[Federal Register Volume 63, Number 232 (Thursday, December 3, 1998)]
[Notices]
[Pages 66798-66806]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 98-32071]
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ENVIRONMENTAL PROTECTION AGENCY
[FRL-6196-5]
Retrofit/Rebuild Requirements for 1993 and Earlier Model Year
Urban Buses; Certification of Equipment
AGENCY: Environmental Protection Agency (EPA).
ACTION: Notice of Agency certification of equipment.
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SUMMARY: EPA received an application dated March 6, 1998 from Johnson
Matthey, Incorporated (JM), for certification of urban bus retrofit/
rebuild equipment pursuant to 40 CFR 85.1401--85.1415. The kit is
identified as the Cam Converter Technology (CCTTM) Upgrade
Kit and applies to Detroit Diesel Corporation's (DDC) 6V92TA model
engines of model years 1985 through 1993 with power ratings of 253 and
277 horsepower and having electronically-controlled fuel injection
(DDEC). Applicable engines include those certified to meet federal and
California emissions standards.
On May 14, 1998, EPA published a notice in the Federal Register (63
FR 26795) that the notification had been received and made the
notification available for public review and comment for a period of 45
days. EPA has completed its review and the Director of the Vehicle
Programs and Compliance Division has determined that it meets the
requirements for certification, conditioned on the terms discussed
below in section IV. The effective date of certification is discussed
below under DATES.
The certified equipment complies with the particulate matter (PM)
standard of 0.10 gram per brake horsepower-hour (g/bhp-hr).
In addition, two methods of marketing the CCT kit, discussed below
as supply options, are approved by EPA.
Certification of the CCT kit, as it applies to all applicable
engines of model years 1985 through 1990 and all applicable engines of
model years 1991 through 1993 that are not equipped with ECM programs
#259 through #264 for kit operation on diesel fuel #1, is conditioned
upon JM complying with the terms discussed below in section IV.
Certification is unconditional for 1991 through 1993 model year engines
that are equipped with ECM programs #259, #260, #261, #262, #263, or
#264 and operate on diesel fuel #1 after kit installation.
The certification of this equipment does not trigger any new
requirements for transit operators. However, EPA certification makes
the CCT kit available as an option to those operators that are required
to use equipment certified to the 0.10 g/bhp-hr standard.
ADDRESSES: The JM application, as well as other materials specifically
relevant to it, are contained in Public Docket A-93-42, Category XXI-A,
entitled ``Certification of Urban Bus Retrofit/Rebuild Equipment''.
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.
DATES: Today's Federal Register notice announces the Agency's decision
to certify the CCT equipment, as described below.
The effective date of certification was established in a letter
dated October 21, 1998, from the Director of the Vehicle Programs and
Compliance Division to Johnson Matthey. (A copy of the letter is in the
public docket, which is located at the address noted above.)
This certified equipment may be used immediately by urban bus
operators, subject to the condition in Section IV.
FOR FURTHER INFORMATION CONTACT: William Rutledge, Engine Programs and
Compliance Division (6403J), U.S. Environmental Protection Agency, 401
M St. SW, Washington, D.C. 20460. Telephone: (202) 564-9297.
SUPPLEMENTARY INFORMATION:
I. Background and Equipment Identification
In a notification of intent to certify signed March 6, 1998,
Johnson Matthey, with principal place of business at 434 Devon Park
Drive, Wayne, Pennsylvania 19087-1889, applied for certification of
equipment under the urban bus program. The notification and equipment
are further clarified in letters provided subsequently from JM to EPA,
and are available from the public docket at the address above.
JM states that the equipment, referred to as the Cam Converter
Technology (CCTTM) upgrade kit, consists of patented engine
cam shafts, a CEM IITM catalytic exhaust muffler, specified
engine rebuild parts, and a set of instructions. The instructions
specify fuel injector height, 0.015 offset key size, and electronic
control module (ECM) software program. The kit composition and supply
options are described below in this section.
JM provides emissions data from testing two baseline engines, one
certification engine, and one test engine in an uncertified
configuration. The results of the engine testing are summarized below
in Table 1. The emissions data were developed using engine dynamometer
testing conducted in accordance with the Federal Test Procedure (FTP)
for heavy-duty diesel engines (40 CFR Part 86), and conducted using
test engines rated at 277 horsepower.
One of the baseline engines was rebuilt to a 1988 model year
configuration and the other rebuilt to a 1991 configuration.
Certification testing, using both diesel fuel #1 and #2, was performed
on an engine rebuilt with the appropriate CCT Upgrade Kits. The parts
used to rebuild the engines are provided in the March 6, 1998
notification and letters dated September 28 and October 7, 1998.
Documents can be found in the public docket at the address listed
above.
The data of Table 1 indicate that, when an engine is rebuilt with
the CCTTM kit having the 0.015 offset key, PM emissions are
less than 0.10 g/bhp-hr, and emissions of hydrocarbon (HC), carbon
monoxide (CO), oxides of nitrogen (NOX), and smoke opacity
are less than or equal to the federal and California standards
applicable to the 1993 model year. The certification test data were
provided to EPA in the March 6, 1998 notification and in a letter from
JM dated September 28, 1998. One certification test was conducted using
diesel fuel #1, and all of the other tests were conducted using diesel
fuel #2.
The ``uncertified kit'' of Table 1, using an 0.010 offset key, does
not comply with the 5.0 g/bhp-hr NOX standard and is not the
certified configuration of today's Federal Register notice. That
``uncertified kit'' consisted of all of the parts of the CCT kit except
for use of an 0.010 offset key. The data is provided as support data
demonstrating compliance with the 0.10 g/bhp-hr PM standard.
EPA believes that CCT-equipped engines using the 0.015 offset key
will meet the 0.10 g/bhp-hr PM standard because installation of the kit
upon engine rebuild results in the replacement of all emissions-related
parts with a specific set of parts. JM has provided testing which
demonstrates compliance of this set of parts with the 0.10 g/bhp-hr PM
standard. The fuel consumption impact of the CCT kit is discussed in
section II below.
