Contract # 582-14-40056 PGA and Notice to Commence #FY14-01 Task 1.4 QUALITY ASSURANCE PROJECT PLAN (QAPP) QA Category: III Repower/Replace Diesel Vehicles in Municipal Fleets Prepared for: Heart of Texas Council of Governments 1514 South New Road Waco, TX, 76711 Prepared by: ENVIRON International Corporation 773 San Marin Drive, Suite 2115 Novato, California, 94998 www.environcorp.com P-415-899-0700 F-415-899-0707 July 2014 July 2014 CONTENTS 1.0 PROJECT DESCRIPTION AND OBJECTIVES ........................................................................ 5 1.1 Purpose of Study .............................................................................................................5 1.2 Project Objectives............................................................................................................5 2.0 PROJECT ORGANIZATION AND RESPONSIBILITIES ........................................................... 6 2.1 Responsibilities of Project Participants ...........................................................................6 2.2 Project Organization and Schedule .................................................................................6 3.0 SCIENTIFIC APPROACH ................................................................................................... 8 3.1 Data Collection and Generation Methods ......................................................................8 3.1.1 Vehicle and Engine Data .......................................................................................8 3.1.2 Vehicle Engine Replacement Data ........................................................................8 4.0 QUALITY METRICS .......................................................................................................... 9 4.1 Quality Requirements of Data .........................................................................................9 4.1.1 Vehicle and Engine Data .......................................................................................9 4.1.2 Engine Replacement Feasibility and Cost Data ....................................................9 4.2 Verification and Validation Methods of the Secondary Data .........................................9 5.0 DATA ANALYSIS, INTERPRETATION AND MANAGEMENT .............................................. 10 5.1 Data Reporting Requirements .......................................................................................10 5.2 Data Validation Procedures ...........................................................................................11 5.2.1 Audits of Data Quality .........................................................................................11 5.2.2 Reporting of QA Findings ....................................................................................11 5.3 Data Summary ...............................................................................................................11 5.4 Data Handling and Storage Methods ............................................................................11 6.0 REPORTING .................................................................................................................. 12 7.0 REFERENCES ................................................................................................................ 14 i July 2014 TABLES Table 1. The ENVIRON project participants and their primary responsibilities. ..................6 Table 2. Summary of project schedule and milestones. .......................................................7 Table 3. Summary of QC procedures for data collected as part of this project. ..................9 FIGURES Figure 1. Project organization. ...............................................................................................7 ii July 2014 APPROVAL PAGE _______________________________________________________ Barry Exum ___________________ Date Project Manager, Texas Commission on Environmental Quality _______________________________________________________ Quality Assurance Project Plan Officer, ___________________ Date Texas Commission on Environmental Quality 3 July 2014 DISTRIBUTION LIST Barry Exum, Project Manager, Texas Commission on Environmental Quality Quality Assurance Project Plan Officer, Texas Commission on Environmental Quality Heart of Texas Council of Governments Air Quality Advisory Committee 4 July 2014 1.0 PROJECT DESCRIPTION AND OBJECTIVES ENVIRON has prepared this Level III Quality Assurance Project Plan (QAPP) for the Texas Commission on Environmental Quality (TCEQ) following EPA guidelines. The nature of the technical analysis and tasks to be conducted as part of this project are consistent with quality assurance (QA) Category III: Data Evaluation or Use for Secondary Purpose. This project involves data and information that we plan to use but that have not been newly generated by the project and called “existing data.” The existing data may also be known as “secondary” data or non-direct measurements. 