Retrofit/Rebuild Requirements for 1993 and Earlier Model Year Urban Buses; Approval of a Notification of Intent To Certify Equipment

Related Material

Other Related Documents

[Federal Register: September 21, 1998 (Volume 63, Number 182)]
[Notices]
[Page 50225-50237]
From the Federal Register Online via GPO Access [wais.access.gpo.gov]
[DOCID:fr21se98-57]

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ENVIRONMENTAL PROTECTION AGENCY

[FRL-6163-6]

Retrofit/Rebuild Requirements for 1993 and Earlier Model Year
Urban Buses; Approval of a Notification of Intent To Certify Equipment

AGENCY: Environmental Protection Agency (EPA).

ACTION: Notice of Agency approval of an application for equipment
certification.

-----------------------------------------------------------------------

SUMMARY: The Agency received an application dated October 21, 1997 from
the Engelhard Corporation (Engelhard) with principal place of business
at 101 Wood Avenue, Iselin, New Jersey for certification of urban bus
retrofit/rebuild equipment pursuant to 40 CFR 85.1404-85.1415. The
equipment is applicable to Detroit Diesel Corporation's (DDC's)
petroleum-fueled 6V92TA model engines having electronically controlled
fuel injection (DDEC) of model years 1988 through 1993. On April 9,
1998 EPA published a notice in the Federal Register (63 FR 17411) that
the notification had been received and made the notification available
for public review and comment for a period of 45 days. EPA has
completed its review and the Director of the Vehicle Programs and
Compliance Division has determined that it meets the requirements for
certification, conditioned on the terms discussed below in section IV.
The effective date of certification is discussed below under DATES.
The certified equipment complies with the 0.10 gram per brake
horsepower-hour (g/bhp-hr) particulate matter (PM) standard for the
engines for which it is certified (see below). In addition, the
equipment will be offered to all parties for $7,940 or less (in 1992
dollars) incremental to the cost of a standard rebuild. Certification
of the ETX equipment, as it applies to engines of model years 1988
through 1990, is conditioned upon Engelhard complying with the terms
discussed below in section IV.
The certification of this equipment triggers requirements for all
transit operators using compliance Program 1 (including engines
certified to meet California emissions standards) that have engines in
their fleet covered by this certification.

[[Page 50226]]

ADDRESSES: The Engelhard application, as well as other materials
specifically relevant to it, are contained in Public Docket A-93-42,
Category XXII-A, entitled ``Certification of Urban Bus Retrofit/Rebuild
Equipment''. Docket items may be inspected from 8 a.m. until 5:30 p.m.,
Monday through Friday. As provided in 40 CFR part 2, a reasonable fee
may be charged by the Agency for copying docket materials.

DATES: Today's Federal Register notice announces the Agency's decision
to certify the ETX equipment, as described below. The effective date of
certification was established in a letter dated July 1, 1998, from the
Director of the Vehicle Programs and Compliance Division to Engelhard
Corporation. (A copy of the letter is in the public docket, which is
located at the address noted above.) This certified equipment may be
used immediately by urban bus operators, subject to the condition in
Section IV. Transit operators having affected engines and using
compliance program 1 are required to use equipment certified to the
0.10 g/bhp-hr PM standard when rebuilding or replacing applicable
engines six months or more after September 21, 1998. For determining
compliance with the requirements of program compliance option 1, the
effective date of certification is September 21, 1998.

FOR FURTHER INFORMATION CONTACT: William Rutledge, Engine Programs and
Compliance Division (6403J), U.S. Environmental Protection Agency, 401
M St. SW, Washington, D.C. 20460. Telephone: (202) 564-9297.

SUPPLEMENTARY INFORMATION:

I. Background and Equipment Identification

In a notification of intent to certify signed October 21, 1997,
Engelhard Corporation (Engelhard) applied for certification of
equipment under the urban bus program. The notification is clarified in
letters from Engelhard dated February 9, 1998, June 4, 1998, June 15,
1998, July 1, and August 6, 1998. The equipment is referred to as the
ETX rebuild kit, and is applicable to 1988 through 1993 model year
Detroit Diesel Corporation 6V92TA diesel engines equipped with Detroit
Diesel Electronic Control (DDEC).
The notification states that the ETX rebuild kit is designed to
update all electronically controlled DDC 6V92TA DDEC II engines to
either 253 or 277 horsepower (hp). The ETX kit incorporates engine
components (cylinder head fire deck, valve faces and piston crowns)
that are coated with Engelhard's proprietary GPX technology, a CMX
catalytic muffler, and an improved turbocharger. The GPX
and CMXTM technologies are identical to the technologies of
the kit certified to the 0.10 g/bhp-hr standard for DDC 6V92TA model
engines that use mechanical unit injectors (MUI). That certification is
described in the Federal Register on March 14, 1997 (62 FR 12166).
The basis for the kit is a 6V92TA DDEC II engine that is rebuilt to
a standard 1991 to 1993 DDC specification. However, when the engine is
rebuilt it will utilize ETX-specific coated cylinder heads, coated
valves, cylinder kits incorporating coated piston domes, an improved
turbocharger, and a CMX-5 catalytic muffler. The 1988 to 1990 model
year engines also receive an upgraded control program for the
electronic control module. The ETX parts list is provided in the letter
to EPA dated August 6, 1998, which can be found in the public docket at
the address listed above.
Engelhard indicates that the coated engine components utilize
unique properties to improve the combustion efficiency of the engine to
reduce the engine-out emissions of particulate matter (PM). The
improved turbocharger operates like a typical turbocharger but with
improved efficiency and airflow. The improved airflow improves
combustion efficiency which reduces engine-out PM. The CMX-5 catalytic
muffler incorporates Engelhard's oxidation catalyst technology to
reduce PM emissions in the exhaust.
The specific catalytic converter part to be used depends on the
type of coach as well as the type of engine. Engelhard's notification
provides a table listing the various catalytic converter kits available
for different engine/coach combinations. Therefore, transit operators
cannot use the previously certified converter in place of the new
converter in the candidate kit.
Using engine dynamometer testing conducted in accordance with the
Federal Test Procedure (FTP) for heavy-duty diesel engines, Engelhard
documented in its October 21, 1997 notification, PM emissions below the
0.10 g/bhp-hr level. This test data is shown in Table 1.
Engelhard presents emissions data from testing two baseline
engines, one rebuilt to a 1988 California (50-state) configuration, and
the other rebuilt to a 1991 through 1993 model year DDC DDEC II
standard configuration (using a DDC DDEC II upgrade kit). A
certification test was performed on the engine after being rebuilt with
the ETX Rebuild Kit. Lists of parts used in the rebuilds are provided
in a letter dated February 9, 1998, from Engelhard. This letter can be
found in the public docket at the address listed above. Transient
testing was performed in accordance with the federal test procedure of
40 CFR part 86, subparts N and I.
The certification testing document a PM emissions level of 0.09 g/
bhp-hr, and also show that emissions of hydrocarbon (HC), carbon
monoxide (CO), oxides of nitrogen (NO_X), and smoke are
within the applicable standards.
The emissions data of the notification are summarized below in
Table 1. Based on this testing demonstration, EPA believes that all
ETX-equipped engines will meet the 0.10 g/bhp-hr PM standard because
installation of the kit upon engine rebuild results in the replacement
of all emissions related parts with a specific set of parts, the
combination of which results in a documented PM level of 0.09 g/bhp-hr.
The fuel consumption impact of the ETX kit is discussed below as it
relates to the life cycle cost analysis.