[[Page 66799]]
Table 1.--Summary of Johnson Matthey Testing
--------------------------------------------------------------------------------------------------------------------------------------------------------
Transient emission engine test (g/bhp-hr) of 6V92TA DDEC II
1991 HDDE -------------------------------------------------------------------------------
Gaseous and particulate test: standards 1988 baseline 1991 baseline Uncertified
\1\ \2\ CCT kit \3\ CCT kit \4\ kit \5\
--------------------------------------------------------------------------------------------------------------------------------------------------------
HC...................................................... 1.3 0.4 0.46 0.2 0.3 0.2
CO...................................................... 15.5 1.2 1.2 0.6 0.77 0.8
NOX..................................................... 5.0 8.4 4.9 5.0 4.19 5.8
PM...................................................... 0.25 0.15 0.19 0.091 0.090 0.097
BSFC \5\................................................ .............. 0.459 0.483 0.489 0.497 0.483
--------------------------------------------------------------------------------------------------------------------------------------------------------
Smoke test: Standards
percent Percent opacity
--------------------------------------------------------------------------------------------------------------------------------------------------------
ACCEL................................................... 20 2.9 2.7 2.3 4.0 2.3
LUG..................................................... 15 0.8 1.2 1.2 2.1 0.3
PEAK.................................................... 50 4.3 3.7 3.7 5.6 4.7
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\1\ Engine id number 6VF160626 using 2D fuel.
\2\ Engine id number 6VF186640 using 2D fuel.
\3\ Engine id number 6VF186640 using 2D fuel and 0.015 offset key.
\4\ Engine id number 6VF186640 using 1D fuel and 0.015 offset key.
\5\ Engine id number 6VF160626 using 2D fuel and 0.010 offset key (not certified).
\6\ Brake Specific Fuel Consumption (BSFC) is measured in units of lb/bhp-hr.
The CCT kit is applicable to all Detroit Diesel Corporation (DDC)
6V92TA DDEC two-stroke/cycle urban bus engines from model years 1985
through 1993 with power ratings of 253 and 277 horsepower (hp),
including those certified to federal and California standards.
The CCT kit is intended to be installed at the time of a standard
engine rebuild using standard DDC rebuild practices, except where
amended by JM. The contents of the CCT kit, shown in Table 2, will vary
depending upon the supply option and the particular engine to be
rebuilt. If the first supply option is selected by the installer, then
Johnson Matthey will provide all of the following parts: CEM II
catalytic muffler, patented engine camshafts, CCT cylinder kits, 0.015
offset key, fuel injectors, 40T blower gear, turbo charger, blower
assembly, blower bypass valve, and if necessary, ECM program. In
addition, the kit for 1985 through 1987 DDEC 1 engines, regardless of
supply option, will include the DDEC I to DDEC II conversion parts
listed in the letter dated September 28, 1998 from JM to EPA. If the
second supply option is selected by the installer, then JM will provide
only the ``unique'' parts (including, if necessary, the ECM program)
for the particular engine to be rebuilt. The balance of the CCT kit
parts, that is, the ``non-unique'' parts, must be acquired by the
installer through other channels. The non-unique parts are parts that
would be replaced during the standard rebuild of particular engines,
and must be the particular DDC components specified in the CCT kit.
Table 2.--CCT Kit Parts \1\ Provided Under Supply Option 2
----------------------------------------------------------------------------------------------------------------
1985-87 DDEC 1 1988-90 DDEC 1991-93 DDEC II
Part provided in kit? -------------------------II----------------------------------------
Diesel 1 & 2 Diesel 1 & 2 Diesel 1 Diesel 2
----------------------------------------------------------------------------------------------------------------
CEM II...................................... Yes Yes Yes Yes
Patented Cams............................... Yes Yes Yes Yes
CCT Cylinder kits........................... Yes Yes Yes Yes
0.015 Offset Key............................ Yes Yes Yes Yes
Fuel Injectors.............................. Yes Yes No No
ECM Program................................. Yes Yes \3\ No Yes
40T Blower Gear............................. Yes No No No
Turbo Charger............................... Yes No No No
Blower Assembly............................. Yes No No No
Blower Bypass Valve......................... Yes No No No
DDEC 1 to DDEC 2............................ \2\ Yes not applicable
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\1\ The balance of the CCT kit parts must be acquired by the installer and must be the DDC components specified
in the CCT kit.
\2\ The kit for 1985 through 1987 DDEC I engines, regardless of supply option, will include the DDEC I to DDEC
II conversion parts.
\3\ 1991-93 engines having ECM program 259 through 264 for CCT kit operation on diesel fuel #1 do not require a
new ECM program.
The CEM II is a direct, bolt-on replacement for the original
equipment muffler, and is designed to fit the specific bus/engine
combination. The 0.015 offset key replaces the standard Woodruff key
between the pulse wheel and camshaft, and functions to offset the
electronic pulse wheel to retard fuel injection timing. The list of
specific engine parts is provided in the notification of intent to
certify dated March 6, 1998.
All CCT kits will include a CEM II catalytic muffler, patented
engine camshafts, CCT cylinder kits, and 0.015 offset key, regardless
of supply option. For 1985 through 1987 model year engines, all of the
parts of Table 2 are unique parts and therefore, required to be
provided in the certified CCT kit. For 1988 to 1990 model year engines,
the CCT kit includes fuel injectors and an upgrade of the ECM program.
For the 1991-1993 model year engines, the fuel injectors, turbocharger,
blower assembly, blower bypass valve, and 40 teeth blower drive gear
are non-unique,
[[Page 66800]]
standard rebuild components and therefore, not required to be in the
certified CCT kit. To complete a rebuild using supply option 2, an
operator must acquire on its own, the other required (specified)
standard engine rebuild parts. The parts not provided with the kit are
required to be the DDC-supplied parts specified with the kit
instructions, because DDC components were used for JM's certification
testing. JM is required to provide a 100,000 mile defect warranty and
150,000 mile emissions performance warranty for the components supplied
to the transit operator in each kit.
