United States Air and Radiation EPA420-S-99-006
Environmental Protection December 1999
Agency
svEPA Guidelines for
Retrofit Applicants
> Printed on Recycled Paper
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EPA420-S-99-006
December 1999
for
Regional and State Programs Division
Office of Mobile Sources
U.S. Environmental Protection Agency
NOTICE
This technical report does not necessarily represent final EPA decisions or positions.
It is intended to present technical analysis of issues using data which are currently available.
The purpose in the release of such reports is to facilitate the exchange of
technical information and to inform the public of technical developments which
may form the basis for a final EPA decision, position, or regulatory action.
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Guidelines for Retrofit Applicants
Purpose of this Document
This document is intended as a guideline for companies preparing applications to the U.S.
Environmental Protection Agency (EPA) Retrofit/Rebuild Program. This document
summarizes and adds to information found in the Retrofit/Rebuild Final Report also
posted on this website.
What is the Retrofit/Rebuild Program?
The Retrofit/Rebuild Program was developed by a diverse group of state, federal, and
industry personnel and is intended to reduce heavy-duty engine emissions by encouraging
retrofit with emission control devices. The program provides states with methods to
calculate SIP credits from retrofit projects. In addition, an independent third party
verification system has been established to provide states with information on available
retrofit products. During the verification process, an independent, voluntary review
committee examines test data to verify emission reduction claims by emission control
equipment manufacturers. Once a product has gone through the verification process
successfully, information on the control technology will be posted on the Retrofit
Website, maintained by EPA. This information can then be used by states, public
agencies, and private groups who are interested in initiating retrofit projects.
Who should apply to the Retrofit/Rebuild Program?
Companies that manufacture emission control devices and who wish to have their
products appear on the EPA Retrofit Website for use by states, agencies, and private
organizations or companies.
What Information is Needed?
As outlined in the Retrofit/Rebuild Final Report found on this website, three types of
data/information should be included in the application: 1) test data showing the emission
reduction potential of the control equipment; 2) a description of the kinds of engines the
control equipment can be retrofitted onto and a supporting engineering analysis; and 3) a
proposed method for spot testing units in-use. The test data requirement for application
to this program has been modeled after the requirements of the EPA Urban Bus Program.
Sections I through VI detail the information and the manner in which it should be
presented in the application packet.
Review Process
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The review committee will make best efforts to review completed applications within 60
days from the date of submission.
I. Preliminary Testing Plan for Applicants
Those companies that have already gathered test data should skip to Section II. This form
should be filled out by those applicants to the Voluntary Retrofit Program who have not
yet initiated a testing program to gather data on a retrofit device.
The purpose of submitting a preliminary testing plan is to solicit input from the review
committee on the applicability of the proposed testing plan. Review of this preliminary
testing plan could reduce the costs of the testing program by focusing testing and
eliminating any elements that are not necessary. It can also help to avoid additional
testing to support product claims. Potential applicants should submit the information
detailed below and submit the completed forms to the retrofit program coordinator before
testing is begun. The review committee will comment on the proposed testing plan and
respond to the submitting company.
Company name
Product name
Product type (ex. oxidation catalyst)
Application (ex. mobile heavy-duty)
Potential engines to be applied to (ex. all heavy-duty diesel on-highway)
Description of testing planned:
Example Description: A 1998 Cummins L10 diesel engine will be tested on an engine
dynamometer at (insert testing lab name). The testing cycle will be the FTP for heavy-
duty highway engines. Three FTP tests will be taken to establish a baseline and then the
200 cpsi oxidation catalyst will be installed on the engine. The catalyst will have been
"de-greened" for a period often hours. The engine will then be tested on the FTP three
times to determine post baseline emissions. Pollutants to be measured will include NOx,
PM, HC, CO, and smoke. Continuous emissions data for NOx, HC, and CO will be
submitted with the corresponding load, speed, and temperature conditions of the engine.
Continuous backpressure measurements will be taken during testing and fuel
consumption over the test cycle will be determined.
NOx emissions will be measured with a Horiba chemilumninescent analyzer, HC with a
heated flame ionization detector, CO with an NDIR detector, and PM with filtration and
gravimetric measurement in accordance with (for example) SAE recommended test
procedures or EPA federal regulations.
