated
a Full scale
b Contaminated fuel Run 3 drift was 4.9 percent of span. Average NOX value is the mean of Runs 1 , 2, and 3a for contaminated fuel
0 Total accumulated error (Shigehara et al., 1970)
3-3

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3.2.1
       Emission Measurements
The DQOs for emissions performance (defined as changes in emission rates) were based on anticipated
reductions in emission rates (10 percent) and the accuracy goals (DQIs) for each of the measurements
used in this determination  (including pollutant concentration, exhaust gas flow rate, fuel consumption,
and fuel LHV). Table 3-2 and the discussions below show that the DQI goals were met for emission
concentration measurements.  However, overall uncertainty in emission rate changes are a function of not
only measurement accuracy, but also the magnitude of the changes realized through use  of the Enviro
System.   Since no  statistically significant  changes in emission rates  were measured, uncertainty in
changes in emission rates  could not be evaluated.   The following paragraphs  discuss the data quality
evaluations associated with each variable measured to determine the pollutant emission rates.

3.2.1.1    Exhaust Gas Flow Rate and TPM Emissions

In the Test Plan, discussion of DQI accuracy goals were assessed from a worst case perspective; i.e., it
was assumed that individual measurement errors would be additive and would occur at their maximum
allowed values.  Of course this error accumulation rarely occurs, but a conservative approach is used in
the planning stage to help ensure that the instruments and procedures put in place will consistently meet
or better data quality goals.

Field and laboratory calibrations showed that the test instrumentation  errors were significantly smaller
than the method's allowed values as summarized in Table 3-3.
Table 3-3. Results of Additional TPM Emissions Testing QA/QC Checks
QA/QC Check
Minimum Sample Volume
Percent Isokinetic Rate
Analytical Balance
Calibration
Dry Gas Meter Calibration
Sampling Nozzle
Calibration
Pitot Tube Dimensional
Calibration / Inspection
Thermocouple Calibration
When
Performed/Frequency
after each test run
after each test run
once before analysis
once before and once
after testing
once for each nozzle
before testing
once before and once
after testing
once after testing
Expected or Allowable
Result
corrected vol. > 31.8 dscf
80 % < I < 120 %
± 0.0001 g
±5%
± 0.004 in.
see 40CFR60 Method 2,
Section 10.0
± 1 .5 % of average stack
temperature recorded during
final test run
Results Achieved
all acceptable except for
Runl (3 1.45 dscf)
all acceptable
(99 to 101 %)
± 0.0001 g
±0.3 %
± 0.0002 in.
Pitot acceptable
± 0.7 %
As opposed to the conservative approach used in planning, anormally distributed errors rarely compound
additively.  A more realistic approach is to estimate a "three sigma" error as the square root of the sum of
the errors squared (Shigehara  et al.,  1970).  Table 3-4 illustrates this estimation for the exhaust gas flow
and particulate emission rates.
                                               3-4

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Table 3-4. Exhaust Gas Flow and Particulate Emission Rate Error Propagation
Contributing Parameter
Atmospheric Station Pressure (in. Hg)
Pitot Coefficient (dimensionless)
Stack Gas Moisture Content (proportion)
Stack Gas Molecular Weight (Ib/lb mol)
Stack Gas Temperature (°F)
Stack Static Pressure (in. H2O)
Velocity Pressure (in. H2O)
Jl^err2 ) (Exh. Gas Flow, dscf/hr or Ib.mol/hr )
Particulate Catch (g)
Sample Volume (dscf)
"VvS err 2 ) (^articulate Emissions, Ib/hr)
As-Found Error, %
+ 0.35
+ 0.98
+ 0.50
+ 0.25
+ 0.70
+ 1.28
+ 3.40
±3.88
+ 0.42
+ 2.00
±4.39
The 3.88 percent error found during field testing for exhaust gas flow rate is less than the 5 percent error
assumed in the Test Plan.  Compounding of the particulate  weight and sample volume errors with the
exhaust gas flow rate error yields a total estimated TPM emission rate error of 4.39 percent.  This is also
less than the 5 percent error assumed in the Test Plan.

3.2.1.2    Gaseous Pollutant Emissions

EPA Reference Methods  were used to quantify emission rates of criteria pollutants and GHGs.  The
Reference Methods specify the sampling and calibration procedures, and the data quality  checks that must
be followed.  For the instrumental methods (CO, CO2, NOX, O2, and THCs), these methods ensure that
run-specific  quantification of  instrument and sampling system drift and accuracy  occurred  for each
emissions test.  The DQIs  specified in  the  Test Plan were the sampling system bias determinations
conducted before and after each test.  The methods specify a system bias of ± 5 percent of span or less for
each of the pollutants.

These calibrations  are conducted by introducing the zero gas and an upscale gas for each parameter into
the sampling system at  the probe and recording the system  response.  Sampling system bias was then
calculated by comparing  the  system  responses to the analyzer calibration errors  determined  at  the
beginning of each day (see  discussion below).  The system bias  was recorded and had to be within 5
percent of instrument span for the system to be acceptable for testing. Measured pollutant concentrations
were corrected for system bias in accordance with the  reference methods. As shown in  Table 3-2, the
system bias checks for CO, CO2, NOx, O2, and THCs were less than 0.5, 0.7, 4.9, 0.0,  and 1.0 percent,
respectively.