Table 1.--Summary of Engelhard Testing
--------------------------------------------------------------------------------------------------------------------------------------------------------
g/bhp-hr
-----------------------------------------------------------------------------------------------------------------
Gaseous and particulate test HDDE standards
------------------------------------------ 1988 Calif 6V92TA DDEC 1991-1993 6V92TA DDEC 6V92TA DDEC II with
1988 1990 1991 II baseline \1\ II baseline \2\ ETX kit
--------------------------------------------------------------------------------------------------------------------------------------------------------
HC.................................... 1.3 1.3 1.3 0.8.................... 0.5................... 0.2
CO.................................... 15.5 15.5 15.5 1.4.................... 1.9................... 0.6
NO<INF>X................................... 10.7 6.0 5.0 5.5.................... 4.7................... 5.0
PM.................................... 0.60 0.60 0.25 0.43................... 0.28.................. 0.094
BSFC \3\.............................. 0.481.................. 0.498................. 0.503

[[Page 50227]]

Hp (R/O) \4\.......................... 277/273................ 277/281............... 277/266
--------------------------------------------------------------------------------------------------------------------------------------------------------
Smoke Test
(2)Standards (percent)
--------------------------------------------------------------------------------------------------------------------------------------------------------
ACCEL.................................
(2)20 3.6
LUG...................................
(2)15 0.6
PEAK..................................
(2)50 8.1
--------------------------------------------------------------------------------------------------------------------------------------------------------
\1\ All 6V92TA testing was performed on engine identification number 6VF-118287.
\2\ The DDC upgrade kit (25% reduction) configures an engine to the 1991 model year.
\3\ Brake Specific Fuel Consumption (BSFC) is measured in units of lb/bhp-hr.
\4\ Horsepower (Rated/Observed during testing).

Today's certification extends certification of equipment to engines
originally certified, or rebuilt, to meet emissions standards of
California (also referred to as 50-state configurations). The impact of
this decision on transit operators is discussed in more detail in the
``Transit Operator Requirements'' section below.
The ETX kit is intended to be installed at the time of a standard
engine rebuild. The contents of the ETX kit will vary depending upon
the model year of the engine to be rebuilt. All ETX kits will include
coated cylinder heads, coated cylinder kits, improved turbocharger, and
CMX-5 catalytic muffler. Additionally, the kit for applicable 1988
through 1990 model year engines will include fuel injectors, engine
camshafts, and ECM upgrade. To complete a rebuild of 1988 through 1990
model year engines, an operator must acquire on its own, the other
required (specified) standard engine rebuild parts: Blower and engine
gasket kit. To complete a rebuild of 1991 through 1993 model year
engines, an operator must acquire the specified standard blower, fuel
injectors, engine camshafts, and gasket kit. The emissions defect
warranty will cover the parts which Engelhard supplies in the ETX kit.
Engelhard is required to provide a 100,000 mile defect warranty and
150,000 mile emissions performance warranty for the components of ETX
kit.
The ETX equipment is certified to a PM emission level of 0.10 g/
bhp-hr for all 1988 through 1993 DDC 6V92TA DDEC II urban bus engines
using either diesel fuel #1 or #2 (including engines originally
certified, or rebuilt, to meet California emissions standards). Table 2
lists the applicable engine models and certification levels associated
with the certification announced in today's Federal Register.

Table 2.--Certification Levels
------------------------------------------------------------------------
Applicable models \1\ Engine code Certified PM level
------------------------------------------------------------------------
1988-1993 Detroit Diesel ALL (including those 0.10 g/bhp-hr.
6V92TA DDEC II. certified or
rebuilt to meet
California or 50-
state emissions
standards).
------------------------------------------------------------------------
\1\ Conditional certification applies to 1988 through 1990 model year
engines. See discussion in section IV.

II. Summary and Analysis of Comments

Comments were received from four parties in response to the Federal
Register notice (63 FR 17411, April 9, 1998): Detroit Diesel
Corporation (DDC), Johnson Matthey, Incorporated (JMI), New York City
Transit (NYCT), and Chicago Transit Authority (CTA). DDC is the
original manufacturer of the engines to which the ETX kit applies, and
both DDC and JMI have applied for certification of equipment to meet
the 0.10 g/bhp-hr standard under the urban bus program for these
engines. NYCT and CTA are both operators of urban bus fleets in areas
to which the Urban Bus Rebuild Requirements apply.
Comments and issues generally fell into the following categories:
(a) Equipment identification; (b) engine power rating; (c) emissions
testing; (d) durability and in-service concerns; (e) installation and
maintenance instructions; (f) exhaust back pressure; (g) components of
the kit; (h) life cycle cost; and, (i) California Engines. These are
discussed in the sections below.
Copies of the complete comments and other documentation are
available in the public docket, which is located at the address stated
above.

a. Equipment Identification

The Engelhard notification of October 21, 1997, proposed upgrading
all engines to one standard 277 hp configuration. Both DDC and JMI
comment that Engelhard should provide the programming for the
electronic control module (ECM) for each applicable engine and fuel
combination (left-hand rotation, right-hand rotation, diesel fuel #1,
and diesel fuel #2). DDC also notes that two different sets of engine
camshafts are necessary, depending upon engine rotation direction.
In response, Engelhard provides the ECM program numbers in its June
4 and 15, 1998 letters to EPA, as well as the camshaft part numbers for
left-and right-hand rotating engines.

b. Engine Power Rating

Both DDC and JMI comment that the ETX kit would update all
applicable engines, generally 253 and 277 horsepower, to only one
standard 277 horsepower (hp) configuration. JMI questions whether there
are additional costs or ramifications for transit operators who operate
253 hp engines, and states that Engelhard should justify

[[Page 50228]]

the upgrading of the 253 hp engines. DDC states that requiring
conversion from 253 hp to 277 hp would unfairly penalize operators who
presumably originally selected the 253 hp rating because it best met
their operating requirements, would create hardship if vehicle cooling
systems or drive lines needed to be upgraded to accommodate the higher
power level. DDC states that, if the ETX kit is approved as a trigger
of program requirements, then the trigger requirement should be
restricted to the 277 hp rating.
In response, in letters to EPA dated June 15 and August 6, 1998,
Engelhard states that it will offer 253 hp (high and low torque)
configurations of the ETX kit. EPA notes that today's certification
will trigger the 0.10 g/bhp-hr standard for both 253 hp and 277 hp
engines. EPA notes that the only difference between either the 253 hp
and 277 hp configurations is the ECM programming. Engelhard notes that
DDC's own DDEC 25% upgrade kit, converts both 253 hp and 277 hp engines
to one standard 277 hp. Engelhard states that the ETX 277 hp conversion
does not require an upgrade of the cooling system--both the 253 hp and
277 hp engine ratings use the same cooling system. Further, the ceramic
coated parts in the ETX kit reduce the load on the cooling system.
EPA notes that DDC's 25 percent upgrade kit for the DDEC engines
converts applicable engines to one standard 277 hp configuration.
However, this DDC kit is not required to be used by any operator,
because the kit did not trigger any program requirements. Instead, the
certified DDC 25 percent kit was an available option to operators that
were required to meet the program requirement of reducing PM emissions
by at least 25 percent.

c. Emissions Testing

NYCT comments that, although the ETX kit functioned adequately
under the Federal Test Procedure (FTP), further emissions testing is
required to prove that the ETX will perform to the same level of
emission reduction when subjected to a bus's operational cycle. NYCT
recommends using the Federal Transit Administration's Advanced Design
Bus Urban Driving Cycle to provide assurance that the projected
reductions are being achieved and that the full value of the investment
in the technology can be achieved.
Engelhard notes that the testing required by the regulation was
conducted, and that alternative cycle testing was not conducted.
EPA notes that to comply with the 0.10 g/bhp-hr PM standard of the
Urban Bus Rebuild Requirements, manufacturers must show compliance
using the FTP described at 40 CFR part 86 subpart N. This requirement
is consistent with EPA's new engine certification program, which
requires the engine FTP. Chassis cycle testing, as NYCT suggests,
generally determines emission rates on a grams per mile basis, which is
difficult to directly correlate to the grams per brake-horsepower-hour
(g/bhp-hr) determined by the engine FTP. While the level of emissions
reductions achieved by the ETX kit under the Advanced Design Bus Urban
Driving Cycle would be interesting, emission reductions determined by
chassis cycle testing may vary depending upon the specific driving
cycle and the specific coach used, and these reductions may not be
equivalent to the reductions predicted by the FTP. Chassis testing
would be of no use towards determining compliance with the 0.10 g/bhp-
hr standard because compliance with this absolute standard does not
necessarily correlate with a specific reduction, and it would be a
significant additional testing burden. The program regulation also
requires that candidate equipment must not cause an engine to fail to
meet applicable federal emission requirements (other than PM) under
part 86, which also requires testing using the engine FTP. EPA believes
that the FTP is the appropriate test cycle for determining compliance
with the 0.10 g/bhp-hr standard, and that it is not appropriate to
require Engelhard to conduct chassis testing to prove compliance with
that standard.

