Test/QA Plan for Heavy-Duty Diesel Retrofit Devices at SwRI
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TEST/QA PLAN FOR THE VERIFICATION TESTING OF
DIESEL EXHAUST CATALYSTS, PARTICULATE FILTERS, AND
ENGINE MODIFICATION CONTROL TECHNOLOGIES FOR
HIGHWAY AND NONROAD USE DIESEL ENGINES
EPA Cooperative Agreement No. CR826152-01-2
RTI Project No.: 07012.015
SwRI project number: 08-04244
Prepared by:
M. Van Hecke and C. Tatsch
Southwest Research Institute
6220 Culebra Road
P.O. Drawer 28510
San Antonio, Texas 78228-0510
Phone: 210-522-2654
FAX: 210-522-3950
Email: liilhnan@swri.org
HRTI
INTERNATIONAL
TM
Research Triangle Institute
3040 Comwallis Road
P.O. Box 12194
Research Triangle Park, NC 27709-2194
Phone: 919-541-6072
FAX: 919-541-6936
Email: irf@rti.org
This plan has been reviewed and approved by:
T. Ulman, Test Manager, Southwest Research Institute Date
M. Van Hecke, QA Officer, Southwest Research Institute
Date
J. Fanner, RTI ETV/APCTVC Program Manager
Date
R Wright, RTI ETV/AVCPCT QA Manager
Date
T. Bma, EPA ETV/APCT Program Manager
Date
P. GrofF, EPA ETV/APCT QA Manager Date
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Distribution:
U.S. EPA
Ted Brna
Paul Groff
Research Triangle Institute
Jack Farmer
Bob Wright
Gene Tatsch
Southwest Research Institute
Terry Ulman
Mike Van Hecke
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Table of Contents
1 INTRODUCTION 6
1.1 Organization of this Plan 6
1.2 Competence of SwRI as an ETV Testing Organization 6
1.3 Referenced SwRI Quality Documents 6
1.4 Purpose 7
2 TEST DESCRIPTION AND TEST OBJECTIVES 7
3 CRITICAL MEASUREMENTS, DATA QUALITY OBJECTIVES, DATA QUALITY INDICATOR
GOALS, SCHEDULE AND MILESTONES 7
3.1 Critical Measurements 7
3.2 Data Quality Objectives (DQOs) 7
3.3 Data Quality Indicator Goals (DQIGs) 8
3.4 Schedule and Milestones 8
3.5 Test Specifications for Non-critical Measurements 8
4 TEST ORGANIZATION AND RESPONSIBILITIES 9
4.1 Organizational Responsibilities 10
4.1.1 EPA 10
4.1.2 RT1. 10
4.1.3 SwRI 11
5 DOCUMENTATION AND RECORDS 11
6 TEST DESIGN 11
7 SAMPLING PROCEDURES 12
7.1 Exhaust Gas Sampling System 12
7.2 Exhaust Gas Measurement System 12
7.3 Filter Weighing 13
8 SAMPLE HANDLING AND CUSTODY 13
8.1 Particulate Filters 13
8.2 Bag Samples 13
9 ANALYTICAL PROCEDURES 13
9.1 Filter Weighing 13
9.2 Gaseous Analyzers 13
10 TEST-SPECIFIC PROCEDURES FOR ASSESSING DATA QUALITY INDICATORS 14
11 INSTRUMENT CALIBRATION AND FREQUENCY 14
11.1 Gas Meter Calibrations 14
11.2 Gaseous Analyzers 14
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11.2.1 Hydrocarbon Analyzers 14
11.2.2 Carbon Monoxide Analyzers 14
11.2.3 Oxides of Nitrogen Analyzers 14
11.2.4 Carbon Dioxide Analyzers 14
11.2.5 Methane Analyzers 14
11.3 Analyzer Gases 15
12 DATA ACQUISITION AND MANAGEMENT 15
13 INTERNAL AND EXTERNAL AUDITS 16
13.1 Quality System and Technical Systems Audits 16
13.2 Performance Audits 16
13.3 Audit of Data Quality 16
13.4 External Assessments 16
14 CORRECTIVE ACTION 16
15 ASSESSMENT REPORTS TO EPA 16
16 DATA REDUCTION, REVIEW, VALIDATION AND REPORTING. 16
17 REPORTING OF DATA QUALITY INDICATORS FOR CRITICAL MEASUREMENTS 16
18 LIMITATIONS OF THE DATA 16
19 DEVIATIONS FROM GVP 17
20 REFERENCED QUALITY DOCUMENTS 17
20.1 EPA-ETV 17
20.2 APCTV 17
20.3 Southwest Research Institute 17
20.3.1 Quality Policy and Procedures (QPPs) 17
20.3.2 Standard Operating Procedures (SOPs) 18
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List of Figures
Figure 1 - Testing Organization 9
