Retrofit/Rebuild Requirements for 1993 and Earlier Model Year
Urban Buses; Approval of an Application for Certification of Equipment
Related Material
[Federal Register: February 2, 2000 (Volume 65, Number 22)]
[Notices]
[Page 4959-4965]
From the Federal Register Online via GPO Access [wais.access.gpo.gov]
[DOCID:fr02fe00-65]
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ENVIRONMENTAL PROTECTION AGENCY
[FRL-6531-4]
Retrofit/Rebuild Requirements for 1993 and Earlier Model Year
Urban Buses; Approval of an Application for Certification of Equipment
AGENCY: Environmental protection agency (EPA).
ACTION: Notice of agency approval of an application for equipment
certification.
-----------------------------------------------------------------------
SUMMARY: The Agency received a request to amend a notification of
intent to certify urban bus retrofit/rebuild equipment for 4-stroke
petroleum fueled diesel engines pursuant to 40 CFR part 85, subpart O
from Engelhard Corporation (Engelhard). Engelhard requested to amend
the original notification to include additional engine models. Pursuant
to section 85.1407(a)(7), a November 30, 1998 Federal Register document
summarized the amendment and announced that the amendment request and
accompanying data would be available for public review and comment, and
initiated a 45-day period during which comments could be submitted. In
the document, the Agency stated it would review this request to amend
the notification of intent to certify, as well as comments received, to
determine whether the equipment should be certified for the additional
models.
EPA has completed its review of this amendment request and the
Director of the Certification and Compliance Division (CCD) has
determined that the requirements for certification have been met.
Accordingly, today's Federal Register document describes the
certification of this equipment for the engine models listed in Table C
of this document.
Testing documentation presented to the Agency demonstrates a
reduction in particulate matter (PM) of at least 25% for the engines
listed in Table C. Life cycle cost information was not submitted by
Engelhard and this approval does not trigger requirements for the
additional models. Certification of this equipment makes it available
for operators complying with the 25% particulate matter reduction
requirements of compliance program 1 and may also be used by operators
utilizing program 2 to achieve target fleet emission levels.
DATES: Today's Federal Register document announces the Agency's
decision to certify the CMX equipment for certain 4 stroke/cycle urban
bus engines. The effective date of certification was established in a
letter dated November 30, 1999 from the Director of the Certification &
Compliance Division to Engelhard Corporation. A copy of this letter is
in the public docket located at the address noted above. This equipment
may be used immediately by urban bus operators.
ADDRESSES: The application, as well as other materials specifically
relevant to it, are contained in Public Docket A-93-42 (Category XVII-
A), entitled ``Certification of Urban Bus Retrofit/Rebuild Equipment''.
This docket is located in room M-1500, Waterside Mall (Ground Floor),
U.S. Environmental Protection Agency, 401 M Street SW, Washington, DC
20460.
[[Page 4960]]
Docket items may be inspected from 8:00 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.
FOR FURTHER INFORMATION CONTACT: Anthony Erb, Engine Compliance
Programs Group, Certification & Compliance Division (6403J), U.S.
Environmental Protection Agency, Ariel Rios Building, 1200 Pennsylvania
Avenue, N.W. Washington, D.C. 20460. Telephone: (202) 564-9259. Email
Address: ERB.ANTHONY@EPA.GOV.
SUPPLEMENTARY INFORMATION:
I. Program Background
On April 21, 1993, the Agency published final Retrofit/Rebuild
Requirements for 1993 and Earlier model Year Urban Buses (58 FR 21359).
The retrofit/rebuild program is intended to reduce the ambient levels
of particulate matter (PM) in urban areas and is limited to 1993 and
earlier model year (MY) urban buses operating in metropolitan areas
with 1980 populations of 750,000 or more, whose engines are rebuilt or
replaced after January 1, 1995. Operators of the affected buses are
required to choose between two compliance programs: Program 1 sets PM
emissions requirements for each urban bus engine in an operator's fleet
which is rebuilt or replaced; Program 2 is a fleet averaging program
that establishes specific annual target levels for average PM emissions
from urban buses in an operator's fleet.