d. Equipment Durability and In-service Concerns

DDC provided several comments regarding durability. First, DDC
states that the performance and durability of the ETX kit has not been
demonstrated and that there is insufficient information in the
Engelhard notification. DDC acknowledges that the urban bus retrofit/
rebuild regulations do not require such testing as a condition of
certification, but expresses the concerns because trigger technology
places requirements on transit operators. DDC notes that the ETX
turbocharger is new, and without additional information, the effects of
the turbocharger on the operational characteristics can't be assessed.
DDC states concerns that the cylinder kits utilize DDC 15-to-1 nominal
compression ratio piston domes modified to accept the GPX coating. The
effective compression ratio of this cylinder kit is roughly 12.96
compared to roughly 13.96 with the standard DDC piston dome. The
reduction in compression ratio can have substantial effects on cold
starting, cold smoke, and noise. Experience with the ETX kit for the
MUI engine should not be taken as evidence of satisfactory cold
starting and noise performance because injection timing and spray
characteristics are different between the DDEC and MUI systems.
JMI also provided several comments regarding durability. JMI notes
that this ETX kit includes a new turbocharger, and that Engelhard
should be required to provide durability data or history for the use of
this part. Also, JMI states that Engelhard should be required to state
which piston dome is used in the ETX kit, because of recent changes
that DDC has made in certain design parameters in the piston dome,
piston rings, and piston skirt of its 25 percent upgrade kit. JMI
indicates that if the previous piston dome is used in the ETX kit, then
transits should expect to incur problems related to the rings, and that
Engelhard should modify its kit components and retest to confirm
emissions data.
Both NYCT and CTA comment about durability and reliability. CTA
asks whether Engelhard has performed thorough and long term in-service
reliability testing to ensure that the coated parts will last as long
as standard, non-coated parts. CTA notes durability problems that they
experienced with CMX converter model 0060, requiring replacement of
over 200 units in their fleet, and asks how much testing was performed
on the CMX-5 to ensure that problems will not be duplicated.
Maintenance, testing and reusability of used converts is a concern. CTA
also asks how a transit operator judges whether a converter is still
functioning correctly, and whether the engine coatings will affect oil
analysis and other maintenance programs.
NYCT comments that there is virtually no in-service operation
experience with the ETX kit, and states that such information is
essential to show that the technology can function reliably on a large
scale in daily operation. NYCT also states that it has experienced
extraordinary costs using a previously certified Engelhard converter.
NYCT has discovered that in certain circumstances the converter becomes
plugged, which drastically reduces the service life of the units. The
reduction in service life must affect the life cycle cost calculations.
NYCT states that it has installed more than 1,500 Engelhard catalytic
converters, and in-service back pressure checks have been very
inconsistent and in some case are increasing. Two catalyst units are
known to have plugged and have had to

[[Page 50229]]

be disassembled for repair. Increased back pressure results in greater
fuel consumption, which should be included in the life cycle cost
analysis.
In response to the DDC comments, Engelhard states that the improved
Engelhard turbocharger of the kit operates on the same principal as
DDC's certified MUI kit utilizing the Turbodyne Turbopac--increased air
flow and improved turbocharger response and that Engelhard has had
urban bus DDEC engines operating with GPX for nearly 7 years,
turbochargers in operation for over 100,000 miles, and diesel oxidation
catalysts in operation for over 300,000 miles. A turbocharger has been
in operation since December 1997 on a revenue-service DDC 6V92 DDEC II
bus with no durability, performance or operational problems. Engelhard
says that the transit operator is happy with the improved fuel economy
and performance due to the installation of the turbocharger. A similar
turbocharger has accumulated over 100,000 miles of normal operation on
a Class 8 tractor trailer utilized by Engelhard.
EPA notes that DDC does not specifically state what additional
information on the Engelhard's turbocharger that it needs, and that
Engelhard requests that information on the turbocharger remain
confidential. Regarding the comment that the cylinder kit will reduce
the compression ratio of the engine, Engelhard states that the
statement is false and the combination of the coated cylinder head and
coated piston is designed to maintain a compression ratio nearly
identical to that of a standard cylinder head and piston.
In response to the JMI comments, Engelhard states that it supplies
the cylinder kits of the ETX kit, which it assembles from standard DDC
parts, and Engelhard wishes that the specific part descriptions remain
confidential. In its May 30, 1997 letter to EPA, DDC describes the
changes that it made to its cylinder kits in order to improve cylinder
kit life, and states that the design changes have no effect on engine
performance or emissions. DDC also notes that the previous parts are to
be discontinued. Based on the available information, EPA has no reason
to believe that the parts of the ETX kit will negatively affect
emissions. Also, EPA notes that the components, as part of the
certified kit, are required to be covered by the program warranties.
In response to the NYCT comments, Engelhard states that DDEC
engines have been operating with GPX for nearly 7 years, turbochargers
in operation for over 100,000 miles, and diesel oxidation catalysts in
operation for over 300,000 miles. Over 500 buses (with MUI engines)
have installed ETX kits with some in operation for over 18 months with
no complaints about the coated components. The issue of coating
durability was addressed during the certification process of the ETX
kit for the MUI engines. If a coated component fails under warranty it
will be replaced by Engelhard free of charge as specified in the
emissions warranty. If one part of an ETX kit fails outside of the
warranty, a transit will be able to purchase specific components having
a standard Engelhard product warranty.
Engelhard states that it has worked closely with CTA to resolve the
early problems experienced with the CMX model 0060, which were caused
by inherent design defects of the bus and engine installation. The
engine in this bus model vibrates excessively and has continually
destroyed engine mounts, OEM mufflers, and catalytic mufflers
regardless of the supplier. The CMX 0060 has been redesigned to
overcome the problems. Due to the bus design, correct muffler
installation is critical for the muffler durability. Engelhard worked
with CTA to ensure proper installation to prevent future failures. All
units have been replaced at Engelhard's expense, including those that
failed due to incorrect installation, vibration failure, and muffler
design failures. Engelhard states that the problems experienced are
caused by the original bus design and limited to this one particular
bus and CMX combination. The particular bus model is essentially
limited to CTA, and is therefore not a widespread problem. Engelhard
solved all of the durability issues associated with this CMX unit with
the Engelhard re-design, which includes strengthening the inlet and
outlet pipe mounting points to the CMX body, upgrading the muffler
material from aluminized steel to stainless steel, and revising the
catalyst sleeving. This redesign will be incorporated in the CMX-5
provided with the ETX kit.
Regarding NYCT's catalyst comments, Engelhard states that NYCT's
problematic units were supplied by DDC and Donaldson as trap
replacement converter mufflers, and do not have an Engelhard warranty.
As a result, Engelhard does not know the history of the units.
Engelhard and its distributor have been working very hard with NYCT to
resolve their problems. Engelhard strongly suspects that the problem is
caused by engine malfunctions and engine failures, because the
catalysts have been installed for several years at this point in time,
and the engines were probably not rebuilt prior to catalyst
installation (since the catalysts were trap replacement units).
Certified catalysts, which began to be installed since the end of 1995,
are generally installed at the time an engine is rebuilt. When an
engine begins to fail it starts to use excessive oil and emit
particulate that have a very high soluble organic fraction, which can
result in plugging. The 2 catalyst units that NYCT references as being
plugged are Donaldson units in-use for 4 to 5 years (possibly beyond
the 100,000-mile warranty period that would have been applicable to a
certified catalyst), and the engines were not rebuilt prior to
installation of the catalysts. Engelhard has offered to reclaim some of
these Donaldson units for no cost to NYCT, but is under no warranty to
provide the service.
Regarding the in-service back pressure checks conducted by NYCT,
Engelhard has told EPA in a telephone conversation, that back pressure
can vary due to several factors, including the amount of prior idling,
and ambient pressure.
EPA notes that the NYCT comments reference several problems with
catalysts. For several reasons, however, EPA does not believe that
there is clear evidence that it is appropriate to apply additional
costs, either in terms of additional fuel consumption or maintenance,
to the life cycle cost analysis. First, catalysts used to replace
exhaust traps are not certified under the urban bus program, and it is
not clear that all in-service experience with such catalysts are
relevant to certified catalysts. (Pursuant to an agreement between DDC
and EPA, Donaldson traps were removed, because of severe durability
concerns, and replaced with catalytic converter-mufflers.) As Engelhard
notes, the problems NYCT has experienced occurred with uncertified
trap-replacement catalysts, not those certified under the urban bus
program, and the units were installed on engines that were not rebuilt
prior to installation. Second, NYCT does not present any data for
quantifying additional costs. NYCT does not indicate how much fuel
economy is affected by any in-use increases in back pressure, or how
often catalyst cleaning is necessary and how much time and material are
required for cleaning. NYCT comments do not substantiate that a
reduction in service life is due to catalyst plugging, or that
additional maintenance for cleaning the catalyst is necessary. EPA
notes that, from the information provided in NYCT's comments, 2 units
plugged out of 1500, and that these were trap-replacement