Figure 2 - Gaseous and Particulate Emissions Sampling System System (PDP-CVS) 12
Figure 3 - Exhaust Gas Sampling and Analytical Train 13
Figure 4 - ETV Data Management System 15
Figure 5 - Typical Test-Specific Tasks and Schedule 19
List of Tables
Table 1 Data Quality Indicator Goals (DQIGs)
8
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1 Introduction
This Environmental Technology Verification (ETV) Test/QA Plan for heavy-duty diesel engine
testing at the Department of Emissions Research (DER) of Southwest Research Institute (SwRI)
describes how the Federal Test Procedure (FTP), as listed in 40 CFR Part 86 (§86) for highway
engines and 40 CFR Part 89 (§89)for nonroad engines, will be specifically implemented for this
testing program. Where the FTP is followed exactly, the phrase "without deviation" is used.
Where the FTP allows flexibility (e.g., "Alternate methods ... may be used ..."), the specific
implementation using this flexibility is described; where the flexibility is not implemented, the
phrase "without deviation" is used.
DER certifies that this document and its associated quality documents conform to and contain all
the required quality assurance project plan (QAPP) elements that are specified in EPA
Requirements for Quality Assurance Project Plans, EPA QA/R-5 (EPA Publication Number
EPA/240/B-01/003, March 2001) and in Environmental Technology Verification Program
Quality and Management Plan for the Pilot Period (1995-2000) (EPA ETV QMP, EPA
Publication Number EPA/600/R-98/064, May 1988).
1.1 Organization of this Plan
This plan is organized to reflect the expectation that SwRI will test several similarly configured
technology devices (i.e., diesel exhaust catalysts, particulate filters, and engine modification
control technologies) under EPA's ETV program. Sections 1-20 of this document present
elements of SwRI's quality system as a testing organization that are common to all tests. Test-
specific planning will be documented in a required test-specific addendum, which will be
reviewed and approved by EPA before testing.
1.2 Competence of SwRI as an ETV Testing Organization
The following describes the accreditations and registrations of SwRI relevant to this Test/QA
Plan (T/QAP).
The DER is registered to International Organization for Standardization (ISO) 9002 "Model for
Quality Assurance in Production and Installation." This independently-assessed quality system
provides the basis for quality procedures that are applied to every project conducted in the DER.
DER is accredited to ISO/IEC Guide 25 "General Requirements for the Competency of
Calibration and Testing Laboratories" and EN 45001, "General Criteria for the Operation of Test
Laboratories." Under American Association for Laboratory Accreditation (A2LA) Certificate
Number 0702-01, DER has been accredited to perform evaluations of automotive fluids, fuels
emissions, automotive components, engine and power-train performance and durability using
stationary engine dynamometer test stands (light-duty, nonroad, and heavy duty) and vehicle
dynamometer facilities, and automotive fleets (see http://www.a21a2.net/scopepdf/0702-01.pdf).
The certificate accredits DER to use specific standards and procedures, including dynamometer
procedures for hydrocarbons, carbon monoxide, oxides of nitrogen, and particulate matter.
DER has also achieved Ford Tier 1 status for providing engineering services, received the Ford
Q1 Quality Award and the Ford Customer-Driven Quality Award, and maintains its status as a
Caterpillar-certified Supplier.