Following Method 6C specification criteria, the  system bias checks were conducted before and after each
test period.  In some cases where these criteria were exceeded, the runs were invalidated and repeated.
The pre- and  post-test system bias calibrations were also used to calculate analyzer drift for each pollutant
analyzer. All drift checks  for each of the pollutants were well within the specified  3 percent of instrument
span for all valid runs.  In conclusion, the system bias goals and drift goals  were met for all pollutants
during validated test periods.
                                               3-5

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Other QA/QC checks conducted during the verification were analyzer calibration error tests.  These were
conducted at the beginning of each day of testing.  During these calibrations, a suite of calibration gases
was  introduced directly to each analyzer  and the  analyzer responses were recorded.  EPA Protocol 1
calibration gases were used  for these calibrations.   Three gases were used for NOX, CO2, and O2,
including: 0, 40 to 60 percent of span, and 80 to  100 percent of span.  Four gases were used for CO and
THC including: 0 and approximately 30, 60, and 90 percent of span.  The analyzer calibration errors for
all gases other than THC were below the allowable levels (2  percent of instrument span) as shown in
Table 3-5.   THC error was slightly higher  during one calibration (-2.2 percent), but this was not expected
to affect test results (note that Reference Method 25A for THC does not specify this additional QA/QC
check).  Results of each of the sampling system calibrations, including bias and drift checks,  are presented
in Appendix A-l.
Table 3-5. Results of Additional Gaseous Pollutant Emissions Testing QA/QC Checks
Parameter
NOX
CO, CO2,
NOX, 02,
THCs
QA/QC Check
Analyzer interference
check
NO2 converter
efficiency
Analyzer calibration
error test
When
Performed/Frequency
once before testing
begins
once before testing
begins
daily before testing
Expected or Allowable
Result
± 2 % of analyzer span
or less
98 % efficiency or
greater
± 2 % of analyzer span
or less
Maximum Result
Measured During
Tests (%)
0.00
98.7
0.7 % for CO
-0.1 %forCO2
0.1 %forNOx
0.2 % for 02
-2.2 % for THCs
Two additional QA/QC checks were performed to better quantify the NOX data quality.  An interference
test was conducted on the NOX analyzer once before the testing started to confirm that the presence of
other pollutants in the exhaust gas did not interfere with the accuracy of the NOX analyzer.  This test was
conducted by injecting the following calibration gases into the analyzer and recording the response of the
NOX analyzer, which must be 0.0 ± 2 percent of span:

       •   CO - 3980 ppm in balance nitrogen (N2)
       •   CO2-8.01 percent in N2
       •   O2 - 8.03 percent in N2
       •   SO2-97.8ppminN2
As shown in Table 3-5, no value greater than zero was observed, so the analyzer passed the test.

The NOX analyzer converts any NO2 present in the gas stream to NO prior to gas analysis.  The second
QA/QC check consisted of determining NO2 converter efficiency prior to beginning emissions testing.
This was done by introducing a mixture of mid-level calibration gas and air to the analyzer. The analyzer
response was recorded every minute for 30 minutes.  If the NO2 to NO conversion was  100 percent
efficient, the response would have been stable at the highest peak value observed.  If the  response
decreased by more than 2 percent from the peak value observed during  the 30-minute test period, the
converter would have been judged faulty and the analyzer would have needed repair or replacement prior
to testing. As shown in Table 3-5, the converter efficiency was measured  at 98.7  percent and was above
the efficiency level required.
                                               3-6

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As shown in Table 3-2, the CH4 analyses reported a DQI of approximately 1.8 percent accuracy.  The
GC/FID  used for  CH4  analyses was fitted with a linear calibration curve developed using  analyzer
calibrations to four levels of NIST-traceable calibration standards.  The calibration curve was then tested
using a fifth calibration standard (an audit sample). Accuracy was then defined as the difference between
the audit sample and the instrument response, in this case 1.8 percent.

As reported in Section 2.3.1, the Method 6 testing for SO2  emissions was invalidated due to questionable
results (all were below the detection limit of approximately 0.5  ppmv).  Following Method 6, several
QA/QC checks were conducted in the field and laboratory, and acceptable results were reported for all
checks. These included:

       •  Pre- and post-test dry gas meter calibrations met the method specification
       •  Sampling train leak checks before and after each test run were all acceptable
       •  The barium standard solution was standardized to a normality of 0.008247
       •  Replicate titrations were conducted  on each sample, and all were within  the specified
           difference of ± 1 percent

Since all of the method QC criteria were either met or exceeded, it is  unclear why test results were non-
detectable when small levels of SO2  were expected.  For this reason,  the GHG Center invalidated these
results and relied on the sulfur content in the fuel to calculate theoretical SO2 emissions.