Certification of retrofit/rebuild equipment is a key element of the
retrofit/rebuild program. To demonstrate compliance under either of the
compliance programs, operators of the affected buses must use equipment
that has been certified by the Agency. Emissions requirements under
either of the two compliance programs depend on the availability of
certified retrofit/rebuild equipment for each engine model. To be used
for program 1, equipment must be certified as meeting a 0.10 g/bhp-hr
PM standard or as achieving a 25 percent reduction in PM. Equipment
used for program 2 must be certified as providing some level of PM
reduction that would in turn be claimed by urban bus operators when
calculating their average fleet PM levels attained under the program.
For program 1, information on life cycle costs must be submitted in the
notification of intent to certify in order for certification of the
equipment to initiate (or trigger) program requirements. To trigger
program requirements, the certifier must guarantee that the equipment
will be available to all affected operators for a life cycle cost of
$7,940 or less at the 0.10 g/bhp-hr PM level, or for a life cycle cost
of $2,000 or less for the 25 percent or greater reduction in PM. Both
of these values are based on 1992 dollars.
II. Notification of Intent to Certify
By a notification of intent to certify signed November 18, 1996,
Engelhard applied for certification of equipment applicable to all
Cummins L-10 engines that were originally manufactured prior to and
including 1993. The notification of intent to certify stated that the
candidate equipment would reduce PM emissions 25 percent or more on
petroleum-fueled diesel engines that are rebuilt to Cummins
specifications.
The candidate equipment consists of a ``catalytic converter
muffler'' or CMXTM, that is an exhaust noise muffler
containing an oxidation catalyst. Life cycle cost information was
submitted with the original notification, along with a guarantee that
the equipment would be offered to all affected operators for less than
the incremental life cycle cost ceiling. After completion of its
review, EPA determined that the certification approval for the November
18 application was limited to the Cummins L-10 electronically
controlled (EC) engines based on the testing data supplied. EPA
certified this equipment as a trigger for the requirements for
operators using compliance option 1, to reduce PM by 25% when
rebuilding or replacing 1992-1993 Cummins L-10 EC models. A document
was published in the Federal Register on March 30, 1998 (63 FR 13660)
announcing this certification.
In a letter to EPA dated April 20, 1998, Engelhard requested that
the March 30 certification be amended to include all pre-1994 Cummins
L-10 models (including the non-electronically controlled models) and
all other 4-stroke urban bus engines. On November 30, 1998 EPA
published a document in the Federal Register requesting comment on the
amendment request and on the appropriateness of the engines being
considered for this certification and requested information on any
additional engines for which this certification may be applicable. In
response, the Detroit Diesel Corporation (DDC) commented that it had
certified and produced the Series 50 engine for use in urban bus
applications for which this certification might be applicable in the
``all other 4-stroke'' general category. Accordingly, EPA has included
the Series 50 engine for consideration in the ``all other 4-stroke''
urban bus engine category in this document. Table A below provides a
listing of the 4-stroke urban bus engines and the certification levels
for which the candidate equipment was considered.
Table A.--Affected Models and Proposed Engelhard CMX Certification Levels \1\
--------------------------------------------------------------------------------------------------------------------------------------------------------
Cummins Retrofit PM
control New Engine Retrofit PM level with
Cummins/other engine family parts list Manufacture dates PM level level with CMX and
(CPL) CMX Cummins kit
--------------------------------------------------------------------------------------------------------------------------------------------------------
343B............................................................... 780 11/20/85 to 12/31/87........... 0.58 0.44 0.26
343B............................................................... 0781 11/20/85 to 12/31/87........... 0.59 0.44 0.26
343C............................................................... 0774 11/20/85 to 12/31/89........... 0.46 0.34 0.26
343C............................................................... 0777 11/20/85 to 12/31/89........... 0.61 0.46 0.26
343C............................................................... 0996 12/04/87 to 08/19/88........... 0.61 0.46 0.26
343C............................................................... 1226 07/26/88 to 12/31/90........... 0.50 0.38 0.26
343F............................................................... 1226 07/12/90 to 08/26/92........... 0.45 0.34 0.26
343F............................................................... 1441 12/18/90 to 12/31/92........... 0.46 0.34 0.26
343F............................................................... 1622 04/24/92 to 12/31/92........... 0.46 0.34 0.26
343F............................................................... 1624 04/24/92 to 12/31/92........... 0.45 0.34 0.26
Other \2\ 4-stroke engines......................................... N/A Pre-1988....................... 0.50 0.38 N/A
[[Page 4961]]
CAT
GM
IH/Navistar
MAN
Saab-Scania
Volvo
Other 4-stroke engines............................................. N/A 1988 to 1993................... (\3\) (\4\) N/A
CAT
DDC/Series 50
GM
IH/Navistar
MAN
Saab-Scania
Volvo
--------------------------------------------------------------------------------------------------------------------------------------------------------
\1\ The new Engine PM certification levels for Cummins engines are based on the certification level or the average test audit result for each engine
family. It is noted that for engine family 343F, although the PM standard for 1991 and 1992 was 0.25 g/bhp-hr and the NOX standard was 5.0 g/bhp-hr,
Cummins certified the 1226, 1441, 1622, and 1624 CPLs to a Federal Emission Limit (FEL) of 0.49 g/bhp-hr PM and 5.6 g/bhp-hr NOX under the averaging,
banking and trading program.