1.3 Referenced SwRI Quality Documents
Based upon the ISO registration and the A2LA accreditation achieved, the DER Quality System
Manual (QSM), Quality Policy and Procedures (QPPs), and Standard Operating Procedures
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(SOPs) will be referenced in this document. These internal quality documents are considered
proprietary to SwRI and will be made available for review during the pretest, on-site assessment
of the DER technical and quality systems. Any approval of this document is conditional until the
referenced quality documents have been reviewed by EPA and Air Pollution Control Technology
Verification Center (APCTVC) assessors and have been determined to conform to the specific
required elements of an EPA QAPP. In the following sections of this document, specific SwRI
quality documents that describe DER's conformance with specific QAPP required elements will
be referenced. The specific required elements will be also referenced in these sections.
1.4 Purpose
The purpose of this Test/QA Plan is to describe testing that satisfies the specifications of the
Generic Verification Protocol (GVP) for Diesel Exhaust Catalysts, Particulate Filters, and
Engine Modification Control Technologies for Highway and Nonroad Use Diesel Engines
developed under the authority of the APCTVC at RTI. Specifically, it is written to conform to all
specifications of EPA Requirements for Quality Assurance Project Plans, EPA QA/R-5 and the
EPA ETV QMP. Specifically, this document describes the quality system of SwRI and the
procedures applicable to meeting EPA quality requirements that are common to all ETV tests.
Test-specific addenda, noted below, will be reviewed and approved by EPA prior to testing.
2 Test Description and Test Objectives
This testing, based on the FTP, is to quantify the effectiveness of commercial ready emissions
control technologies for oxides of nitrogen (NOx), hydrocarbons (HCs), particulate matter (PM),
and carbon monoxide (CO) that are intended for use on diesel engines considered mobile sources
of air pollution. For a specific technology, the number and type of FTP tests may differ [see
GVP, Section 5.7] from certification requirements in order to satisfy the data quality objectives
[see GVP, Section 2.3],
A description of a specific technology and engine to be tested will be documented as a test-
specific addendum to this document that will be submitted for EPA review and approval prior to
the start of testing. The test-specific addendum will conform to required elements A5 (Problem
Definition/Background) and A6 (Project/Task Description) of EPA QA/R-5.
3 Critical Measurements, Data Quality Objectives, Data Quality
Indicator Goals, Schedule and Milestones
3.1 Critical Measurements
Critical measurements are for the exhaust gas concentrations of NOx, HC, PM and CO [see GVP,
Section 2.3],
3.2 Data Quality Objectives (DQOs)
The data quality objectives of this testing [see GVP, Section 2.3] focus on the measurements of
NOx, HC, PM, and CO. Test requirements are those found in §86 and §89 FTP test methods,
with the number of tests being determined by:
1. A minimum of 3 tests,
2. Additional tests indicated [see GVP, Section 5], and
3. Additional tests desired by the applicant.
The rationale for the number of FTP test cycles will be included in the test-specific addenda to
this document, which will conform to required element B1 of EPA QA/R-5.
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3.3 Data Quality Indicator Goals (DQIGs)
The DQIGs for individual measurements will conform to those specified in relevant sections of
the FTP, as shown in Table 1.
Table 1 Data Quality Indicator Goals (DQIGs)
Param
SOP
CFR
Acceptance Criteria
NOx
06-002
86.1323-84(a)(4)
NO2 content < 5% of NO concentration
NOx
06-002
86.1323-84(a)(7)
Converter efficiency >90% (SwRI: 95%)
06-003
Gas Divider linearity: |known - observedl < 2.0%
06-003
Gas Divider linearity, Full-Scale: |known - observedl < 0.5%
NOx
06-025
Analyzer initial zero = 0.0 + 0.5 meter division
NOx
06-025
Analyzer initial span: |known - observedl < 0.5 meter division
NOx
06-025
Analyzer Post-check zero & span: drift < 1.0 meter division
NOx
06-041
CO2 quench, pre-test zero: 0.0 + 0.5% full scale
NOx
06-041
CO2 quench, pre-test span: |known - observedl < 0.5% full scale meter
NOx
06-041
CO2 quench, post-test zero & span: drift < 2%full scale meter
NOx
06-041
CO2 quench: < 3% full scale meter
Sampling
07-003
20°C < CVS (constant volume sampler) dilution air temp < 30°C
Sampling
07-009, 07-038
Background of CVS & Tunnel: < 10 ppmC (carbon)
Sampling
07-009, 07-038
Background: |CVS tunnel - bag| < 2 ppmC
Sampling
07-009
NOx post-test zero & span drift < 2% full scale meter
Sampling
07-009
HC post-test zero & span drift < 3% full scale meter
Weighing
07-020
Chamber: 19 °C < Temperature < 25°C
Weighing
07-020
Chamber: 37% < relative humidity < 53%
Weighing
07-020
Reference Filter weight change < 20 micrograms
Weighing
07-020
Reference Mass weight change < 10 micrograms
Bag Cart
07-023, 07-038
Pre-test zero: 0.0 + 0.5%full scale meter
Bag Cart
07-023, 07-038
Pre-test span: |known - observedl < 0.5%full scale meter
Bag Cart
07-023, 07-038
Pre-test zero & span check: |known - observedl < 1 %full scale meter
Bag Cart
07-023
Post-test zero & span: drift < 2%fs
Testing
07-028
Gas Meter #2 (secondary flow) counts > 373 counts/min
Test-specific DQIGs will be documented in the test-specific addenda to this document.
