SRI/USEPA-GHG-VR-16
                                June 2002
Environmental  Technology
Verification Report
MIRATECH Corporation
GECO™ 3001 Air/Fuel Ratio Controller
(Manufactured by Woodward Governor Company)
Phase II Report
             Prepared By:
      Greenhouse Gas Technology Center
        Southern Research Institute

        Under a Cooperative Agreement With
    U.S. Environmental Protection Agency

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                                      EPA REVIEW NOTICE

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

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                                                 SRI/USEP A-GHG-VR-16
                                                            June 2002
 Greenhouse Gas Technology Center
A U.S. EPA Sponsored Environmental Technology Verification ( £IY ) Organization
    Environmental Technology Verification Report

                MIRATECH Corporation
        GECO™ 3001 Air/Fuel Ratio Controller
      (Manufactured by Woodward Governor Company)
                          Phase II
                         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

LIST OF FIGURES	iii
LIST OF TABLES	iii
ACKNOWLEDGMENTS	iv

1.0   INTRODUCTION	1-1
     1.1   BACKGROUND	1-1
     1.2   GECO™ 3001 AIR/FUEL RATIO CONTROLLER DESCRIPTION	1-2
     1.3   TEST FACILITY DESCRIPTION	1-6
     1.4   OVERVIEW OF VERIFICATION PARAMETERS AND EVALUATION
          STRATEGIES	1-6
          1.4.1   Changes in Lubrication Oil Degradation Rate	1-7

2.0   VERIFICATION RESULTS	2-1
     2.1   OVERVIEW	2-1
     2.2   RESULTS OF OIL PROPERTIES MEASUREMENTS	2-2
          2.2.1   Degradation Profiles: Lubrication Oil Nitration and Oxidation	2-2
          2.2.2   Degradation Profile: Lubrication Oil Total Acid Number	2-3
          2.2.3   Degradation Profile: Lubrication Oil Viscosity	2-4
          2.2.4   Numerical Data Analysis	2-5

3.0   DATA QUALITY ASSESSMENT	3-1
     3.1   DATA QUALITY INDICATORS	3-1
          3.1.1   Introduction	3-1
          3.1.2   Completeness, Accuracy, and Repeatability Results	3-1
     3.2   AUDITS	3-4

4.0   REFERENCES	4-1

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                                     LIST OF FIGURES
                                                                                         Page
Figure 1-1       Relationship of Excess Air and Exhaust Gas Characteristics	1-3
Figure 1-2       Schematic of the GECO 3001 Controller	1-4
Figure 2-1       Oil Nitration During Verification Period	2-2
Figure 2-2       Oil Oxidation During Verification Period	2-3
Figure 2-3       Oil Total Acid Number Throughout the Verification Period	2-4
Figure 2-4       Oil Viscosity Throughout the Verification Period	2-5
                                      LIST OF TABLES
                                                                                         Page
Table 1-1        GECO Air/Fuel Controller System Components	1-5
Table 1-2        Lubrication Oil Analyses	1-8
Table 2-1        Schedule of Lubrication Oil Sampling  	2-1
Table 2-2        Results of Analysis of Oil Properties	2-6
Table 2-3        Summary of Changes in Engine Emission Rates from Phase 1	2-7
Table 3-1        Summary of Data Quality Indicators for Lubrication Oil Analyses	3-3
Table 3-2        Results of Duplicate Oil Analyses	3-4
                                              111

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                                   ACKNOWLEDGMENTS
The Greenhouse Gas Technology Center wishes to thank personnel at the natural gas transmission station
where testing was  conducted for hosting  this verification.  The name and location of the host site are
omitted at their request.  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 ETV is to
further environmental protection by substantially accelerating the acceptance and use of improved and
innovative environmental technologies.  Congress funds ETV in response to the belief that there are many
viable environmental technologies that are not being used for the lack of credible third-party performance
data.  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 U.S. 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 Test and Quality Assurance Plans (Test Plans) 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
GHG Center's  Oil  and Gas  Industry Stakeholder Group  offers advice on technologies  that have the
potential to improve operation and efficiency  of natural gas transmission activities.  They also assist in
selecting verification factors and provide guidance to ensure that the performance evaluation is based on
recognized and reliable field measurement and data analysis procedures.

In the natural gas industry, transmission pipeline operators use internal combustion (1C) gas-fired engines
to provide the  mechanical  energy needed to  drive pipeline gas compressors.   As  such, owners and
operators of compressor stations are interested in the performance of these engines with regard to engine
fuel consumption, reliability, availability,  and emissions.   MIRATECH  Corporation has developed a
technology that  has the  potential to improve engine performance and committed to participate in a
verification of this technology.  MIRATECH's GECO™ 3001  Air/Fuel Ratio Controller (Controller) is
designed  to balance  lean-burn  engine  fuel  mixtures   and  improve  fuel  economy,  maintenance
requirements, and emissions performance.

Performance testing of the Controller was  carried out at a natural gas processing station in the  southern
U.S. This station employs several reciprocating engines in support of its gas processing and transmission
activities. The design of the Controller is  applicable to two of the lean-burn engines at this facility, and
these units were used for evaluation of the technology. The verification was executed in two phases of
                                               1-1

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testing.   Phase I evaluated Controller installation  requirements, and changes in fuel consumption and
engine emission rates realized through use of the Controller. Phase II evaluated changes in lubrication oil
degradation rates realized by using the Controller.  Details on the verification test design, measurement
test procedures,  and Quality Assurance/Quality Control  (QA/QC) procedures for both phases of testing
can be found in the Test Plan titled Test and Quality Assurance Plan, MIRATECH Corporation GECO™
3001 Air/Fuel Ratio Controller (SRI 200 la).  Results of the Phase I testing are documented in a separate
report  titled Environmental  Technology  Verification  Report,  MIRATECH  Corporation GECO™
3001Air/Fuel Ratio Controller (Manufactured by Woodward Governor Company) (SRI 2001b). Both can
be downloaded from the  GHG Center's Web site (www.sri-rtp.com). This report presents results of the
Phase II testing for evaluation of lubrication oil degradation rates.

