[Federal Register Volume 62, Number 215 (Thursday, November 6, 1997)]
[Notices]
[Pages 60079-60090]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 97-29397]
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ENVIRONMENTAL PROTECTION AGENCY
[FRL-5918-5]
Retrofit/Rebuild Requirements for 1993 and Earlier Model Year
Urban Buses; Certification of Equipment
AGENCY: Environmental Protection Agency (EPA).
ACTION: Notice of EPA certification of equipment provided by Johnson
Matthey Incorporated.
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SUMMARY: Today's Federal Register notice announces EPA's decision to
[[Page 60080]]
certify equipment to the 0.10 g/bhp-hr standard for the Urban Bus
Retrofit/Rebuild Program. The equipment is provided by Johnson Matthey
Incorporated (JMI).
JMI submitted to EPA a notification of intent to certify equipment,
in materials signed December 9, 1996, pursuant to the program
regulations at 40 CFR part 85, subpart O. On January 30, 1997, EPA
published a notice in the Federal Register that the JMI notification
had been received and made the notification available for public review
and comment for a period of 45 days (62 FR 4528). EPA has completed its
review and the Director of the Engine Programs and Compliance Division
has determined that it meets all requirements for certification.
Therefore, EPA certified this equipment in a letter to JMI dated
September 8, 1997.
The certified equipment, initially referred to by JMI as the
Catalytic Reduction Technology-Cam kit, is a kit consisting of
proprietary camshafts, CEM II catalytic exhaust muffler, and specific
engine rebuild parts and certain engine settings. The nomenclature of
the kit, Catalytic Reduction Technology-Cam, has been discontinued by
JMI. The kit will be marketed by JMI under the name, Cam Converter
Technology (CCTTM) upgrade kit. Therefore, today's notice
will refer to the equipment as the CCTTM kit.
The kit is applicable to 6V92TA urban bus engine models made by
Detroit Diesel Corporation (DDC) from model years 1979 to 1989 and
equipped with mechanical unit injectors (MUI), and may be used
immediately by transit operators in compliance with program
requirements. The kit is available in four horsepower ratings (253,
277, 294, and 325 horsepower).
EPA has determined that the CCTTM kit complies with the
0.10 gram per brake horsepower-hour (g/bhp-hr) particulate matter (PM)
standard for the applicable engines. In addition, because JMI will
offer the kit to all parties for $7,940 (in 1992 dollars) or less,
incremental to the cost of a standard rebuild, EPA has determined that
JMI's notification complies with the life cycle cost requirements of
the program regulations. JMI may make an alternative supply option
available to purchasers.
Today's Federal Register notice triggers requirements for transit
operators utilizing compliance Program 1 that have engines rated above
294 horsepower in their fleet covered by this certification (excluding
engines certified to meet California emissions standards).
The notification of intent to certify, as well as other materials
specifically relevant to it, are contained in Category XV-A of Public
Docket A-93-42, entitled ``Certification of Urban Bus Retrofit/Rebuild
Equipment''. This docket is located at the address listed below.
Additional details concerning this certification, the JMI
CCTTM kit, and responsibilities of transit operators, are
provided below.
DATES: EPA certified this equipment in a letter to JMI dated September
8, 1997. Today's Federal Register notice announces this certification,
and triggers the 0.10 g/bhp-hr standard for applicable engines above
294 hp. The 0.10 g/bhp-hr standard was triggered on March 14, 1997 (62
FR 12166) for applicable engines rated at 294 hp and below.
ADDRESSES: The JMI notification, as well as other material specifically
relevant to it, are contained at the U.S. Environmental Protection
Agency's Public Air Docket A-93-42 (Category XV-A), Room M-1500, 401
``M'' Street SW, Washington, DC 20460.
The JMI notification of intent to certify, as well as other
materials specifically relevant to it, are contained in the public
docket indicated above. 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 EPA for copying docket materials.
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) 233-9297.
SUPPLEMENTARY INFORMATION:
I. Description of the Certified CCTTM Kit
The certified CCTTM kit described in today's Federal
Register notice, the Cam Converter Technology (CCTTM)
upgrade kit, is provided by Johnson Matthey Incorporated (JMI). It is
certified to the 0.10 g/bhp-hr standard, and complies with the
applicable life cycle cost requirements.
The certification described in today's notice applies to 1979
though 1989 model year DDC 6V92TA engines that are equipped with
mechanical unit injectors (MUI) and certified to federal emissions
standards. It does not apply to engines certified to California
emissions standards. The impact of this decision on transit operators
is discussed in more detail in the ``Transit Operator Requirements''
section below.
The CCTTM kit, described further below, consists of a
CEM II catalytic exhaust muffler, proprietary cam shafts, specified
emissions-related engine rebuild parts, and specified engine settings.
The kit is available in four horsepower (hp) ratings (253, 277, 294 and
325 horsepower).
The CEM II is the same size and shape as the CEM catalytic exhaust
muffler (certified for the Urban Bus Program as described in the
Federal Register on April 17, 1996, at 61 FR 16773), is a direct, bolt-
on replacement for the original equipment muffler, and is designed to
fit the specific bus/engine combination.
The camshafts, a proprietary JMI design, change exhaust valve lift
and duration. The CCTTM kit includes a timing height gauge
for the unique timing height of the fuel injectors. The procedure and
specifications for setting the exhaust valve clearance is unchanged
from the DDC recommended procedure.
For retrofit with the CCTTM kit, an engine is rebuilt in
accordance with standard DDC rebuild procedures, using specified engine
parts that produce unique engine configurations. The specified
emissions-related engine parts consist of the following DDC components:
turbocharger, fuel modulator, piston dome kit, piston skirt, piston
ring set, cylinder liner, blower drive gear, blower assembly, fuel
injectors, blower by-pass valve, and governor assembly. The specified
engine settings apply to the fuel injector height and fuel modulator
setting. The specified settings and part numbers for the emissions
related DDC parts are provided in letters from JMI dated July 18, 1997
and August 21, 1997.
For service of a CCTTM-equipped engine, the DDC
compression check procedure remains applicable and JMI will provide
compression specifications with the kit instructions. Other DDC service
procedures remain applicable.
All configurations of the CCTTM include a fuel modulator
to limit throttle advance during acceleration, as replacement of the
standard throttle delay of the original coach engine configuration. The
CCTTM kit includes instructions for installation of the fuel
modulator, and adjustment settings for the fuel modulator.
All affected transit operators may purchase the specified
emissions-related parts from JMI as part of a CCTTM kit.
Additionally, JMI may make available a second supply option whereby the
kit consists of the CEM II, proprietary camshafts, and a list of the
specified emissions-related parts and engine settings. With the second
supply option, an operator is responsible for acquiring the specified
parts from sources of its
[[Page 60081]]
own choosing, as discussed further below. Neither option includes parts
that are rebuilt by transit operators.
All of the testing presented by JMI for this certification was
conducted using OE parts, except for the CEM II and camshafts. As a
result, EPA has no assurance that engines rebuilt using parts that are
not original equipment (OE) would comply with the 0.10 g/bhp-hr
standard. Therefore, use of engine parts that are not the specified OE
parts, or engine parts rebuilt in-house, are not covered by the
certification described in today's Federal Register notice.
Pursuant to 40 CFR 85.1409, JMI will provide a 100,000-mile defect
warranty and a 150,000-mile emissions performance warranty for the
CCTTM kit, and all of its components regardless of which of
the two supply options is used by a transit operator.
JMI states that the maximum cost of the CCTTM kit for
6V92TA MUI engines is $11,495.00 (in 1997 dollars), which includes the
CEM II, proprietary camshafts, specified emissions-related parts, and
specified engine settings. JMI indicates that installation of the whole
CCTTM kit requires an additional two hours (for installation
of the CEM II) beyond the labor associated with a standard rebuild.