3.4 Schedule and Milestones
Following submittal of the T/QAP, an independent quality system and technical system
assessment will be performed.
A typical test-specific schedule is shown in Figure 5 and is based on experience. It depicts the
best estimate of elapsed time required for each listed task, beginning on January 1, 2002.
Corresponding changes can be inferred for different start times.
3.5 Test Specifications for Non-critical Measurements
Critical measurements focus on exhaust gas concentrations of NOx, HC, PM, and CO. The
associated test specifications comply with other specifications of the FTP as noted below.
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4 Test Organization and Responsibilities
The project organization is depicted in Figure 1, including testing team responsibilities at
Southwest Research Institute.
Figure 1 - Testing Organization
The US Environmental Protection Agency (EPA) has overall responsibility for the
Environmental Technology Verification (ETV) Program for APCTVC. Research Triangle
Institute (RTI) is EPA's verification partner in this effort. Southwest Research Institute (SwRI) is
the technology-specific testing organization for mobile sources within the APCTVC.
Management and testing are performed in accordance with procedures and protocols defined by a
series of quality management documents. These include (see Section 20), in order of precedence:
• EPA Requirements for Quality Assurance Project Plans, EPA QA/R-5
• EPA's Quality and Management Plan for the overall ETV program (EPA QMP),
• QMP for the overall APCTVC (APTC QMP),
• SwRI's Quality System Manual -2000, and DER's Quality System Manual (QSM)
• the Generic Verification Protocol (GVP) for Verification Testing of Diesel Exhaust Catalysts,
Particulate Filters, and Engine Modification Control Technologies for Highway and Nonroad
Use Diesel Engines, and
• this Test/QA Plan.
Southwest Research Institute will, for RTI, conduct field verification of applicable technology,
analyze data, and prepare a verification report and verification statement. The various
management and quality assurance (QA) responsibilities are divided between EPA, RTI, and
SwRI key project personnel as defined below. The lines of authority between key personnel for
this project are shown on the project organization chart in Figure 1
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4.1 Organizational Responsibilities
Project management responsibilities are divided among the EPA, RTI, and SwRI staff as
described below.
4.1.1 EPA
4.1.1.1 Project Management
The EPA Project Manager, Ted Brna, has overall EPA responsibility for the APCTVC. He is
responsible for obtaining EPA's final approval of project Test/QA plans and reports.
4.1.1.2 Quality Manager
The EPA Quality Manager for the APCTVC is Paul W. Groff of EPA's Air Pollution Prevention
and Control Division. His responsibilities include:
• Communicate quality systems requirements, quality procedures, and quality issues to the
EPA Project Manager and the RTI Project Manager;
• Review and approve APCTVC quality systems documents to verify conformance with the
quality provisions of the ETV quality systems documents;
• Perform technical systems audits (TSAs) and performance evaluations (PEs) of verification
tests, as appropriate; and
• Provide assistance to APCTVC personnel in resolving QA issues
The EPA Quality Manager (or his designee) will perform the following specific activities
associated with the verification tests:
• Review and approve the GVP for this technology;
• Review and approve
• this SwRI-specific test/QA plan,
• each verification report, and
• each verification statement
for each technology tested under this test/QA plan; and
• Perform a PE of the verification test of SwRI's ETV testing operations.