[[Page 50230]]

units. Engelhard's service procedure for the CMX notes that ``catalytic
converter mufflers are susceptible to plugging if the engine is
operated under low load conditions for extended periods of time while
(a) the engine is improperly maintained; or (b) the engine is not
properly calibrated for the specific fuel type and use of the catalytic
muffler.'' At this time, EPA does not have adequate basis to either
confirm that additional maintenance or fuel consumption occurs with
properly installed certified catalysts, or to quantify additional
costs.
Regarding CTA's concern about re-use of catalytic converters,
Engelhard states that it understands that operators would like to re-
use catalytic mufflers, but a used catalyst is an unknown quantity. A
method for accurately testing PM performance of a catalyst in the field
does not exist. Therefore, Engelhard requires that a complete kit be
installed for warranty purposes.
Engelhard states that the ETX kit does not need or require any
additional maintenance above the recommended DDC maintenance and, in
general, CMX converter mufflers do not require preventative maintenance
if the engines are operating properly. All analysis and maintenance
programs conducted by transit operators should continue as they are
now.
EPA has previously certified an Engelhard equipment package
utilizing GPX coatings (60 FR 47170, September 11, 1995). From the
standpoint of physical durability of the coating, EPA is not aware of
any premature wear or failure of this certified equipment. As mentioned
previously, in response to concerns about the physical durability of
the new GPX-5m coating, in a May 23, 1996 letter to EPA, Engelhard
provided data from three in-use buses using previous generation GPX-4
coatings. Coating thickness measurements were made on piston crowns and
cylinder head combustion chambers, and were found to be within nominal
design specifications at an average of 123,000 miles. In addition,
deposit formations on the combustion surfaces were nearly non-existent.
Engelhard indicates that design advances in the current GPX-5m coatings
are intended to further reduce deposit formation and increase coating
durability beyond that of the GPX-4 coating.
EPA appreciates that transit operators are concerned with the
durability of retrofit/rebuild equipment, and subsequent additional
costs or engine damage that potentially could result from premature
equipment failure. However, EPA notes that the urban bus retrofit/
rebuild regulations do not require an in-service durability
demonstration as a condition of certification. Rather, equipment
certifiers, including Engelhard, are required pursuant to 40 CFR
85.1409 to provide a 100,000 mile equipment defect warranty and a
150,000 mile emissions performance warranty.
EPA believes that equipment suppliers will evaluate the durability
of their equipment in order to minimize their liability resulting from
the emissions defect and performance warranties. EPA believes that the
available information does not indicate a durability concern with the
equipment certified in today's notice, and therefore, does not provide
sufficient basis to deny certification on these grounds. EPA will
continue to monitor problems with this, and other certified equipment,
and encourages transit operators to provide specific detailed
information regarding in-service problems with certified equipment.
The equipment certifier is responsible for the emissions
performance of the engine through the 150,000 mile emissions
performance warranty period, if the transit properly installs and
maintains equipment in accordance with the equipment manufacturer's
instructions. The transit operator is responsible for proper
installation and use of certified equipment, and is responsible for the
emissions performance of equipment operated beyond the 150,000 miles
emissions warranty period. Also, the retrofit/rebuild program does not
obviate compliance with any state or local emission requirements, such
as inspection/maintenance (I/M) or smoke testing programs.

e. Installation Instructions

DDC comments on several items of Engelhard's ETX ``Installation
Instructions'' for the ETX kit that were unclear, contain errors, and/
or lack appropriate instructions or information.
Engelhard agrees with DDC's comments, admits that these items are
not necessary for installation of the ETX, and Engelhard will remove
the requirements from the guidelines. Engelhard notes that the
guidelines were originally developed for installation of GPX in any
engine, and provided rebuild suggestions intended to prevent incorrect
engine assembly.
EPA appreciates DDC's in-depth review of the instructions, but does
not believe a detailed review of each item is necessary in today's
Federal Register notice. Details of these comments are in DDC's letter
to EPA dated May 22, 1998, which is available to interested parties in
the public docket referenced above.

f. Catalyst Checking Procedure

Both JMI and DDC provided comments expressing opposition to the
procedure recommended by Engelhard for determining whether the catalyst
unit requires cleaning. JMI comments that Engelhard, in its procedure
to determine whether the CMX-5 is operating properly, should be
required to change its procedure to match DDC's, which states that
exhaust back pressure measurements should be taken at wide open
throttle and full load.
CTA asks whether the issue of back pressure exceeding DDC's limits
has been addressed and resolved.
Engelhard's instructions involve operating the engine in a rated
speed, no load condition (high idle) and recording the pressure drop
across the CMX-5 unit. This is the same procedure recommended by
Engelhard for determining back pressure across the original CMX
catalytic muffler, and was derived from DDC Service Information
Bulletin 7-D-95. DDC, however, contends that this service procedure was
only intended for a limited population of 6V92TA engines that were
originally equipped with particulate traps. (Pursuant to an agreement
with EPA, these traps were removed because of durability concerns, and
replaced with catalytic converter-mufflers.) DDC's states that its back
pressure limits apply at all engine operating conditions, including the
point of maximum exhaust flow which occurs at rated engine speed, full
load. An exhaust system which just meets DDC's specified back pressure
limit at WOT, no load (which is how the Engelhard procedure is
conducted) will exceed the DDC limit over a large portion of the engine
speed/load operating map and thus would be in violation of DDC's
guidelines. Excessive back pressure results in fuel economy and power
losses, and raises cylinder temperatures and increases soot build-up in
the lubricating oil. These effects can reduce engine life.
Engelhard states that there is no difference between the specific
1993 engine models for which the DDC procedure applies, and the other
standard DDEC II engines. EPA notes that DDC has provided no
explanation of the difference, in terms of susceptibility to back
pressure impacts, between the engines for which Service Information
Bulletin 7-D-95 was intended, and those which are covered by this, and
other, retrofit certifications utilizing catalytic mufflers.

[[Page 50231]]

Regarding back pressure of the CMX units on the CTA buses discussed
above, Engelhard states that in testing done by Donaldson, the OEM
muffler had a back pressure of 3.7 inches Hg at full load. The CMX
actually has a back pressure equal to or lower than the OEM muffler. In
all cases the CMX-5 converter mufflers meet the back pressure
limitations of the OEM muffler designs and DDC specifications.
EPA is not requiring Engelhard to revise the screening procedure,
for several reasons. First, and in general, the program regulations do
not require any specific check procedures for any components of
certified kits. Second, EPA notes that the maximum exhaust back
pressure specification for several engine calibrations (codes) of the
6V92TA DDEC II engines is 4.0 inches of mercury (as specified in DDC's
application for certification of 1991 and 1992 6V92TA DDEC engines
under EPA's new engine certification program), and that the back
pressure specification for the Engelhard procedure is 3.0 inches of
mercury. Third, the Engelhard procedure is intended as a ``screen'' to
determine whether a catalyst muffler needs cleaning, not to measure
exhaust back pressure for comparison with DDC's maximum specifications.
For additional discussion of the issue, refer to page 12177 of the
Federal Register notice describing certification of the ETX kit for
6V92TA MUI engines (62 FR 12166, March 14, 1997.
Any future information provided by interested parties regarding the
impacts of certified equipment on exhaust back pressure would be taken
under consideration. EPA appreciates that there may room for
improvement in maintenance procedures of equipment certified under this
program. Such concerns, in general, can also occur with procedures
relating to new engines. EPA encourages all equipment certifiers to
issue revised check procedures when appropriate. If Engelhard
determines that another check is appropriate, or if EPA becomes aware
that back pressure is exceeding manufacturer limits on in-use buses,
then Engelhard should revise such procedures. Pursuant to 40 CFR
85.1413, EPA has authority to decertify equipment that does not comply
with the requirements of the regulations.