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II. Technology Description
In this section the type of technology that is being submitted to the review committee
should be described. Applications should be submitted for complete emissions control
reduction devices rather than individual components. Two examples are given below:
1) This application is for a Selective Catalytic Reduction system. The SCR system is
designed to reduce NOx emissions. The system includes a vanadium-based SCR
catalyst supported on a 200 cpsi ceramic substrate designed to handle a total flow of
1,500 acfm, manufactured by (insert company name), and a urea injection system
manufactured by (insert company name). The system works by reducing NO and
NO2 emissions to N2 and H2O. The reduction of the nitrogen oxides takes place by
injecting ammonia or a compound generating ammonia such as urea into the exhaust
gas at a temperature of 320 - 420 degrees C and subsequently passing the
ammonia/exhaust gas mixture through a catalyst, where the nitrogen oxides, which
primarily consist of NO and NO2 are converted .
2) This application is being submitted for an oxidation catalyst. The oxidation catalyst
reduces the soluble organic fraction of PM, gaseous HC, CO, and toxic emissions.
The catalyst is installed either as a replacement muffler or as an add-on device to be
inserted into the exhaust system. The catalyst supplied contains Pt/Pd at a metal ratio
of 6:1 and a total loading of 20 g/ft3 supported on a 200 cpsi metallic substrate
designed to handle a total flow of 1,500 acfm. The oxidation of PM, HC, CO, and
toxic emissions takes place when the exhaust gas passes through the catalyst and is
oxidized by the precious metal coating. PM, HC, CO, and toxics are oxidized to H2O
and CO2.
Where information is sensitive and confidential, please divulge as much information as
possible.
III. Engine Application
In this section, a brief, specific description of the type of application the
technology/product will be retrofitted onto. Two examples are listed below.
1) The SCR system is intended for two uses:
• diesel generators;
• marine vessel engines
2) The oxidation catalyst is intended for use in:
• all highway and nonroad diesel engines
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IV. Testing Information and Percent Reduction
In this section, requirements for testing data are described. Subsections A to E detail the
specific data requirements.
A. Engine(s) model, make, and year the product was tested on;
B. Test cycles (a description of appropriate test cycles is given below)
Default Test Cycles
As with the federal urban bus retrofit program the accepted test method will be the
Federal Test Procedure (FTP). The applicant should follow the data generation
requirements as outlined in part 85.1406 of the Federal Register. If it is not
appropriate to use the FTP cycle or if a technology developer wants to generate data
using a test cycle that is different from the FTP, then the manufacturer should use: 1)
test methods recommended by EPA, such as the 8-mode cycle for verification of a
technology with nonroad engines; 2) test methods recommended by CARB; 3) the
Central Business District cycle (CBD) or the New York Bus Composite Cycle
(NYBCC) for chassis dynamometer testing.
Possible Alternative Testing Cycles
If a technology developer has already generated data using a cycle that is not included
as a default testing method then the cycle will need to be reviewed by the
administrative group and the review committee. Such cycles could include, for
example, the R49. In such a case the 60 day review period limit will not be valid.
Testing cycles should reflect the in-use duty cycle. For example, if an SCR system is
intended for marine vessel applications, then a cycle with some transient operation
should be used since marine engines typically go through periods of transient
operation.
C. Test Data
The test data requirements for all technology verifications will be equivalent to that
which is specified for the federal Urban Bus Retrofit/Rebuild program as described in
CFR part 85.1406. Part 85.1406 calls for three FTP tests to establish baseline emissions
and three post-baseline FTP tests to establish post-baseline emissions. The emission
control device should be "de-greened" for a period often hours before post-baseline
testing. Data to be provided for both baseline and post-baseline tests include:
Continuous emissions data for NOx, HC, and CO (bag CO data should also be
acceptable) should be submitted with the corresponding load, rpm, and temperature
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conditions of the engine. Continuous backpressure measurements should be taken during
testing. Specific detail on test procedures by mode should be included.
Other information may be important. For example, in an SCR application, information
on urea consumption and urea slip during testing should be included.
D. Emissions Percent Reduction
The control equipment manufacturer should calculate the percent of PM, NOx, HC, CO
(where applicable) reduced by the control technology as established during engine/chassis
testing. The percent reduction levels should be established by calculating the difference
between baseline or engine out emissions and post-baseline (or post retrofit) emissions.
For example, post-baseline PM emissions in gr/bhp-hr of .2 would be divided by baseline
PM emissions of .3. This figure would then be subtracted from one and multiplied by
100 to arrive at the percent reduction.
E. Testing Laboratory and Equipment
The testing laboratory that conducted emissions testing should be identified as well as the
sampling devices used. For example, NOx emissions were measured with a Horiba
chemilumninescent analyzer, HC with a heated flame ionization detector, CO with an
NDIR detector, and PM with filtration and gravimetric measurement in accordance with
EPA federal regulations.