All 1985 through 1990 model year engines will require a change of
ECM program. A change of ECM program is required for any 1991-1993
model year engine that is not equipped with ECM program 259 through 264
for kit operation on diesel fuel #1. When a change in ECM program is
necessary, it will be included in the purchase price of the kit. In
summary, if a transit operator has an engine that does not have the
CCT-identified ECM program for its particular parameters (hp, rotation,
fuel type, peak torque), then it must change the existing ECM program
to the appropriate CCT-identified program. The ECM programs, often
referred to by DDC as certification word codes (CWC), are listed in
letters from JM dated August 19 and September 28, 1998, from Johnson
Matthey to EPA.
The CCT kit is certified to a PM emission level of 0.10 g/bhp-hr
for all 1985 through 1993 DDC 6V92TA DDEC I and II urban bus engines
using either diesel fuel #1 or #2 (including engines originally
certified, or rebuilt, to meet California emissions standards). Table 3
lists the applicable engine models and certification levels associated
with the certification announced in today's Federal Register.
Table 3.--Certification Levels
------------------------------------------------------------------------
Applicable models \1\ Engine code Certified PM Level
------------------------------------------------------------------------
1985-1993 Detroit Diesel ALL (including those 0.10 g/bhp-hr
6V92TA DDEC I and II rated certified or
at 253 or 277 hp. rebuilt to meet
California or 50-
state emissions
standards).
------------------------------------------------------------------------
\1\ Conditional certification applies to most engines. See discussion in
sections I and IV.
II. Summary and Analysis of Comments
Comments were received from three parties in response to the
Federal Register notice of May 14, 1998 (63 FR 26795): Detroit Diesel
Corporation (DDC), Engelhard Corporation (Engelhard), and Chicago
Transit Authority (CTA). DDC is the original manufacturer of the
engines to which the CCT kit applies, and also supplies equipment
certified to meet the 0.10 g/bhp-hr PM standard under the urban bus
program for these engines. Engelhard has certified several kits under
the Urban Bus Rebuild Program, including the ETX-2002TM
Emissions Rebuild Kit applicable to 1988 through 1998 model year 6V92TA
DDEC II engines. Certification of the ETX kit triggers the requirement
on affected operators to use equipment certified to the 0.10 g/bhp-hr
standard when 1988-1993 DDC DDEC II engines are rebuilt or replaced
after March 22, 1999. (This is discussed further below in section V.)
CTA is a transit operator of an urban bus fleet in an area to which the
Urban Bus Rebuild Requirements apply.
DDC states that it is concerned with the equipment which is
proposed to be certified because it not only involves the addition of
an after-treatment device, but it modifies many of the critical
internal engine components and creates combinations of internal
components for which DDC has no experience. Engelhard states that it
has significant concerns with the ability of the CCT to meet the 0.10
g/bhp-hr standard, and that the kit should not be certified until JM
has provided sufficient data and valid responses to all questions and
concerns. As discussed below in this section relative to prominent
comments, EPA believes that JM has satisfied the requirements necessary
for certification of the CCT kit for applicable DDEC engines.
Comments and issues generally fell into the following categories:
(a) Equipment identification and specification; (b) engine rating; (c)
emissions and testing; (d) durability and in-service concerns; (e)
installation and maintenance instructions; (f) catalyst checking
procedure; (g) components of the kit; and, (h) life cycle cost. These
are discussed below. Copies of the complete comments and other
documentation are available in the public docket, which is located at
the address stated above.
a. Equipment Identification and Specification
DDC comments that it is their understanding that the purpose of the
offset key is to advance fuel injection timing at all operating
conditions compared to the standard DDC timing. However, based on the
description in the JM installation guide, DDC believes that the timing
offset will be in the retard direction. In response, JM states that the
procedure as written will accomplish the intent to retard the injection
timing.
DDC also notes several other clarifications relating to the JM. DDC
notes that JM application erroneously states that the original coach
engine cylinder liner had a 0.95 inch inlet port. Actually, the 0.95
inch liner was used only for the 1985 through 1989 model years. DDC
also notes that DDC does not supply the special engine camshafts or
0.015 offset key as stated in the application.
In response, JM revises its statements to clarify these points
consistent with DDC statements. Additionally, JM states that the
positioning of the offset key is to retard, not advance, the fuel
injection timing.
Engelhard comments that the JM certification engine was installed
with DDC's ECM program number 483, which is a program that DDC
developed for certain engines originally equipped with exhaust traps
and subsequently converted to catalytic converter/mufflers under an
agreement with EPA in 1994. Engelhard notes that some of the programs
specified by JM for the CCT kit are not the same type of program as the
one used for certification. All of the programs in the CCT kit parts
list for use with diesel fuel #2 are ``trap replacement'' programs, but
the programs for diesel fuel #1 are ``standard'' ECM programs. (EPA
notes that the ``standard'' programs to which Engelhard refers are DDC
programs with which the 1991 through 1993 model year 6V92TA urban bus
engine families were certified under EPA's new engine certification
program.) Engelhard states that additional information and data are
need to justify the request for certification using ECM programs for
diesel fuel #1. Engelhard states that the CCT kit, without additional
information, should not be certified for diesel fuel #1. Also, since
the certification engines used an ECM program for trap replacement, all
versions of the CCT kit
[[Page 66801]]
must use that type of program to meet 0.10 g/bhp-hr.
In its letter dated September 28, JM presents emissions data from
testing the CCT kit using diesel fuel #1 with an ECM program that DDC
developed for use with 1991 through 1993 6V92TA DDEC II coach engines
operating on diesel fuel #1. That data acceptably demonstrates
compliance with the 0.10 g/bhp-hr PM standard. The data is listed in
summary Table 1.
b. Engine Rating
DDC comments that the CCT kit appears to be incompletely specified,
because JM did not specify ECM programs that are compatible with the
original DDC 253 horsepower (hp) ``low-torque'' rating. DDC said that
this could be a significant problem for some bus installations where
the increase torque would exceed drive-line or cooling system
capabilities.
In its letter to EPA dated August 19, 1998, JM noted that the
original certification package was for the high-torque only, stated
that its intent is to offer CCT kits for both high and low torque
ratings, and provided an updated list of ECM programs for the kit which
provides for both low and high torque versions of the 253 hp rating.