3.2.1.3    Propagation of Errors for Emission Rate Measurements


Emission rate determinations for all pollutants in terms  of lbpoiiutant/lbfuei and lbpoiiutant/106Btu require the
following measurements:
       •  Stack gas flow rate, Ib.mol/hr (for gases) or dscf/hr (for particulate)
       •  Pollutant concentration, ppmvd (for gases) or Ib/dscf (for particulate)
       •  Fuel mass consumption rate, Ib/hr
       •  Fuel LHV, Btu/lb

Table 3-6 shows how errors in each of these measurements compounded to yield an estimate of the total
measurement error.
Table 3-6. Particulate and Gaseous Pollutant Emission Rate Error Propagation
Contributing Parameter
Fuel Mass Consumption Rate (Ib/hr)
LHV (Btu/lb)
TPM Emission Rate (Ib/hr)
•J(^err2) (Particulate lb/106Btu)
Exhaust Gas Flow Rate (Ib.mol/hr)
Fuel Mass Consumption Rate (Ib/hr)
Gaseous Pollutant Concentration (ppmvd)
LHV (Btu/lb)
J(^err2 ) (Gaseous Pollutant lb/106Btu))
As-Found Error, %
+ 0.03
+ 0.12
+ 4.39
±4.39
+ 3.88
+ 0.03
+ 1.003
+ 0.12
±4.01
a Average uncertainty for all pollutant gas measurements was < 1 .00 percent
                                               3-7

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The Test Plan included an example error propagation for NOX emissions.  The analysis  concluded that
given the method's maximum allowed uncertainty for  each contributing parameter, the  expected error
would be 9.6 percent of the individual NOX lb/106Btu determination.  Expected errors for  particulate and
other  gas emissions are similar.  The 4.39 and 4.01 percent errors (for particulate and gaseous emissions,
respectively) cited in Table 3-6 are less than the expected uncertainties and meet the Test Plan objectives.

3.2.2    Fuel Quality Performance

Fuel cleaning performance was based on the percent change in fuel properties between contaminated and
cleaned fuels.  Similar to emissions performance, the DQOs listed in Table 3-1 were therefore developed
based on anticipated changes in fuel properties. The Test Plan specified a set of ASTM fuel test methods
to measure the fuel properties of interest, and each method for each fuel property had an associated error
estimate.  These error estimates were the DQIs used to develop the DQOs.  The DQO  for the percent
change in each fuel property was  therefore based on the estimated measurement error  (DQI) for that
property, and expected differences in the properties for contaminated and treated fuels.

Table 3-7 summarizes the DQIs for each of the fuel property  measurements.  Table 3-7 includes the
expected or allowable result (based on anticipated levels of change), the range of measurements observed
during the testing, and the actual measurement error (DQIs) for each measurement type.

The percent difference between contaminated  and cleaned fuel properties must be larger than the values
in Table 3-1 to draw valid conclusions.  For example, LHV for cleaned fuel must be at least 1.05 percent
different from LHV for contaminated fuel to conclude that JCH's technology has an effect.

For all fuel quality analyses, the GHG Center used industry-standard methods developed by ASTM, and
believes the QA guidelines required  by those  standards provide a sound,  defensible, and industry-
accepted way of ensuring that good quality data were collected.   Further, these methods provided  an
industry-accepted means by which data quality was determined and reported and, thus, are used to judge
how close SRI came to achieving its original DQOs for fuel quality.
                                              3-8

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Table 3-7. Summary of Fuel Properties Data Quality Indicators
Measurement
Variable
Mass Consumption
D-4809
LHV
D-4052
°API
D-93
Flash Point
D-2709
Water and
Sediment
D-482
Ash
Calibration - QA/QC
Check
Platform scale NIST
calibration
*Scale field verification
*Benzoic acid SRM
analysis
Duplicate sample
analysis
Balance verification
Equipment calibrations
*Water SRM analysis
*Heptane SRM analysis
*Anisole analysis
n-Decane analysis
Equipment calibrations
Comparison of the two
centrifuge tube readings
Equipment calibrations
*Duplicate sample
analysis
Reference oil analysis
Oven temperature record
Equipment calibrations
Balance verification
*Duplicate sample
analysis
When Performed /
Frequency
Once before testing begins
Once before testing begins
Once after testing ends
Once per shift
Once per shift
Once per sample
Within 6 months
Once per shift
Once per shift
Once per shift
Within 6 months
Within 6 months
Once per sample
Within 6 months
Once for each Run 2,
contaminated and cleaned
fuel
Once per shift
Once per sample
Within 6 months
Once per sample
Once for each Run 2,
contaminated and cleaned
fuel
Expected or Allowable
Result
±0.1 % of reading
±0.1 % of reading
±0.1 % of reading
1 1308.79 ± 16.63 Btu/lb
± 50 Btu
±0.1 mg of Class A mass
standard
Varies; see Section 2.4
0.9999 ±0.0004
0.6885 ±0.0002
117±2°F
127 ± 4 °F
Varies; see Section 2.4
± 1 scale division
Varies; see Section 2.4
at 3% water cone., duplicates
must be within ± 0.4%
1.675% (mass) ±0.1 48%
775±25°C
Varies; see Section 2.4
±0.1 mg of Class A mass
standard
Duplicates must be within
0. 18 ±0.024 mass %
Range Observed in
Field
S^ 0 Qfl Q IV./1-if