4.1.2 RTI
4.1.2.1 Project Manager
The RTI Program Manager for the APCTVC is Jack Farmer, director of RTI's Engineering &
Technology Division. He has overall responsibility for QA in the APCTVC and in technology-
specific verification tests. He will assign technology verification task leaders; oversee
verifications; review technical panel makeup; and review generic verification protocol and test-
specific quality documents. These responsibilities are described in greater detail in Section 2 of
the APCT's QMP.
The Deputy Manager, Douglas VanOsdell, reports to the APCTVC Program Manager and
substitutes for the APCTVC Program Manager if he is absent. The Deputy Manager is
responsible for any functions delegated to him by the APCTVC Program Manager. For these
technologies, he will prepare the draft GVP and provide overall management of the verification
test.
4.1.2.2 Quality Manager
The RTI Quality Manager for the APCTVC is Robert Wright of RTI's Center for Environmental
Measurements, which is organizationally independent of the RTI Program Manager. He is
responsible for ensuring that all verification tests are performed in compliance with the QA
requirements of the APCTV CQMP, GVPs, and test/QA plans. He has resources available to
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ensure conformance with the requirements and ensures that all personnel understand the
requirements. Following are his general responsibilities:
• Prepare the APCTVC QMP and assist the RTI Program Manager in the annual review and
revision of this document, as needed;
• Communicate with quality leaders for specific verification tests;
• Review and approve the GVPs, test/QA plans, and any needed SOPs that will be developed
by technology verification test leaders and test-specific quality managers; oversee test-
specific quality training;
• Conduct test-specific TSAs and PEs in cooperation with the EPA Quality Manager and test-
specific quality managers;
• Review and approve the test results and the quality control (QC) results from verification
tests; and
• Prepare the QA section of each verification test report and verification statement.
4.1.3 SwRI
4.1.3.1 Program Management
Terry Ullman has overall responsibility for technical and administrative activities, and exercises
technical leadership to promote quality in project performance. He will also function as liaison
for clients in specific technical areas and supervise the activities of project leaders. He is
responsible for preparing test-specific addenda to this T/QAP.
4.1.3.2 Quality Assurance
Mike Van Hecke plays a central role in the introduction, implementation, and consistent
application of continuous quality improvement at the DER. He fulfills the role as quality
management representative for the department and conducts audits of all pertinent quality
standards to ensure compliance. He is administratively independent of the unit generating the
data. He is responsible for maintaining the official, approved version of this document, for
reviewing and approving test-specific addenda to this document, and for the audit of data quality
(ADQ) (per Section 13.3), and reconciling test results with DQOs via DQIG attainment (per
Section 17).
4.1.3.3 Support Personnel
All persons supporting the project will be qualified as prescribed by QPP 10 (Training and
Motivation).
5 Documentation and records
Test-specific documentation and records will be processed as specified in SwRI QPP 03
(Document Preparation and Control), QPP 14 (Quality Records), QPP 07 (Testing and Sample
Analysis). See Section 12 for details of test data acquisition and management.
In accordance with Part A, Sections 5.1 and 5.3 of EPA's QMP, SwRI will retain all test-specific
documentation and records for 7 years after the final payment of the agreement between SwRI
and the APCTVC. RTI will retain all verification reports and statements for 7 years after final
payment of the agreement between RTI and EPA.
6 Test Design
The test design follows the FTP, with the number of separate FTP tests for a specific technology
determined by the specified algorithm [GVP, Section 5.7],
The rationale for the number of FTP test cycles will be included in the test-specific addenda to
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this document, which will conform to required element B1 of EPA QA/R-5.
7 Sampling procedures
The sampling system is comprised primarily of the exhaust sampling system to which continuous
measurement devices and particulate filters are attached.
7.1 Exhaust Gas Sampling System
The exhaust gas sampling system conforms to §86.1310, and §89.308. The system that will be
used at SwRI is depicted in Figure 2.