EPA is certifying these because the certification test data provided by
JM is determined, at least on torque rating, to be a worse-case test
engine.
c. Emissions and Testing
DDC comments that the certification testing presented by JM does
not represent worst case PM emissions because the test engine was not
set to the worst-case idle speed. DDC states that the effects of
turbocharger lag become more significant and FTP particulate emissions
increase as idle speed is reduced, and that certification testing
should be conducted with the minimum idle speed setting in order to
demonstrate ``worst case'' PM emissions. The JM application shows that
the certification testing was conducted with the engine idle speed set
to 700 rpm, even though DDC originally certified and routinely supplied
6V92TA DDEC engines with a minimum idle speed of 600 rpm. DDC states
that certification should be limited to engines with idle speed
settings of 700 rpm and above unless JM provides FTP data demonstrating
compliance with the 0.10 g/bhp-hr standard when tested with idle speed
settings below 700 rpm.
In its letter dated September 2, 1998, responding to concerns about
the idle speed, JM states that use of the 700 rpm idle setting for its
certification testing was an oversight. When the ECM program was
downloaded into the ECM module, the idle setting was not reset to 600
rpm, but rather it remained at 700 rpm. JM conducted additional
testing, discussed further below, to determine whether the idle speed
would affect the PM level.
The idle speed specified in DDC's application for new engine
certification for the 1991 through 1993 model year 6V92TA DDEC II
engines is listed as 600 rpm (minimum). Additionally, EPA notes that
idle speed on DDEC engines can be programmed in the field with a DDEC
basic code reader. No data has been provided to show how significant
idle speed is with respect to particulate emissions, what fraction of
new engines were supplied with the 600 rpm idle, or how prevalent the
600 rpm idle is in-service. It is not clear that there will not be a
significant PM difference resulting from idle settings of 600 and 700
rpm, and EPA believes that the JM test condition with idle speed set to
700 rpm is reasonably close to 600 rpm. The idle speed of 700 rpm also
complies with the DDC specification. In its September 2 letter, JM
presents data from additional transient testing that it conducted to
determine whether the PM level would be affected by the 600 versus 700
rpm idle setting. While there are concerns with details of this
testing, it indicates minimal to no emissions impact resulting from a
change from 600 to 700 idle rpm. For the above reasons, EPA is not
limiting certification to idle settings of 700 rpm and above, and is
not requiring JM to retest at a lower idle rpm.
Engelhard comments that the JM baseline engine, showing a PM level
of 0.19 g/bhp-hr, is unrepresentative of the typical performance for a
1991 6V92TA DDEC engine, and provides emissions from one DDC test and
several Engelhard tests with PM results between 0.22 and 0.28 g/bhp-hr.
Engelhard questions whether the components utilized in the
certification test engine provided superior emissions performance
compared to typical parts. The low baseline emissions raises concerns
about the CCT kit's ability to meet the 0.10 g/bhp-hr standard when
used with typical engine parts. Engelhard states that JM needs to
provide a complete explanation of the rebuild process, and submit test
data on a baseline engine that has normal PM emissions.
In response, JM states that no exceptional steps were taken in
rebuilding this baseline engine. No exceptional steps were taken in
rebuilding the engine--it was rebuilt using standard DDC engine parts
in accordance with recommended DDC rebuild procedures. Some of the
parts used in the certification test engine were also used in the
baseline test engine because the parts are common to both the CCT kit
and typical 1992 DDEC engine. Further, JM notes that there can be
tremendous variations in emissions from engine to engine. As JM states
in its letter to EPA dated September 28, 1998, after the certification
test the test engine had the cylinder kits, camshafts, ECM program and
offset key changed to the baseline configuration for the baseline test.
The baseline test engine shared fuel injectors, turbocharger, blower
and bypass valve, and cylinder heads, with the certification test
engine.
EPA has not determined that the JM baseline PM emission level is
atypically low. Other data developed for use in certifying equipment
under the urban bus program has shown PM emissions from DDEC II engines
that compare with the JM baseline. The 6V92TA DDEC II engine tested at
Southwest Research Institute (SwRI) for the National Biodiesel Board on
August 24, 1994 (test BL-2D) showed baseline engine PM emissions of
0.20 g/bhp-hr. The 6V92TA DDEC II engine tested at SwRI for Engine
Control Systems on October 25, 1995 (test E1025) showed baseline
emissions of 0.18 g/bhp-hr. EPA also notes that the DDC data, cited by
Engelhard having PM emissions of 0.218 g/bhp-hr (provided by DDC for
certification of DDC's 25 percent DDEC II upgrade kit) was conducted
using diesel #2 fuel having sulfur content between 0.08 and 0.12 weight
percent. On the other hand, testing for the urban bus program is
required pursuant to 85.1406 to use diesel fuel having a maximum of
0.05 weight percent sulfur. While we have not quantified the effect of
sulfur reduction in diesel fuel on PM emissions from 6V92TA DDEC
engines, in the final rule reducing the sulfur level of diesel fuel (55
FR 34121; August 21, 1990), EPA notes that reductions in fuel sulfur
result in small reductions in engine-out particulate. Additionally, as
shown in Table 1 above, the baseline 1988 model year 6V92TA DDEC II
engine tested at SwRI for Johnson Matthey on March 5, 1997 showed PM
emissions of 0.15 g/bhp-hr.
In addition, in its letter to EPA dated September 28, 1998 JM
provides emission data in support of its demonstration that the CCT kit
will comply with the 0.10 g/bhp-hr standard, albeit not the 5.0 g/bhp-
hr NOX standard. This data indicates compliance with the
0.10 g/bhp-hr PM standard on an engine equipped with offset key 0.010
inch (not the specification for the offset key of the
[[Page 66802]]
certified CCT kit of today's Federal Register notice) and emitting 5.8
g/bhp-hr NOX.
The JM baseline data is lower than that produced by Engelhard.
However, EPA does not conclude, from the available data, that the JM
baseline is atypically low or unrepresentative. If it is atypically
low, then it is not clear whether it is the result of test-to-test
variability, and/or engine-to-engine variability. The available
baseline test data are limited in number. If the JM baseline test is
low, then the level might be attributable to the cylinder liners that
were changed before the test conducted on the JM 1991 model year
baseline engine. EPA is not denying certification because of the PM
level of the JM baseline engine.