EPA's certification of the Engelhard Corporation's ETXTM
kit (62 FR 12166; March 14, 1997) triggered the 0.10 g/bhp-hr standard
for 1979--1989 6V92TA MUI engines. That kit provided three power
ratings: 253, 277, and 294 horsepower (hp). JMI will offer the
CCTTM kit in four power ratings: 253, 277, 294, and 325 hp.
Certification of the CCTTM kit described in today's Federal
Register notice, which includes compliance with life cycle cost
requirements, triggers the 0.10 g/bhp-hr standard for engines rated
above 294 hp. This topic is discussed further below.
II. Background and Bases for Certification
In a notification of intent to certify equipment, composed of an
initial document signed December 9, 1996 and subsequent documents,
Johnson Matthey (JMI) applied for certification of the CCTTM
kit under the Environmental Protection Agency's (EPA) Urban Bus
Retrofit/Rebuild Program. Engines applicable to the certified kit are
6V92TA urban bus engine models made by Detroit Diesel Corporation (DDC)
from model years 1979 to 1989 that are equipped with mechanical unit
injectors (MUI) and certified to comply with federal emissions
standards.
The equipment, referred to in initial documents as the Catalytic
Reduction Technology--Cam kit, was renamed by JMI to the Cam Converter
Technology (CCTTM) upgrade kit. The certifier's principal
place of business is: Johnson Matthey Incorporated, Environmental
Products, Catalytic Systems Division, 460 East Swedesford Road, Wayne,
Pennsylvania 19087-1880.
Using engine dynamometer (transient) testing in accordance with the
Federal Test Procedure for heavy-duty diesel engines, JMI demonstrated
compliance with the 0.10 g/bhp-hr particulate matter (PM) emissions
standard. Engine dynamometer data, shown below in Table 1, are the
bases for the certification approval of the CCTTM kit when
used on applicable engines. The emissions test data are part of JMI's
notification of intent to certify, which is available in the public
docket located at the above-mentioned address. All testing was
conducted using #2 low-sulfur diesel fuel.
Table 1.--Summary of JMI Testing
----------------------------------------------------------------------------------------------------------------
1988 HDDE standards
------------------------------------------------------
1984 1984 1983
Gaseous and particulate test g/bhp-hr 6V92TA 6V92TA 6V92TA 6V71TA 6V71TA
MUI MUI MUI with MUI MUI with
baseline1 baseline1 CCTTM \1\ baseline CCTTM
----------------------------------------------------------------------------------------------------------------
HC...................................... 1.3 0.7 0.5 0.3 0.6 0.2
CO...................................... 15.5 1.1 0.9 0.5 1.7 0.8
NOX..................................... 10.7 9.5 13.0 10.2 10.4 10.2
PM...................................... 0.6 0.56 0.251 0.08 0.329 0.096
BSFC2................................... ............... 0.475 0.456 0.470 0.468 0.464
Hp (R/O)3............................... ............... 253/249 277/269 277/274 225/211 265/254
----------------------------------------------------------------------------------------------------------------
Smoke Test Standards (%)
(4)Percent Opacity
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ACCEL................................... 20 3.1 1.3 2.9 2.0 2.3
LUG..................................... 15 2.0 0.5 2.0 2.6 1.3
PEAK.................................... 50 4.8 3.3 3.6 3.0 2.9
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\1\ All 6V92TA testing was performed on engine identification number 6VF-118287.
\2\ Brake Specific Fuel Consumption (BSFC) is measured in units of lb/bhp-hr.
\3\ Horsepower (Rated/Observed during testing).
The exhaust emissions data presented by JMI are from testing
Detroit Diesel Corporation (DDC) engine models 6V71TA and 6V92TA, in
accordance with procedures set forth at 40 CFR part 86, Subparts N and
I. The two engine models were tested in baseline configurations and
equipped with the CCTTM kit. The baseline 6V92 engine was
tested in two horsepower ratings: 253 and 277.
The data of Table 1 demonstrate that for both test engines, when
rebuilt with the CCTTM kit, PM emissions are less than 0.10
g/bhp-hr and, emissions of hydrocarbon (HC), carbon monoxide (CO), and
smoke opacity are within applicable federal standards. The data for the
6V92TA engine indicate that the kit increases NOX emissions
roughly seven (7) percent above the level of the baseline 6V92TA rated
at 253 hp. The data for the 6V71TA engine indicate that the
CCTTM kit does not increase NOx emissions. With
CCTX kits installed, the NOX levels for both the
6V92 and 6V71 certification engines are less than the federal standard
for model years 1985--1989 (10.7 g/bhp-hr).
To facilitate the review process, JMI requested in a letter dated
August 6, 1997, that EPA temporarily restrict its review to 6V92TA
engine models. Therefore, today's Federal Register notice describes
certification of equipment only for 6V92TA MUI engine models. The
emissions data for the 6V71TA engine is included in today's notice to
support the demonstration of compliance of the CCTTM kit
with the 0.10 g/bhp-hr standard. Further action
[[Page 60082]]
taken with regard to 6V71 engines would be done by subsequent Federal
Register notice.
This action applies a PM emissions level of 0.10 g/bhp-hr to all
1979 through 1989 DDC 6V92TA MUI urban bus engines, when properly
equipped with the CCTTM kit and when using either diesel
fuel #1 or #2. Table 2 lists the applicable engine models and
certification levels associated with the certification announced in
today's Federal Register.
Table 2.--Certification Level of CCTTM Kit
------------------------------------------------------------------------
Certification PM
Engine models Engine codes level
------------------------------------------------------------------------
1979-1989 DDC 6V92TA MUI.... All certified to 0.10 g/bhp-hr.
meet federal
emissions standards.
------------------------------------------------------------------------
All engines for which the CCTTM kit is intended to apply
are expected to meet the 0.10 g/bhp-hr PM standard because the kit
instructs the rebuilder to replace all emissions-related parts during
the rebuild with JMI-specified parts, and install a CEM II. The engine-
out emissions level (upstream of the CEM-II catalyst) is expected to be
predictable because all emission-related parts are replaced using the
JMI specified emissions-related parts and settings of the kit. As
demonstrated by the two test engines, the combination of the specified
parts, proprietary camshafts, specified settings of the kit, and CEM-
II, results in a PM level less than 0.10 g/bhp-hr.
Summarized below in Table 3 is a life cycle cost analysis presented
by JMI for the CCTTM kit. A cost analysis is necessary only
for certification of equipment that is meant to trigger a program
emissions standard. Certification of Engelhard Corporation's
ETXTM kit triggered the 0.10 g/bhp-hr standard for 6V92TA
MUI engines, and made available kits rated at 253, 277, and 294 hp. The
Engelhard certification does not provide a kit rated above 294
horsepower. JMI's emissions demonstration and cost analysis applies to
engines rated at 253, 277, 294, and 325 hp. Therefore, the
certification described in today's notice triggers the 0.10 g/bhp-hr
standard for engines rated above 294 horsepower.
JMI's initial notification presented a life cycle cost analysis
based on the CCTTM kit containing the CEM II, the
proprietary cam shafts, and a list of specified emissions related parts
and settings. In a letter dated June 2, 1997, JMI stated its intent to
market the CCTTM kit to include all emissions related parts.
In a letter dated July 3, 1997, JMI presented a cost analysis in
accordance with section 85.1403, for the supply option where JMI
provides all components of the CCTTM kit, including the
specified engine parts. EPA determines that, based on this information,
the notification meets life cycle cost requirements. The analysis is
discussed below.
As shown in the summary of Table 3, total life cycle costs are less
than the life cycle cost ceiling specified in the program regulations
($7,940 in 1992 dollars). The life cycle cost ceiling, updated to May
1997, is to $9,060.54.