The remaining discussion in this section describes  the Controller technology, presents the operating
schedule of the test facility,  and lists the  performance verification parameters that  were quantified.
Section 2 presents the  Phase II verification  test results, and  Section 3 assesses the quality  of the data
obtained.  Section 4, provided by  MIRATECH, provides additional information regarding the Controller.
The GHG Center has not independently verified information provided in Section 4.

1.2    GECO™ 3001 AIR/FUEL RATIO CONTROLLER DESCRIPTION

As engine operations and conditions change over time, engine  performance and emissions can be affected
by these  changes.  Variables such as engine  speed  and load, fuel gas quality, and ambient air conditions
can have significant effects on engine operation and the  air/fuel ratio in the cylinders.  The Controller is
an air/fuel ratio controller designed to improve  performance of natural-gas-fired, four-cycle, lean-burn
reciprocating engines by optimizing and stabilizing the air/fuel ratio over a range  of engine operations and
conditions.

This device was first introduced in  1997, and currently  there are about 25 units in operation in the gas
transmission industry.  The technology uses a closed-loop feedback  system to continuously optimize the
air/fuel mixture  introduced to  the engine. This  system provides the potential  to improve engine fuel
consumption and reduce engine  emissions,  particularly  when changes in engine load, fuel quality,  or
ambient conditions occur. Optimized and stabilized air/fuel ratios may also improve engine performance,
reduce lubrication oil degradation, and help minimize wear to major engine components, thereby reducing
engine maintenance. The Controller can  be  configured to operate based on engine exhaust oxygen (O2)
feedback, or generator output  (kW) feedback (for  engines used to  drive  electrical  generators).  Using
either approach, the Controller monitors the O2 or  kW  sensor  inputs and controls the air/fuel  ratio
generated by the carburetor.   This verification test  addressed only the  exhaust O2 feedback  system
because the Test Engine was not used to drive a generator.

The Controller uses relationships  between excess air in the combustion chamber, measured exhaust gas
O2  concentrations,  and engine emissions to calculate optimum air/fuel ratios at various engine loads.
Typical relationships between excess air  and emissions in lean-burn, gas-fired engines  are illustrated in
Figure 1-1.  Using exhaust gas O2, intake manifold air pressure (MAP), intake manifold air temperature
(MAT),  and magnetic pickup engine speed  (MAG) as  primary indicators of engine operation, the
Controller continuously adjusts air/fuel ratios in the engine by adjusting and  controlling fuel flow to the
carburetor. Fuel flow is  adjusted using a full-authority fuel  valve  that is supplied by  the vendor and
installed  directly into the engine fuel line upstream of the  carburetor/mixer.   Figure 1-2 presents  a
schematic of the Controller.   Table  1-1 summarizes the components that are included in a  typical
Controller installation and their function.
                                               1-2

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Figure 1-1. Relationship of Excess Air and Exhaust Gas Characteristics
                                Typical Uncontrolled Engine Emissions
                                                                  2000 M1RATECH Corporation
   1.031   1.020   1.010  1.000   0.910   0.833  0.769   0.714  0.667   0.625   0.588   0.555   0.526   0.500   0.476
                                         Excess Air Ratio (Phi *)
                                                                   • Phi = StOKhiometric APR 1 Operating APR
                                     1-3

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                               Figure 1-2. Schematic of the GECO 3001 Controller
                                      (provided by MIRATECH Corporation)
CARBURETOR/MIXER  --1
          OOOOOO
                                                                        E^B TH GF:CIJ« D
                   h E'"Htf.1      CCt.lFL ";
                                                    REMOTE 5 TA1US
                                                    fCQMM MODULE
                                                     (OPTOKALI
                                                                                             — DIAGHOSTC R4ILILT
                                                                                              ALARM BELAV
                                                                                              B • 3) '.C.C. UC I HO
                                                                                                      i^,.- ircy-.i j:..••.. «irj. ^.i. .I.*;;
                                                           1-4

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Table 1-1. GECO Air/Fuel Controller System Components
Component
Engine Control Unit
(ECU) Control Board
Keyterm
User Interface Module
Full-Authority Fuel Valve
Manifold Temperature
Sensor
Manifold Pressure Sensor
Engine Speed Sensor
Exhaust Oxygen Sensor
GECO Diagnostic
Software
Function
Includes the microprocessor controller and all electronics associated with power
regulation, signal inputs and filtering, controlled outputs, and communications. Also
includes the closed-loop enable switch.
A terminal useful for communication with the Controller in applications where a
computer is not available.
Allows the user to view the Controller status using three LED displays including
Controller power, shutdown relay, and fault relay.
An electronically actuated, full-authority valve used to control fuel flow to the air/fuel
carburetor/mixer.
A thermal resistor used to monitor intake MAT to determine M-dot air and
calculations (M-dot air is a default air temperature setpoint used during engine start-
up).
A 5-volt reference pressure sensor used to monitor intake MAP from 0 to 43 psia, used
as an indicator of engine load.
A MAG-pickup sensor used to determine engine speed (RPM) by counting pins on the
flywheel.
A universal exhaust gas oxygen (UEGO) sensor used to continuously monitor the
oxygen concentration in the exhaust gas.
Provides advanced troubleshooting capabilities using diagnostic fault codes,
oscilloscope plotting, and data logging.
Figure 1-2 and Table 1-1 show that the four input variables to the Controller during operation are exhaust
gas O2 content, MAP, MAT, and MAG-pickup.  The O2 signal indicates the excess air level, the MAP
signal is used by the Controller to estimate engine load, the MAT signal is used to calculate the intake air
flow breakpoint (a preprogrammed exhaust gas O2  threshold level that disables the  Controller during
engine start-up), and the MAG-pickup sensor monitors engine speed.  After all system components are
installed on an engine and confirmed to be functional, the Controller must then be programmed to control
air/fuel ratios  to levels most desirable for a specific engine and  application.  During programming, the
engine air/fuel ratios are varied while monitoring emissions to determine the optimum ratios with respect
to engine NOX emissions or fuel  consumption.   The optimum  air/fuel ratio value is  identified  as Phi-
desired.  The engine is then operated at a range of loads and, while monitoring the input variables (O2,
MAT, MAP, and engine speed or rpm) to the Controller, the fuel  valve is adjusted to achieve the Phi-
desired ratio at each load.  The valve positions and input variables  at each operating point are stored by
the Controller as the Phi-target table. When  in operation, the Controller produces a continuous valve
command that controls valve position, and subsequently, the air/fuel ratio.