Optional for
Particulate
Background Reading
Zero Air
Discharge ( Gas'
iMeter,
Manometer
Dilution Air Filter / N
Sampling Train [ ]
HC Span Gas
Integrator
Counters
Heated
FID
.0
Ambient
Air Inlet
r
A
Read Background Bagv—'
To Exhaust
Sample Bag
rp
i
Dillution Tunnel
Heated Probe
Particulate Probe
Mixing Orifice
LEGEND
¦CsJ8" Selection Valve
1=1 Particulate Filter
-Q- Pump
\^J Flowmeter
Q Pressure Gauge
m Recorder
Temperature Sensor
Vehicle Exhaust Inlet
Primary Filter (Phase 1 and 3)
Back-up Filter (Phase 1 and
Note: Three filter holders
(one for each phase)
are also acceptable.
Recorder [
1
Heated Sample Line /H\
Ol
Heat Exchanger
4"4-4lA-4«<
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Optional
Atmosphere
LEGEND
Particulate Filter
Flowmeter
Sample
R6 V13
I Sample Pump
J^v Backpressure Regulator with
Jpo' Internal Control Loop Shown
Line Pressure Regulator with
Internal Control Loop Shown
, Ball Valve or Equivalent
jJL (Darkened Leg Indicates
Common Port)
Flow Control or Needle Valve
Plug Valve or Equivalent
(Center Port is Common)
I I Heated Area
CL Chemiluminescent
NDIR Non-dispersive Infra-red
HFID Heated Flame Ionization
Detector
V16
Probe V2 F4 F3
Figure 3 - Exhaust Gas Sampling and Analytical Train
The specific instruments to be used in this test will be selected from those listed in the master list
of calibration equipment maintained in the SwRI DER "Recall Database." This system is
controlled by the Supervisor of Instrumentation.
7.3 Filter Weighing
Particulate filters are stored, conditioned, and weighed in Room LD-3 which conforms to
§86.1312 . The balances that will be used are listed in the "Recall Database."
8 Sample Handling and Custody
Only particulate matter (PM) filter measurements and bag samples involve manual handling,
since gaseous emission measurements are made and recorded by the computer-controlled data
system (Figure 4) associated with the continuous sampling system (Figure 2 and Figure 3).
8.1 Particulate Filters
The PM filters are prepared and processed according to SwRI SOP# 07-020 which specifies a
method of conditioning and weighing filters used to collect particulate samples during exhaust
emission testing. This SwRI SOP conforms to required element B3 (Sample Handling and
Custody) of EPA QA/R-5.
8.2 Bag Samples
Samples are handled according to SwRI SOP 07-023. This SOP conforms to required element
B3 (Sample Handling and Custody) of EPA QA/R-5.
9 Analytical procedures
9.1 Filter Weighing
The chamber in which the particulate filters are conditioned and weighed conforms to §86.112
without deviation.
9.2 Gaseous Analyzers
Gaseous analyzers depicted in Figure 3 conform to §86.309, §86.1311, and §89, Subpt D, App B,
Figure 1 without deviation. Their operation is specified in SwRI SOP# 07-009, which conforms
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to required elements B4 (Analytical Methods), B5 (Quality Control), and B6
(Instrument/Equipment Testing, Inspection, and Maintenance) of EPA QA/R-5.
10 Test-specific procedures for assessing data quality indicators
Activities are specified in QPP 09 for assessing the quality of data from each test event. These
SOPs conform to required elements B5 (Quality Control) and D3 (Reconciliation with User
Requirements) of EPA QA/R-5.
11 instrument calibration and frequency.
Reference: QPP 05 Measurement and Test Equipment, which conforms to required element B7
(Instrument/Equipment Calibration and Frequency) of EPA QA/R-5.
11.1 Gas Meter Calibrations
As specified in SwRI SOP# 06-003, all gas meters, selected from the list of routinely used
instruments given in the DER Recall Database, are calibrated to conform to §86.119 and
§89.319. Any necessary correction is made by mechanically adjusting the meter and
recalibrating.
11.2 Gaseous Analyzers
11.2.1 Hydrocarbon Analyzers
The hydrocarbon analyzers used in this testing program, listed in the DER "Recall Database", are
calibrated in conformance with §86.1321 and §89.319, using the procedures specified by the
applicable flame ionization detector(FID/heated flame ionization detector (HFID) manufacturer.
Their operation is specified by SwRI SOPs #06-012, #06-021, #06-024, and #06-044, which
conform to required element B7 (Instrument/Equipment Calibration and Frequency) of EPA
QA/R-5.