g. Components of the Kit

Engelhard has proposed to exclude certain parts from the ETX kit,
which are typically replaced during a standard rebuild. JMI comments
that Engelhard should include the fuel injectors, camshafts, and blower
in the ETX kit, and provide program warranty coverage for the parts.
JMI feels these parts should be included in the kit because the parts
are emissions related.
Engelhard will make available two ETX kits--one for the 1988
through 1990 model year engines, and the other for 1991 through 1993
model year engines. The particular kit required for any specific engine
will be determined by the DDC parts list requirement for the engine,
which will be determined by engine serial number. The kits differ as
described below. Applying the kit upon engine rebuild will result in
engines configured to one general (physical) ETX configuration. A
difference will be the ECM programming, which is related to power
rating, fuel type, and engine rotation direction.
The ETX kit for the 1988--1990 model year engines will include fuel
injectors and engine camshafts. The kit for the 1991--1993 will not
include the fuel injectors or engine camshafts. Neither kit will
include the blower assembly. The injectors and camshafts that must be
used with the ETX kit are common, non-unique, rebuild components for
the 1991--1993 model year engines, and therefore, not required to be in
the certified kit for 1991--1993 model year engines. A transit operator
would typically acquire the same parts for a ``standard'' engine
rebuild of a 1991 through 1993 model year engine, and the operator is
responsible for doing so when using the ETX kit. These parts (fuel
injectors, engine camshafts, and blower assembly) are required to be
the specified DDC-supplied components, because the DDC components were
used for the certification testing. In a letter from DDC to EPA dated
June 12, 1996, DDC states that there were no emission related design
changes made to the blower between 1988 and 1991. Therefore, EPA does
not require the blower to be included with the ETX kit because it is
not unique for the applicable engines. Engelhard is required to provide
program warranty coverage only for parts included with the kit.
The ETX kit includes a list of the specific engine rebuild parts
that are required to be used upon engine rebuild with the ETX kit. EPA
notes that in accordance with 85.1404, operators are required to
maintain records of all parts used in rebuilds. Using incorrect
components with the ETX kit at the time of kit installation can be
considered as failure to install a certified kit under the urban bus
rebuild requirements, and subject the operator to the significant
penalties provided by the regulation.

h. Life Cycle Cost

EPA requested comments on the life cycle cost analysis in the
Federal Register notice of April 9, 1998 (63 FR 17411) which summarized
the Engelhard notification and made it available for public comment.
Section 1403(b) of the program regulations describe those items which
must be considered when analyzing life cycle cost of equipment,
including equipment purchase price, incremental fuel cost/savings,
installation costs, maintenance costs, and other costs specific to fuel
additives and fuel conversions. All commenters provided input on at
least one cost-sensitive topic area. The comments received are
described below, and are grouped by general item or topic.
JMI comments that Engelhard should substantiate the validity of the
$6,966 that Engelhard uses (in their October 21 notification) for the
cost of a standard rebuild, and that EPA should scrutinize that figure
and subject it to the ``weighted rebuild'' cost analysis that was
completed for the Engelhard 0.10 g/bhp-hr MUI certification. EPA's
determination of life cycle costs is presented below in this section.
EPA's position on comments or issues, and scrutiny and analysis of life
cycle costs, are discussed below.
1. Comments on Purchase Price
Both DDC and JMI comment that Engelhard should include the cost of
reprogramming in the life cycle cost.
In response, Engelhard states that it will include the necessary
ECM reprogramming as part of the cost of the ETX kit.
2. Comments on Maintenance Cost
NYCT comments that it does not know the details of maintenance
required for the ETX kit, but it is confident that there is some
maintenance required, and the cost of such maintenance should be
included in the life cycle cost calculations.
Engelhard states that the ETX kit does not need or require any
additional maintenance above the recommended DDC maintenance. Engelhard
notes that, as with any engine there is a certain amount of up-keep
required. In the ETX application, Engelhard has stated that no
additional maintenance is required above and beyond the standard
maintenance specified by DDC for the 6V92 DDEC engine. Because the
maintenance requirement is identical to a standard engine, a cost of
maintenance is not necessary for the life cycle cost calculation.
Additionally, Engelhard maintains that the CMX-5 catalyst unit

[[Page 50232]]

is maintenance-free over the emissions performance warranty period of
150,000 miles, and notes that the currently certified CMX has been in
operation for over a year.
EPA believes that the engine upgrade portion of this equipment
requires no additional maintenance incremental to that required on a
standard rebuild. In addition, the coated component portion of the kit
cannot be serviced because the coated parts are internal to the engine.
Therefore, no additional maintenance is expected related to the coated
components. Regarding the catalyst unit, EPA has not seen any clear and
convincing information that it requires periodic maintenance during its
warranted lifetime, on properly operating engines. Therefore, in the
life cycle cost analysis presented below, EPA assumes that the ETX kit
does not require any additional maintenance above the recommended DDC
maintenance.
3. Comments on Fuel Consumption
NYCT comments that the ETX kit will have a fuel penalty, when based
on bus operating profiles, that is greater than the $1,315 determined
by Engelhard based on the FTP certification engine test cycle.
Both DDC and JMI comment that the test data indicate one percent
increase in fuel consumption between the ETX (0.503 lb/bhp-hr) and the
1991 DDEC engine test (0.498 lb/bhp-hr), and that this cost impact
should be included in the life cycle cost analysis. JMI states that
Engelhard's standard rebuild engine (a California configuration) is not
an appropriate baseline for fuel consumption impact because the
California standard for NO_X (6.0 g/bhp-hr) is lower than the
49-state standard (10.7 g/bhp-hr), and an engine operating with lower
NO_X emissions has higher fuel consumption. Also, it is
improper to use the DDC DDEC II 25% upgrade kit fuel penalty, because
the ETX kit uses a different turbocharger, and calls for Engelhard to
conduct a baseline test on a 1988 federal engine. JMI has accumulated
test data from a 1988 federal engine, and has made this data available
to EPA. The data show a brake-specific fuel consumption (BSFC) for a
1988 federal configuration 6V92TA DDEC II engine of 0.460 lb/bhp-hr.
JMI presents this data solely to illustrate that there is a difference
between 1988 federal and California engines, and not to suggest that
Engelhard should use JMI's baseline data.
With regard to NYCT's comment about fuel consumption, Engelhard
responds that the fuel consumption data was generated during the
Federal Test Procedure (FTP) as specified by the urban bus rebuild
regulations. Therefore, Engelhard must use it as the basis for the life
cycle cost.
EPA notes that 40 CFR 85.1407 (a)(3) states, in part, that
certifiers must include in their notification of intent to certify
``(t)he percent change in fuel economy * * * based on testing performed
over the heavy-duty engine Federal test procedure or an approved
alternative test procedure''. Engelhard complied with this requirement
by providing the percent change in fuel economy resulting from use of
the ETX kit as measured over the heavy-duty engine Federal test
procedure (FTP) described at 40 CFR Part 86 Subpart N. In addition, in
order to demonstrate compliance with the 0.10 g/bhp-hr PM, and other
regulated exhaust emissions standard, testing must be conducted using
the engine-based FTP. Therefore, the procedure used by Engelhard is in
compliance with program requirements, and EPA is not requiring
Engelhard to perform testing beyond the program requirements.
Regarding the JMI and DDC comments that the data show a one percent
fuel consumption penalty when the ETX kit is applied to 1991 model year
engines, Engelhard has submitted, in one of its letters dated June 15,
1998, data from one additional test of the ETX configuration and two
additional tests of the original DDC 1991-1993 model year
configuration. The fuel consumption data, referred to as brake specific
fuel consumption (BSFC), is measured in units of pounds of fuel per
unit of engine work, or brake-horsepower-hour (lb/bhp-hour). The
totality of fuel consumption data provided by Engelhard is summarized
below in Table 3. All of this testing was conducted in the same test
cell using the same basic engine (and power rating).

Table 3.--Engelhard Baseline and ETX Test Data
------------------------------------------------------------------------
Test description BSFC \1\ Average
------------------------------------------------------------------------
ETX Kit (277 hp)........................ 0.503 ..............
ETX Kit (277 hp)........................ 0.513 0.508
1991 50-s (277 hp)...................... 0.498
1991 50-s (277 hp)...................... 0.519
1991 50-s (277 hp)...................... 0.511 0.509
1988 50-s (277 hp)...................... 0.481 0.481
------------------------------------------------------------------------
\1\ Brake-specific fuel consumption measured in units of pounds of fuel
per brake horsepower-hour.