The Controller can be used in three different modes of operation:  open-loop,  closed-loop,  and  manual.
When the engine is started, the Controller sets the fuel valve to a crank default position that can be preset
as desired. The valve remains in this position until the engine reaches 400  rpm, at which point the
Controller goes into open-loop mode  and sets valve positions according to a preprogrammed valve learn
table.  The Controller will  operate in open-loop mode  until the preprogrammed target air/fuel  ratio is
surpassed, at which point the Controller will go into closed-loop mode of operation.  Once in closed-loop
mode, the Controller uses input signals for engine speed and air pressure (the MAG-pickup  and MAP
sensors) to look up the Phi-target valve positions from the preprogrammed valve table, and set the valve
at that position to optimize the air/fuel ratio. Manual mode is primarily a troubleshooting tool that allows
the user to disable the Controller and manually control the fuel valve to observe the sensor and emissions
responses and to program the Controller during system installation and setup.
                                                1-5

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1.3    TEST FACILITY DESCRIPTION

The facility that hosted this verification is a natural gas plant where gas is extracted and processed for
subsequent transport and sale.  The plant recovers hydrocarbons of C2 and heavier from the natural gas,
then compresses the residual gas for transport and subsequent sale.  The plant has a capacity of greater
than 20 million cubic feet of gas per day, and is equipped with  five internal combustion (1C) engines
including two Caterpillar Model 3516-LE recompressors that were  used to conduct this verification.

One engine was equipped with the Controller and designated as the Test Engine. The twin engine without
the Controller was designated as the  Control Engine and used for comparison of engine oil conditions.
Both units were exchanged during a scheduled overhaul with zero-hour units (engines with no run time)
during the first week of August 2000.  Shortly before field  testing was conducted,  both engines received
scheduled maintenance including fresh lubrication oil, a tune-up, and other routine maintenance.

Both  engines  have  a rated  power  output of  1,085  brake horsepower  (bhp)  and  each  consumes
approximately 7,200 cubic feet per hour  (cfh) natural gas from a common fuel  header during normal
operation.  During normal  plant operations, plant residual gas used to fuel the engines is very uniform in
composition with methane concentrations of approximately 91 percent and fuel lower  heating  value
(LHV) between 980 and 990 Btu/scf.  Engine fuel composition can change in response to plant upsets or
changes in  station operations, but these occurrences are rare.  The engines  are lean-burn design and no
additional emission controls are employed.  Both engines drive reciprocating gas compressors that elevate
pipeline gas pressure from approximately 250 to 850 psig.  The compressors are Ariel Model JGK two-
stage units.   The two engine/compressor sets operate on the same schedule and load during normal station
operation.  Engine  speed  may  vary  somewhat between the engines depending on inlet gas volumes.
Under normal operations, the engines run at or near full capacity with an average annual utilization of
approximately 96 percent.  The engines were operated at  reduced operating loads for  short periods in
order to  facilitate the testing  planned  for this  verification.  The  station  monitors  engine operations
continuously, but has limited  data acquisition  capabilities.  Therefore, engine operating parameters that
were key to this verification were monitored by the GHG Center  using procedures described in Section
1.4.1 of this report and detailed in Section 2.2.1 of the Test Plan (SRI 2001 a).

For this verification, one Controller was installed on the designated Test Engine by MIRATECH on May
8, 2001.    GHG  Center personnel were  on-site to observe  and document installation  activities and
requirements.   On  the day  immediately preceding the  verification  testing, MIRATECH personnel
programmed the Controller using the procedures outlined in Section 1.2 to  operating conditions specific
to the Test Engine.

1.4    OVERVIEW OF VERIFICATION PARAMETERS AND EVALUATION STRATEGIES

This verification was designed to quantify changes in engine fuel consumption rates, criteria pollutant and
greenhouse gas (GHG) emissions, and oil degradation rates that occur with the use of the Controller. The
evaluation was designed to characterize, via measurements and other means, the  following verification
parameters:

       •   Changes in fuel consumption rates  (Btu/bhp-hr)
       •   Changes in emissions of NOX, CO, THC, CO2, and CH4 emissions (g/bhp-hr)
       •   Controller installation requirements (labor and capital)
       •   Lubrication oil degradation rates (extended Phase II evaluation)
                                              1-6

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Changes in fuel consumption rate and engine emissions were evaluated during Phase I testing over a 4-
day period after completion of Controller installation, shakedown,  and start-up activities on the  Test
Engine.  The performance evaluation approach and test procedures for those evaluations are  detailed in
the Phase I report and are not repeated here.

1.4.1     Changes in Lubrication Oil Degradation Rate

Evaluation of oil degradation rates continued over an additional 8-month period from June 2001 through
February 2002.  This  extended evaluation was conducted by  comparing the oil  characteristics  of the
engine equipped with the Controller (Test Engine) to the oil in  an identical engine  (Control Engine) that
was not equipped with a Controller and operated under similar conditions.