V. Applicable Engines
The manufacturer should provide a recommendation as to the engine families the control
technology can be used with. This recommendation should be in the form of an
engineering analysis conducted either in-house or by an outside group. The analysis
should use sound engineering judgment to determine what engine families the
retrofit/rebuild equipment can be used in. Particulate matter composition (soluble
organic fraction estimates), exhaust temperature, space velocity, duty cycle and other
operating conditions should be considered in the engineering analysis. The manufacturer
and the review committee will use best judgement in applicability to non tested engines.
Relational data may be used with sound engineering assumptions. The committee will
review the engineering analysis to determine which engine families the control equipment
can be used with. In reviewing the submission, the review committee will use good
engineering and scientific judgment and analyze all submitted data on a given product to
make its determination. The review committee will document each decision and submit
records to the administrator so that the analysis can be justified if EPA chooses to review
the committee decision.
Following is an example of considerations that need to be taken into account in the
engineering analysis.
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1) This SCR system is limited to a temperature window of 320-420 degrees C. The SCR
system can be used in (include information on engine families) based on manufacturer
specifications for exhaust temperature under rated speed and load conditions. If
maximum emission reduction percentages are to be used, the application should be
limited to engines in which operations result in exhaust temperatures within the
temperature window indicated. Alternatively, expected NOx reductions should be
adjusted based on expected exhaust temperature profiles. For example, if under
typical conditions, exhaust temperatures are below 320 degrees for 30 percent of the
time, the expected emission reduction percent should be adjusted from 70 percent to
49 percent (70% NOx reduction for 70% of operating time).
Note: In the future, an example of an engineering analysis will be added to this document
to assist applicants.
VI. In-Field Testing Method
The applicant should submit a proposed "field testing" plan to the review committee.
The manufacturer is required to test a number of units in the field (this number can be as
low as four and as high as 10 or 15). The testing is meant to be a cost effective means of
determining whether or not an emissions control unit is reducing emissions as expected.
The field testing plan describes how units in the field will be tested for performance. As
an example, a truck retrofitted with an oxidation catalyst could be tested (upstream and
downstream of the catalyst) using a five gas analyzer to check for CO emissions.
Estimated percent reductions must be met during field testing. For some applications
such as fuel additives and rebuild kits, field test methods will be more difficult to
develop. In these cases, manufacturers might choose to designate two fleet vehicles of
similar make and model year, one retrofitted with the control technology and one
without. The vehicle without the control technology could act as a "control" vehicle for
field testing purposes.
The field testing should be taken while the engine operates under typical conditions
based upon operator's input on best and worst case conditions.
In addition to a field method such as using an electrochemical portable analyzer, a more
comprehensive testing method needs to be developed by the product manufacturer in the
case of dynamometer testing. For example if an oxidation catalyst fails field tests and
must then be tested in dynamometer tests, then a potential testing method would be to
remove the catalyst and attach it to a "slave" engine in a testing lab. Another possibility
could be to test on a mobile chassis dynamometer. As in the case of verification testing,
the third party verifier will automatically approve of a method that uses either the FTP or
other EPA approved test cycles, CARB approved test cycles, the CBD, and the NYBC
cycles. Alternative cycles may be used, but must first be approved of by the review
committee. A pass rate of 67% must be established or credit will be revoked. The
manufacturer may conduct as many tests as are necessary to achieve this percent pass
rate.
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Backpressure Measurement
In addition to emissions testing, backpressure measurements will be taken during
field testing to ensure that retrofit equipment is not increasing backpressure beyond
manufacturer acceptable limits in retrofitted engines.
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Application to the Voluntary Retrofit/Rebuild Program
Applicants should complete the following form for the Voluntary Retrofit/Rebuild
Program:
1) Company name
2) Contact information
• contact person
• telephone number
• e-mail address
mailing address_
5) Type of product to be verified
(if a system is required, submit information on all components)
6) Name of product to be verified
7) Application
(ex. mobile heavy-duty diesel on-highway and marine engines)
6) Applicable engines (please see guideline document for a description)
8) Attach testing data including:
(please see guideline document for a description of testing data requirement)
• Preliminary testing plan if completed
• Engine(s) product tested on
• Method (ex. chassis dynamometer, engine dynamometer)
• Space velocity (for aftertreatment devices)
• Description of catalyst type (in case of catalytic aftertreatment)
• RPM, exhaust temp, backpressure data taken during testing
• Detail on test results by mode and test cycle for baseline and post-baseline
• Identify lab where testing was done
• Identify testing equipment
8) Attach engineering analysis (please see guideline document for a description)
9) Attach spot test method proposal (please see guideline document for a description)
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