18281 - 18373 Btu/lb
34.1 -34.2°API
163 - 167 °F
0.005 -0.150vol. %
none detected
Results Achieved
(DQIs)
±0.0 %
+ 0.03 % average
- 0.04 % average
11372.4 + 8.1, -13. 4
Btu/lba
±19.3 Btu, average
±0.1 mg
Satisfactory
1.0000 ±0.0000
0.6884 ±0.0001
117 + 1 °F
131 °F
Satisfactory
Satisfactory
Satisfactory
Satisfactory; largest
difference was
± 0.04 %
1.675 + 0.041,
- 0.046 %
Not available13
Satisfactory
Not available0
Satisfactory; all results
were below the method
detection limit
                                                           (continued)
3-9

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Table 3-7. Summary of Fuel Properties Data Quality Indicators (continued)
Measurement
Variable
D-6217
Particulate
D-613
Cetane Number
D-2622 Sulfur
D-381
Gums and Resins
D-6079
Lubricity
Calibration / QA/QC
Check
Tare filter analysis
Balance verification
Equipment calibrations
*Duplicate sample analysis
*Consensus standard
analysis
Equipment calibrations
* Standard analysis
Equipment calibrations
Balance verification
*Duplicate sample analysis
*Cat 1-H oil analysis
*Isopar solvent/oil analysis
Cat 1-H and Isopar
duplicate analyses
Equipment calibrations
When Performed /
Frequency
Once per sample
Once per sample
Within 6 months
Once for each Run 2,
contaminated and cleaned
fuel
Once per shift
Within 6 months
Once per shift
Within 6 months
Once per sample
Once for each Run 2,
contaminated and cleaned
fuel
Every 20 samples
Every 20 samples
Every 20 samples
Within 6 months
Expected or Allowable Result
< 0.5 mg weight gain
± 0. 1 mg of Class A mass
standard
Varies; see Section 2.4
Duplicates must be within 10 ±
3. 6 mg/L
41.6 ± 0.9 cetane numbers
Varies; see Section 2.4
± 0.002 wt% at expected cone.
Varies; see Section 2.4
± 0. 1 mg of Class A mass
standard
Duplicates must be within 20 ±
8.5mg/L
0.29 ± 0.08 mm WSD @ 25 °C;
0.41 ± 0.08 mm WSD @ 60 °C
0.58 ± 0.08 mm WSD @ 25 °C;
0.62 ± 0.08 mm WSD @ 60 °C
Duplicate results ± 0.08 mm
WSD @ 25 and 60 °C
Varies; see Section 2.4
Range Observed in
Field
3.8-24.3mg/L
46.7 - 48.4
0.041- 0.043 wt.%
39.1 -79.1 mg/100
mL
0.345 -0.410mm
WSD @ 60°C
Results Achieved
0>QIs)
Not availabled
±0.1 mg, average
Satisfactory
At 10.4, duplicate was - 0.8
mg/L
41.6 ± 0.5 cetane numbers
Satisfactory
±0.001 5 wt%
Steam jet calibration within
8 months; others are
satisfactory
±0.1 mg, average
At 79. 1, duplicate was -8.0;
at 39.4, duplicate was -0.3
mg/L
Satisfactory: 0.38mm
WSD@60°Ce
Satisfactory: 0.62 mm
WSD@60°Ce
Cat 1H ± 0.005,
Isopar ±0.01 mm WSD @
60 °C
Calibration within 8 months
* Results from these QC checks were used as the primary DQI goals
a Certified benzoic acid LHV was 1 1,373 Btu/lb
b Lab oversight. Logging of the oven temperature profile is a non-standard procedure
0 Although the SwRI formal report did not include the balance verification, it did include the NIST-traceable calibration from May 5, 2001
d SwRI did not submit blank filter analyses with the report
e Lubricity results reported for 60 °C only
3-10

-------
Each ASTM method specified a different combination of QA/QC checks, calibrations, reference material
analyses, duplicate sample analyses, and others as indicated.  ASTM states that, if each of these QA/QC
checks is performed according to the method, the corresponding sample analysis has a specific numerical
reproducibility.  ASTM further states that method accuracy  may be  derived from these reproducibility
results, and has justified this through extensive inter-laboratory round-robin testing for each method.