Users of 1C engines typically collect oil samples from the engines at routine intervals and analyze the
samples for compounds that can corrode and degrade combustion equipment. These analyses are a useful
preventive maintenance tool for operators and  can help to evaluate the performance and condition of the
engines.  The test host site typically  performs these  oil analyses every 45 days.  Poor fuel quality,
excessive fuel blow-by (unburned fuel passing the piston rings and entering  the crankcase), unstable
air/fuel ratios, and fuel mixtures that  are too rich or  lean can all accelerate the rate of oil degradation. In
support of this verification,  oil samples  were collected  and analyzed for both the  Test and Control
Engines each month to evaluate if use of the  Controller on the Test Engine slowed the oil degradation
process.

Both engines were equipped with fresh oil in June 2001, approximately 2 weeks prior to the verification
test period. The first set of samples was collected on June 23 immediately after completion of the Phase I
testing.  For the remainder of the Phase II verification period through February 4, 2002, the Test Engine
was  operated with the Controller operating  in  closed-loop mode  (air/fuel ratios were  continuously
controlled).  Samples were then collected on a monthly basis for the duration of the 8-month verification
period to enable the development of oil degradation profiles for each engine.  Engine operators collected
the samples from a sampling port in  each engine oil system located at a point between  the oil filters and
the oil cooler. The Test Plan specified that duplicate samples would be collected each month  in order to
increase the size of the  dataset.   However, instead of collecting duplicate samples,  the  GHG Center
extended the verification period to 8 months  in order to generate additional data and improve the oil
quality profiles.

Samples were shipped to CTC Analytical Laboratories in Phoenix, Arizona, each month after collection
to quantify each of parameters listed in  Table 1-2.   Station operating logs  were used to  document the
operating hours of both engines during the verification period. In order to make a meaningful comparison
of oil degradation rates on the two engines, operating hours needed to be similar.  Typically, the engines
operate on the same schedule so long as equipment malfunctions do not occur.
                                               1-7

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Table 1-2. Lubrication Oil Analyses
Analyte
Oxidation
Nitration
Viscosity @ 40°C
Total Acid Number
Reference Method
Not Specified
Not Specified
ASTM-D445
ASTM-D974
Principle of Analysis
Fourier- Transform Infra-red
Spectroscopy
Fourier- Transform Infra-red
Spectroscopy
Kinematic
Potentiometric Titration
Reporting
Units
absorbance per
centimeter (cm)
absorbance per
centimeter (cm)
centistokes (cSt)
mg KOH/g
The analytes listed in the table are indicators of oil condition and often times related.   Oil nitration,
quantified in units  of absorbance per centimeter (cm),  is a result  of piston blow-by and fuel and/or
combustion products mixing with the engine oil. The products of nitration are highly acidic and therefore
have an obvious impact on total acid numbers, but also can increase or accelerate the effects of oxidation,
and increase the oil viscosity.  Oxidation, also quantified as absorbance per cm, is a chemical change in
oil  composition caused by nitration and high-temperature operation.   Oxidation can also increase oil
viscosity and reduce the oil's ability to lubricate engine components.

Viscosity, quantified as centistokes (cSt), is a measure of the thinness of the oil and is used as a primary
indicator of the oil's lubricating abilities.  Abnormally high or low oil viscosity can be caused by dilution,
contamination,  or oxidation and can be  damaging  to engine  components.  Total  base  and total acid
numbers are also indicators of oil condition and  contamination. Most oils contain alkaline additives to
help neutralize the effects of acidic products that accumulate in  the oil  over time.   In an  engine
experiencing excessive blow-by, improper air/fuel ratios, or poor fuel quality, the total acid number can
increase dramatically over time, thereby reducing ability of the oil to maintain neutral pH.

The trends observed in the viscosity, oxidation, nitration, and total  acid levels between the oil in the two
engines were used to develop degradation profiles, and identify differences that  developed between the
Test and Control Engines. The operator that hosted this test has  a  strict policy  of changing engine oil
whenever abnormal analytical parameters are reported, or every  4 months, whichever occurs first. During
planning of this test, the GHG Center recognized that, in a 4-month period, oil degradation may not have
been  severe  enough  to observe conclusive trends  regarding  how  use of the Controller  impacts the
condition of the oil, or reduced oil degradation. During this verification, the laboratory's recommendation
to change oil occurred after the fourth monthly samples were collected, and therefore coincided with the
facility's policy of changing after a 4-month period.  Both engines were charged with fresh oil after two
consecutive 4-month periods.

QA/QC procedures specified in the above referenced analytical methods were followed by  the laboratory,
including instrument  calibrations and  performance checks.   In  addition,  duplicate  analyses  were
conducted  on two samples  from  each  engine  to  demonstrate  analytical  repeatability.  A  detailed
discussion of the data quality of the oil sampling is provided in Section 3.0 of this report.
                                                1-8

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                                  2.0 VERIFICATION RESULTS
2.1
      OVERVIEW
The Test and Control Engines were charged with fresh lubricating oil on June 2, 2001.  Installation and
programming of the Controller was completed  on June 19,  2001.   The Phase I field testing for  fuel
consumption and engine emissions was conducted from June 20 to 23, 2001.  The first set of oil samples
was collected on June 23 at the conclusion of the Phase I test period.  Samples were then collected each
month through February 2002, except during January 2002 when site operators did not collect samples.