1.1 Purpose of Study The Heart of Texas Council of Government’s (HOTCOG’s) ozone modeling indicates that NOx emissions from on-road vehicle engines in the 6-county HOTCOG area contribute to ozone at the Waco Mazanec monitor. The purpose of this study is to perform engine repowers and/or vehicle replacements of HOTCOG area municipal fleets of light-duty, medium- duty and heavyduty diesel vehicles, and to evaluate the resulting NOx emissions reductions in the 6-county area. 1.2 Project Objectives There are two principal objectives for this project: (1) Compile information on HOTCOG area municipal vehicle fleets to identify candidate engine(s) or vehicle(s), and (2) Identify candidate vehicles through phone and email outreach to municipal fleet managers. The objective is to identify individual light-duty, medium- duty and heavyduty diesel vehicles that upon engine or vehicle replacement would provide the most cost effective NOx emission reductions. The candidate vehicles’ cost effectiveness depends upon the age of the vehicle, technical feasibility of repowering/replacing, the current usage of the vehicle, and the cost per vehicle repower or replacement. (3) Obtain quotes for repower/placement, (4) Repower or replace the identified vehicle(s) (5) Document the NOx emissions benefits of the repower or replacement. 5 July 2014 2.0 PROJECT ORGANIZATION AND RESPONSIBILITIES 2.1 Responsibilities of Project Participants This study will be conducted by ENVIRON International Corp. (ENVIRON). The ENVIRON Project Manager is Chris Lindhjem, who will be assisted by other ENVIRON project managers and staff as described in Table 1 below. Table 1. The ENVIRON project participants and their primary responsibilities. Participant Dr. Greg Yarwood Dr. Chris Lindhjem Dr. Sue Kemball-Cook Mr. Jim King Project Responsibility Overall review of all documentation, and quality assurance review Project manager, conducting outreach to municipal fleet managers, conducting research on engine replacement vendors, overseeing contracts to install new engines, preparing technical report on the study Support on outreach to fleet managers and interaction with HOTCOG staff, oversight of engine replacement contracts, quality assurance review of testing results, and quality assurance review of documentation Support on outreach to fleet managers, support on research of candidate vehicles, support on vendor feasibility and cost estimates, and support on preparing the technical report Additional independent quality assurance reviews will be conducted by the HOTCOG Air Quality Advisory Committee (AQAC) Technical Committee, who will review the selected engines, candidate retrofit emission control systems, and findings of the emissions testing. Additionally, the HOTCOG AQAC Technical Committee and TCEQ staff will participate in the review of the technical report for the study. 2.2 Project Organization and Schedule The project is divided into four major tasks: (1) perform project management and quality assurance, (2) conduct outreach to municipal fleet managers, (3) conduct survey to identify feasible engine replacement for each candidate vehicle and survey the cost of engine or whole vehicle replacement, (4) provide a report and rank the most cost effective vehicles to conduct an engine or vehicle replacement and follow up on engine/vehicle replacement projects funded during the course of the study. The table below shows the overall schedule for completion of this project including interim milestones. 6 July 2014 Table 2. Summary of project schedule and milestones. Deliverable Task 1: QAPP Deliverable –QAPP Task 2: Outreach to Municipal Fleet Managers Completion Date July 7, 2014 August 1, 2014 Task 3: Survey Vehicle Engine Replacement Vendors September 1, 2014 Task 4: Reporting and Ranking of Eligible Vehicles Deliverable – Draft Report Deliverable – Final Report November 30, 2014 June 1, 2015 Note: monthly progress reports will be supplied to the HOTCOG project manager and to the TCEQ project manager. Figure 1 below shows the organization of the project, including the primary responsibilities for each participant. TCEQ Project Manager HOTCOG AQAC ENVIRON Task Work & Technical Task Management Data Quality Control, Data Storage and Handling, Documentation of QA/QC Procedures and Activities TASK 1 TASK 2 TASK 3 TASK 4 Work plan and QAPP Outreach to Municipal Fleet Managers Survey Engine Replacement Vendors Reporting Figure 1. Project organization. 7 July 2014 3.0 SCIENTIFIC APPROACH This section addresses the secondary data needed to meet the project objectives, which can include the type of data, the source of the data, and emissions modeling outputs. 3.1 Data Collection and Generation Methods 3.1.1 Vehicle and Engine Data In Task 2, we will identify candidate vehicles for engine replacement or whole vehicle replacement. Candidate vehicles will be identified through surveys of HOTCOG municipal fleet managers. Vehicle specification information will be requested from the municipal fleet managers and include the following information: 1. Vehicle type, vocation, and gross vehicle weight rating 2. Engine make/model, model year, and horsepower; 3. Current activity in annual vehicle mileage accumulation. This information will be gathered from municipal vehicle fleet managers. ENVIRON will provide survey forms that can be filled out by the fleet managers or will use fleet manager records if available. ENVIRON will identify candidate vehicles for engine or vehicle replacement and rank them in order of cost effectiveness and emission reduction potential. 