11.2.2 Carbon Monoxide Analyzers
The carbon monoxide analyzers used in this testing program, listed in Attachment 1, are
calibrated in conformance with §86.1322 and §89.320, using zero-grade air. Their operation is
specified by SwRI SOPs #06-016 and #06-023, which conform to required element B7
(Instrument/Equipment Calibration and Frequency) of EPA QA/R-5.
11.2.3 Oxides of Nitrogen Analyzers
The oxides of nitrogen analyzers used in this testing program, listed in the DER "Recall
Database," are calibrated in conformance with §86.1323 and §89.321, using zero-grade air. Their
operation is specified by SwRI SOPs #06-002, #06-012, #06-025, and #06-041, which conform
to required element B7 (Instrument/Equipment Calibration and Frequency) of EPA QA/R-5..
11.2.4 Carbon Dioxide Analyzers
The carbon dioxide analyzers used in this testing program, listed in the DER "Recall Database,"
are calibrated in conformance with §86.1324 and §89.322, using zero-grade air. However, these
measurements are not critical measurement for this testing program. Their operation is specified
by SwRI SOP #06-023, which conforms to required element B7 (Instrument/Equipment
Calibration and Frequency) of EPA QA/R-5.
11.2.5 Methane Analyzers
The methane analyzers used in this testing program, listed in the DER "Recall Database," are
calibrated in conformance with §86.1325, without deviation. However, these measurements are
not critical measurement for this testing program.
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11.3 Analyzer Gases
The gases used for instrument calibration conform to §86.114 and §89.312 without deviation.
12 Data Acquisition and Management
Data acquisition and data management are performed according to QPP #08 Data Processing and
Reduction, which conforms to required element BIO (Data Management) of EPA QA/R-5.
The planned data streams, with responsibilities of the test manager and QAO, are depicted in
Figure 4. The test manager is operationally responsible for all aspects of a test. The QAO is
operationally responsible for all data quality aspects of a test, with primary, but not exclusive,
focus on the areas indicated in the figure.
Test Manager:
QA Officer:
Test Oversight and Data Production
Quality System and Data Integrity
Data Flow
NOTE:
QAO role focused on indicated areas with regular review of other data sources
Figure 4 - ETV Data Management System
Qualitative data regarding the technology to be tested, per §86.1344, and §89.405, are manually
recorded on the data sheets specified in SwRI #SOP 07-003. Operating and emissions data are
captured by the data system, described schematically in Figure 4.
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13 Internal and External Audits
13.1 Quality System and Technical Systems Audits
Internal audits by SwRI are conducted as specified in QPP #12 (Internal Audits) and SwRI SOP
#12-001 (Quality Audits), which conform to required element CI (Assessments and Response
Actions) and C2 (Reports to Management) of EPA QA/R-5.
13.2 Performance Audits
Performance audits are performed according to QPP 12 (Internal Audits), which conforms to
required element CI (Assessments and Response Actions) and C2 (Reports to Management) of
EPA QA/R-5.
13.3 Audit of Data Quality
In accordance with Table 9.1 of the ETV QMP, the QAO will conduct an audit of data quality
(ADQ) of at least 10 percent of all of the verification data. The ADQ will be conducted in
accordance with EPA's Guidance on Technical Audits and Related Assessments for
Environmental Data Operations. EPA QA/G-7 (EPA Publication Number EPA/600/R-99/080.
January 2000), including a written report detailing the results of custody tracing, a study of data
transfer and intermediate calculations, a review of QA and QC data, a study of project incidents
that resulted in lost data, and a review of study statistics. The ADQ report ends with conclusions
about the quality of the data from the project and their fitness for their intended use.
13.4 External Assessments
SwRI will cooperate with any external assessments by EPA or APCTVC. RTI and/or EPA
assessors will conduct a single mandatory quality and technical systems assessment of DER
before the start of the first test at DER. They may conduct optional witness assessments during
the first test or any subsequent test. The external assessments will be conducted as described in
EPA QA/G-7.
14 Corrective Action
Corrective action is performed according to QPP 11 Nonconformance and Corrective Action,
which conforms to required elements B5 (Quality Control) and CI (Assessments and Response
Actions) of EPA QA/R-5.