Station operating logs were used to document the operating hours of both engines during the verification
period. Engine operating hours and sample collection dates are summarized in Table 2-1.
Table 2-1. Schedule of Lubrication Oil Sampling
Date
06/02/01*
06/23/01
07/12/01
08/08/01
09/05/01
10/10/01
10/11/01*
11/08/01
12/12/01
02/04/02
Activity (Both Engines)
1st Oil Change
Samples Collected
2nd Oil Change
Samples Collected
Operating Hours on Current Oil Charge
Test Engine
na
496
945
1590
2252
3054
na
722
1526
2736**
Control Engine
na
497
946
1594
2251
3051**
na
722
1549
2808**
* An oil change with fresh lubricant occurred on both engines.
** Based on the analytical results from these samples, the laboratory recommended that the engine oil be changed.
na = Not applicable
For samples collected on October 10, analytical results indicated that only the oil in the Control Engine
had degraded to abnormal levels. The laboratory flags oil analysis results as abnormal (or critical in some
cases), when values exceed industry-accepted standards.  For the oil parameters examined here, abnormal
values include total acid numbers greater than 3.0 mg KOH/g oil, nitration  greater than 35  absorbance
units in cm, and oxidation greater than 25 cm.

The engine oil was  changed with fresh lubricant on both engines  on October  11, 2001, even though
results of the oil analysis on the Test Engine were within normal tolerances. This is because the host site
changes oil if abnormal values are  indicated, or after 4 months  have elapsed since the last  oil change.
Results of the samples collected on February 4 indicated abnormal oil conditions (i.e., elevated total acid,
nitration, and oxidation levels) on both engines. At this time, the oil in both engines was changed again
and the verification testing was concluded.

The  operational  hours presented in Table  2-1  show that  both engines  operated  on nearly identical
schedules during the period following the first oil change (June to October 2001). The Control Engine
operated  72 hours longer than the Test Engine during the second period,  about 3 percent longer.   Site
                                               2-1

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operators  confirmed that the Test Engine's Controller remained in closed-loop mode for the entire test
period, continuously trying to optimize the air/fuel mixture introduced to the engine.
2.2
      RESULTS OF OIL PROPERTIES MEASUREMENTS
In the Test Plan, the GHG Center  proposed to prepare degradation "profiles" or graphical plots  of
viscosity, oxidation,  nitration, and total acid.   These profiles  would  be used  to identify significant
differences  in  the  rate of oil degradation between the Test  and Control  Engines (e.g., accelerated
degradation in one engine compared to the other). It was envisioned that, if significant differences in the
oil properties  for both engines occurred, they would be revealed  using  graphical profiles, but it was
recognized that these differences might be small and/or obscured by  the variability that commonly occurs
in oil analyses.

Graphical profiles for each oil parameter are shown in the sections that follow.  With the possible
exception of nitration, these graphs suggest that clear and significant differences were not evident in the
rate  of oil degradation between the Test and Control Engines.   However, some trends observed in the
profiles are identified and analyzed in the following section.  Following  this graphical assessment is a
more traditional numerical analysis of the data.

2.2.1    Degradation Profiles: Lubrication Oil Nitration and Oxidation

Each of the samples was analyzed for nitration and oxidation to develop degradation profiles for the Test
and Control Engines.  Results of the nitration and oxidation analyses  are presented in Figures 2-1 and 2-2.
                       Figure 2-1. Oil Nitration During Verification Period
oc _
on _

Si
Don -
is
z
1 n -
c .
n .
u


I '
' .
, ' •




I Test Engine
• Control Engine


*
! hirst un unange j [ second uil Change i


                  0   500  1000 1500 2000 2500 3000 3500 4000 4500  5000 5500 6000 6500

                                      Hours of Operation Since
                                           First Oil Change
                                                2-2

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                       Figure 2-2. Oil Oxidation During Verification Period
               30
               25
            E  20
            o
            IS
            '><
            O
10
•i
! f
I
!

I I I Test Engine
7~" | • • Control


j First Oil Change j j j Second Oil Change j

=ngine

                 0   500 1000 1500 2000 2500 3000 3500 4000 4500 5000  5500 6000 6500
                                      Hours of Operation Since
                                          First Oil Change
Both the Test and Control Engines operated nearly continuously as expected, and nitration and oxidation
in both engines increased over time. It is generally accepted in the industry that fuel combustion products
cause increases  in nitration, and that nitration  can accelerate the oil oxidation process.   One cause  of
nitration is fuel mixtures that are either too rich  or too lean, and exposure of lubrication oil to combustion
products that contain acid gases like NOX.

With the Controller  maintaining optimum air/fuel ratios and lower NOX formation on the Test Engine, it
is possible that nitration rates, and subsequently oxidation rates, could be reduced.  The data in Figure 2-
1 suggest that oil degradation, as expressed by increases in nitration (an oxidation precursor), is lower on
the Test Engine.  The Test Engine often had lower nitration values than the Control Engine. It should be
noted that both the nitration and oxidation figures are skewed somewhat by the presence of data outliers,
which  are identified  and examined more closely  in Section 2.2.4.

2.2.2    Degradation  Profile: Lubrication Oil  Total Acid Number

Most nitration products formed in the  oil are highly  acidic and, therefore, whenever nitration levels
increase, as was the  case in these samples, the oil's total acid number is also likely to increase.  Increasing
oil acidity is evident for both engines  during this verification, as illustrated in Figure 2-3.
                                                2-3

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              Figure 2-3. Oil Total Acid Number Throughout the Verification Period

•^ Q n _
9. or
2£ Z.O "
£ 9 n -
!5 1 c
— -i n -
ns I-U
0.0 -
|
i

!
• i
|


1 Test Engine
• Control Engine



: : : • :
I Fiibl Oil Chanye • • I Secund Oil Change •


                     0   500 1000 1500 2000 2500 3000 3500 4000 4500 5000 5500 6000 6500
                                        Hours of Operation Since
                                             First Oil Change
Acidity in the Control Engine oil after about 3,000 hours of operation was identified by the laboratory as
abnormal prior to the second oil change, while the acidity in the Test Engine oil was at a  narrowly
acceptable level.  Near the end of the second oil charge, the acid number for the oil in both engines was
identified as abnormal after approximately 2,700 hours.  The profile for total acid in the graph above does
not present a clear indication that one engine's oil was acidifying more than the other.