\2\ Applicable to the following 4-stroke engines installed in applicable urban buses: Caterpillar 8 cylinder engines, General Motors 6 cylinder and 8
cylinder engines, International Harvester/Navistar 8 cylinder engines, MAN 6 and 8 cylinder engines, Saab-Scania 6 cylinder engines, and Volvo 6
cylinder engines.
\3\ Certification level.
\4\ 25% reduction from certification PM levels.
In today's Federal Register document, EPA is identifying the
engines in the ``all other 4-stroke'' category as listed in Table A. In
a letter to EPA dated March 16, 1998 Engelhard stated that the
inclusion of ``all other 4-stroke engines'' in the Engine Control
Systems certification dated January 29, 1998 (63 FR 4445) caused
confusion in the marketplace because it was not clear which engines
were included in the ``all other 4-stroke engine'' classification.
Accordingly, the November 30 Federal Register document sought to
clarify this matter by identifying the applicable engines. As stated,
EPA's intent is that the list of engines apply to the candidate
Engelhard certification discussed herein, the Engine Control Systems
certification referenced above, and to future notifications of intent
to certify equipment under the urban bus rebuild regulations that
include engines in the ``all other 4-stroke'' classification.
The equipment to be applied to the engines is a ``catalytic
converter muffler'' or CMXTM, that is a muffler containing
an oxidation catalyst. The CMX is intended to replace the standard
muffler previously installed in the engine exhaust system. The CMX is
intended to be maintenance free, requiring no service for the full in-
use compliance period. The engine fuel to be used with this equipment
is standard diesel fuel with a maximum sulfur content of 0.05 weight
percent sulfur.
Engelhard presented exhaust emission data from testing a 1987 240hp
Cummins L-10 engine, control parts list number 0777 (CPL 0777) and on a
Cummins L-10 engine built to CPL 0774 along with additional data to
support this certification. Table B below provides a summary of the
emissions test data. Under 40 CFR 85.1406(a), a test engine must
represent the ``worst case'' with respect to particulate emissions of
all those engine configurations for which the equipment is being
certified. The worst case configuration is defined as the engine
configuration having the highest engine-out PM level, prior to
installation of the retrofit/rebuild equipment. In the case at hand,
the Cummins L-10 test engine has a specified pre-rebuild PM emission
level of 0.61 g/bhp-hr listed in the table at section
85.1403(c)(1)(iii)(A). The PM levels listed in the table at section
85.1403(c)(1)(iii)(A) for all other models and are less than the stated
level for the L-10 test engine. Accordingly, the engine tested for this
certification qualifies as a worst case configuration for the engine
models listed in Table A herein. Section 85.1406 of the urban bus
rebuild regulation allows the emission results to be extrapolated to
engine types and model years known to have engine-out PM levels equal
to or less than that of the test engine.
Table B.--Exhaust Emissions Summary G/BHP-HR
----------------------------------------------------------------------------------------------------------------
1987 L-10 1987 L-10 1987 L-10 w/CMX 1987 L-10 w/
Gaseous and particulate test baseline baseline CPL# 0774 formula CMX CPL#
CPL# 0774 CPL# 0777 1/formula 2 0777
----------------------------------------------------------------------------------------------------------------
HC.................................................... 2.29 2.29 1.07/0.68 1.07
CO.................................................... 2.19 2.65 1.52/1.01 1.31
NOX................................................... 5.50 5.89 5.23/5.09 5.41
PM.................................................... 0.476 0.473 0.326/0.287 0.335
BSFC \1\.............................................. 0.399 0.413 0.394/0.394 0.400
Smoke Test............................................ ........... ........... ................. ...........
