EPA-AA-SDSB-80-10
Technical Report
Report Impact Analysis for the
Proposed Heavy-Duty Diesel Particulate Regulation
by
Daniel Reiser
August 1980
NOTICE
Technical Reports do not necessarily represent final EPA decisions
or positions. They are intended to present technical analysis of
issues using data which are currently available. The purpose in
the release of such reports is to facilitate the exchange of
technical information and to inform the public of technical deve-
lopments which may form the basis for a final EPA decision, posi-
tion or regulatory action.
Standards Development and Support Branch
Emission Control Technology Division
Office of Mobile Source Air Pollution Control
Office of Air, Noise and Radiation
U.S. Environmental Protection Agency
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Report Impact Analysis for the
Proposed Heavy-Duty Diesel Particulate Regulation
EPA is preparing to propose a particulate emission standard
for 1986 and later model year heavy-duty diesel vehicles. Under
Executive Order 12044, Improving Government Regulations, government
agencies must report new reporting burdens or recordkeeping re-
quirements before new significant regulations are adopted.^/ EPA
requires a "report impact analysis" to comply with Executive Order
12044.^/ This analysis has been performed in fulfillment of this
requirement. This report will examine the information already
required and determine the additional information that will have to
be submitted. Also to be addressed are the reasons for requesting
this additional information.
Most of the paperwork for heavy-duty diesel engine manufac-
turers at present is involved with certification and Selective
Enforcement Auditing (SEA). The promulgation of this particulate
regulation will add no new requirements to the heavy-duty diesel
engine manufacturers in these two areas. However, it will impact
the existing requirements somewhat. The certification requirements
will be discussed first as these are the primary cause of paperwork
for the heavy-duty diesel engine manufacturers.
Certification is the process in which EPA determines whether a
manufacturer's engine conforms to applicable regulations and can be
made available for sale. The engine manufacturers must demonstrate
that its engines are designed and will be built such that they are
capable of complying with the emission standards over their full
useful life. The certification process begins by a manufacturer
submitting to EPA an application for certification. A recommended
formal application of certification is sent to all manufacturers.^/
This formal application can be broken down into two parts. Part I
of this application is a declaration of the manufacturers intention
to certify his diesel engine, in conformance with 40 CFR Part 86.
Part II is a request for issuance of certificate of conformity.
Part I of this application will be discussed and analyzed first.
The Part I can be conveniently subdivided into two parts,
Subparts IA and IB. Subpart IA contains general information
relating to the applicant's facilities and product line. Subpart
IB contains specific information relating to the product line for a
particular model year. Only Subpart IA would be affected by this
particulate regulation, primarily because of the new test equipment
required, the new test procedures being implemented, and the new
emission controls being used. None of these three additions should
greatly impact the paperwork involved and only five sections out of
the twelve total sections require some additional paperwork. These
sections are: Section V, Facility and Test Procedure Description,
Section VI, General Technical Information, Section IX, Detailed
Specifications and to a lesser extent Section IV, Test Fuels, and
Section VII, Test Engine Maintenance. Each section will be
analyzed separately to determine the effect of a new particulate
regulation.
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In Section V, Facility and Test Procedure Description, manu-
facturers are presently required to submit narrative explanations
with schematic drawings and photographs, if applicable, on service
accumulation for gasoline-fueled engines, test equipment and
procedure, strip charts, and horsepower correction for diesel
engines. Only descriptions of the test equipment and test proce-
dure would be changed for a new particulate regulation. Currently,
manufacturers must decribe all of their test equipment and the
corresponding test procedure used for measuring gaseous emissions.