Table 3.--Life Cycle Cost Analysis of CCTTM Kit for 6V92TA Engines
------------------------------------------------------------------------
1997 dollars
------------------------------------------------------------------------
CCTTM Upgrade Kit Maximum Cost............................ $11,495.00
Cost Offset (for Kit parts normally replaced during
standard rebuild)........................................ \1\ (3,978.5
8)
Installation Labor for CEM II (2 hours)................... 79.88
3% Fuel penalty........................................... 964.30
Total Life Cycle Costs................................ 8,560.60
LCC Ceiling \2\ ($7,940 x 160.1 140.3)............ 9,060.54
------------------------------------------------------------------------
\1\ Weighted Rebuild Costs for parts, normally replaced during a
standard rebuild, are from 62 FR 12166, March 14, 1997, and adjusted
to 1997 dollars using a base CPI of 158.3 for October 1996, and the
CPI of 160.1 for May 1997.
\2\ CPI for 1992=140.3. CPI for May 1997=160.1.
As shown above in Table 3, JMI states that the maximum cost of the
CCTTM kit, including all specified engine parts, is $11,495.
The proprietary camshafts and other specified engine components
provided with the CCTTM kit result in an ``offset'' for
parts which otherwise are replaced during a standard engine rebuild.
The costs for the individual rebuild parts that are offset by the kit
parts, as shown in Table 4 below, were determined by EPA in (1996
dollars) for certification of Engelhard Corporation's ETXTM
kit (see 62 FR 12166; March 14, 1997). JMI updates the costs to May
1997 based on a ratio of the Consumer Price Indexes (CPI) noted in
Table 4. These ``offset'' costs are subtracted from the maximum
purchase cost of the CCTTM kit, as shown above in the
summary of Table 3.
Table 4.--CCTTM Upgrade Kit Parts List for 6V92TA MUI Engines
----------------------------------------------------------------------------------------------------------------
October 1996
No. Part Part of standard cost May 1997 cost
rebuild? (CPI=158.3) (CPI=160.1)
----------------------------------------------------------------------------------------------------------------
1............................ CEM II................ No.................... ............... ...............
2............................ Cam RB................ Yes................... $607.45........ $614.363
3............................ Cam LB................ Yes................... 607.45......... 614.364
4............................ Modulator............. No.................... ............... ...............
[[Page 60083]]
5............................ Blower drive gear 40T. No.................... ............... ...............
6............................ Blower bypass valve... No.................... ............... ...............
7............................ Governor Ass'y........ No.................... ............... ...............
8............................ Governor cover ass'y.. No.................... ............... ...............
9............................ Turbocharger.......... Yes................... 464.43......... 469.71
10............................ Fuel Injectors........ Yes................... 420.50......... 425.28
11............................ Dome kit or crown..... Yes................... 1,522.74....... 1,540.05
12............................ Piston Skirt.......... Yes................... With #11....... With #11
13............................ Ring Set.............. Yes................... With #11....... With #11
14............................ Cylinder Liner........ Yes................... With #11....... With #11
15............................ Blower Ass'y.......... Yes................... 311.28......... 314.82
---------------------------------------------------------------------------------
Offset Total.............. ...................... ...................... ............... 3,978.58
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Except where amended by JMI written instructions, an engine is to
be rebuilt according to the engine manufacturer's standard written
rebuild procedures and specifications. Therefore, installation of the
CCTTM kit is essentially identical to a standard engine
rebuild plus the installation of the CEM II catalyst exhaust muffler.
Therefore, the labor cost for installation of the kit, incremental to a
standard rebuild, is based on an additional two hours for installation
of the CEM II. The two hours additional installation time is added to
the life cycle costs of the kit, as shown above in Table 3. In
accordance with section 85.1403, the labor rate specified in the
regulation, $35/hour (in 1992 dollars), when updated to May 1997, is
$39.94/hour.
JMI states that engines equipped with the CCTTM kit will
have no additional maintenance or service requirements. Therefore,
incremental maintenance costs for engines equipped with the
CCTTM kit is zero.
JMI presents baseline data from testing two standard 1984 model
year configurations rated at 253 and 277 horsepower. Based on
comparison with the testing of the baseline 277 hp engine, fuel
consumption when the CCTTM kit is installed is determined to
be three (3) percent higher. Based on this 3 percent penalty, the
incremental fuel cost for the kit is calculated in accordance with
section 85.1403(b)(1)(ii)(c)(1), and added to the life cycle costs as
shown above in Table 3.
The total life cycle costs for the CCTTM kit, as shown
above in Table 3, is determined to be $8,560.60. The life cycle cost
ceiling ($7,940 in 1992 dollars), when updated to May 1997 using a
ratio of the CPIs noted in Table 3, is $9,060.54. In conclusion, based
on the above analysis, EPA determines that the CCTTM kit for
6V92TA MUI engines complies with the life cycle cost requirements of
the urban bus program.
In a letter dated August 6, 1997, JMI requested the ability to
supply transits under two supply option scenarios. Under supply option
1, JMI would supply the CCTTM kit including the CEM II, the
proprietary camshafts, and all of the specified emissions related
engine parts. Under supply option 2, the CCTTM kit would
include the CEM II, the proprietary camshafts, and a list of specified
parts with certain fuel injector and fuel modulator settings. JMI
indicated that supply option 2 might include specific parts that could
be rebuilt by transits to JMI specifications and subject to strict
controls by JMI.
EPA approves supply option 1 and part of supply option 2. For
supply option 1, transit operators purchase the entire CCTTM
kit from JMI or its distributors. This supply option is the option upon
which life cycle costs have been determined, and upon which the 0.10 g/
bhp-hr standard is triggered for engines having ratings above 294
horsepower. Therefore, the supply option 1 is required to be available
to any and all operators. Supply option 2, described below, may be made
available at JMI's discretion. Operators that choose the supply option
2, do so voluntarily, and EPA makes no representation concerning the
impact of this supply option on life cycle costs. The certification of
today's Federal Register notice does not include use of parts that are
rebuilt by transit operators because EPA lacks assurance that parts
rebuilt by transit operators would have the same emissions performance.
For supply option 2, JMI will provide the list of specified DDC
emissions-related engine parts and engine settings to transit operators
upon purchase of the CEM II and proprietary camshafts. Transit
operators will then purchase the specified emissions-related parts
(excluding the CEM II and proprietary camshafts, which must be obtained
from JMI) through supply channels of the operator's choosing. The
certification of today's Federal Register notice does not include use
of parts that are rebuilt by transit operators.
III. Summary and Analysis of Comments and Concerns
Comments were received from three parties in response to the
Federal Register notice of January 30, 1997 (62 FR 4528). The
commenters are Detroit Diesel Corporation (DDC), Engelhard Corporation,
and New York City Transit Authority (NYCTA). DDC and Engelhard,
provided extensive comment. DDC is the original manufacturer of the
engine models to which the CCTTM kit applies, and has
applied for certification of equipment to comply with the 0.10 g/bhp-hr
standard. Engelhard is the manufacturer of equipment certified under
the urban bus program that triggered the 0.10 g/bhp-hr standard for the
1979-1989 6V92TA MUI engines (see 62 FR 12166; March 14, 1997). NYCTA,
as a large transit bus operator in a major metropolitan area, is
subject to requirements of the urban bus program.
Comments or issues fell into the following general categories: (A)
applicability of the kit; (B) description of the kit; (C) testing
demonstration and documentation; (D) life cycle cost
[[Page 60084]]
analysis; and, (E) warranty. All correspondence, comments, and other
documentation are located in the public docket at the address above.