The Test Plan approach adopted for this verification was that the DQI goals must be met, and results of
specific pre-defined QA/QC checks (e.g., duplicate sample analysis, comparisons with standard reference
methods) were used to determine  if the DQIs goals were achieved. The data in Table 3-7 clearly show
that all of the  DQIs were met.  A true reconciliation with the DQOs was based on minimum changes in
fuel properties.   The DQI data  show that  SwRI's analyses exceeded the  methods' requirements for
reproducibility. This means that measurement uncertainties were less than those assumed in the Test Plan
to develop the DQO.  The results for most fuel properties, however, show no  statistically significant
difference between contaminated and cleaned  fuel.   For those that were statistically significant, the
differences were less  than  the minimum assumed in the Test Plan.  Appendices B-l and B-2 provide
additional detail regarding sample handling, and quality  control checks for each analysis.  Completeness
goals for fuel  quality analyses were to obtain three valid samples for  both contaminated and treated fuel
for each parameter.  Completeness goals were met.

3.2.3    Ambient Measurements

Ambient temperature and RH  at the test site were monitored throughout the test periods.  The instruments
used are identified in Table 3-2 along  with instrument ranges, data quality goals, and data quality
achieved.  A Vaisala Model 35HMP probe was used to monitor both temperature and RH.  The probe was
factory calibrated prior to the verification testing using reference materials traceable to NIST standards.
Results of these calibrations indicate that the ± 2 °F accuracy goal for temperature and ± 3 percent for RH
were met.

3.3    AUDITS

An audit of data quality (ADQ) was conducted by the GHG Center's  QA Manager.  To ensure that data
quality  objectives could be  met,  a pre-test audit was also conducted to  review  procedures and
experimental design during  Test Plan preparation.  The ADQ confirmed that the data handling system and
calculations conducted after collecting field data  were correct.  This was done  by  selecting a random
sample of data and tracing all of the calculations through the data processing sequence for each of the
primary verification parameters.
                                              3-11

-------

-------
                                      4.0  REFERENCES

American Society for Testing and Materials, ASTM Specification D 975 - 98b, Standard Specification for
Diesel Fuel Oils, Baltimore, MD, 1999.

Cummins Engine Company, Inc., Operation and Maintenance Manual - C Series Engines, Cummins P/N
3810354, Louisville, KY, 1991a.

Cummins Engine Company, Inc., Troubleshooting and Repair Manual - C Series Engines, Cummins P/N
3666003, Louisville, KY, 1991b.

Electrical  Generating  Systems Association (EGSA), Quarterly Generator Shipment  Survey for  the
Quarter Ended December 31, 2000, Boca Raton, FL, March 14, 2001.

Hastings Filters, Performance Testing: Fuel (SAEJ905), Data Sheet, Kearney, NE, 2001.

Onan Corporation, DGFC 60 Hz Diesel Generator Set, Form #S-1131b, Minneapolis, MN, 2001.

Onan Corporation, EPA Tier 1 Exhaust  Emission  Compliance Statement, 200DGFC 60 Hz Diesel
Generator Set, Form#EPAlCS-1018A, EDS-177A, Minneapolis, MN, 1999.

Shigehara, R.T., Todd, W.F.,  and Smith, W.S., Significance of Errors in Stack Sampling Measurements,
presented at the annual meeting of the Air Pollution Control Association, St. Louis, MO, 1970.

Southern Research Institute (SRI). Test and Quality Assurance Plan, JCH Fuel Solutions, Inc., Enviro
Automated Fuel Cleaning and Maintenance System, Research Triangle Park, NC, July 2001.

U.S. Environmental Protection Agency.  Code  of Federal Regulations, Title 40, Part 60 (Appendix A),
Reference Methods for Determination of Emissions Rates, Washington, DC, 1999.

U.S. Environmental Protection Agency.  Compilation of Air Pollutant Emission Factors, Fifth Edition,
Volume 1: Stationary Point  and Area Sources,  AP-42 (NTIS PB95-196028), Office of Air Quality
Planning and Standards, Research Triangle  Park, NC, January 1995.
                                             4-1

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-------
                                     APPENDIX A
Table A-l        Analyzer Spans and Calibration Gas Values	A-2
Table A-2        Summary of System Bias and Drift Checks	A-2
                                          A-l

-------
Table A-l. Analyzer Spans and Calibration Gas Values
Analyzer
NOX
CO,
o,
CO
THCs
Span
5000
14
25
408
500
Units
ppmv
%
%
ppmv
ppmv
Cal. Gas
2447
12.02
11.96
87.2
85.0
Units
ppmv
%
%
ppmv
ppmv
Table A-2. Summary of System Bias and Drift Checks
Run:
Analyzer,
Gas
NOX , Zero
NOx , High
CO2 , Zero
CO2 , High
Oi , Zero
O2 , Mid
CO, Zero
CO, Low
THCs, Zero
THCs, Low
QA/QC Check
System Response, ppm
System Bias, % of span
Drift, % of span
System Response, ppm
System Bias, % of span
Drift, % of span
System Response, %
System Bias, % of span
Drift, % of span
System Response, %
System Bias, % of span
Drift, % of span
System Response, %
System Bias, % of span
Drift, % of span
System Response, %
System Bias, % of span
Drift, % of span
System Response, ppm
System Bias, % of span
Drift, % of span
System Response, ppm
System Bias, % of span
Drift, % of span
System Response, ppm
System Bias, % of span
Drift, % of span
System Response, ppm
System Bias, % of span
Drift, % of span
Initial
Calibra-
tion
0.00
0.00