ACCEL................................................. 8.2% 11.7% 9.3%/11.0% 10.9%
LUG................................................... 1.5% 1.7% 1.8%/1.4% 2.0%
PEAK.................................................. 14.8% 29.2% 15.7%/20.3% 24.8%
----------------------------------------------------------------------------------------------------------------
\1\ Brake Specific Fuel Consumption (BSFC) is measured in units of lb/bhp-hr.
[[Page 4962]]
Engelhard did not provide life-cycle cost data relative to this
amendment request to include the additional models. Therefore, this
equipment is not being considered in today's Federal Register document
for certification in compliance with the life cycle cost requirements
for the additional engines covered by the amendment. However, in a
letter dated December 4, 1998, Engelhard requested that life cycle
costs apply for this equipment for all applicable models. In the
December 4 letter, Engelhard has submitted pricing information along
with a guarantee that this equipment will be offered to affected
operators for less than the incremental life cycle cost of $2,000 (in
1992 dollars). On July 30, 1999, a Federal Register document was
published concerning this request to include life cycle costs (64 FR
41417). Comments have been received in response to the July 30 document
and are currently being reviewed by EPA. If certified to comply with
life cycle cost requirements, this equipment will trigger program
requirements for the engines included in the general category of ``all
other 4-stroke engines.'' A separate document will be published in the
Federal Register announcing EPA's decision on Engelhard's request to
certify this equipment to include life cycle costs when the review is
complete.
The engines to which the certification announced in today's Federal
Register document applies are listed in Table C below. The equipment is
certified to post-rebuild PM certification levels listed in Table C for
each respective engine. Under program 1, all rebuilds or replacements
of applicable engines for which a 25% or greater reduction of PM is
required may utilize this certified Engelhard equipment (or other
equipment certified to reduce PM by at least 25 percent). Urban bus
operators who choose to comply with program 2 and use this equipment
will use the appropriate PM emission value from Table C when
calculating their average fleet PM level.
Table C.--Engelhard CMX Certification Levels \1\
--------------------------------------------------------------------------------------------------------------------------------------------------------
Cummins Retrofit PM
control New Engine Retrofit PM Level with
Cummins/other engine family parts list Manufacture dates PM level Level with CMX Cummins
(CPL) CMX kit
--------------------------------------------------------------------------------------------------------------------------------------------------------
343B.................................................................... 780 11/20/85 to 12/31/87...... 0.58 0.44 0.26
343B.................................................................... 078 111/20/85 to 12/31/87..... 0.59 0.44 0.26
343C.................................................................... 0774 11/20/85 to 12/31/89...... 0.46 0.34 0.26
343C.................................................................... 0777 11/20/85 to 12/31/89...... 0.61 0.46 0.26
343C.................................................................... 0996 12/04/87 to 08/19/88...... 0.61 0.46 0.26
343C.................................................................... 1226 07/26/88 to 12/31/90...... 0.50 0.38 0.26
343F.................................................................... 1226 07/12/90 to 08/26/92...... 0.45 0.34 0.26
343F.................................................................... 1441 12/18/90 to 12/31/92...... 0.46 0.34 0.26
343F.................................................................... 1622 04/24/92 to 12/31/92...... 0.46 0.34 0.26
343F.................................................................... 1624 04/24/92 to 12/31/92...... 0.45 0.34 0.26
Other \1\ 4-stroke engines.............................................. N/A Pre-1988.................. 0.50 0.38 N/A
CAT
GM IH/Navistar
MAN
Saab-Scania
Volvo
Other 4-stroke engines.................................................. ........... 1988 to 1993.............. (\3\) (\4\) N/A
CAT
GM
IH/Navistar
MAN
Saab-Scania
Volvo
--------------------------------------------------------------------------------------------------------------------------------------------------------
\1\ The new Engine PM certification levels for Cummins engines are based on the certification level or the average test audit result for each engine
family. It is noted that for engine family 343F, although the PM standard for 1991 and 1992 was 0.25 g/bhp-hr and the NO standard was 5.0 g/
bhp-hr, Cummins certified the 1226, 1441, 1622, and 1624 CPLs to a Federal Emission Limit (FEL) of 0.49 g/bhp-hr PM and 5.6 g/bhp-hr NO
under the averaging, banking and trading program.