(A) Applicability
In the January 30, 1997, Federal Register notice, EPA stated that
the information provided in JMI's initial notification did not support
certification of engines beyond model year 1989, because the federal
new engine standard for NOX dropped in 1990 to 6.0 g/bhp-hr
and in 1991 to 5.0 g/bhp-hr. (The NOX level of either
certification test engine, when rebuilt with the kit, is greater than
10 g/bhp-hr.) Additionally, EPA noted that the JMI notification lacked
support for certification of DDC's ``DDEC'' engines, because neither
test engine is equipped with electronically-controlled fuel injection.
In comments dated March 14, 1997, DDC stated that the
CCTTM kit should not be certified for numerous types of DDC
two stroke/cycle engines including all California engine models. In
general, DDC indicated that the JMI notification lacked support of
testing demonstration and/or documentation, and because the test data
showed that the kit exceeds the California NOX standards.
DDC also noted that engines rated at 325 and 340 hp are beyond the
range normally used in urban bus applications.
In a letter dated December 17, 1996, JMI restricted its
notification to DDC 6V92TA, 6V71T, and 6V71TA MUI engines of model
years 1979 through 1989. Furthermore, in a letter dated August 6, 1997,
JMI requested that EPA temporarily restrict its review to 6V92TA MUI
engines in order to expedited the certification process. Therefore,
today's Federal Register notice pertains only to EPA's certification of
the CCTTM kit as applicable to 6V92TA MUI engine models. EPA
also notes that documentation from Dallas Area Rapid Transit indicates
that it has buses equipped with 325 hp 6V92TA MUI engines. EPA
therefore believes it appropriate to include the 325 hp rating in the
certification described in today's notice.
In a letter to JMI dated March 17, 1997, the California Air
Resources Board (CARB) indicated that, without further test data
showing that California-certified engines are not adversely affected by
the CCTTM kit, CARB cannot allow use of the CCTTM
kit. 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. Those interested in additional information
should contact the Aftermarket Part Section of CARB, at (818) 575-6848.
(B) Description of the CCTTM Kit
Engelhard commented that the CCTTM kit specifies use of
a fuel modulator, and notes that it is not standard on 6V92TA coach
engines. Standard equipment on such coach engines is a throttle delay.
Engelhard claims that the fuel modulator will cause serious bus
driveability problems if not properly set and used in combination with
the appropriate engine configuration. DDC states that it has no
experience with the hardware combinations for which JMI has requested
certification. Both DDC and Engelhard indicate that the effect of the
CCTTM kit on bus driveability needs to be determined before
the kit is certified.
EPA notes that field experience to date, although limited, does not
indicate driveability problems. (Field experience is discussed further
below.) The basis for Engelhard's claim concerning driveability
problems appear to be conjecture based on theory of how an improperly
set fuel modulator would function in conjunction with an engine
operating on ``low'' boost pressure. Given the field experience
presented by JMI, EPA does not believe there is justification for a
delay in certification.
DDC questions JMI's original proposal to allow operators to use
aftermarket parts equivalent to original equipment, noting that DDC's
design and manufacturing specifications and tolerances are proprietary
and not available to aftermarket part suppliers. Relatedly, NYCTA
questions the use of non-DDC components, and expresses concern
regarding the maintenance, durability, emissions levels, and warranty
coverage associated with such parts.
In response, JMI modified its notification in a letter dated June
2, 1997, to restrict the specified parts of the CCTTM kit to
DDC-supplied original equipment. EPA notes that JMI's 6V92TA
certification engines were equipped with DDC components.
DDC questions the applicability of its procedures for checking
cylinder compression and camshaft timing, given the unique combination
of parts in the CCTTM kit. JMI states that the injector cam
maintains a standard profile, and the exhaust valves open less and for
a shorter time. JMI states that the DDC service method for checking
camshaft timing by measuring cam lift versus crank angle remains
applicable. JMI indicates that the procedure for checking cylinder
compression remains appropriate, but that the compression
specifications are different as a result of the lower compression ratio
of the CCTTM engine. JMI will provide cylinder compression
specifications with the CCTTM kit.
DDC references section 85.1406(d) of the program regulations, which
includes the requirement that ``* * * installation of any certified
retrofit/rebuild equipment shall not * * * result in any additional
range of parameter adjustability or accessibility to adjustment than
that of the vehicle manufacturer's emission related part'', and notes
that the JMI injector height setting of 1.420 inches is outside the
range of 1.460 to 1.520 inches which DDC allows and supports with
gauges for service adjustment.
EPA notes that the purpose of the cited passage of section
85.1406(d) is to prevent retrofit/rebuild equipment from increasing the
likelihood or potential for tampering. Although the CCTTM
kit requires a unique fuel injector timing height, the kit does not
change the inherent ``range of adjustability'' or ``accessibility to
adjustment'' of DDC's basic fuel injector system. The height setting of
the CCTTM kit is not tampering, indeed it is a requirement
of the kit to ensure compliance with emissions levels demonstrated by
JMI's testing. JMI will provide a gauge, for setting fuel injector
height, with the CCTTM kit.
Both Engelhard and DDC provide numerous comment on the unique
components and settings in the CCTTM kit, and are concerned
that there is not sufficient field or in-use experience. DDC notes that
the JMI fuel injection height specification (1.420 inches) is less than
the minimum DDC allows (1.460 inches), and states that a potential
unfavorable stack-up of component and adjustment tolerances may cause
engine problems due to injector follower bottoming in real-world
operating conditions. DDC notes that its minimum timing height
specification takes into consideration such unfavorable stack-up plus
the potential separation of the injector actuation linkage which can
occur under engine overspeed (over-revving) conditions. Engelhard notes
that JMI's 277 and 294 hp ratings use the same injector, asks how much
power the JMI 325 hp rating actually produces, and asks for explanation
of why the CCTTM
[[Page 60085]]
kit use larger injectors than the corresponding original DDC ratings.
JMI acknowledges that the fuel injector height setting (1.420
inches) of the CCTTM kit is outside DDC's normal range.
However, JMI states that testing performed on injectors at Southwest
Research Institute and JMI distributors indicate that the injectors
bottom-out between 1.380 and 1.390, and that successful operation has
been sustained at a setting of 1.400. JMI believes that the specified
injector setting will present no risk to the correct operation of the
engine. JMI notes that the CCTTM technology, including the
1.420 setting, has been used extensively in other industry
applications, as described further below. JMI will provide a gauge for
setting injector height with the CCTTM kit.
EPA does not know whether or how prevalent engine over-speed
conditions occur in transit operation (for example, whether it may
occur during long downhill conditions when a bus might drive its engine
to high speeds), or how significant of a problem it presents to the JMI
settings for the injectors. Consequently, EPA does not know whether
there is an adequate margin of safety in the injector height setting of
the CCTTM kit to preclude any engine problems under all
potential bus engine operating conditions. JMI, however, has
demonstrated engine-dynamometer experience, some in-use transit bus
operation (discussed further below), and in-use experience in other
industries with no noted problems. Additionally, an emissions defect
warranty, pursuant to section 85.1409 of the program regulations, is
provided by JMI for all components of the CCTTM kit, which
include the fuel injectors and proprietary camshaft. The warranty may
leave other parts of the injector actuating mechanism without coverage.
However, EPA does not believe such coverage to be necessary at present.
EPA may take additional action, if significant in-use problem develop.
For example, EPA has authority under section 85.1413 of the program
regulations to decertify equipment if, for example, use of certified
equipment severely degrades driveability, operation, or function.
EPA does not believe it necessary for JMI to explain why injectors
in the CCTTM kit are larger than those typically used in
corresponding DDC ratings. EPA recognizes that the CCTTM-
equipped engine is a unique combination of components, and fuel
injectors are clearly emissions-related components.
Engelhard comments that the severe injection advance plus lower
compression ratio of the CCTTM kit will result in problems,
including cold weather starting problems, shorter engine life,
reduction in low speed performance and higher fuel consumption, and
calls for JMI to demonstrate the need for the injection advance and the
affect on durability, fuel economy and performance. Engelhard states
that JMI should use a non-biased third party test facility to
demonstrate that the kit does not degrade performance. DDC notes that
the kit differs from DDC configurations and that they have no
experience with it.