2447
0.00

0.00
0.00

12.00
-0.14

0.00
0.00

12.00
0.16

0.00
0.00

85.00
-0.54

0.00
0.00

85.00
0.00

1
Initial
0.00
0.00

2447
0.00

0.00
0.00

11.90
-0.86

0.00
0.00

12.00
0.16

0.00
0.00

87.00
-0.05

0.00
0.00

85.00
0.00

Final
0.00
0.00
0.00
2447
0.00
0.00
0.00
0.00
0.00
12.00
-0.14
0.71
0.00
0.00
0.00
12.00
0.16
0.00
0.00
0.00
0.00
87.00
-0.05
0.00
0.00
0.00
0.00
85.00
0.00
0.00
2
Initial
0.00
0.00

2447
0.00

0.00
0.00

12.00
-0.14

0.00
0.00

12.00
0.16

0.00
0.00

87.00
-0.05

0.00
0.00

82.00
-0.60

Final
0.00
0.00
0.00
2447
0.00
0.00
0.00
0.00
0.00
12.00
-0.14
0.00
0.00
0.00
0.00
12.00
0.16
0.00
0.00
0.00
0.00
87.00
-0.05
0.00
0.00
0.00
0.00
87.00
0.40
1.00
3
Initial
0.00
0.00

2447
0.00

0.00
0.00

12.00
-0.14

0.00
0.00

12.00
0.16

0.00
0.00

87.00
-0.05

0.00
0.00

87.00
0.40

Final
0.00
0.00
0.00
2200
-4.94
-4.94
0.00
0.00
0.00
12.00
-0.14
0.00
0.00
0.00
0.00
12.00
0.16
0.00
0.00
0.00
0.00
87.60
0.10
0.15
0.00
0.00
0.00
85.00
0.00
-0.40
3a
Initial
0.00
0.00

2200
-4.94

0.00
0.00

12.00
-0.14

0.00
0.00

12.00
0.16

0.00
0.00

87.60
0.10

0.00
0.00

260.00"
-0.20

Final
0.00
0.00
0.00
2200
-4.94
0.00
0.00
0.00
0.00
12.00
-0.14
0.00
0.00
0.00
0.00
12.00
0.16
0.00
0.00
0.00
0.00
86.90
-0.07
-0.17
0.00
0.00
0.00
255.00"
-1.20
-1.00
                                        (continued)
A-2

-------
Table A-2. Summary of System Bias and Drift Checks (continued)
Run:
Analyzer,
Gas
NOX , Zero
NOX , High
CO2 , Zero
CO2 , High
Oi , Zero
O2 , Mid
CO, Zero
CO, Low
THCs, Zero
THCs, Low
QA/QC Check
System Response, ppm
System Bias, % of span
Drift, % of span
System Response, ppm
System Bias, % of span
Drift, % of span
System Response, %
System Bias, % of span
Drift, % of span
System Response, %
System Bias, % of span
Drift, % of span
System Response, %
System Bias, % of span
Drift, % of span
System Response, %
System Bias, % of span
Drift, % of span
System Response, ppm
System Bias, % of span
Drift, % of span
System Response, ppm
System Bias, % of span
Drift, % of span
System Response, ppm
System Bias, % of span
Drift, % of span
System Response, ppm
System Bias, % of span
Drift, % of span
4
Initial
0.00
0.00

2447
0.00

0.00
0.00

12.00
-0.14

0.00
0.00

12.00
0.16

0.00
0.00

86.00
-0.29

0.00
0.00

85.00
0.00

Final
0.00
0.00
0.00
2447
0.00
0.00
0.00
0.00
0.00
12.00
-0.14
0.00
0.00
0.00
0.00
12.00
0.16
0.00
0.00
0.00
0.00
87.00
-0.05
0.25
0.00
0.00
0.00
86.00
0.20
0.20
5
Initial
0.00
0.00

2447
0.00

0.00
0.00

12.00
-0.14

0.00
0.00

12.00
0.16

0.00
0.00

86.00
-0.29

0.00
0.00

86.00
0.20

Final
0.00
0.00
0.00
2447
0.00
0.00
0.00
0.00
0.00
12.00
-0.14
0.00
0.00
0.00
0.00
12.00
0.16
0.00
0.00
0.00
0.00
87.00
-0.05
0.25
0.00
0.00
0.00
82.50
-0.50
-0.70
6
Initial
0.00
0.00

2447
0.00

0.00
0.00

12.00
-0.14

0.00
0.00

12.00
0.16

0.00
0.00

86.00
-0.29

0.00
0.00

85.00
0.00

Final
0.00
0.00
0.00
2447
0.00
0.00
0.00
0.00
0.00
12.00
-0.14
0.00
0.00
0.00
0.00
12.00
0.16
0.00
0.00
0.00
0.00
87.00
-0.05
0.25
0.00
0.00
0.00
83.00
-0.40
-0.40
6a
Initial
0.00
0.00