\2\ Applicable to the following 4-stroke engines installed in applicable urban buses: Caterpillar 8 cylinder engines, General Motors 6 cylinder and 8
cylinder engines, International Harvester/Navistar 8 cylinder engines, MAN 6 and 8 cylinder engines, Saab-Scania 6 cylinder engines, and Volvo 6
cylinder engines.
\3\ Certification level.
\4\ 25% reduction from certification PM levels.
III. Summary and Analysis of Comments
EPA received comments from three parties on the Engelhard
application during the comment period: Detroit Diesel Corporation
(DDC), Johnson Matthey Corporation (JMI), and Engine Control Systems
(ECS). DDC is the original manufacturer of the Series 50 engine. JMI
and ECS are both certifiers and suppliers of equipment under the urban
bus rebuild program.
The Detroit Diesel Corporation (DDC) commented that the DDC Series
50 engine should not be included in the certification. DDC also
commented on the reported hydrocarbon results for the baseline test.
Regarding DDC's comments relative to the Series 50 engine, DDC stated
that it had certified and produced 1992-1993 model year Series 50
engines for use in urban bus applications. DDC stated that the Series
50 is an electronically controlled engine with PM emissions in the
range of 0.07 to 0.13 g/bhp-hr that was not equipped with an exhaust
catalyst when certified. DDC stated that the Series 50 model engines
were not cited in the November 30,1998 Federal Register document and
should not be included in this certification among the additional
engines in the general class of ``all other 4-stroke engines'' based on
the test data presented in the document. DDC noted that the Engelhard
certification tests were for a 1987 model year Cummins L-10 with
baseline test results of 0.47 g/
[[Page 4963]]
bhp-hr PM and extremely high HC overall suggesting the engine may have
a high soluble fraction. DDC stated that since catalysts are known to
be most effective on the soluble fraction of particulate and relatively
ineffective in reducing the dry soot, the overall catalyst
effectiveness increases with the soluble fraction. DDC states that the
Series 50 has low PM with a low soluble fraction. Because of the
differences in the quantity and composition of particulate emissions
from the two engines, it would not be appropriate to extrapolate the
results of the Engelhard L-10 testing to conclude that the CMX will
achieve the required 25% particulate reduction when applied to the
Series 50 engines. Thus, DDC stated the Series 50 inclusion in this
certification would not be justified.
In response to DDC's comment, Engelhard provided data from testing
conducted on a 1995 275 hp DDC Series 50 engine. Engelhard conducted
testing using CMX technology exploring the effects of fuel sulfur on
particulate matter emissions. Fuel sulfur levels of 500 parts per
million (ppm) and 315 ppm were run on the CMX catalyst. The report
containing this data titled, ``The Effect of Diesel Sulfur Content and
Oxidation Catalysts on Transient Emissions at High Altitude from a 1995
Detroit Diesel Series 50 Urban Bus Engine'' has been placed in the
public docket listed above. After review of the above report and the
comments received, EPA determined that additional information would be
needed before it could be determined that Engelhard had demonstrated a
25% PM reduction for Series 50 engine. Upon EPA informing Engelhard of
the need for additional data and evaluation relative to the Series 50
engine, Engelhard requested that the Series 50 be removed from
consideration under this certification. Engelhard made this request so
that certification approval for the remaining models would not be
delayed due to time necessary to receive and evaluate additional
information relative to the Series 50. Accordingly, EPA has removed the
Series 50 model from consideration under this certification. However,
as noted earlier the Series 50 was added to the general class of ``all
other 4-stroke engines'' for consideration under the Urban Bus Rebuild
Program.
DDC's second comment concerns the hydrocarbon (HC) level reported
as 2.29 g/bhp-hr in the baseline Cummins L-10 engine test. DDC states
that this HC level is indicative of an engine fault and questions the
certification data. In response, Engelhard notes that while this engine
does have high HC emissions, data from five tests conducted after it
had rebuilt this engine to various configurations consistently show HC
emissions that are around 2.0 g/bhp-hr on average with standard Cummins
rebuild specifications. The HC result for the certification test of the
CPL 0777 configuration provided by Engelhard in the amendment was 2.29
g/bhp-hr. EPA notes that based on the consistent HC results for this
engine after rebuild, it is apparent that the HC results are inherent
to this engine in a standard rebuild configuration. EPA notes that it
has seen considerable variation in the test results for baseline
engines for the applications that have been reviewed for certification.