EPA notes that the JM baseline testing was conducted after the
certification testing and, while the data is low compared with the
Engelhard baseline tests, there is no regulatory requirement to provide
baseline data to demonstrate compliance with the 0.10 g/bhp-hr standard
when life cycle cost information is not provided. The availability of
the baseline data conducted for JM and others, may benefit bus
operators that are interested in the fuel consumption impact of the
certified equipment. EPA appreciates that JM conducted and provided the
baseline data, when it may not have been required in accordance with
the regulations.
Engelhard notes that the CCT kit operates on the principle of
camshaft induced EGR and injection timing advance, that EPA is
currently investigating electronically controlled engines for increased
``off-cycle'' NOX emissions, and asks whether the JM
camshafts and injection timing advance will irritate this situation. In
response, JM states that the CCT kit uses mechanical means to reduce
NOX and PM along with specific ECM programming, and the PM
level is then further reduced by the CEM II catalytic muffler. JM
points out that the offset key retards the injection timing for
reducing NOX emissions and, if there is an effect, it will
be to reduce off-cycle NOX emissions. EPA believes that,
generally speaking, injection retard would tend to decrease
NOX emissions.
Engelhard comments that the converter muffler for the CCT kit had a
reading of over 4 inches of mercury during a smoke test, and asks
whether that level is typical for a JM converter muffler.
JM states that the CEM and CEM II catalytic exhaust mufflers are
designed to function with the DDC specified back-pressure limits during
normal transit operation. The exhaust back-pressure reading that
Engelhard refers to during the smoke test is a function of the test
itself, and has no relation to the back-pressure observed during normal
transit bus operation.
EPA notes that the smoke test should be conducted in accordance
with 40 CFR Part 86 Subpart I. Section 86.884-8(c) of that subpart
states: ``The smoke exhaust system shall present an exhaust back-
pressure within 0.2 inch Hg of the upper limit at maximum
rated horsepower, as established by the engine manufacturer in his
sales and service literature for vehicle application.'' EPA believes
that the test data presented by JM for certification of the CCT kit was
collected under a worst case test condition for smoke generation.
d. Durability and In-service Concerns
DDC comments that there is insufficient information in the JM
notification to assess performance and durability impacts. DDC notes
that the CCT kit includes proprietary camshafts that reduce engine
airflow and cylinder scavenging, 15:1 compression ratio piston domes
instead of the 17:1 domes used by DDC, and an offset key that modifies
the injection timing compared with the DDC design. DDC has no
experience with the kit's combination of components and that it
represents a substantial departure from DDC's original design which
could have significant effects on engine performance and durability.
DDC refers to the possibility of reduced engine airflow and cylinder
scavenging, raised cylinder temperatures, degraded cylinder component
life, difficult cold starting, and increased cold smoke and noise
emissions. DDC believes that EPA should consider performance and
durability before certifying equipment.
Engelhard also comments that JM has specified a piston dome that
provides 15:1 compression ratio, and asks whether JM has conducted
testing to verify that a 2-point reduction in compression ratio will
not cause starting and operational problems in cold weather.
In response, JM notes that it has had a CCT kit in trial on a 6V92
DDEC bus in New York state since June 1997 with no problems, including
no cold weather starting problems. Also, JM points out that the same
type of system (proprietary cams, specified engine parts, and CEM
catalytic muffler) has already been certified by EPA for 6V92 MUI
engines, and a significant number of the kits have been installed, are
running well, and have operated during this past winter in cold weather
with no cold start problems. Based on this record, JM states that
performance and durability are not issues.
EPA notes that the urban bus retrofit/rebuild regulations do not
require a durability demonstration as a condition of certification.
Rather, equipment certifiers, including Engelhard, are required
pursuant to 40 CFR Section 85.1409 to provide a 100,000 mile equipment
defect warranty and a 150,000 mile emissions performance warranty. The
available information does not indicate a performance or durability
concern with the equipment certified in today's notice.
CTA comments that durability problems are a big concern to it, and
states that this issue must be addressed prior to certification,
because of ``excessive'' failures of certified catalytic converters on
retrofit/rebuilt engines. This is especially important when internal
engine components are replaced. CTA states that there are no
requirements for durability, and notes EPA's authority to decertify
equipment that fail to meet program requirements. However, CTA states
that this does not address the concerns of transit operators that have
spent substantial amounts of money on kits, and would not get
reimbursed for the cost of ``decertified'' kits.
CTA also has a couple comments about warranties. First, the
warranty does not cover the labor and consequential damage due to use
of a kit. CTA believes that warranty repair is not part of normal
maintenance and should not be the responsibility of the transit
operator. Second, CTA has had ``negative'' experience with warranty on
certified catalytic converters--failures are being replaced with brand
new units that are warranted only for the balance of the warranty
period for the original unit.
EPA notes that, while the program does not require a demonstration
of durability, JM has provided information on its in-service experience
with the CCT kit. As discussed in a previous paragraph, JM has had a
DDEC CCT kit in trial on a bus in New York State and a significant
number of MUI CCT kits have been installed. JM states that performance
and durability are not issues.
Additionally, CTA is incorrect in presuming that the program has no
durability requirements. The program regulations at 40 CFR 85.1409
require that certifiers provide both an emissions defect warranty for
100,000 miles, and an emissions performance warranty for 150,000 miles.
Under the performance warranty, certifiers are responsible for the in-
use performance of their
[[Page 66803]]
equipment for 150,000 miles. (Additional discussion on the emissions
performance warranty can be found in the preamble to the final rule of
April 21, 1993 at 58 FR 21359.) Under the defect warranty, certifiers
are responsible for replacing defective parts of a certified kit, free
of charge. CTA has not identified any problematic catalytic converters
or any situations in which warranty claims were denied by an equipment
certifier.
EPA appreciates that transit operators are concerned with the
durability of retrofit/rebuild equipment. When internal engines
components are supplied as part of a certified kit, those parts are
covered by the defect warranty for 100,000 miles.