3.1.2 Vehicle Engine Replacement Data Once candidate vehicles have been identified and vehicle and engine characteristics and activity data gathered, ENVIRON will contact engine vendors to determine the feasibility and cost of engine replacement. Specifications of the candidate vehicles will be provided to the engine manufacturers/vendors/maintenance shops to determine if an engine replacement is feasible for each vehicle. Estimated cost information for materials and labor will be gathered from the vendors/manufacturers, and final quotes will be gathered for those vehicles selected for engine replacement. 8 July 2014 4.0 QUALITY METRICS This section addresses the quality requirements of the data and QA activities that occur after the data collection phase of the project is completed. Implementation of these elements determines whether or not the data conform to the specified criteria, thus satisfying project objectives. 4.1 Quality Requirements of Data The quality requirements of data gathered for the study are presented below for vehicle and engine data. 4.1.1 Vehicle and Engine Data Vehicle and engine data specified in section 3.1.1 must be obtained directly from vehicle and engine specification records and engine plates and the data reported must exactly match these specifications. Vehicle activity estimates will be gathered from odometer records. 4.1.2 Engine Replacement Feasibility and Cost Data Engine replacement feasibility and cost estimates will be gathered from vendors, and fixed quotes will be gathered from the vendors. 4.2 Verification and Validation Methods of the Secondary Data The process to be used for verifying and validating data is presented in Table 3 of this QAPP. 100% of engine data submitted by participating companies and data associated with the first installation emissions performance will be reviewed, and at least 10% of the subsequent installation engine testing data will be reviewed for QA/QC purposes. Table 3. Summary of QC procedures for data collected as part of this project. QC Activity Vehicle and Engine Data Procedure Verify that all required vehicle and engine data has been submitted. Acceptance Criteria 90% Vendor Installation Data Verify engine replacement feasibility and estimated cost. Engine replacement quotes 100% 100% Corrective Action If less than 100%, then contact managers for missing data. Compare against list of municipalities in the study area. Check against TCEQ TERP and other Texas regions projects. Review contract quotes with HOTCOG and TCEQ staff. As described in the Work Plan, engine data collection will be conducted by ENVIRON through data requests to municipal fleet managers. ENVIRON will verify the quality of the data following the procedures in Table 3. Any deficiencies noted in the data that could be addressed through additional information will result in ENVIRON contacting the fleet managers to request additional data. 9 July 2014 5.0 DATA ANALYSIS, INTERPRETATION AND MANAGEMENT 5.1 Data Reporting Requirements As described in Sections 3 and 4, ENVIRON will gather vehicle and engine data from municipal fleet managers and engine replacement feasibility and cost estimates from engine vendors. ENVIRON will compile all data into spreadsheet tables logging the vehicle and engine data, the annual activity, and other data necessary for estimating potential emission reductions. For emissions estimates, the EPA MOVES model will be used to estimate emission factors (emission per vehicle mile) by specific vehicle type and model year of original and replacement engine. Emission factors EFi will be estimated using the EPA MOVES model with and without the new engine, i.e. uncontrolled and controlled emission factors for the vehicle type and typical operation (long trips on freeways, short local trips, or area-wide average trips). These will be used to estimate an in-use control factor for the engine replacement as well as to compare against the rated emission factor of the engine from the engine specification data. The emission reduction potential of each retrofit control system installation will be estimated. Emission reduction potential: EFi ,controlled ) EF Ei VMTi i ,uncontrolled 907185 Where: Ei is the emission reduction potential of pollutant i [ton/yr] EFi,uncontrolled is the uncontrolled (old engine) emissions factor of pollutant i [g/bhp-hr] EFi,controlled is the controlled (new engine) emissions factor of pollutant i [g/bhp-hr] VMT is the vehicle miles traveled per year [mi/yr] Finally the cost-effectiveness of the retrofit control system will be estimated. Cost-effectiveness: 1 i n i C n 1 i 1 CEi Ei Where: CEi is the cost-effectiveness of reducing pollutant i [$/ton] C is the capital cost of the retrofit control system [$] i is the discount rate [3%] n is the useful life of the retrofit control system [yr] Ei is the emission reduction potential of pollutant i [ton/yr] 10 July 2014 These procedures for reducing the data will be followed for all vehicle/engine replacements that may be addressed as part of the study, including any engine or vehicle replacements accomplished. Data reduction will focus on developing the emission reduction potentials and the cost-effectiveness values of the engine or vehicle replacement. 5.2 Data Validation Procedures ENVIRON will perform technical systems audits (TSA), audits of data quality and reporting of QA findings. 