With this particulate regulation manufacturers would add descrip-
tions of a dilution tunnel, heat exchangers, and other related
particulate sampling instruments. Manufacturers would also need to
discuss the additions and modifications to the current test
procedure. In all, the additional test equipment and procedures
represent a small fraction of the existing equipment and proce-
dures. For example, the cost of an existing diesel test cell is
about $650,000 (1979 dollars),4/ while the cost of the modifica-
tions for particulate testing is about $34,000 per cell (1980
dollars) with an additional $33,000 per test facility (1980 dol-
lars). Also, the test procedures added for particulate testing
have increased the length of the overall test procedure by about 10
percent. Thus, while there is some additional paperwork involved
in Section V with a new particulate regulation it should be no more
than 10 percent of paper work already required.
In Section VI, General Information, manufacturers must provide
general technical information regarding construction and operation
of various engine parts. Emission control systems are among these
engine parts. EPA requires that discussions with sketches and
cross-sectional views should be provided to adequately present the
necessary information. It is expected that manufacturers would
incorporate a trap-oxidizer system to meet the particulate stan-
dard. This would necessitate discussions, sketches, and cross-
sectional views for some or all of its components. However, this
additional requirement should not be more than about 10 percent of
the information already required for existing engine parts such as
governors, turbochargers, aftercoolers, and smoke and gaseous
emission controls.
In Section IX, Detailed Specifications, the information that
is submitted determines how the applicant's product line is sub-
divided into separate engine families and provides the data which
are used by EPA to select the engines. In Section VI, General
Information, a manufacturer describes and discusses the operation
of emission controls that are common to all of his engine models.
However, in Section IX, the manufacturer lists the emission con-
trols used on each model as well as specifying the characteristics
of that emission control unit, such as dimensions, weight and
volume, material composition, and location in the engine. A
manufacturer usually provides a configuration of each component as
well as a scaled schematic of the whole emission control system.
To explain the general operation of a specific component, the
manufacturers may reference the General Information section. Once
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again, for a particulate regulation most of the additional paper-
work in this section would involve the trap-oxidizer system, and
should not be more than about 10 percent of descriptions already
required.
Section VII, Test Engine Maintenance, may also require some
additional work. A manufacturer must submit a statement of the
recommended maintenance and procedures that are necessary to assume
that the engines will conform to the regulations when in use. With
a new particulate regulation additional maintenance instruction
may have to be submitted for the trap-oxidizer system. A manufac-
turer may also have additional paperwork associated with Section
IV, Test Fuels, if a new test fuel is used. Both sections are
expected to have additional paperwork that would probably add up to
less than 5 percent of what is already required.
In summary, the most additional paperwork of Part I is con-
tained in Subpart IA and would probably be involved with Section
VI, General Information, Section IX, Detailed Specifications, and
Section V, Facility and Test Procedure Description. The additional
work required within these sections should be about 10 percent more
than present requirements. Some additional work is also necessary
for Sections IV and VII, Test Fuels and Test Engine Maintenance,
and this is only about 5 percent. The extra paperwork for Part I,
considering that at most 5 sections out of 12 total requires some
additional work in Subpart IA and that no additional work is
required in Subpart IB, would be roughly 3-5 percent of current
requirements. This should not be a burden to heavy-duty diesel
engine manufacturers.
Part II of the application for certification will also require
some additional paperwork, but to a much lesser extent than Part
I. Part II is the request for issuance of certificate. For a new
particulate regulation Part II most likely requires an additional
line or column wherever similar gaseous emission results are
currently listed. For example, a deterioration factor summary and
an emission data summary are required where manufacturers simply
list particulate results and perform calculations in the same
manner as for gaseous emissions. Manufacturers must also list the
particulate control hardware used in their engine to be certified,
but this is small and about one extra page of paperwork when
compared to other engine parts and control hardware that must
already be listed. Most additional work in Part II may involve the
writing of maintenance instructions which is provided to the
ultimate user, but again this should only amount to one or two
additional instructions compared to the list of instructions
currently submitted. The additional paperwork in Part II should be
very small and on the order of about 1-2 percent of what must
already be submitted. The total certification paperwork burden
would then be less than 2-5 percent of present paperwork require-
ments when Parts I and II are combined. Manufacturers should be
able to meet these extra requirements with little problem.