As noted previously, the urban bus rebuild regulations do not
require an in-service durability demonstration as a condition of
certification. Rather, the regulations require equipment certifiers,
including Johnson Matthey, to warranty their equipment. EPA believes
that equipment suppliers will evaluate the durability of their
equipment in order to minimize their liability resulting from the
emissions defect and performance warranties. The available information
does not indicate a performance or durability concern with the
equipment certified in today's notice, and therefore, does not provide
sufficient basis to deny certification on these grounds. EPA will
continue to monitor problems with this, and other certified equipment,
and encourages transit operators to provide specific detailed
information regarding excessive in-service problems with certified
equipment.
CTA is correct that the defect warranty does not cover labor and
consequential damage to use of a kit. As noted in the preamble to the
final rule (April 21, 1993; 58 FR 21381), transit operators are
responsible for proper installation and maintenance of certified
equipment, and are responsible for the emissions performance of
equipment operated beyond the 150,000 miles emissions warranty period.
Additionally, as CTA has noted, the program warranty does not require
coverage of ``secondary'' or ``consequential'' damage due to use of
certified equipment.
With regard to CTA's concern with an extended warranty for
equipment replaced under warranty, the program requires that coverage
extend for the warranty period of the initially-purchased equipment.
There is no program requirement that a warranty period be extended
beyond the period of the initially-purchased kit, even when an original
unit is replaced with a brand-new one under the warranty. In other
words, only one warranty period accompanies each kit purchase,
regardless of how many times parts may be replaced under that warranty.
JM responds that it takes its warranty obligations very seriously,
and is their practice to work with any transit that has a warranty
claim, to identify and correct any problems with Johnson Matthey-
supplied equipment.
CTA notes that they have no way to determine whether a catalyst is
continuing to function as designed and, in some cases involving
warranty, CTA suspects the catalyst has lost ability to reduce
emissions due to the physical deterioration of the catalyst.
EPA currently knows of no method that is readily available to
transit operators for accurately testing PM performance of a catalyst
in the field. However, to the extent a catalyst is mechanically
clogging, use of the defect warranty may be an appropriate remedy.
e. Installation and Maintenance Instructions
Engelhard notes that JM requires that a DDEC data reader be used to
determine the current ECM program, and asks several questions: (1) Do
transits have the data reader; (2) how much will it cost; (3) is JM
required to provide the ECM re-programming; (4) how will JM verify that
the correct program is used; (5) is the cost of the re-programming
included with the CCT kit price; and, (6) why does JM specify ``non-
trap'' (that is, ``standard'') ECM programs for use with diesel fuel #1
when a ``trap-replacement'' program was used for certification?
JM responds that if a transit operator does not have a data reader,
then JM authorized distributors have the capability to read the ECM
program number. The proper ECM program will be downloaded by authorized
DDC distributors. The proper ECM number will be confirmed by submittal
of the warranty card for the CCT kit.
EPA notes that JM will include ECM reprogramming, if it is
necessary, with the purchase price of the kit. As Engelhard notes, JM
specifies the particular ECM programs to be used with diesel fuel #1.
The specified programs are consistent with what JM tested to
demonstrate compliance with the 0.10 g/bhp-hr standard when diesel fuel
#1 is used.
Additionally, EPA has authority to conduct audits of transit
operators to determine compliance with the Urban Bus Rebuild
Requirements. During such audits, EPA has authority to review actual
bus engines, documentation, and records to determine whether certified
kits have been properly installed in bus engines. EPA may check ECMs to
verify whether or not the correct ECM program is installed.
Engelhard comments that the JM application lists the kit as
applicable to DDEC 1 engines. Engelhard understands that the DDEC I
version differs significantly from the DDEC II and will require
significant changes to the ECM and sensors for upgrading to a DDEC II
configuration. JM must provide full explanation of the changes required
to upgrade this engine, plus life cycle cost information.
EPA notes that life cycle cost information is required only when
equipment is certified as a trigger of a particular emissions standard.
Because JM does not intend to trigger the 0.10 g/bhp-hr standard, life
cycle cost information is not required. A list of parts required for
conversion of DDEC I engines to DDEC II is provided by JM in its letter
to EPA dated September 28.
Engelhard provided multiple comments concerning JM's Installation
Guidelines: First, Engelhard states several questions relating to
identification marks that JM places on parts of the CCT kit. Engelhard
asks where the marks on the parts are located, whether the marks will
wear off, whether the warranty will be voided if the marks wear off,
and, how JM will verify that parts have the mark.
In response, JM states that their identification mark is a non-
intrusive, harmless mark that is placed on a non-critical surface. The
intent of marking the parts is to ensure compliance with use of all the
correct parts and to minimize warranty issues regarding use of the
parts. Piston rings are marked with an indelible paint, while other
parts are etched. The marks do not come off during normal operation.
EPA notes that the program regulations are silent with regard to
marking parts of a kit, but that the bus operator is responsible for
the correct installation of certified kits.
Second, Engelhard comments that the JM Installation Guide states
that piston gauge J-2539-A cannot be used with the CCT kit, and asks
which gauge should be used.
In response, JM states that neither DDC nor Kent Moore supply a
gauge to identify the 15:1 compression-ratio pistons of the CCT kit.
The statement in the Installation Guide is intended as a caution to
installers against use of piston gauge J-2539-A with the 15:1 pistons,
because that gauge is limited to identifying 17:1 or 19:1 pistons. If
for any reason the engine is being rebuilt, the 15:1 mark on the piston
crown would be covered with soot, and use of the piston gauge J-2539-A
would be misleading.
[[Page 66804]]
Finally, Engelhard questions why the Installation guide requires
that an installer ``thoroughly inspect the camshaft for any
contamination in the passage through the cam''. JM needs to provide
guidance for this procedure and an estimation of how long it will take.
JM responds that, while it does not expect any contamination to be
present, issues with handling or storage could result in contamination.
The inspection will take a few minutes and, if cleaning is necessary,
it can be done in a few minutes with standard cleaners.
f. Catalyst Checking Procedure
DDC opposes the procedure recommended by JM for determining whether
the catalyst unit requires cleaning.
JM's instructions involve operating the engine at full load, wide
open throttle or at full stall, and measuring the exhaust pressure at
the pressure tap located on the manifold immediately after the engine.
In the CEM II clean-out procedure it is noted that a pressure
measurement gage should be installed ``in the pressure tap located on
the inlet side of the CEM II''.
