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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