2447
0.00

0.00
0.00

12.00
-0.14

0.00
0.00

12.00
0.16

0.00
0.00

86.00
-0.29

0.00
0.00

87.00
0.40

Final
0.00
0.00
0.00
2447
0.00
0.00
0.00
0.00
0.00
12.00
-0.14
0.00
0.00
0.00
0.00
12.00
0.16
0.00
0.00
0.00
0.00
87.00
-0.05
0.25
0.00
0.00
0.00
87.50
0.50
0.10
a THC Run 3a Calibration Gas was 26 1 .0 ppm
A-3

-------

-------
                                    APPENDIX B
Appendix B-l     SwRI Sample Handling Procedures	B-2
Appendix B-2     SwRI Fuel Analysis QA/QC Procedure	B-4
                                         B-l

-------
                      Appendix B-l. SwRI Sample Handling Procedures


August 29, 2001


Dear Mr. Richards:

We received groups of 2.5 liter aluminum cans  labeled as follows,  accompanied by a chain of custody
form. Instructions on the chain of custody form were to combine these samples into containers to be used
for the following tests.  We were also instructed  to note which cans  had the locking ring removed.  Data
was handwritten on the chain of custody form  by our technical specialist.  He handled each group of
samples individually, so that all the containers were not open at one time, but only those containers for the
current  sample  group.  The combined samples  were given sample ID numbers  at this time,  and
instructions to "Shake well before sampling for  each test" were inscribed on the top of each combined
sample. The combined samples were put into 2-gallon translucent plastic jugs with handles, making them
easy to shake and to pour out for individual tests. These containers still contain sample, and are currently
being stored in our cold box to slow deterioration or microbial growth.

Can labels action sample ID

CLN20
CLN22 combined for Run 1 clean fuel 17043

CLN23
CLN25
CLN26 combined for Run 2 clean fuel 17044

CLN27
CLN29 combined for Run 3 clean fuel 17045

PT02
PT03 combined for "as received fuel" 17046 (open)

CONT01
CONT03 combined for Run 1 contaminated 17047 (open)

CONT04
CONT06
CONT07 combined for Run 2 contaminated 17048

CONT08
CONT10 combined for Run 2 contaminated 17049

The samples 17044  and 17048 contain more fuel than do the other  samples,  in keeping with their being
the 3-container samples.

                                                                                 (continued)
                                            B-2

-------
                  Appendix B-l. SwRI Sample Handling Procedures (continued)
Note  in  the  data  report,  that many  of the  test show consistent data for the "as  received"  and the
contaminated fuels, with consistently different data on the clean fuels.  These parameters include the
sulfur content, which is 0.0411 to 0.0413 in the dirty fuel, while the clean is 0.0422 to 0.0430.  The
carbon/hydrogen contents are very consistent across the dirty fuels, and show a distinct higher hydrogen,
lower carbon value in the  clean fuels. All of the gross heats of combustion for the dirty fuels are above
19500, while the clean fuels are all below 19500. The Cetane numbers of the dirty and as received  fuels
are all 46.7, while the clean fuel shows a consistently higher value, from 47.8 to 48.4. Even the density of
the samples is consistent, with the clean samples showing a very slightly heavier (0.8537) value than the
dirty and as received samples (0.8535 to 0.8536).  Gums and resins  also remain consistent among the
groups, with values of 39 to 47 for the as received and dirty, and values of 63 to 79.1 for the clean.

These basic fuel properties are consistent with a dirty fuel of a consistent C/H/S make-up which, in the
clean fuels, has been dosed with  a small amount of sulfur containing material, enough to add about 10
ppm sulfur to those  samples.  This additive is enough to affect some of the basic fuel  properties in a
detectable  way.  The values of water and sediment, or particulate contamination, can  easily  vary  by
differences in filtration characteristics of the particular samples we obtained, but the consistent change in
basic fuel  properties is consistent with an  added product  containing sulfur.   If there are  any other
identifiable components in the additive,  we  can further verify the sample identifications by measuring
those components.  If the product contains sulfur, this may be sufficient.

Please let me know if you have any further questions, or if there is additional information we can provide.
We Fed-Exed another copy of the  report to you today.