5.2.1 Audits of Data Quality ENVIRON will audit the data quality of spreadsheets generated as part of this project. 10% of all data will be audited. If problems are found, all data sets will be audited, including independent verification of every spreadsheet or automated calculation once and 25% of manual calculations. ENVIRON will follow standard QC practices for each data type. For example, data entered into spreadsheets will be verified against the source data to ensure proper data entry. Spreadsheet formulas and cell references will be reviewed for accuracy. 5.2.2 Reporting of QA Findings ENVIRON will report all QA findings for all data gathered and estimations, including engine data, first engine testing data, subsequent engine testing data, emissions reduction potential estimates and cost-effectiveness value estimates in the final project report. 5.3 Data Summary Following the data reduction procedures described above, ENVIRON will summarize all vehicle and engine data, the emission reduction potential and cost-effectiveness values in a master table. The average cost-effectiveness and emission reduction potential will be estimated, as well as the high and low cost-effectiveness and emission reduction potential. If sufficient data points are gathered to justify the derivation of additional statistics – including standard deviation and/or confidence interval – these statistics will be developed. 5.4 Data Handling and Storage Methods ENVIRON will prepare and maintain an electronic database (e.g., Microsoft Excel or Access format) with summaries of all data received from municipal fleet managers. The database will contain lists of vehicles by type and size, engine specifications, and annual activity. Original copies of all data obtained for this project will be preserved and stored in electronic format. If data are provided on paper, the paper documents will be scanned to electronic PDF files for storage. Project data will be housed on data protected hard drives (a level 5 redundant array of independent disks – RAID5). Project data will be copied and archived to offsite storage every week. 11 July 2014 6.0 REPORTING A Final Report will be delivered to the TCEQ Project Manager electronically (i.e., via file transfer protocol (FTP) or e-mail) in Microsoft Word format no later than the deliverable due date shown below. The final report will include the following components: 1. An executive summary or abstract. 2. A brief introduction that discusses background and objectives. Include relationships to other studies if applicable. 3. A discussion of the pertinent accomplishments, shortfalls, and limitations of the work completed under each Work Plan task. 4. Recommendations, if any, for what should be considered next as a new study. The Final Report will provide a comprehensive overview of activities undertaken and data collected and analyzed during the work. The Final Report will highlight major activities and key findings, provide pertinent analysis, describe encountered problems and associated corrective actions, and detail relevant statistics including data and parameter completeness, accuracy and precision, as described in Section 5.2.3. The draft final report will summarize the procedures used and data gathered, the data reduction and analysis conducted on the data, and the resulting cost-effectiveness and emission reduction potential of the engine or vehicle replacement program. Specifically, the report will contain: A description of the methodology used and data gathered to determine municipal vehicle fleets and the outreach efforts to fleet managers (i.e. emails, telephone outreach, etc.); A list of all vehicle data gathered for the study; Calculations of cost-effectiveness and emission reduction potential will be described in detail including methodology and the data used, ranked lists of cost-effectiveness and emission reduction potential by vehicle; A discussion of the conclusions of the study and recommendations as to most feasible vehicles for future engine replacement. The procedure for review of the report is outlined below. The draft final report will be provided to the HOTCOG AQAC for review and comment. Once comments are received the draft final report will be revised in consultation with the HOTCOG AQAC Technical Committee and a draft final report delivered to the TCEQ. Upon receipt of comments from the TCEQ, ENVIRON will revise the draft report accordingly and submit the final report to the HOTCOG AQAC, who will then submit it to the TCEQ. Electronic copies of deliverable documents and other work products will be provided in Microsoft Word, Microsoft Excel, and PDF format. All electronic deliverables will meet State of Texas Accessibility requirements in 1 TAC 213. Electronic copies of all text, graphic, spreadsheet files and models used in the preparation of any documents related to the project 12 July 2014 reports, to document results and conclusions (e.g. sampling data, work files, etc.) or developed as work products under this Contract, shall be supplied the conclusion of the project (or earlier, as requested by the TCEQ Project Manager). 13 July 2014 7.0 REFERENCES EPA 2014. “MOVES (Motor Vehicle Emission Simulator),” Available online at http://www.epa.gov/otaq/models/moves/index.htm 14