15 Assessment Reports to EPA
Internal assessment reports will be reviewed by the SwRI QAO who will respond as noted in
Section 14. The written report of the ADQ will be submitted to the APCTVCfor review.
16 Data Reduction, Review, Validation and Reporting.
Reference: QPP 08 Data Processing and Reduction, QPP 09 Analysis and Reporting,
which conforms to required elements D1 (Data Review, Verification, and Validation) and D2
(Verification and Validation Methods) of EPA QA/R-5.
17 Reporting of data quality indicators for critical measurements.
Reference: QPP 08 Data Processing and Reduction, QPP 09 Analysis and Reporting, which
conforms to required element D3 (Reconciliation with user requirements) of EPA QA/R-5.
18 Limitations of the Data
Reference: QPP 08 Data Processing and Reduction, QPP 09 Analysis and Reporting, which
conforms to required element D3 (Reconciliation with User Requirements) of EPA QA/R-5.
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19 Deviations from GVP
No deviations from the GVP or this document are anticipated. If any deviations are identified in
the course of planning and implementing a technology-specific test, the SwRI staff will consult
with APCTVC staff as soon as possible to resolve the issues. As per Section 2.7 of EPA/QA R-
5, EPA will be notified of any significant deviations and the QAO will revise this document and
submit it to EPA for review and approval.
20 Referenced Quality Documents
20.1 EPA-ETV
EPA Requirements for Quality Assurance Project Plans, EPA QA/R-5,
Office of Environmental Information, U.S. Environmental Protection
Agency, EPA Publication Number EPA/240/B-01/003, March 2001.
Environmental Technology Verification Program Quality and
Management Plan for the Pilot Period (1995-2000), National Risk
Management Research Laboratory, National Exposure Research
Laboratory, Office of Research and Development, U.S. Environmental
Protection Agency, EPA Publication Number EPA/600/R-98/064, May
1998 (or current version)
Guidance on Quality Assurance Project Plans, EPA QA/G-5, Office of
Environmental Information, U.S. Environmental Protection Agency, EPA
Publication Number EPA/600/R-98/018, February 1998
Guidance on Technical Audits and Related Assessments, EPA QA/G-7,
Office of Environmental Information, U.S. Environmental Protection
Agency, EPA Publication Number EPA/600/R-99/080, January 2000
Verification Testing of Air Pollution Control Technology, Quality
Management Plan, October 1998.
Generic Verification Protocol for Diesel Exhaust Catalysts, Particulate
Filters, and Engine Modification Control Technologies for Highway
and Nonroad Use Diesel Engines, January 2002.
20.3 Southwest Research Institute
20.3.1 Quality Policy and Procedures (QPPs)
QSM QUALITY SYSTEM MANUAL - 2000, April 2001
QPP-03 Document Preparation and Control
QPP-05 Measurement and Test Equipment
QPP-07 Testing and Sample Analysis
QPP-07-003 Transient Test for Heavy-Duty Diesel Engines
QPP-08 Data Processing and Reduction
QPP-09 Analysis and Reporting
QPP-10 Training and Motivation
EPA
QA/R-5
EPA ETV
QMP
EPA
QA/G-5
EPA
QA/G-7
20.2 APCTV
APCTVC
QMP
GVP
QPP-11
Nonconformance and Corrective Actions
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QPP-12 Internal Audits
QPP-14 Quality Records
20.3.2 Standard Operating Procedures (SOPs)
SOP-06-003 Linearity Verification of Gas Dividers
SOP-06-002 NOx Converter Efficiency Determination
SOP-06-012 Monthly Calibration of Analyzers for Continuous Dilute Gaseous
Exhaust
SOP-06-016 Wet CO2 Interference Check for CO Analyzers
SOP-06-021 FID Response for Methane
SOP-06-025 NOx Analyzer and System Response Checks
SOP-06-041 NOx Analyzer CO2 Quench Check
SOP-06-044 Hydrocarbon Analyzer Optimization
SOP-07-009 Emissions Testing During Heavy-Duty Diesel Engine Transient Cycle
SOP-07-020 Particulate Filter Conditioning and Weighing
SOP-07-023 Operation of Bag Cart
SOP-12-OOl Quality Audits
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