The average fuel consumption of the two ETX tests (0.508 lb/bhp-hr)
indicate that the ETX kit will present no fuel consumption penalty when
compared to the average of three tests in the 1991 model year
configuration (0.509 lb/bhp-hr). Also, the data indicate that
installing the ETX kit on 1988 through 1990 50-state (California)
engines will result in 5.6 percent increase in fuel consumption
(comparing 0.508 to 0.481).
With regard to JMI's comment that Engelhard should conduct baseline
testing using a 1988 model year 49-state (federal) engine, this data is
not available (Engelhard has not conducted testing on a 1988 model year
configuration). With regard to Engelhard's use of DDC data (supplied by
DDC during the certification process for its 25-percent DDEC upgrade
kit) for Engelhard's life cycle cost analysis, EPA believes that it is
not the most accurate way to determine fuel consumption impact because
of variables such as engines of different power ratings, in different
test cells, and being conducted two years apart. Additionally, because
different test cells were used, EPA agrees with JMI that it is not
appropriate to use JMI's 1988 federal engine data as a baseline to
compare data from ETX testing conducted for Engelhard. Instead, EPA
believes that other data, as discussed below, is adequate to determine
the impact of the ETX kit on 1988 through 1990 model year 49-state
(federal) engines.
In a telefax to EPA dated June 5, 1998, JMI provided documentation
of testing the 1988 model year federal 6V92TA that is referenced in its
above-mentioned comments. Additionally, JMI provided documentation from
testing a

[[Page 50233]]

1992 model year 6V92TA, in its notification of intent to certify
equipment dated March 6, 1998. EPA believes that these test data,
performed on 277 hp engines in the same test cell, can be used to
compare a 1991 configuration (the 1992 model year is considered
equivalent to the 1991) with a 1988 configuration. EPA believes that
the difference predicted by these data will be equivalent to the impact
on 1988-1990 engines resulting from installation of the ETX kit,
because the above-mentioned ETX testing indicates that the ETX kit will
result in no increased consumption compared to 1991 model year engines.
The JMI test documentation show a measured fuel consumption of 0.483
lb/bhp-hr for the 1992 engine, which is 5.2 percent greater than the
0.459 lb/bhp-hr measured for the 1988 engine. These data predict that
1988 through 1990 model year configurations will experience 5.2 percent
increased fuel consumption when equipped with the ETX kit. This level
of impact is generally supported by the above-mentioned DDC data. That
DDC data, as noted by Engelhard in its October 21, 1997 notification,
shows an impact of 4.7 percent. The 5.2 percent impact predicted using
the JMI data is greater than originally proposed by Engelhard (based on
the DDC data) in its notification of October 21. Also, EPA believes use
of the JMI data is more accurate because it was conducted using two
configurations (1992 and 1988 model years) of the same power rating in
the same test cell. The testing conducted by JMI can be found in the
public docket located at the above address.
EPA recognizes that the available data is limited, but believes it
adequate for the purpose of determining the life cycle cost analysis.
In summary, the installation of the ETX kit on 1991-1993 model year
engines is determined to result in no additional fuel consumption, on
1988-1990 50-state (California) engines is determined to result in 5.6
percent increased fuel consumption, and on 1988-1990 49-state (federal)
engines is determined to result in 5.2 percent increased in fuel
consumption. The impact of increased fuel consumption on life cycle
costs is determined below.
4. EPA Determination of Life Cycle Cost
Section 1403(b)(1)(ii) describes those items which must be
considered when analyzing life cycle cost of equipment, including
equipment purchase price, incremental fuel cost, installation costs,
maintenance costs, and costs of any fuel additives required. To trigger
the 0.10 g/bhp-hr standard, the life cycle cost of equipment can be no
more than $7,940 (in 1992 dollars), incremental to the cost of a
standard rebuild.
In this section, EPA analyzes the life cycle costs using a
methodology similar to that described in the Federal Register notice of
March 14, 1997, which describes the certification of Engelhard's ETX
kit applicable to DDC's 6V92TA engines with mechanical unit injectors
(MUI). The analysis first determines the cost of a ``weighted''
rebuild, which reflects operators' use of non-original equipment parts
and rebuilding certain components in-house. The weighted rebuild
``corrects'' all cost information to a 1992 base, which is the time
period for which the life cycle cost limit of $7,940 is based. EPA uses
the cost of a weighted rebuild to represent the cost of a standard
rebuild, which is then used to determine a maximum allowable purchase
price such that the life cycle cost of the equipment meets the life
cycle cost limit. The maximum purchase price, when added to the
incremental fuel penalty and installation cost, and offset by the value
of displaced standard rebuild parts, must be no more than $7,940 (in
1992 dollars), incremental to the cost of a standard rebuild.
i. Cost of a standard rebuild. Engelhard presented a life cycle
cost analysis in its notification signed October 21, 1997, and made
changes to the analysis in subsequent letters to EPA. The Engelhard
analyses rely on DDC suggested list prices to determine the cost of a
``standard'' rebuild. Engelhard, in one of its letters dated June 15,
1998, provides a letter from Atlantic Detroit Diesel-Allison with
current suggested list prices for DDC parts. Table 4 below presents OE
list prices presented by Engelhard for the standard rebuild parts
affected by the ETX kit. In the table, EPA has corrected the
information to a 1992 time period, using a multiplicative ratio of
Consumer Price Indices (CPI). The average CPI for 1992 is 140.3, as
specified by the program regulation. The April 1998 CPI, for all items
and all urban consumers, is 162.5. These values are available from the
U.S. Department of Labor, Bureau of Labor Statistics.

Table 4.--Original Equipment (OE) Parts Prices
----------------------------------------------------------------------------------------------------------------
Price
OE suggested corrected to
Item in kit (quantity) list price Normally replaced at overhaul ? 1992 (based on
CPIs)
----------------------------------------------------------------------------------------------------------------
Cylinder Kits (6)............................ $2,394 Yes.............................. $2,067
Gasket Kit (1)............................... 207 Yes.............................. 179
Fuel Injectors (6)........................... 1,688 Yes.............................. 1,457
LB Camshaft (1).............................. 854 Yes.............................. 738
RB Camshaft (1).............................. 731 Yes.............................. 631
Blower Ass'y (1)............................. 575 Yes.............................. 496
Turbo Ass'y (1).............................. 890 Yes.............................. 768
Heads Ass'y (2).............................. 1,166 Yes.............................. 1,007
ECM Program (1).............................. (\1\) No............................... ..............
Totals................................... $8,505 ................................. $7,343
----------------------------------------------------------------------------------------------------------------
\1\ Not required.

Engelhard, in one of its letters dated June 15, 1998, states that
it is their experience that almost all major transits in major
metropolitan areas use 100 percent DDC parts. Therefore, non-OE parts
do not affect the life cycle cost. Also, Engelhard states that,
although at one time a common practice, today virtually no large urban
transit companies re-manufacture their own components (such as
turbochargers, blowers, and heads). Engelhard further notes that in-
house engine rebuilding refers to the process of disassembling and
reassembling the engine, and that this is different from re-
manufacturing engine components.