Engelhard and DDC also comment on the design of the proprietary
camshaft, indicating that a change in camshaft design can impact engine
performance and durability. Engelhard's concerns range from the
dynamics of the valve train, which might affect durability of valve
train parts, to increased internal exhaust gas recirculation (EGR),
which might increase wear of cylinder liners and rings due to increased
oil contamination with soot. Engelhard calls for durability data to
verify that the valve train will not fail prematurely, and to ensure
that the CCTTM kit will not cause additional maintenance
and/or engine failure.
JMI has presented information in support of the durability and
performance of the CCTTM kit. JMI states that it has two
field trials underway. One is a 1983 Gillig powered by a 6V92TA MUI at
Kitsap Transit in Bremerton, Washington. No problems have been reported
as of July, with 16,000 miles of routine transit service. A second
transit trial on a 6V92TA DDEC II engine has been initiated in an un-
named northern city. JMI presents three routine analyses of the
lubrication oil from the Kitsap transit bus, and indicates that the
analyses show typical, normal patterns of engine break-in with no
unusual results. Soot is unmeasurable in the oil at 4,451 miles. In a
letter to EPA dated June 10, 1997, the Kitsap Director of Vehicle
Maintenance, acknowledging that six weeks and 12,000 miles of
accumulated service is a relatively short period of time, notes that
the bus is responsive to driver demands in a fashion that is in keeping
with this engine (somewhat more powerful), and no increase in fuel or
oil consumption.
Additionally, JMI presents information that the engine components
of the CCTTM kit have been used on several engines in the
oil and water pumping industries in stationary source locations, with
no reported problems. In general, these stationary engines operate in a
cyclic mode from low speed to wide-open-throttle, full load, to supply
power for drilling and pumping rigs. One such engine, a 6V92TA, has
been run for more than 3,500 hours with no reported problems. Another
diesel engine has been run more than 13,000 hours with no reported
problems.
In comments dated July 21, 1997, DDC states that the differences in
fuel modulator and throttle delay response characteristics may also be
observed in real world driving conditions. DDC further notes that,
although the Kitsap tests may not be representative of all engine, bus,
and driving pattern combinations, it suggests that the CCTTM
kit can be employed without serious loss of vehicle performance and the
tests go a long way to allaying the concern expressed in DDC's original
comments.
Regarding its proprietary camshaft, JMI states that the injector
cam profile of its proprietary cam is identical to the original
equipment (OE) cam profile, and the ramps and acceleration of the
exhaust cam are the same as the original equipment (OE) camshaft.
Additionally, the transition from the cam base circle to the first rise
is slightly more gradual than the OE camshaft. JMI states that the
dynamics of the CCTTM camshaft (exhaust valves open less and
for a shorter time) may result in improved mechanical durability
compared to the OE camshaft. While noting that the CCTTM
technology slightly increases the amount of internal EGR, JMI notes the
above-described long-term experience in the oil and pumping industry.
Further, oil analyses being conducted in the Kitsap field trial,
described above, indicates no additional soot contamination of the
lubrication oil.
JMI presented the above-discussed information in support of the
operability and durability of the CCTTM kit. No evidence has
been presented that indicates a specific problem with the design,
operability, or durability of the CCTTM kit. While there is
no requirement under the program regulations for a certifier to
demonstrate operability or durability of equipment, EPA remains
concerned about the long-term performance of all certified equipment.
However, any conclusions regarding decreased performance, durability,
or operability of CCTTM-equipped engines are speculative at
present, and the in-use information presented by JMI does not indicate
concern with the CCTTM kit. As noted above, EPA has
authority under section 85.1413 to decertify equipment that fails to
comply with requirements of the regulations.
EPA notes that JMI is required to cover the fuel injectors,
camshaft, cylinder liners, pistons, piston rings, and other components
of the CCTTM kit,
[[Page 60086]]
regardless of supply option, under the emissions defect warranty
required pursuant to section 85.1409.
DDC notes that its maximum back pressure limit for the 6V92TA MUI
bus engines is typically 3 inches of mercury, and expresses concern
that the addition of the CEM II catalytic muffler could cause DDC
exhaust back pressure limits to be exceeded in many bus installations.
DDC also is concerned about the JMI's field service procedure for
checking exhaust back pressure, which states that it should be measured
at full stall conditions. DDC indicates that the only way to check back
pressure for conformance with DDC back pressure limits is with an
engine operating at rated speed and wide-open-throttle. Back-pressure
measurements made at any other condition will under-represent the full
engine exhaust back pressure, and checking back pressure under these
conditions may lead to excessive back pressure when the engine is
operated in service. DDC calls for assurances that the CEM II will not
cause DDC back pressure limits to be exceeded for any affected bus
application. Verification must account for not only for the restriction
of a clean catalyst core, but must also account for restrictions
imposed by other exhaust system components, and the effects of core
aging and ash accumulation over time.
JMI states that the CEM II is physically identical to the design of
the original CEM, and its back pressure performance will be identical
to the back pressure performance of the CEM under the same conditions.
JMI notes that back pressure due to standard commercial mufflers vary,
and may range from less than 0.5'' mercury (Hg) to more than 1.0'' Hg.
Additionally, total back pressure may vary according to exhaust system
design, engine speed or horsepower. JMI states that back pressure
testing was conducted, as standard production practice, on CEM and CEM
II units, using a 6V92TA of 322 hp, to ensure compliance with the 3.0''
Hg maximum set by DDC. All CEM models tested had back pressure values
between 1.0'' to 1.5'' mercury.
EPA, in general, is concerned with in-use problems resulting from
excessive back pressure. However, no information presented by
commenters substantiate a concern for excessive back pressure with the
CEM II. More specifically, EPA has not received comments from transit
operators or others indicating significant problems with high back
pressure from the CEM catalyst muffler, which JMI indicates is
physically identical to the CEM II.
Regarding the ``full stall'' method of checking back pressure, JMI
states that it is a common, practical tool used by transit operators to
measure exhaust backpressure. JMI notes that conducting measurements at
rated speed and wide-open-throttle is difficult because transit
operators typically do not have chassis dynamometers available to
permit such measurements. EPA notes that, as a general diagnostic tool,
such measurement of back pressure could be useful with any exhaust
system (catalyst or muffler). While the full transmission stall test
may under represent full back pressure, it appears to provide some
usefulness as a back pressure check. As with other CCTTM kit
components, JMI is required to warrant the CEM II under the warranties
required pursuant to section 85.1409. As noted previously, EPA can take
action in the event of significant in-use problems and, ultimately, has
authority to decertify equipment.
Few certifiers have extensive experience from in-use transit
service to comprehensively demonstrate the durability and performance
of equipment certified for the urban bus retrofit/rebuild program. Nor
does the program regulation require such comprehensive demonstration.
JMI has presented information of in-use experience in support of these
characteristics of the CCTTM kit, and EPA knows of no reason
at this time to oppose certification.
(C) Testing Demonstration and Documentation
NYCTA comments that the PM emissions levels of the certification
engines are close to the 0.10 g/bhp-hr standard, expresses concern that
CCTTM equipped engines will emit above the standard after
in-use operation, and asks whether deterioration factors have been
included in the certification levels. NYCTA also notes that the
emissions data for the 6V92TA engine indicates that NOX
emissions increase, and NYCTA believes that some buses equipped with
the CCTTM kit will emit above the 1988 emissions standard
(10.7 g/bhp-hr).