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Additional paperwork requirements for Selective Enforcement
Auditing (SEA) should also be small. The addition of a particulate
standard is not expected to increase the number of SEA tests
performed on heavy-duty diesels. These engines would have to be
audited for compliance with gaseous emissions in any event. Thus,
no additional paperwork could occur because of an increase in the
number of engines tested. As with certification, additional SEA
paperwork can be attributed to SEA requirements already estab-
lished. Preparation of SEA requires a description of test equip-
ment, engine components including emission control devices, engine
family distinction, and test data results.^/ It is estimated that
SEA paperwork additions over present requirements is roughly the
same as certification paperwork additions over present require-
ments, or less than 5 percent. Again, this should not greatly
impact diesel engine manufacturers.
While a heavy-duty diesel particulate standard should require
some additional paperwork for diesel engine manufacturers, it is
not expected that this paperwork should be more than 5 percent of
what is already required for preparation of certification and SEA.
Additional paperwork is necessary primarily for description of test
equipment, test procedure, emission control, and test engine
maintenance. A small amount of paperwork is also necessary for
particulate emission data and results. By the time a 1986 partic-
ulate standard becomes effective, most of the paperwork for prepar-
ation of certification and SEA will have already been completed.
Thus, the proposed heavy-duty diesel particulate standard for 1986
and later engine models should not be a burden to diesel engine
manufacturers.
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References
I/ "Improving Government Regulations" (Executive Order 12044), FR
~~ Vol. 43, No. 58, March 24, 1978, pp. 12661-12665.
2j "Improving Environmental Regulations," FR Vol. 44, No. 104,
~ May 29, 1979, pp. 30988-30998.
3J "The Preparation and Submission of Applications for Certifi-
cate of Conformity for New Gasoline-Fueled and Diesel Engines
for Use in Heavy-Duty Vehicles (Pursuant to 40 CFR Part 86),
1979 Model Year," Certification Division, OMSAPC, OANR, EPA.
47 "Selective Enforcement Auditing of New Gasoline-Fueled and
Diesel Heavy-Duty Engines," (Subpart K), FR Vol. 45, No. 14,
January 21, 1980, pp. 4170-4181.
5/ "Regulatory Analysis and Environmental Impact of Final Emis-
sion Regulations for 1984 and Later Model Year Heavy-Duty
Vehicles," OMSAPC, EPA, December 1979.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Aug. 12, 1980
Release of Report
FROM:
TO:
Daniel P. Reiser
Standards Development and Support Branch
Charles L. Gray, Jr., Director
Emission Control Technology Division
THRU: Richard A. Rykowski, Project Manager
Standards Development and Support Branch
The attached Technical Report has been prepared by SDSB and is now
submitted for your clearance. No formal distribution is planned.
The report will be placed in the docket for the proposed heavy-duty
diesel particulate regulation.
Number and Title
EPA-AA-SDSB-80-8, "Report Impact Analysis for the Proposed Heavy-
Duty Diesel Particulate Regulation."
Subject Matter
EPA requires a "report impact analysis" on the additional paperwork
burden to manufacturers before a new significant regulation is
promulgated. This analysis was prepared as a part of the Notice of
Proposed Rulemaking for the control of heavy-duty diesel particu-
late emissions. The additional paperwork that could occur was
examined for certification and Selective Enforcement Auditing (SEA)
requirements.
Conclusion
The promulgation of this particulate regulation will add no new
requirements to the heavy-duty diesel engine manufacturers in
certification and SEA, but will impact the existing requirements
somewhat. .It is expected that this paperwork should not be more
than 5 percent of what is already required. Thus, the proposed
standard for 1985 and later engine models should not be a burden to
diesel engine manufacturers.
Approved:
Charles L. Gray, ' Jr •'/ Dir-e€toV
Emission Control Technology Division
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'Date
EPA FORM 1320-6 (REV. 3-76)
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