[[Page 50234]]

In response to Engelhard's comments about the current practice of
(not) re-manufacturing components in-house, EPA believes that the
current practice is not relevant. Instead, the relevant practice is the
amount of in-house re-manufacturing at the point in time when the life
cycle cost ceiling was established (that is, in the 1992-1993 time
frame). EPA acknowledges that industry practice may have changed since
1993, for various reasons, such as general industry trends, or perhaps
the urban bus program certification of kits that include most emissions
related parts. However, at the relevant point in time (1993 or
earlier), EPA believes that a significant number of transits re-
manufactured parts in-house. EPA understands Engelhard's comment
concerning the difference between in-house engine rebuilding and
component re-manufacturing, but the practice of in-house re-
manufacturing is supported by Engelhard's comments (``at one time this
was a common practice . . .'') and EPA telephone conversations with
transit operators. Therefore, for the determination of the cost of a
weighted rebuild, EPA assumes that some parts used in the rebuild of
engines are non-OE parts, and that most transits re-manufacture certain
components in-house.
In comments related to certification of its ETX kit for 6V92TA MUI
engines, Engelhard stated that the weighted cost approach should be
adjusted to reflect an additional cost to transit operators who rebuild
in-house, because parts are occasionally not rebuildable due to
catastrophic failure. EPA is retaining this methodology for determining
the cost of a weighted rebuild for DDEC engines. Engelhard stated that
10 percent of turbochargers and blowers are not rebuildable, and that
50 percent of cylinder heads are not rebuildable. When parts are non-
rebuildable, a transit operator would typically purchase a new
component at fleet cost. The nominal cost of these components assumes
the exchange of a rebuildable core. If the core is not rebuildable,
then the operator pays a core charge plus the nominal cost of the
component. The sum of the component fleet price plus the core charge
represent additional costs to fleets that rebuild in-house, due to non-
rebuildable parts. When weighted based on the frequency at which the
part is non-rebuildable, it yields an additional cost on a per-
component basis. Consistent with the past cost analysis, EPA assumes
in-house rebuild of three components: the turbocharger, the blower, and
the cylinder heads. Table 5 below summarizes estimates of the
additional costs related to the in-house rebuild of these parts.
Also, EPA has included injectors in Table 5 below, based on new
information presented by Engelhard in one of its letters dated June 15,
1998. Engelhard stated that injectors should be included in this table
because operators normally purchase rebuilt injectors that have a core
charge. The 1998 core charge is $200 per injector and approximately 10
percent fail, but since the list price of a new injector is $604, an
operator will pay the core charge and still purchase a rebuilt
injector.

Table 5.--Core Cost Impact of Non-rebuildable Parts
[1992 Dollars]

OE In-house
Item suggested OE fleet rebuild Fraction Core charge Total cost
price price cost damaged (1) to transit
A B C D E F G
1 Injector....................... $243 $224 NA 0.10 $173 $242
Blower............................ 496 459 $223 0.10 474 294
Turbo............................. 768 710 346 0.10 288 411
1 Head........................... 503 465 227 0.50 395 543
----------------------------------------------------------------------------------------------------------------

The OE Fleet Prices for the blower, turbocharger, and cylinder
heads are estimated by EPA, using the same ratio of the prices for
these parts set forth during the certification process of the ETX kit
for 6V92TA MUI engines. Core charges for the blower, turbocharger, and
cylinder head are estimated by EPA based on the fractions (of OE
suggested prices) as the values EPA used in the methodology of the
analysis of weighted rebuild in the ETX 0.10 MUI kit. The core charge
for the injectors is provided by Engelhard in one of its letters dated
June 15, 1998. In-House Rebuild Costs are 45% of OE suggested prices,
based on JMI comment relating to certification of the DDC MUI 25%
upgrade kit (60 FR 51472, October 2, 1995).
For the blower, turbocharger, and heads, Table 5 above makes a
correction to the calculation described in the July 19, 1996 Federal
Register (61 FR 37738). Table 5 determines a weighted Total Cost to
Transit, based on the fraction of parts damaged. Total Cost to Transit
= (1-E)(D)+(E)(C+F) for the blower and turbocharger. For the cylinder
heads, the Total Cost = (D)/2 + (C+F)/2, which is an average cost for
one head. For fuel injectors, the Total Cost = (1-E)(C)+(E)(C+F) per
injector.
Table 6 below summarizes the cost of a weighted rebuild (in 1992
dollars) including adjustments to the above components.

Table 6.--Cost of a Weighted Rebuild
[1992 Dollars]
----------------------------------------------------------------------------------------------------------------
OE list OE fleet Weighted
Item in kit price Non-OE cost price rebuild
----------------------------------------------------------------------------------------------------------------
1 Cylinder Kit............................................. $2,067 $1,049 $1,777 $1,540
2 Gasket Kit............................................... 179 134 153 147
3 Fuel Injectors........................................... 1,457 NA 1,346 1,450
4 LB Camshaft.............................................. 738 553 632 606
5 RB Camshaft.............................................. 631 473 541 519
6 Blower Ass'y............................................. 496 294 459 302
7 Turbo Ass'y.............................................. 768 411 710 424
8 Heads Ass'y.............................................. 1,007 1,087 930 1,079

[[Page 50235]]

9 ECM Program.............................................. (\1\) (\1\) (\1\) (\1\)
Totals.................................................. 7,343 ........... ........... 6,067
----------------------------------------------------------------------------------------------------------------
\1\ Not required.

The non-OE cylinder kit cost is based on an Engelhard comment dated
July 19, 1995, that the aftermarket cylinder kit costs 1,139.94,
corrected to 1992 dollars (the CPI for June 1995 is 152.5). The prices
of non-OE gasket kit and camshafts are 75% of the 1992 corrected OE
prices, based on 25 percent discount from OE list prices, as discussed
in the March 14, 1997 Federal Register notice (62 FR 12177). The OE
Fleet Prices are estimated by EPA, as the same fractions (of OE
suggested prices) as the values EPA used in the analysis of the
Engelhard 0.10 MUI kit.
As was done in the analyses of a MUI weighted rebuild, EPA makes
two adjustments to its analysis of the cost of a weighted rebuild.
First, all costs are corrected to 1992 dollars. Second, the weighted
rebuild is modified to reflect non-OE parts costs that are 25 percent
less than OE cost.
For the cylinder kits, gasket kit, and both camshafts, a weighted
cost is determined as the sum of the non-OE cost, weighted 32.6
percent, plus the DDC suggested cost of parts, weighted 67.4 percent.
This weighting is based on the APTA survey showing the relative split
in operators' parts business between OE and non-OE parts suppliers. The
APTA survey (American Public Transit Association Transit Bus Diesel
Engine Rebuilding Survey by Michael J. Meloche, January 1991) indicates
that 67.4% of operators parts business is with OE parts suppliers, and
32.6% is with non-OE suppliers. The APTA survey can be found in the
public docket at the above address. The cost of the fuel injectors are
determined above in Table 5. Based on the APTA survey, 95.5 % of the
blower, turbochargers, and heads are assumed to be re-manufactured in-
house at the Non-OE Costs, and the balance purchased at OE fleet
prices. The ECM is not reprogrammed during a standard rebuild.
EPA recognizes that there are a number of uncertainties and
assumptions involved with this ``weighted'' approach, but believes,
based on the available information, that the cost of a standard rebuild
of a DDC 6V92TA DDEC engine is best approximated by the weighted
rebuild costs shown above in Table 6, for the purposes of determining
the maximum allowable purchase price for the Engelhard ETX kit.
ii. Incremental fuel cost. The percentage fuel consumption impacts,
as discussed in above Section 3, are shown below in Table 7 along with
the impact due to increased life-time fuel costs pursuant to the
calculations of 40 CFR 85.1403(b)(1).

Table 7.--Fuel Consumption Impact of ETX Kit
[1992 dollars]
------------------------------------------------------------------------
Fuel penalty
Applicable engine Percent BSFC per 40 CFR
impact 85.1403(b)(1)
------------------------------------------------------------------------
1988-1990 49-s.......................... -5.2 ($1,473)
1991-1993 49-s.......................... 0.2 0
1988-1990 50-s.......................... -5.6 (1,581)
------------------------------------------------------------------------

iii. Installation costs. As defined in 40 CFR 85.1403
(b)(1)(ii)(B), the installation cost of certified equipment is ``the
labor cost of installing the equipment on an urban bus engine,
incremental to a standard rebuild, based on a labor rate of $35 per
hour'' (in 1992 dollars). Engelhard states that the labor required to
rebuild an engine will be the same for a standard rebuild and the ETX
kit, with the exception of the additional labor required for
installation of the CMX catalytic muffler. The urban bus engines for
which this equipment is intended were not originally equipped with
catalytic convertors. Therefore, the muffler unit must be removed from
the engine, and the CMX-5 unit installed in its place. Engelhard states
that installation of the CMX-5 catalyst unit requires a maximum time of
six hours to install on an urban bus engine. Using the labor rate of
$35.00 per hour, as specified in the regulation (40 CFR 85.1403), the
six hours is valued at $210 (in 1992 dollars). The $210 is incremental
to the cost of a standard rebuild.
iv. Maintenance costs. Engelhard states that after installation of
the ETX kit, an engine will require no maintenance above the standard
rebuild. EPA has no information to conclude that any additional
maintenance is necessary for the CMX-5 catalyst muffler, or would
increase life cycle costs. Therefore, no additional maintenance costs
are listed for the ETX kit.
v. Costs of fuel additives. No fuel additives are required for the
ETX kit.
vi. Total life cycle cost calculation. The regulation at 40 CFR
85.1403 requires that the life cycle cost, for equipment that triggers
the 0.10 g/bhp-hr standard, be no more than $7,940 (in 1992 dollars)
incremental to the cost of a standard rebuild. Table 8 below summarizes
the life cycle costs for the ETX kit for each of the three groups of
applicable engines: 1988 to 1990 model year 49-state engines, 1988
through 1990 model year 50-state engines, and 1991 through 1993 model
year 50-state engines. Separate summaries are presented because of the
differing kits, and the different fuel penalty determined for each
group.