The urban bus program regulations do not specifically require
manufacturers to demonstrate the durability of their candidate
equipment. Similarly, there is no requirement for certifiers to develop
an empirical basis for determining a deterioration factor. During the
initial design of the urban bus program, EPA recognized that durability
demonstration would impose a significant burden on certifiers, and
expected that such burden would prevent technologies from coming
forward. A program without certified technology would provide minimal
emission reductions. Instead of requiring a durability demonstration,
the program is based on the requirement for certifiers to warrant their
equipment for defects and emissions performance (as specified in
section 85.1409), on EPA's authority to perform in-use testing of
certified equipment, and on EPA's authority to decertify noncompliant
equipment (as specified in section 85.1413). As stated in the preamble
to the final rule of April 21, 1993 (58 FR 21379): ``EPA believes that,
therefore, it is sufficient to hold manufacturers responsible for the
emissions performance of their equipment through an emissions
performance warranty * * *'' and ``Manufacturers will want to evaluate
the durability of their equipment before selling it under this program
to minimize their liability risk.'' Section 85.1413 provides authority
to EPA to decertify equipment that EPA determines does not meet
emissions requirements in-use. These emissions requirements include the
HC, CO, NOX, and smoke standards of a particular engine, in
addition to the PM standards of the urban bus regulation.
The JMI notification indicates that the test engines were selected
as ``worst case'' based on Table 3 of 58 FR 21373 (April 23, 1993).
Engelhard comments that the test engine is not worst case for emissions
from a catalyst-equipped engine, basically because the exhaust flow
from higher horsepower engines would increase engine exhaust back
pressure and reduce residence time of the exhaust within the catalyst,
lowering catalyst effectiveness. Engelhard also claims that the CEM II,
subject to higher exhaust temperatures from the higher horsepower
engines, will have a greater tendency to make sulfate. DDC comments
that the exhaust flow from higher hp engines is expected to be greater,
but the 277 hp engine is the most popular for transit usage and
therefore makes it the proper choice for certifying equipment for use
on engines rated at 253, 277, and 294 horsepower.
For several reasons, EPA believes that the 6V92TA test engine
equipped with the CCTTM kit, and rated by JMI at 277 hp, is
acceptable to demonstrate compliance for 253, 277, 294, and 325 hp
ratings. First, the test engine is clearly the engine model for which
JMI is claiming applicability of the CCTTM kit. Further, the
rating of the certification test engine is the most popular power
rating according to the engine manufacturer. It therefore is the most
representative power rating. Second, JMI has also presented
[[Page 60087]]
emissions testing data from a 6V71TA engine model, which also
demonstrates compliance of the CCTTM kit with the 0.10 g/
bhp-hr standard.
Regarding Engelhard's concern for higher exhaust flow with higher
horsepower, no information is presented for the potential increase in
sulfate emissions and that contribution to the total particulate
emissions of any of the engine ratings. Additionally, it is not clear
that an engine of the JMI-rated 294 hp or 325 hp, would have
significantly different exhaust emissions or flow rate from the
certification test engine. This is because, as DDC notes, higher
horsepower ratings generally produce higher exhaust temperatures which
may compensate for lower catalyst residence time (that is, higher
temperatures are generally conducive to higher catalytic conversion
efficiency). Furthermore, JMI analyzed data published for DDC engine
configurations, to show that exhaust flow rates of higher horsepower
engines may increase only in the order of a few percent over the flow
rate of a 277 hp engine. JMI notes that one 330 hp 6V92TA has a
standardized flow rate that is 1.4 percent greater, and another 330 hp
6V92TA has a standardized flow rate that is 3.7 percent less, than the
published flow rate for a 277 hp 6V92TA coach engine. JMI states that
this increase in flow rate is well within the margin of safety that is
engineered into the CEM II and will represent no loss in conversion. In
summary, EPA is not convinced that exhaust flow is clearly related to
engine horsepower rating, or that a higher horsepower test engine would
necessarily be worst case. EPA is not aware of evidence suggesting a
problem with back pressure from this catalytic muffler design. Also,
JMI has more than one catalyst biscuit size, and the emissions testing
on the 6V92TA was performed on its smallest biscuit. JMI bears the
burden of the emission performance warranty required by program
regulations.
In its letter of August 11, 1997, Engelhard comments that the same
fuel injectors are used in the CCTTM kit for the 277 hp
rating and 294 hp rating, and concludes that there is no 294 hp kit.
Engelhard indicates that JMI needs to provide an explanation regarding
the injector specifications.
EPA is aware that typical industry practice is to use larger fuel
injectors for higher horsepower, because, as Engelhard notes in its
comments, larger injectors result in higher horsepower. JMI has not
provided EPA with torque curves for its power ratings other than the
certification test engine rated at 277 hp. The requirements of the
urban bus program were designed to minimize testing burden, while
demonstrating emissions compliance, but not to verify performance of
every engine rating. While JMI has demonstrated compliance with the
0.10 g/bhp-hr standard, operators should be aware that EPA has not
verified the power output of ratings other than that which JMI tested
for exhaust emissions.
Engelhard compares the engine torque curves developed during JMI's
testing of the CCTTM kit and baseline engine, and comments
that the CCTTM kit results in an significant loss of low
torque and horsepower compared to a standard urban bus engine.
Engelhard concludes that this will cause significant performance,
acceleration, and fuel economy problems for users of the
CCTTM kit. In its initial comments of March 14, 1997, DDC
also notes the low torque developed at low engine speeds. DDC and
Engelhard call for demonstration of in-use performance and durability
evaluation.
In response, JMI states that low speed acceleration of a bus
equipped with the CCTTM kit is improved, because the kit
includes replacement of the throttle delay (standard equipment on bus
engines) with a fuel modulator. JMI states that a bus equipped with a
standard throttle delay experiences a limit on the full fuel
acceleration. The throttle delay is designed to make full engine torque
developed available in 4 to 7 seconds. An engine equipped with the
CCTTM kit will immediately have all the torque developed
available to the driver for acceleration. Therefore, low speed
acceleration is improved.
Comments from Kitsap Transit, reflecting limited experience with
the CCTTM-equipped engine, state that ``* * * our drivers
believe that on board power has been improved.'' In its comments of
July 21, 1997, DDC notes that, although the Kitsap tests may not be
representative of all engine, bus, and driving pattern combinations, it
suggests that the CCTTM kit can be employed without serious
loss of vehicle performance and the tests go a long way to allaying the
concern expressed in DDC's original comments.
EPA recognizes differences between the torque maps generated for
the baseline and the certification engine. However, EPA believes that
the torque curve (that is, the torque map) generated for transient
emissions testing can be a misleading representation of the torque that
would be available at any instant from a similar engine during in-use
service. This is due to the manner in which the torque map is generated
for the transient emissions test and the particular fuel control means
(such as throttle delay or fuel modulator) used on an engine. As DDC
notes in its comments, the torque map is generated with the throttle
delay fully discharged and the fuel rack in the full fuel position.
Therefore, the influence of the throttle delay on fuel control is not
reflected in the torque reported for the torque map. DDC states that
the differences in fuel modulator and throttle delay response
characteristics may also be observed in real world driving conditions.
EPA therefore believes that conclusions based solely on comparison of
torque maps may be misleading.
In summary, regarding the relative performance of CCTTM-
equipped engines, EPA is not aware of any clear evidence indicating a
performance concern. Actual in-use experience, although limited,
suggests that the CCTTM kit provides performance comparable
to an original configuration.
DDC notes that during certification testing the CEM II was
installed at a distance of six feet from the exhaust outlet of the
turbocharger turbine, and comments that if the CEM II is installed in a
location on a bus which is more than 6 feet from the turbine outlet,
then the exhaust gases will be cooler and the effectiveness of the
catalyst in oxidizing soot emissions will be less than was observed in
the certification testing.