DDC, however, contends that back-pressure should be measured just
downstream of the turbocharger outlet. DDC states that its back-
pressure limits apply at all engine operating conditions and should be
checked at the maximum exhaust flow condition (rated engine speed and
full load). DDC states that neither of JM's alternative test conditions
(full load, wide open throttle or, full stall) are adequate. ``Full
load, wide open throttle'' is an ambiguous condition, and ``full
stall'' is inadequate because it does not produce a maximum exhaust
flow condition. An exhaust system which just meets DDC's specified back
pressure limit at WOT, no load (which can be how the JM procedure is
conducted) will likely exceed the DDC limit over a large portion of the
engine speed/load operating map and thus would be in violation of DDC's
guidelines. Excessive back pressure results in fuel economy and power
losses, and raises cylinder temperatures and increases soot build-up in
the lubricating oil. These effects can reduce engine life.
JM states that it stands by its CEM II back-pressure procedure, and
notes that it is the same procedure that DDC recommends using in its
own 0.10 DDEC kit.
EPA is not requiring JM to revise the screening procedure, for
several reasons. First, and in general, the program regulations do not
require any specific check procedures for any components of certified
kits. Second, EPA notes that the maximum exhaust back pressure
specification for several engine calibrations (codes) of the 6V92TA
DDEC II engines is 4.0 inches of mercury (as specified in DDC's
application for certification of 1991 and 1992 6V92TA DDEC engines
under EPA's new engine certification program), and that the back
pressure specification for the JM procedure is 3.0 inches of mercury.
Third, the JM procedure is intended as a ``screen'' to determine
whether a catalyst muffler needs cleaning, not to measure exhaust back
pressure for comparison with DDC's maximum specifications. For
additional discussion of the issue, refer to page 12177 of the Federal
Register notice describing certification of Engelhard's ETX kit for
6V92TA MUI engines (62 FR 12166; March 14, 1997.
Any future information provided by interested parties regarding the
impacts of certified equipment on exhaust back pressure would be taken
under consideration. EPA appreciates that there may room for
improvement in maintenance procedures of equipment certified under this
program. Such concerns, in general, can also occur with procedures
relating to new engines. EPA encourages all equipment certifiers to
issue revised check procedures when appropriate. If JM determines that
another check is appropriate, or if EPA becomes aware that back
pressure is exceeding manufacturer limits on in-use buses, then JM
should revise such procedures. Pursuant to 40 CFR Section 85.1413, EPA
has authority to decertify equipment that does not comply with the
requirements of the regulations.
g. Components of the Kit
CTA notes that the CCT kit replaces all ``emissions-related''
parts, many of which are standard DDC parts, and asks whether these
parts are required to be purchased through JM, or whether the standard
parts can be purchased elsewhere.
As described above, JM requested to supply the CCT kit to
installers under different supply options. EPA approves two options of
supply, in order to provide as much flexibility to transit operators as
possible while assuring emissions reductions. At JM's option, either
option can be made available, because this certification does not
trigger program requirements. For the first supply option, transit
operators purchase the entire CCT kit from JM or its distributors. For
the second option, transit operators purchase all of the unique parts
of the kit from JM, and acquire the non-unique DDC engine parts
specified by JM through sources of its own choosing. Both supply
options must provide all parts which are unique to a standard rebuild
for the particular engine to be rebuilt. Parts which would typically be
acquired by an installer for a standard rebuild of a particular model
year engine are not required to be part of the CCT kit under supply
option 2. The specified parts must be acquired by the transit operator.
Aftermarket parts are not permitted for the specified parts of the
CCT kit under the certification described today. Because the
certification testing was conducted on an engine equipped with DDC
components, EPA has no assurance that an engine equipped with other
parts can achieve the 0.10 g/bhp-hr PM standard. JM is required to
provide the applicable 100,000 mile emissions defect warranty and the
150,000 mile emissions performance warranty for all parts of the kit
which it supplies to the transit operator.
The CCT kit includes a list of the specific engine rebuild parts
that are required to be used upon engine rebuild with the CCT kit. EPA
notes that in accordance with 85.1404, operators are required to
maintain records of all parts used in rebuilds. Using incorrect
components with the CCT kit at the time of kit installation can be
considered as failure to install a certified kit under the urban bus
rebuild requirements, and subject the operator to the significant
penalties provided by the regulation.
h. Life Cycle Cost
Engelhard comments that JM has not provided a life cycle cost
analysis to justify their certification. EPA notes that life cycle cost
information is not required for certification of equipment which would
not trigger a standard.
Chicago Transit Authority (CTA) understands that certification of
the CCT kit will not trigger program requirements, but comments that
life cycle costs are very important. CTA asks what the kit will cost.
JM responds that it currently is not able to provide a list price
for the DDEC CCT kit, but will provide CTA with a list price as soon as
possible.
CTA asks whether data is available on the emissions, fuel economy,
and exhaust back-pressure for the 253 Hp rating. Back-pressure, fuel
economy, and oil life appear to be affected by some catalytic converter
installations which can affect engine life and operating costs.
In response, JM states that its certification, based on testing the
highest power rating (277 Hp) on diesel fuel #2, covers 253 Hp engines
and both diesel fuels #1 and #2. EPA notes that JM provided data from
testing using
[[Page 66805]]
diesel fuel #1, but has not provided any data on the 253 Hp rating.
Engelhard comments that JM does not include information on the fuel
economy impact of installing the CCT kit, and that this type of
information is essential for a transit operator to make a complete
evaluation of the kit. In analysis that Engelhard performs, it notes
that the CCT kit uses 0.489 pounds of fuel per brake-horsepower-hour
(lb/bhp-hr), compared to 0.483 lb/bhp-hr for a 1991 model year baseline
engine tested by JM. This is a 1.2 percent fuel economy penalty for
1991-1993 DDEC engines. Furthermore, JM's baseline data for a 1988
federal engine shows a fuel consumption of 0.459 lb/bhp-hr, which
translates into a 6.5 percent fuel penalty if the CCT kit is installed
on a 1988 to 1990 engine. Engelhard also asks about the fuel
consumption impact of the CCT kit on DDEC 1 engines.