2.2.3    Degradation Profile: Lubrication Oil Viscosity

Many variables can impact oil viscosity, including nitration, oxidation, and acidity of the lubrication oil.
Therefore, whenever levels of these three parameters increase, the oil's viscosity is likely  to degrade.  On
both engines, viscosity increased over time at similar rates as illustrated in Figure 2-4.  The viscosity data
do not present a clear indication  that one engine's oil was degrading more significantly than the other.
                                                2-4

-------
                   Figure 2-4.  Oil Viscosity Throughout the Verification Period
4-1
w
o
o
'in
o
o
(0
>
14 n -
19 n -
1 n n -


A n -
2.0 -
0.0 -
T t * f * 1 *




L



1 Test Engine
• Control Engine



• ,_. ± ^., ^, • • i ^ , ^., ^,
s I list DM unange \ i -: oecond DM on
ange i 	


                     0   500 1000 1500 2000 2500 3000 3500 4000 4500 5000 5500 6000 6500

                                         Hours of Operation Since
                                             First Oil Change
2.2.4
        Numerical Data Analysis
In addition to the trends described above, an analysis of the profiles revealed the presence of several
apparent outliers. To assess the validity of these apparent outliers, the data's reasonableness was assessed
based on input  from experts at the oil analysis  laboratory, and an assessment of data trends and oil
properties for both engines. The outliers identified and actions taken are outlined below.

•   Test Engine: In Figure  2-1 (nitration  data), the fourth data point for  the Test Engine  appears
    unreasonably low, especially considering the previous two samples had significantly higher nitration
    values, and nitration levels should not be reduced with added exposure to engine operations.  Dilution
    with large quantities of fresh oil  could cause such a  large reduction in nitration, but evidence of a
    large dilution is not apparent in the other results,  and if additions  did  occur, site operators indicate
    they would be small (under 4 percent  of total volume  per month).  Later in this section, the average
    difference in nitration values between the Test and Control Engines is calculated.  When this is done,
    the  questionable fourth data point for  the Test Engine (October  10, 2001) is considered invalid and
    not  used  in the calculations.    To  avoid  biasing  average results  for  the Control Engine, the
    corresponding October 10, 2001, sample for this engine was also invalidated and not used.

•   Control Engine:  In  Figure  2-2 (oxidation data), the fifth oxidation  data point in the  chart for the
    Control Engine appears unreasonably low (2.0 cm). This oxidation sample was the first one collected
    after the second engine oil change  occurred  and, in comparison with  other samples collected soon
    after an oil change, the 2.0 cm value is much lower.  Specifically, the initial oxidation values for the
    Test Engine are  6 to 8 times higher, and the initial oxidation value  for the Control Engine in June
    2001 is 6  times higher.  As such, the  questionable fifth oxidation data point for the Control Engine
    (November 8, 2001) is considered invalid,  and is not used in determining the average difference in
    oxidation values between the Test and Control Engines.  To avoid biasing average results for the Test
    Engine, the corresponding November  8, 2001, sample collected for this engine was also invalidated
    and not used.

After removing the  outliers as described  above, differences between  the  Test  and  Control Engine oil
properties were  examined further.   For each sample  pair collected  on the same day, the  GHG Center
subtracted  oil  properties measured for the Test Engine from the same  oil properties measured on the
                                               2-5

-------
Control Engine.  The average of these differences  is calculated and reported in Table 2-2 for each oil
parameter (Average Difference).  Separate Average Difference values are reported, one including all valid
samples collected following the first oil change, and one including all valid samples collected following
the second oil change.

Table 2-2 presents  the results described above.  In  addition, the Overall Average Difference  is reported
near the end  of the table for each oil parameter.  It is calculated by averaging all of the  differences
reported in Table 2-2 for that parameter.  Finally, the Overall Average Percent difference is calculated and
presented at the end of the table.  This value provides an indication of the significance of any  differences
found, and was calculated by dividing the Overall Average Difference, calculated as described above, by
the overall average  value of that oil parameter for the Control Engine. The example below illustrates this
calculation.

                        Overall Average Percent  Difference For Viscosity =
            100*[average of all viscosity differences/average of all Control Engine viscosity values]
                                      = 100*[0.21 cSt/14.52 cSt]
                                               = 1.4%
Table 2-2. Results of Analysis of Oil Properties
Date of
Sample

R/9/O1
6/93/01
7/19/01
R/R/CI1
Q/R/m
10/10/01
m/11/m
1 1 /8/01
19/19/01
2/4/02
Viscosity @ 40°C
(cSt)
Control
Enaine
Test
Enaine
Difference
Oxidation
(cm)
Control Test
Enaine Enaine
Difference
Nitration
(cm)
Control
Enaine
First Oil Change
14.23
14.26
14.59
15.18
14.75
14.11
14.26
14.72
15.01
15.35
-0.12
0.00
0.13
-0.17
0.60
12 12
14 15
22 21
0
1
-1
17
18
29
Test
Enaine
Difference
Total Acid Number
(mg KOH/g)
Control
Enaine