[[Page 50236]]

Table 8.--Life Cycle Costs
[1992 dollars]
----------------------------------------------------------------------------------------------------------------
Applicable engines
-----------------------------------------------
1988-1990 49- 1991-1993 49- 1988-1990 50-
State State State
----------------------------------------------------------------------------------------------------------------
Maximum Allowable Purchase Price................................ $11,876 $10,774 $11,768
Offset for kit parts normally replaced during a standard rebuild (5,619) (3,044) (5,619)
Installation Cost............................................... 210 210 210
Fuel Penalty.................................................... 1,473 0 1,581
Total Incremental Life Cycle Cost............................... 7,940 7,940 7,940
----------------------------------------------------------------------------------------------------------------

The table displays the maximum allowable purchase prices for the
ETX kits, in 1992 dollars. The total incremental life cycle cost is the
sum of the listed items. An ``offset'' is provided to the life cycle
cost because certain components provided in the ETX kits offset costs
for parts which otherwise are replaced during a standard engine
rebuild. The values, for the individual rebuild parts that are offset
by the kit parts, are discussed above in conjunction with the
determination of a weighted rebuild and itemized in Table 6. To
determine the incremental life cycle cost, these ``offset'' costs are
subtracted, as shown in Table 8. As shown in the table, the total
incremental life cycle cost is no more than the ceiling specified in
the program regulations, $7,940 in 1992 dollars. Engelhard, in its
letter to EPA dated July 1, 1998, guarantees to make ETX kits available
to all affected urban bus operators for no more than the maximum
allowable purchase price. Current values of the maximum purchase prices
are discussed below.
vii. Current Maximum Allowable ETX Purchase Price. Table 9 below
shows the maximum allowable purchase price (in 1992 dollars) as
determined above. The current (April 1998) maximum allowable purchase
prices, calculated using a multiplicative ratio of CPI's, are also
shown in the table. The average CPI for 1992 is 140.3, as specified by
the program regulation. The April 1998 CPI, for all items and all urban
consumers, is 162.5. These CPI values are provided by the U.S.
Department of Labor, Bureau of Labor Statistics.

Table 9.--Current Maximum ETX Kit Purchase Price
------------------------------------------------------------------------
April 1998
Applicable model year 1992 maximum maximum
purchase price purchase price
------------------------------------------------------------------------
1988-1990 49-State...................... $11,876 $13,755
1991-1993 50-State...................... 10,774 12,479
1988-1990 50-State (California)......... 11,768 13,630
------------------------------------------------------------------------

III. California Engines

The NO_X emission standard for new engine certification
applicable to 1988 through 1990 model year engines sold in the State of
California is 6.0 g/bhp-hr. For 1991 through 1993, the standard is 5.0
g/bhp-hr. The emissions testing presented by Engelhard demonstrate a
NO_X emissions level that complies with the 5.0 g/bhp-hr
standard. Therefore, today's certification of the ETX kit for DDEC II
engines applies to DDEC II engines certified to meet California
emissions standards, subject to the conditions discussed below.
The equipment certified today may require additional review by the
California Air Resources Board (CARB) before use in the State of
California. EPA recognizes that special situations may exist in
California that are reflected in the unique emissions standards, engine
calibrations, and fuel specifications of the State. While requirements
of the federal urban bus program apply to several metropolitan areas in
California, EPA understands the view of CARB that equipment certified
under the urban bus program, to be used in California, must be provided
with an executive order exempting it from the anti-tampering
prohibitions of that State. Parties interested in additional
information should contact the Aftermarket Part Section of CARB, at
(818) 575-6848.

IV. Certification and Conditional Certification

EPA has reviewed this notification, along with comments received
from interested parties, and finds the equipment described in this
notification of intent to certify:
(1) Complies with a particulate matter emissions standard of 0.10
g/bhp-hr, without causing the applicable engine families to exceed
other applicable emission requirements, subject to the conditions
discussed below;
(2) Will not cause an unreasonable risk to the public health,
welfare or safety;
(3) Will not result in any additional range of parameter
adjustability; and
(4) Meets other requirements necessary for certification under the
Urban Bus Rebuild Requirements (40 CFR Sections 85.1401 through
85.1415).
With the following conditions, EPA hereby certifies this equipment
for use in the Urban Bus Retrofit/Rebuild Program. As noted above, the
equipment being certified today includes, for 1988-1990 model year
engines, an upgraded control program for the electronic control module.
EPA has recently become concerned that many electronically controlled
engines may have been equipped by the original manufacturers with
strategies designed to decrease fuel consumption during certain driving
modes not substantially included in the federal test procedure, with
the effect of substantially increasing NO_X during these
modes. Such electronic control strategies have the potential to be
``defeat devices'' as defined at 40 CFR 86.094-22, and thus may violate
40 CFR 85.1406 and 85.1408 if included in an urban bus retrofit
application. The upgraded control program used for the 1988-1990 model
year upgrade must therefore be reviewed for such violations.

[[Page 50237]]

As a result, certification of the ETX kit, as it applies to 1988
through 1990 model year engines, is conditioned upon Engelhard
demonstrating by January 1, 1999 that any replacement engine control
module (ECM) or ECM program used in conjunction with the certified kit
will not adversely impact the emissions of NO_X in comparison
to the ECM or ECM program that is being replaced under conditions which
may reasonably be expected to be encountered in normal vehicle
operation and use unless such conditions are substantially included in
the Federal emission test procedure. The equipment, the ETX-
2002TM Emissions Rebuild Kit, may be used immediately by
transit operators in compliance with requirements of this program,
subject to the above condition.

V. Transit Operator Responsibilities

Today's Federal Register notice announces certification of the
above-described Engelhard equipment, when properly applied, as meeting
the 0.10 g/bhp-hr particulate matter standard of the Urban Bus Rebuild
Program for urban bus engines certified as meeting both federal and
California emissions standards. Affected urban bus operators who choose
to comply with compliance program 1 are required to use this, or other
equipment that is certified to meet the 0.10 g/bhp-hr particulate
matter standard, for any engines listed in Table 2 which are rebuilt or
replaced on or after March 22, 1999, subject to the condition of
Section IV.
Urban bus operators who choose to comply with compliance program 2
may use the certified Engelhard equipment, and those who use this
equipment may claim the respective particulate matter certification
level from Table 2 when calculating their Fleet Level Attained (FLA),
subject to the condition of Section IV.
Urban bus operators must be aware of their responsibility for
maintenance of records pursuant to 40 CFR 85.1403 through 85.1404. The
ETX kit may not include, depending upon model year of the applicable
engine, fuel injectors, engine camshafts, and blower assembly. As
stated in the program regulations (40 CFR 85.1401 through 85.1415),
operators should maintain records for each engine in their fleet to
demonstrate that they are in compliance with the Urban Bus Rebuild
Requirements beginning on January 1, 1995. These records include
purchase records, receipts, and part numbers for the parts and
components used in the rebuilding of urban bus engines. Urban bus
operators must be able to demonstrate that all parts used in the
rebuilding of engines are in compliance with program requirements. In
other words, urban bus operators must be able to demonstrate that all
required components of the kit certified in today's Federal Register
notice are installed on applicable engines.

Dated: September 11, 1998.
Robert Perciasepe,
Assistant Administrator for Air and Radiation.
[FR Doc. 98-25198 Filed 9-18-98; 8:45 am]
BILLING CODE 6560-50-P

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