Thanks,
Karen Kohl
Petroleum Products Research Dept.
(210)522-2071  FAX (210)522-4544
kkohl@swri.org
                                               B-3

-------
                     Appendix B-2.  SwRI Fuel Analysis QA/QC Procedure


                                       QA Supplement
                                                                                 August 13, 2001
ASTM D 4809         Lower Heating Value
QA documents include control chart for benzoic acid, weight challenge information from the balance,
calibration  certificate from the balance, calibration certificate from the thermistor, and label from the
reference benzoic acid from the instrument manufacturer.
Also included in this section are control charts for the sulfur and carbon-hydrogen analyses used in the
heat-of-combustion calculation.
No unusual behavior was observed during testing. The data for this test are the average of two results.  In
the report table, the two individual data points are shown, followed by the average value underlined.
ASTM D 4052         Density, API Gravity, and Specific Gravity
QA documents  consist of a copy of a heptane label and the control charts for heptane and water for the
instrument used in the test.  The individual daily values for verification of the system are detailed and
dated in the table at the top of the control chart.  No unusual behavior was observed during testing.  All
three data points are available from the equipment at the time of analysis, so all three values are shown in
the report table.
ASTM D 93           Flash Point
QA documents include the control chart for Anisole, our daily control reference material, a calibration
certificate on the flash point analyzer,  including temperature  control, labels from our Anisole and our
decane.  The test value for the decane  was 131 °F, which is  within the allowed 52.8±2.3 °C  (122.9 to
131.2 °F). No unusual behavior was observed during testing.
ASTM D 2709         Water and Sediment
QA document consists  of the calibration verification certificate on the  centrifuge.  As no reference
material exists for this test, no control chart is available.   Since the test does not involve two tubes of
sample, the testing was  performed in duplicate, with both  results being reported.  The test results were
within the reproducibility of the ASTM test method, which  is 0.041 volume percent.  The sample labeled
Run 1 Clean fuel showed a clear bottom layer with a black interface between that layer and the brown
fuel layer. The sample labeled As Received fuel appeared as a tiny black interface with a tiny clear layer
under it.  The sampled  labeled as Run 3 Contaminated fuel appeared to be a very small solid black
residue.
                                                                                     (continued)
                                              B-4

-------
                Appendix B-2. SwRI Fuel Analysis QA/QC Procedure (continued)
ASTM D 482          Ash
QA documents consist of the control chart for the test, the calibration certificate for the furnace used in
the procedure, and the calibration certificate for the balance used in the procedure.  Weight verification
was performed using Ainsworth weight 100.0005 g, serial number 4254-S.  Duplicate analyses were
performed on two of the samples.   All results were < 0.001 mass percent, so all  were within expected
precision.  The only measurable weights occurred with the Run 2 Contaminated fuel, where weights of
0.0002 and 0.0003 g were observed.  These would have calculated to 0.0002 and 0.0003 mass percent.
All other values were 0.0000 g weight changes. No unusual behavior was observed during testing.
ASTM D 6217         Particulate Contamination
QA documents include verification certifications for the timer, the thermometer, and the balance used in
the procedure.  A sheet for weight challenge to the balance is also included, along with the certificate for
the weights used. Duplicate analyses were performed on two of the samples. These data were within the
expected precision for the procedure of within 2.19 at the  10.4 level, and within 1.63 at the 5.8 mg/1000
mL level.  The filters have been retained in case you are interested in examining them later.  Appearances
of the residue varied, and descriptions of each are included below. The duplicate filters were identical in
appearance.  All of the materials were difficult and slow to filter compared with the usual fresh diesel #2
samples we receive.

17043  Clean Run 1 - Solid dark brown stain
17044  Clean Run 2 - Solid medium brown with small amount of debris particles
17045  Clean Run 3 - Solid dark brown stain with small amount of debris
17046  As Received Fuel - Medium brown deposit with some powder texture and some flaking
17047  Contaminated 1 - Very dark brown deposit with dried mud pattern on filter
17048  Contaminated 2 - Medium brown deposit with small areas showing dried mud pattern
17049  Contaminated 3 - Dark brown film with flaking
ASTM D 613          Cetane Number
QA documents include a control chart for the engine, engine maintenance  documents,  and calibration
certifications for the thermometers and timers used with the engines.  The consensus value for the check
fuel used is 41.3.   The test value for the shift where the test samples were  run was 41.6.   No unusual
behavior was observed during testing.
                                                                                    (continued)
                                             B-5

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                Appendix B-2. SwRI Fuel Analysis QA/QC Procedure (continued)
ASTM D 381          Gums and Resins
QA documents include a weight verification data sheet and calibration certificates for the temperature
readout, the gum block, and the balance used.  Since no reference material is available for this test, no
control chart is available.  Duplicate analyses were performed on two of the samples. Precision for the
repeat data was within the expected repeatability for an aviation turbine fuel for the test (i.e., 79 ± 20.3
mg/100 mL and 39 ± 10.3 mg/100 mL). No unusual behavior was observed during testing.
ASTM D 6079         Lubricity
QA documents  include the control charts for the Isopar solvent and the Cat 1-H oil analyses performed
every 20 samples, and the certificate of calibration for the equipment. The duplicate Isopar analyses for
8/1/01 were 0.620 and 0.630 mm, and for the Cat 1-H on 8/1/01, 0.380 and 0.375 mm.
Descriptions of each wear scar are as follows:
17043 evenly abraded oval
17044 oval inside an oval
17045 oval inside an oval
17046 oval inside an oval
17047 hourglass-shaped scar inside lightly worn oval
17048 two circular scars;  one more abraded inside the outer, less worn scar
17049 hourglass-shaped, lightly abraded scar inside lightly worn oval
                                              B-6

-------