10
22
24
-7
4
-5
2.37
2.80
2.96
Test
Enaine
Difference

2.09
2.88
2.51
-0.28
0.08
-0.45
see footnote a
26 20
-6
36b
18b
na
3.50
2.90
-0.60
Second Oil Change
13.94
14.57
14.64
14.60
14.55
15.20
Average Difference
Met ni rhannp'^
Average Difference
(9nri oil changpl
Overall Average Difference
Overall Average Percent
Diffprpnnp
0.66
-0.02
0.56
0.09
0.40
0.21
1.4
2b 17b
13 18
25 24




na
5
-1
-2
2
-0.3
-2
16
22
38

13
11
28




-3
-11
-10
-3
-8
-5
-21
1.50
2.74
3.23

1.86
2.81
3.79




0.36
0.07
0.56
-0.31
0.33
-0.04
-1.4

a Sampling data unavailable: analyses of these parameters were not specified on the chain of custody forms submitted by site
operators.
b Data considered outlying values are included in the table for information, but not included in the analysis.
na: Not aDDlicable
                                                2-6

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There appear to be no consistent and significant Average Difference between the oxidation, viscosity, and
total acid numbers for the Control Engine, and the values of these parameters for the Test Engine.  Small,
and often inconsistent, differences can be seen in these parameters and, for several samples, differences
reported are within the repeatability of the measurements (repeatability results of 1.11 to 2.18 percent are
reported in Chapter 3).

Consistent with the graphical analysis discussed earlier, the data in Table 2-2 suggest that the amount of
lubrication  oil nitration is significantly less in the Test Engine: 21 percent less than the Overall Average
nitration value associated with the Control Engine.  This is consistent with the Phase I finding that NOX
emissions were reduced by about 30  percent, and that exposure of lubrication oil to acid gases like NOX
can increase nitration as combustion gases or "blow-by" mix with lubrication oil in the crank case. Table
2-3 shows the NOX emission reductions verified as part of the Phase I evaluation.  The emission changes
measured for other air pollutants and GHGs are also shown. More details on the data from Phase I can be
obtained  from the  Phase  I report Environmental  Technology  Verification  Report,  MIRATECH
Corporation, GECO™ 3001 Air/Fuel Ratio Controller (Manufactured by Woodward Governor Company)
(SRI 2001b). This report can be obtained online at www.sri-rtp.com or www.epa.gov/etv.
Table 2-3. Summary of Changes in Engine Emission Rates from Phase I
Test
ID
1
10
11
Engine
Operation
Full Load
Average Change
2
12
13
Reduced Load
Average Change
Reduction3 in Engine Emissions (%)
NOX
18.1
38.6
34.9
30.5
19.1
38.2
32.7
30.0
CO
9.9
3.1
2.3
5.1
3.6
2.2
1.5
2.4
THC
22.3
(11.6)
(4.3)
(2.1)
(9.2)
(14.0)
(9.9)
(11.0)
CH,
23.0
(11.7)
(4.0)
(2.4)
(8.8)
(13.8)
(9.9)
(10.8)
C02
(0.9)
(1.1)
(0.2)
(0.7)
0.6
(1.9)
(1.2)
(0.8)
a Values in parentheses indicate percent increases.
                                               2-7

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                                3.0 DATA QUALITY ASSESSMENT
3.1    DATA QUALITY INDICATORS
3.1.1    Introduction

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 occurs in the final results.  The
desired levels of data quality are normally defined as data quality  objectives (DQOs).  The process of
establishing DQOs starts with  determining the desired level of confidence in the primary verification
parameters (e.g., during Phase I, these were changes in fuel consumption and engine emission rates).  The
next step is  to identify all measured values that impact the primary verification parameters and estimate
the level of error that can be tolerated.  Prior to testing, error propagation is often used to estimate the
cumulative effect of all measured variables on the quality of the verification parameters  measured. This
allows individual measurement methods and instruments to  be chosen which perform well enough to
satisfy the DQO for each verification parameter.  The technique used to determine if DQOs are met is to
identify data quality indicators (DQIs) for each of the required critical measurements.  The DQIs usually
define the accuracy, precision, and completeness goals for each measured variable.

In the Test Plan, the GHG Center intentionally did not include a DQO for changes in oil degradation rates
because degradation rates can vary widely and contain large variation.  There are many engine design and
operational variables that can contribute to oil degredation.  The GHG Center did identify DQIs for each
of the oil analysis parameters, to ensure that the measurements were as reliable as possible and consistent
with generally accepted industry standards.

3.1.2    Completeness, Accuracy, and Repeatability Results

This section presents the results of all QA/QC checks for the oil analyses methods, and reconciles the
DQIs.   Table 3-1 summarizes the range of measurements observed  in the field, the  DQI goals, the
achieved DQIs, and completeness goals. In all cases, collected samples were analyzed within 23 days of
collection.  This deviates from the interval of 1 day  specified in the Test Plan but, given the stability of
sealed oil samples during storage, this deviation is not expected to affect results.

The completeness goal for the oil analyses was to obtain a valid sample each month during 90 percent of
the verification period.  Achieved completeness of 78 percent was short of that goal.  This was because
the September 5, 2001, samples were mistakenly analyzed for viscosity only because the other analyses
were not specified on the chain-of-custody form prepared by the host site operators.  A second reason for
the low completeness was that the host site  did  not submit  samples for January 2002.  Both of these
omissions contributed to difficulties encountered in interpreting the oil degredation profiles presented in
Section 2.   However, valid samples were generally available for the preceding and following months,
allowing the GHG Center to bound the period where sampling was not conducted.  This significantly
reduces the  impact  of losing  data, allowing the  GHG Center to form reliable conclusions with a
reasonable degree of confidence. One exception was the nitration variable where, as a result of the outlier
analysis discussed in Section 2.2.4, one sample was removed for the Test Engine.  In this case, nitration
trends  and performance results are reasonably clear in spite of the data loss, the trends observed are
consistent with emissions findings  in Phase  I and, as  such, the conclusions reached for nitration are
considered reliable.
                                               3-1