Consistent with 40 CFR 85.1406(a), the certification engine is not
required to meet Federal emission standards before the retrofit/rebuild
equipment is installed. The retrofit/rebuild regulation requires that
the PM reduction must be shown to be incremental to a standard rebuild.
Based on the fact that the baseline engine in this certification was
rebuilt to a standard configuration with no obvious defects, EPA finds
the results to be acceptable. It is noted that with the addition of the
CMX technology the HC emissions are reduced to 1.07 g/bhp-hr during
testing and are within specified standards in accordance with the
regulations. After review of the data presented, EPA finds that the
test engine and the emission results presented are acceptable.
Engine Control Systems, Ltd. (ECS) commented that this application
should be reviewed in conjunction with the life cycle costs as
submitted in Engelhard's December 4 letter, in order to solicit the
full range of comments needed to justify triggering the 25% PM
reduction requirements for the affected engines. ECS also commented on
catalyst applicability, effectiveness, performance, PM reduction,
backpressure, and the identification of the different catalyst
formulations. ECS commented on testing it has performed and results of
Engelhard testing on Cummins N14 engines and other data conveyed by
Engelhard. ECS also commented that it should be clearly stated that
this certification applies only to applicable urban bus engines.
With regard to the ECS comment that product performance and cost
should be addressed together to solicit the full range of comments for
those engines constituting the ``all other 4-stroke'' category, the
urban bus retrofit/rebuild regulation allows for certification based on
emission reduction without including cost data. In response, EPA
believes that the urban bus retrofit/rebuild regulation clearly allows
for certification based on emission reductions without cost data. In
fact, prior to this certification review, EPA has reviewed and approved
several certifications of equipment under this program without life
cycle cost data.
Life cycle cost data is necessary to trigger retrofit/rebuild
requirements under program 1. Since Engelhard had not provided cost
information with this amendment request, this certification will not
trigger new requirements for any of the affected engines and a review
of cost data is not necessary for approval. However, Engelhard has more
recently requested to include cost data and to certify this equipment
within the specified life cycle cost requirements. A document was
published in the Federal Register on July 30, 1999 (64 FR 41417)
regarding this amendment request to include life cycle costs for this
certification. Comments have been received and are currently under
review. A separate document will be published in the Federal Register
announcing EPA's decision after review is completed.
ECS has requested that Engelhard divulge its catalyst formulation
and size publicly. Engelhard states that this information is
proprietary and declines to provide this information in a public
format. Customarily, EPA allows manufacturers to maintain catalyst
specifications as confidential business information provided such
information is presented for EPA review and is found to be acceptable.
Engelhard has provided descriptions of the various catalysts and
formulations used during testing and EPA finds the information
presented to be acceptable under the urban bus program.
ECS commented that it is not clear which formulation is being
proposed to cover the 4-stroke engines included in this certification.
If different formulations are proposed which catalysts are meant to
cover the various engines? What data shows the effectiveness of these
formulations and how will they be identified in the marketplace to
ensure appropriate use? Engelhard has responded that it will provide a
specific CMX unit for a specific bus and engine combination using the
certified catalyst. In the amendment request and subsequent
information, Engelhard documented tests performed on a wide range of
catalyst formulations on an engine designated to be the ``worst case''
and has also provided data based on other engine configurations. In the
regulations, EPA stated it will allow results of emission tests for
after treatment devices to be extrapolated to
[[Page 4964]]
engine types and model years known to have engine-out PM levels equal
to or less than the test engine. In the application, Engelhard has
presented data from Cummins engine with CPL 0777 which is considered to
be the worst case configuration for the engines to be included in this
certification. In addition, Engelhard has presented data from tests
performed on Cummins CPL 0774 to support this amendment request.