In response, JM states that it has not applied as a trigger
technology for the 0.10 g/bhp-hr standard. JM notes that it has placed
in the public docket, baseline data for 1991-1993 and 1988-1990 model
year engines.
In general, EPA agrees that the impact of a kit on fuel consumption
would be of interest to transit operators. However, fuel consumption
data is not required for equipment which would not trigger a standard.
The availability of the baseline data conducted for JM and others, as
discussed in a section above, may benefit bus operators that are
interested in the fuel consumption impact of the certified equipment.
EPA appreciates that JM conducted and provided the baseline data.
III. California Engines
The NOX emission standard for new engine certification
applicable to 1988 through 1990 model year engines sold in the State of
California is 6.0 g/bhp-hr. For 1991 through 1993, the standard is 5.0
g/bhp-hr. The emissions testing presented by Johnson Matthey
demonstrate a NOX emissions level that complies with the 5.0
g/bhp-hr standard. Therefore, today's description of the CCT kit for
DDEC II engines applies to engines certified to meet California
emissions standards, subject to the conditions discussed below.
The equipment certified today may require additional review by the
California Air Resources Board (CARB) before use in the State of
California. EPA recognizes that special situations may exist in
California that are reflected in the unique emissions standards, engine
calibrations, and fuel specifications of the State. While requirements
of the federal urban bus program apply to several metropolitan areas in
California, EPA understands the view of CARB that equipment certified
under the urban bus program, to be used in California, must be provided
with an executive order exempting it from the anti-tampering
prohibitions of that State. Parties interested in additional
information should contact the Aftermarket Part Section of CARB, at
(626) 575-6848.
IV. Certification and Conditional Certification
EPA has reviewed this notification, along with comments received
from interested parties, and finds the equipment described in this
notification of intent to certify:
(1) Complies with a particulate matter emissions standard of 0.10
g/bhp-hr, without causing the applicable engine families to exceed
other applicable emission requirements, subject to the conditions
discussed below;
(2) Will not cause an unreasonable risk to the public health,
welfare or safety;
(3) Will not result in any additional range of parameter
adjustability; and
(4) Meets other requirements necessary for certification under the
Urban Bus Rebuild Requirements (40 CFR Sections 85.1401 through
85.1415).
With the following conditions, EPA hereby certifies this equipment
for use in the Urban Bus Retrofit/Rebuild Program. As noted above, the
equipment being certified today includes for some engines, an upgraded
control program for the electronic control module. EPA has recently
become concerned that many electronically controlled engines may have
been equipped by the original manufacturers with strategies designed to
decrease fuel consumption during certain driving modes not
substantially included in the federal test procedure, with the effect
of substantially increasing NOX during these modes. Such
electronic control strategies have the potential to be ``defeat
devices'' as defined at 40 CFR 86.094-22, and thus may violate 40 CFR
85.1406 and 85.1408 if included in an urban bus retrofit application.
Most of the upgraded control programs used for the CCT kit must
therefore be reviewed for such violations. As a result, certification
of the CCT kit, as it applies to the following engines is conditioned
upon Johnson Matthey demonstrating by January 1, 1999 that any
replacement engine control module (ECM) or ECM program used in
conjunction with the certified kit will not adversely impact the
emissions of NOX in comparison to the ECM or ECM program
that is being replaced under conditions which may reasonably be
expected to be encountered in normal vehicle operation and use unless
such conditions are substantially included in the Federal emission test
procedure. Certification is conditional as it applies to all applicable
engines of model years 1985 through 1990, and all applicable engines of
model years 1991 through 1993 that are not equipped with ECM programs
#259 through #264 for kit operation on diesel fuel #1.
The equipment, the CCTTM Upgrade Kit, may be used
immediately by transit operators in compliance with requirements of
this program, subject to the above condition. Unconditional
certification is provided for the CCT kit as it is applied to 1991
through 1993 model year engines that are equipped with ECM programs
#259, 260, 261, 262, 263, or 264, for operation on diesel fuel #1 after
kit installation.
V. Transit Operator Responsibilities
In a Federal Register notice dated September 21, 1998 (63 FR
50225), EPA announced certification of a retrofit/rebuild kit supplied
by the Engelhard Corporation (the ETXTM kit for DDEC
engines). That certification triggers the 0.10 g/bhp-hr PM standard for
1988 through 1993 model year DDC 6V92TA DDEC model engines, which 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
these engines after March 21, 1999.
Today's Federal Register notice announces certification of the
Johnson Matthey CCT Upgrade kit, when properly applied, as meeting the
0.10 g/bhp-hr particulate matter standard of the Urban Bus Rebuild
Program. Affected urban bus operators who choose to comply with
compliance program 1 are required to use this, or other equipment that
is certified to meet the 0.10 g/bhp-hr particulate matter standard for
1988 through 1993 model year DDC 6V92TA DDEC model engines which are
rebuilt or replaced on or after March 22, 1999, subject to the
condition of Section IV.
Urban bus operators who choose to comply with compliance program 2
may use the CCT equipment, and those that use this equipment may claim
the certification level from Table 3 when calculating their Fleet Level
Attained (FLA), subject to the condition of Section IV. 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.
Urban bus operators must be aware of their responsibility for
maintenance of
[[Page 66806]]
records pursuant to 40 CFR Sections 85.1403 through 85.1404. The CCT
kit may not include, depending upon the supply option selected and the
particular applicable engine, certain emissions-related parts that are
required to complete the CCT kit. As stated in the program regulations
(40 CFR 85.1401 through 85.1415), operators should maintain records for
each engine in their fleet to demonstrate that they are in compliance
with the Urban Bus Rebuild Requirements beginning on January 1, 1995.
These records include purchase records, receipts, and part numbers for
the parts and components used in the rebuilding of urban bus engines.
Urban bus operators must be able to demonstrate that all parts used in
the rebuilding of engines are in compliance with program requirements.
In other words, urban bus operators must be able to demonstrate that
all required components of the kit described in today's Federal
Register notice are installed on applicable engines.
Dated: November 24, 1998.
Robert Perciasepe,
Assistant Administrator for Air and Radiation.
[FR Doc. 98-32071 Filed 12-2-98; 8:45 am]
BILLING CODE 6560-50-P