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Instrument calibration  and performance  data  supplied by  the  laboratory were reviewed to document
proper instrument operation, and to qualitatively verify achievement of instrument accuracy DQI goals for
viscosity, nitration, and oxidation.  These records were obtained and reviewed by the GHG Center, and
they revealed that the accuracy-related DQI goals were achieved for the three parameters listed above.
Instrument performance data for total acid number were not obtained and reviewed. The CTC Analytical
Laboratory maintains continuous QA/QC procedures as standard operation for all  of the instrumentation
used in these analyses. Oxidation and nitration levels are determined using a Perkin Elmer Model 1600
Fourier Transformation Infrared Spectrometer (FTIR). The instrument has background checks run every
half-hour  during  use  and is internally standardized to an accuracy of  ± 1-cm  absorbance or lower.
Viscosity  is determined in accordance with the American Society for Testing and Materials (ASTM)
D445  using a Houllion Viscometer.   This  instrument measures sample viscosity  under  controlled
conditions (100 °C).  A Statistical Process Control (SPC) standard sample is checked daily to verify that
the viscometer has an accuracy of ± 0.05 cSt.  For total acid number (ASTM D974), the  method uses a
color indicator to indicate the titration endpoint, and the titrant is certified for its normality.  Triplicate
titrations were conducted on each sample.  In  addition, daily calibration is conducted  using  an SPC
sample which yields a method accuracy of ± 0.5 percent of reading.

Duplicate analyses for all the oil variables examined were conducted to confirm the achievement of the
repeatability DQI goal for  the total acid number  method,  and to  provide important repeatability
characterizations for the other three methods used. Many Phase II performance assessments involve the
calculation of a difference between two measured parameters (e.g., the Test Engine nitration minus the
Control Engine nitration), so repeatability is perhaps more important than accuracy or bias  as an indicator
of data reliability (measurement bias would tend to cancel out when measured values are subtracted).

Duplicate analyses were carried out on four of the samples submitted, and these results are presented in
Table 3-2.  For samples with duplicate analyses, the  average value of the two results was used to report
results in Section 2.2.  The DQI goal for total acid number was to demonstrate repeatability of ± 5 percent
using duplicate analyses  and, as Tables  3-1  and  3-2 show,  this goal was achieved  (1.7 percent was
achieved).  Repeatability results for the other three methods  ranged from about 1 percent for the viscosity
and oxidation methods, to about 2 percent for the nitration method.  The Test Plan called for duplicate
analyses on every sample collected. This  was not conducted on every sample by the laboratory but, given
the results of the duplicates conducted, demonstrated repeatability is acceptable.
                                               3-2

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Table 3-1. Summary of Data Quality Indicators for Lubrication Oil Analyses
Measurement Variable
Lubrication
Oil Analyses
Viscosity
Nitration
Oxidation
Total Acid
Number
Instrument Type /
Manufacturer
Kinematic Capillary
Viscometer
NicoletFTIR
Spectrometer
Automatic Karl
Fischer (KF1 Titrator
Instrument
Rated
Accuracy
+ 0.05 cSt
+ 1 cm
+ 0.5% of
readina
Measurement
Range
Observed
13.95to 15.35
cSt
10 to 38 cm
2 to 26 cm
1.50 to 3.79 mg
KOH/g oil
Frequency of
Measurements
Once every
month for
duration of
verification
period
DQI Goal
+ 0.05 cSt
± 1 cm
±5%
repeatability
DQI Achieved
+ 0.05cSt
+ 1 cm
+ 1.6%
repeatability
How Verified /
Determined
Reviewed
laboratory
calibration
records
Duplicate analyses
Completeness
Achieved
78 percent
(this excludes
outliers removed
as discussed in
Section 2.2.4)
3-3

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Table 3-2. Results of Duplicate Oil Analyses
Parameter
Viscosity (cSt)
Nitration (cm)
Oxidation (cm)
Total Acid (mg
KOH)
Analytical Results (initial/duplicate)
6/23/01, Test
Engine
14.12/14.09
10/10
12/12
2.07/2.10
6/23/01,
Control
Engine
14.18/14.27
17/17
12/12
2.36/2.37
8/8/01, Test
Engine
14.56/14.87
23/25
21/21
2.56/2.45
8/8/01,
Control
Engine
14.48/14.69
29/29
21/22
2.95/2.96
Average
Repeat-
ability (%)
1.1
2.1
1.2
1.7
3.2
      AUDITS
The GHG Center's QA Manager conducted an audit of data quality (ADQ). The ADQ confirmed that all
data handling and calculations were adequate and correct. This was done by selecting a random sample of
verification results, duplicating all the calculations performed to determine those results,  confirming the
proper extraction and tabulation of measurements data by examining a section of raw data reports
supplied by the laboratory,  and confirming the proper use and interpretation of laboratory-supplied
duplicate analysis results.  A field activities technical systems  audit (TSA) was not conducted on this
portion of the verification because samples were collected only at 1-month intervals.
                                               3-4

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                                     4.0 REFERENCES
ASTM D445.   American Society for Testing and Materials, Standard Test Method for Kinematic
Viscosity of Transparent and Opaque Liquids (the Calculation of Dynamic Viscosity (D445-01), West
Conshohocken, PA, 2001.

ASTM D974.  American Society  for Testing and Materials, Standard Test Method for Acid and Base
Number by Color-Indicator Titration (D974-01), West Conshohocken, PA, 2001.

SRI 2001 a.  Southern Research Institute. Test and Quality Assurance Plan, MIRATECH Corporation,
GECO™ 3001 Air/Fuel Ratio Controller, Research Triangle Park, NC, February 2001.

SRI 2001b.  Southern Research Institute. Environmental Technology Verification Report, MIRATECH
Corporation GECO™ 3001 Air/Fuel Ratio Controller (Manufactured by Woodward Governor Company),
SRI/USEPA-GHG-VR-11, Research Triangle Park, NC, September 2001.
                                            4-1

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