Engelhard has responded that in order to simplify certification, it
will only utilize the catalyst formulation tested on the Cummins L-10
CPL 0777. EPA has reviewed the effectiveness of the formulation to be
used with this equipment and designated for this certification and
finds it to be acceptable. ECS commented that the emissions profile of
Cummins L-10 engine (CPL 0777) that Engelhard tested was significantly
different from the L-10 engine ECS tested for its certification. ECS
commented that Engelhard testing of CPL 0774 showed very high insoluble
carbon reductions and ECS questions on all the L-10 test data. The
urban bus retrofit/rebuild rule does not specify the percentage
reduction which must occur in either the soluble or insoluble PM
fractions. In its March 30, 1998 submission, Engelhard provided data
showing that the CMX technology reduces the total particulate matter by
at least 25 percent based on the tests conducted on CPL 0774. While it
is recognized that the insoluble portion of the PM appears relatively
high, Engelhard has provided data showing the CMX technology reduces
the soluble and the insoluble fraction of total particulate to meet the
requirements of the bus regulation. Furthermore, Engelhard has provided
test data for CPL 0777 demonstrating at least a 25% reduction in total
PM. No data was provided by Engelhard regarding the soluble versus
insoluble portion of the PM for CPL 0777. However, such data is not an
explicit requirement of the regulation. Based on the total PM reduction
shown in the test data, EPA finds that the test results demonstrate
compliance with the standard of reducing PM by at least 25%.
ECS commented that the tests conducted by Engelhard were conducted
in a very uniform and procedural fashion with a backpressure setting
which is atypical from actual in-use applications. Further, ECS
commented that additional support data should be required to determine
whether claimed PM reductions will occur on actual in-use buses. The
regulation clearly states that the emission test to be used is the
Heavy-Duty Engine Federal Test Procedure set forth in 40 CFR Part 86
Subpart N or an approved alternative test procedure. EPA notes that the
testing supplied by Engelhard for this certification was conducted
according to the specified test procedure as put forth in 40 CFR and is
accepted.
The urban bus retrofit/rebuild regulation does not require
durability testing or in-use testing. However, it does require that the
certifier supply a defect warranty over the initial 100,000 mile period
of use of a certified system. Accordingly, the certifier is required to
replace any defective part that is included in the certified kit during
the 100,000 mile warranty period. As well, the certifier is required to
warrant that the equipment, if properly installed and maintained, will
meet the emission requirements for a period of 150,000 miles from when
the equipment is installed.
ECS commented that both Engelhard and ECS are participating in
Ottawa test programs. Specifically, Engelhard CMX technology has been
retrofit on two buses equipped with Cummins N14 4 stroke/cycle engines.
ECS asked if Engelhard will disclose the results of this testing to EPA
and discuss the results. ECS believes that the data from the Ottawa
program does not support a broad certification of the CMX for all 4
stroke/cycle engines for a 25% PM reduction. In response Engelhard has
stated that this information is not relevant to this application
because the catalyst used during that program was undersized compared
to the catalyst which would be supplied under this certification.
Engelhard asserts that a properly sized CMX catalyst will achieve the
25% reduction over the FTP on an N-14 engine.
ECS provided documentation which ECS stated was presented by
Engelhard at a recent workshop in Hong Kong. ECS comments that the data
presented shows that the expected PM emissions reductions with the CMX
converter muffler for several engine families is below 25%. In response
Engelhard states that the referenced data incorporates testing on
undersized catalysts and that the data referenced by ECS was based on
obsolete catalyst formulations. Engelhard will utilize only the high
activity catalyst formulation used for testing the Cummins L-10 CPL
0777 in this application. A description of this catalyst was provided
by Engelhard as confidential business information for EPA's review. EPA
finds that Engelhard has demonstrated that this catalyst will provide
for at least a 25% PM reduction on the applicable engines included in
this certification. Engelhard states that it will size the catalyst
according to the applicable engine size to achieve the specific PM
reductions specified.
In the data provided with this amendment, Engelhard has documented
test results utilizing a range of catalyst formulations on the worst
case configuration. EPA finds that this data demonstrates that the
Engelhard CMX will reduce PM by a minimum of 25 percent. The regulation
allows that after treatment devices such as the CMX equipment may be
applied to other engines based on testing performed on the worst case
engine. Engelhard has complied with this requirement for this
certification.
ECS requested that EPA specifically state, in granting of any 4-
stroke engine certification based on emissions from data from a single
engine, that such certifications only apply to specific urban bus
engines. In this document, EPA has identified the specific urban bus
engines to which it applies. ECS also requested that EPA state that
this certification should not be used by state agencies in the
assessment of non-urban bus retrofit programs. EPA does not believe
this statement is appropriate in this document because it is outside of
the purview of the urban bus rebuild program.