JMI presents exhaust temperature data from testing performed during
certification of the CEM, which indicate a reduction of 10 degrees in
exhaust gas temperature (from 627 degrees F to 617 degrees F) over a
six-foot length between the turbine outlet and CEM. JMI states that if
the CEM II is located an additional three or even six feet away from
the outlet, then the exhaust temperature would decline by only an
additional 5 to 10 degrees, which would have no effect on catalyst
activity.
The temperature of the exhaust gases from a bus engine is
continually changing during in-use operation due to variations in
engine speed and load. EPA has no information that an additional few
degrees drop in exhaust gas temperature is of significant concern
regarding catalyst effectiveness. EPA has accepted in the past, as
demonstration of compliance with emissions requirement of the urban bus
program, emissions data developed from testing catalysts at a distance
of six feet from the turbine outlet.
(D) Life Cycle Cost Analysis
NYCTA comments that the power ratings of the JMI certification test
engine is above the range normally used in urban bus applications, and
this should be included in the incremental life cycle cost analysis
because of
[[Page 60088]]
implications related to higher wear on driveline components and higher
fuel consumption. Also, NYCTA states that it is not clear what power
ratings are being offered by JMI.
JMI states that it will offer the CCTTM kit for the
6V92TA models in four horsepower ratings (253, 277, 294, and 325) that
are for the most part, typical to the transit industry. (JMI has asked
EPA to temporarily restrict its review to CCTTM kits
applicable to 6V92TA engine models.) While JMI has not provided EPA
with torque curves for its ratings other than the certification test
engine rated at 277 hp, EPA notes that the certification engine
produced a maximum power of 274 hp during the torque map, which is
within roughly 1 percent of the JMI rating (277 hp). Therefore, EPA
believes that JMI's nomenclature (that is, the ``rating'') for the
CCTTM kit configuration it tested, 277 hp, is consistent
with the actual power produced for the emissions test. EPA believes
that operators having engines originally rated at 277 hp will most
likely choose a retrofit kit of the same horsepower rating.
NYCTA also comments that data is needed, such as periodic catalyst
inspection or replacement, in order to estimate the incremental
maintenance cost component of the life-cycle costs. NYCTA also
indicates that field testing experience in transit service is needed in
order to estimate incremental life cycle costs.
JMI states that there is no incremental maintenance costs
associated with the CCTTM kit--the maintenance checks
required for a standard DDC engine also apply, at the same interval, to
a CCTTM-equipped engine. There is no scheduled replacement
of the CEM II catalyst.
NYCTA notes the significant difference in the torque
characteristics of the CCTTM equipped engine compared to the
original configuration. NYCTA comments that modifications to the drive
train may be required to maintain acceptable acceleration, and this
should be included in the life-cycle estimates.
The need for drive train modifications appear to be speculative at
present. EPA believes that comparing the torque maps of the baseline
and CCTTM equipped engine as discussed above, may be
misleading for purposes of predicting vehicle acceleration.
Additionally, JMI states that the field trial being conducted at Kitsap
Transit indicate that the performance, power and acceleration of the
CCTTM equipped engine is not impaired.
The JMI cost analysis includes incremental costs for 2 hours of
labor for installation of the CEM II catalytic muffler. Both DDC and
Engelhard question this cost. Engelhard comments that an installation
time of 4 to 6 hours is more appropriate. DDC questions the
appropriateness of the time estimate for installation of the CEM II,
given that the installation time budgeted for the converter muffler of
the Engelhard ETXTM kit (see 62 FR 12166; March 14, 1997) is
6 hours, and installation of the two converters are ``* * * seemingly
similar activities * * *''. DDC also states that installation time
should include time to check that back pressure limits are not
exceeded, and should account for installation of the water drainage
device required for some applications of the kit, and incremental
maintenance costs associated with routine vehicle maintenance.
JMI indicates that over 54 designs of CEMs have been engineered to
cover the broad range of coach and engine combinations. The initial
application for the CEM estimated a maximum installation time of 6.5
hours as a best estimate. JMI's installation time for the CEM II of 2
hours is based on field experience with actual installation of the CEM.
JMI also has provided data and statements from operators supporting the
accuracy of the two-hour installation time.
EPA believes that 2 hour installation time is appropriate for the
cost analysis, and is included above in Table 3. JMI states that the
water drainage device is not necessary on any vertical exhaust stack,
and is therefore not included in the LCC analysis. JMI provides an
emissions defect warranty, pursuant to section 85.1409 of the program
regulations, which includes coverage of the CEM II. JMI also states
that the CCTTM kit does not have additional routine
maintenance requirements, incremental to standard DDC maintenance,
service or installation procedures, including routine checks of the CEM
II.
Engelhard comments that JMI's initial baseline engine, a DDC 6V92TA
engine configured to a 253 hp rating, is invalid for comparison because
of the specific parts used in the JMI certification engine. Engelhard
claims that the turbocharger and fuel injectors of JMI's certification
engine are from a 294 hp configuration and, therefore, for an accurate
comparison of fuel economy and emissions, the CCTTM kit of
277 rating needs to be compared with a baseline engine of 294 hp.
Engelhard claims that comparing the JMI engine with a 294 hp baseline
engine from a previous Engelhard test program shows a 12 percent loss
in fuel economy for the CCTTM kit.
In response, JMI subsequently tested a second baseline engine, a
DDC configuration rated at 277 hp as shown above in Table 1. Engelhard
comments that this baseline engine is not performing properly because
the NOx emissions (13.0 g/bhp-hr) are significantly higher than the
federal standard (10.7 g/bhp-hr) applicable to 1985 through 1989 model
year.
EPA notes that JMI's 6V92TA certification engine produced a maximum
power of 274 hp during the torque map, which is within roughly 1
percent of the JMI rating (277 hp). Therefore, EPA believes that JMI's
nomenclature (that is, the ``rating'') for the CCTTM kit
configuration it tested, 277 hp, is consistent with the actual power
produced for the emissions test. The actual combination of parts
developed by JMI for its 277 hp rating, while perhaps unique, is not
relevant to choice of baseline engine for fuel consumption comparison.
EPA believes that operators having engines originally rated at 277 hp
will most likely choose a retrofit kit of the same horsepower rating.
Therefore, for comparison of fuel consumption, engines of the same
rating should be compared.
Regarding the NOX emission level of the 277 hp baseline
engine, the measured value (13.0 g/bhp-hr) may be higher than typical
for this rating. However, EPA believes that the test of the 277 hp
baseline engine is adequate for its sole purpose--to determine the
impact of the CCTTM kit on fuel consumption.
DDC comments that the only proper way to make fuel economy
comparisons is at equivalent power ratings, and Engelhard in its
comments notes the potential for significant cell-to-cell variations
that make correlating data between test cells unreliable.
DDC also comments that comparison made at maximum hp and maximum
torque with DDC's published values suggests that the CCTTM
kit imposes a 6 to 7 percent fuel economy penalty.
EPA believes that a typical operating cycle for urban buses cannot
be characterized by fuel consumption determined at steady state, full
power output, as DDC has suggested. EPA notes that a comparison of the
253 hp baseline engine with the certification engine (JMI-rated at 277
hp) indicates a one percent improvement with the kit. Additionally, JMI
references preliminary in-service experience from the Kitsap field
trial that indicates a 20 percent improvement in fuel economy, and
states that JMI's position is that no fuel penalty should apply.
Section 85.1407 of the program regulations require that incremental
fuel cost be
[[Page 60089]]
determined based on testing performed over the heavy-duty engine
federal test procedure, or an approved alternative test procedure. EPA
believes that it is appropriate to compare data from engines of the
same horsepower and from the same test cell, when available, for
determining the fuel economy impact. This data is available from the
JMI testing and such comparison is consistent with the requirements of
the regulations. Comparison of the baseline DDC-rated 277 hp engine to
the JMI-rated 277 hp certification engine indicates a fuel penalty of 3
percent for the CCTTM kit. Using the calculations required
for this determination, as set forth at section 85.1403(b)(1), the
impact on the life cycle cost analysis of the CCTTM kit, as
shown above in Table 3, is determined to be a penalty of $964.30.
Engelhard states that fuel modulators are not standard on 6V92TA
coach engines. The standard throttle delay will have to be removed and
the fuel modulator installed and the additional labor associated with
this should be included in the LCC analysis. JMI indicates that a
standard rebuild would include the removal, and reinstallation and re-
calibration of the throttle delay. This is necessary in order to remove
and replace the fuel injectors and other key engine components. When an
engine is rebuilt with the CCTTM kit, the fuel modulator is
installed in place of the throttle delay. EPA believes that use of the
fuel modulator in a CCTTM kit presents no costs, incremental
to the costs of a standard rebuild.
In its comments of July 21, 1997, DDC indicates that it is in
fundamental agreement with the JMI life cycle cost analysis, except for
the cost offset of the proprietary cam of the CCTTM kit. The
cost offset in the analysis is $1229, and DDC believes that the offset
should be $320, which is the cost for remanufactured camshafts
available from DDC. DDC believes that most operators would be expected
to use remanufactured parts when replacing camshafts at the time of
rebuild.
EPA determined the cost of a ``weighted'' rebuild for the cost
evaluation of DDC's upgrade kit for the 6V92TA MUI (61 FR 37734; July
19, 1996), and later updated that cost for certification of the
Engelhard ETXTM kit (62 FR 12166; March 14 1997), both using
cost information provided by DDC, and others, at those times. For the
evaluation of the CCTTM kit, EPA relies on the cost
determination for a ``weighted'' rebuild published in the Federal
Register on March 14, 1997, updated to May 1997. EPA has not modified
its March 14th determination of the cost because it has no data on the
fraction of operators which are expected to use remanufactured
camshafts.
(E) Warranty
DDC commented that the JMI warranty does not provide coverage for
non-JMI parts that are used in conjunction with a CCTTM kit
in rebuilding an engine, and does not cover any liability for labor
costs or for any incidental or consequential damages. DDC also noted
that use of standard DDC parts in conjunction with the CCTTM
kit could result in the parts being subjected to unduly harsh operating
environments, and DDC's parts warranty does not extend to parts that
have been misapplied or misused. DDC noted that the warranty applies
coverage only if an engine is operated with ``unadulterated'' diesel
fuel, yet it is common practice for many operators to use fuel
additives.
During the review process, JMI's warranty language underwent
changes, as did the description of the CCTTM kit of today's
notice. As noted previously, JMI restricted the specified emissions-
related parts of the kit to DDC-supplied parts. Also, JMI changed its
warranty language to make clear that it covers the emissions-related
parts that JMI specifies to be used with the CCTTM kit.
Warranty coverage applies to both supply options. The JMI warranty was
also modified so that coverage is not conditioned on the use of
``unadulterated'' fuel. JMI states that additives are permissible, but
requests to review the constituents of any additives used by transit
operators before they are used by the transit.
With regard to labor costs, JMI is not required to cover labor
costs associated with warranty repair because labor associated with
equipment installation and maintenance is the responsibility of the
transit operator. (Maintenance includes warranty repair.) This point is
stated in the preamble to the final rule of April 21, 1993 ( 58 FR
21381): ``Bus operators will be responsible for the proper installation
and maintenance of the equipment.'' Additionally, incidental or
consequential damages, or non-JMI parts used in conjunction with
retrofitting with a CCTTM kit, are not required to be
covered pursuant to the warranty requirements of the program
regulations (section 85.1409). EPA is not aware of any evidence that
incidental or consequential damages will occur. If significant in-use
problems develop, then EPA may take action.
IV. Certification
The Agency has reviewed the notification of intent to certify and
other information provided by JMI, along with comments received from
interested parties, and finds that the CCTTM kit described
above:
(1) Complies with the particulate matter exhaust emissions standard
of 0.10 g/bhp-hr, without causing the applicable engine families to
exceed other exhaust emissions standards;
(2) Complies with the life cycle cost requirements pursuant to
section 85.1403(b)(1);
(3) Will not cause an unreasonable risk to the public health,
welfare, or safety;
(4) Will not result in any additional range of parameter
adjustability; and,
(5) Meets other requirements necessary for certification under the
Retrofit/Rebuild Requirements for 1993 and Earlier Model Year Urban
Buses (40 CFR Sections 85.1401 through 85.1415).
Therefore, today's Federal Register notice announces certification
of the above-described Johnson Matthey CCTTM kit for use in
the urban bus retrofit/rebuild program as discussed below in section V.
V. Transit Operator Responsibilities
Today's Federal Register notice announces certification of the
above-described CCTTM kit, when properly applied, as meeting
the 0.10 g/bhp-hr particulate matter standard of the Urban Bus
Retrofit/Rebuild Program.
In a Federal Register notice dated March 14, 1997 (62 FR 12166),
EPA announced certification of a retrofit/rebuild kit produced by the
Engelhard Corporation (the ETXTM kit). That certification
means that urban bus operators using compliance program 1 must use
equipment certified to the 0.10 g/bhp-hr standard when rebuilding or
replacing applicable 1979 through 1989 model year DDC 6V92TA MUI model
engines after September 14, 1997. The certified JMI equipment described
in today's notice may be used by operators in compliance with the 0.10
g/bhp-hr standard. Operators using compliance program 2 having
applicable engines may use the certified CCTTM kit and claim
the certification PM level from Table 2 above, when calculating their
Fleet Level Attained (FLA). Under program 2, an operator must use
sufficient certified equipment so that its actual fleet emission level
complies with the target level for its fleet.
As mentioned above, certification of the Engelhard ETXTM
kit triggered the 0.10 g/bhp-hr standard for applicable 1979-1989
6V92TA MUI engines. That kit provides three power ratings: 253, 277,
and 294 horsepower. JMI will offer the CCTTM kit in four
power ratings: 253, 277, 294, and 325 hp. Certification of the
CCTTM kit described in today's
[[Page 60090]]
Federal Register notice triggers the 0.10 g/bhp-hr standard for engines
rated above 294 hp. This means that urban bus operators using
compliance program 1 must use equipment certified to the 0.10 g/bhp-hr
standard when rebuilding or replacing applicable engines above 294 hp
after May 6, 1998.
Urban bus engines certified to meet California emissions standards
are not applicable to the CCTTM kit discussed in today's
Federal Register notice. Additionally, the 0.10 g/bhp-hr PM standard is
not triggered for engines certified to meet California emission
standards. Operators of such urban buses, who choose to comply with
program 1, are not required to use equipment certified to the 0.10 g/
bhp-hr PM standard until the standard has been triggered for such
engines. Operators of urban buses having engines certified to meet
California emission standards, and who choose to comply with program 2,
may not use the CCTTM kit described in today's notice to
meet program requirements.
As stated in the program regulations (40 CFR 85.1401 through
85.1415), operators must, beginning January 1, 1995, maintain records
for each engine in their fleet to demonstrate that they are in
compliance with the requirements of the Urban Bus Retrofit/Rebuild
Program. 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 using the supply option 2, as
described previously in today's Federal Register notice, must be aware
of their responsibility for maintenance of records pursuant to 40 CFR
Sections 85.1403 through 85.1404, because they do not purchase the
complete CCTTM kit from JMI. Urban bus operators using
supply option 2 must be able demonstrate that all parts used in the
rebuilding of engines are in compliance with program requirements. In
other words, such urban bus operators must be able to demonstrate that
all components of the kit certified in today's Federal Register notice
are installed on applicable engines.
Dated: October 29, 1997.
Richard D. Wilson,
Acting Assistant Administrator for Air and Radiation.
[FR Doc. 97-29397 Filed 11-5-97; 8:45 am]
BILLING CODE 6560-50-P