The Johnson Matthey Corporation (JMI) commented on the use of CPL
0777 as the worst case configuration. JMI also commented on the use of
two different catalyst formulations during emission testing and
questioned which was used during certification testing and how each
formulation would be identified for use.
Johnson Matthey Corporation (JMI) commented that the worst case
engine should be based on the highest exhaust flow rate rather than
using the engine with the highest engine out PM. JMI commented that
Engelhard should explain the reasoning for selecting CPL 0777. The
regulations specify that the worst case engine configuration shall be
the engine configuration having the highest engine-out particulate
matter emission levels prior to installation of the retrofit/rebuild
equipment. The Cummins engine CPL 0777 meets this criteria and
qualifies as the worst case engine configuration for the engines
included in this certification under the regulations.
JMI commented that Engelhard provides performance data for two
different catalyst formulations on the engine configured to CPL 0744.
JMI commented that only one catalyst formulation was tested on CPL 0777
and Engelhard should be required to identify which formulation was used
for
[[Page 4965]]
certification testing. In addition, Engelhard should present conclusive
information regarding the specific formulation tested. Further, if more
than one formulation is being certified, the EPA should require
Engelhard to clearly identify each formulation and where it may
appropriately be used. Engelhard has responded that in order to
simplify certification, it will only utilize the catalyst formulation
tested on the Cummins L-10 CPL-0777. Engelhard has provided
confidential business information on the catalyst formulation used in
certification testing. EPA finds it to be acceptable.
IV. Certification Approval
The Agency has reviewed this application, along with comments
received from interested parties, and finds that this equipment reduces
particulate matter emissions without causing urban bus engines to fail
to meet other applicable Federal emission requirements. Additionally,
EPA finds that installation of this equipment will not cause or
contribute to an unreasonable risk to the public health, welfare or
safety, or result in any additional range of parameter adjustability or
accessibility to adjustment than that of the engine manufacturer's
emission related part. The application meets the requirements for
certification under the Retrofit/Rebuild Requirements for 1993 and
Earlier Model Year Urban Buses (40 CFR 85.1401 and 85.1415).
V. Operator Requirements and Responsibilities
This equipment may be used immediately by urban bus operators who
have chosen to comply with either program 1 or program 2 and who have
applicable engines. Currently, operators having certain of the
applicable engines who have chosen to comply with program 1 must use
equipment certified to reduce PM emissions by 25 percent or more when
those engines are rebuilt or replaced. Today's Federal Register
document certifies the above-described Engelhard equipment as meeting
this PM reduction requirement for all engine models listed in Table C
herein. Urban bus operators choosing to comply with program 1 must use
the certified Engelhard equipment (or other equipment that is certified
in the meantime to reduce PM by at least 25 percent) for any Cummins
engine that is listed in Table C that undergo rebuild. The requirement
to use certified equipment demonstration a 25 percent reduction in PM
for the Cummins engines listed is based on an earlier certification by
the Cummins Engine Company as published in a Federal Register document
dated December 13,1995 (60 FR 64048). The requirement remain until such
time as the 0.10 g/bhp-hr standard is triggered for the applicable
engines. For the engines included in the general class of ``all other
4-stroke engines'' as listed in Table C the requirement to use 25
percent reduction equipment will be based on EPA decision on the
December 4, 1998 amendment request from Engelhard referenced earlier.
In the December 4 request Engelhard submitted pricing information along
with a guarantee that this equipment will be offered to affected
operators for less than the incremental life cycle cost of $2,000 (in
1992 dollars) for these engines. On July 30, 1999, a Federal Register
document was published concerning this request to include life cycle
costs (64 FR 41417). Comments have been received in response to the
July 30 document and are currently being reviewed by EPA. If certified
to comply with life cycle cost requirements, this equipment will
trigger program requirements for the engines included in the general
category of ``all other 4-stroke engines'' under program 1. Operators
who choose to comply with program 2 and use the Engelhard equipment
will use the appropriate PM emission level from Table C when
calculating their fleet level attained (FLA).
As stated in the regulations, operators should maintain records for
each engine in their fleet to demonstrate that they are in compliance
with the requirements, beginning 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.
Dated: January 21, 2000.
Robert Perciasepe,
Assistant Administrator for Air and Radiation.
[FR Doc. 00-2180 Filed 2-1-00; 8:45 am]
BILLING CODE 6560-50-U
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