EPA-AA-SDSB-84-2

                  Technical Report
  An Evaluation, of the Particulate Levels Occurring

 Under  1.0/1.2  g/mi NOx  standards  for LDDVs  and LDDTS
                         By

                   Rebecca Kanner


                      May 1984
                       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
developments  which may  form  the  basis  for  a  final  EPA
decision, position 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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I.   Introduction

     The  Diesel  Particulate Study  (DPS)[1]  examined  the level
of  NOx and  particulate  emissions  that  would  be  present  for
three  different  NOx  scenarios:  1)  l.f)/1.2  g/mi,  2)   1.5/1.7
g/mi,  and 3)  2.0/2.3  g/mi  NOx  standards  for LDDVs  and LDDTs,
respectively.  Chapter 1 of  the study estimated  the particulate
emission  level as  a  function of a changing  NOx  emission level.
This relationship  was based on the  certification  test  results
for  LDDVs and  LDDTs  from  1982  and  1983  model  years.   The
methodology   to   estimate   the  particulate  levels   will   be
described in the following section-.   The purpose of this report
is to  compare the  particulate  emissions estimated under the low
NOx  level (i.e.,   1.0/1.2  g/mi) to the actual  1984  California
and  50-state  certification  particulate   levels that   are  now
available at these low NOx levels.

     It   is  important  to  make  this  comparison  because  the
particulate emissions  at  low NOx emission levels  were based on
data at  higher  NOx levels.  Thus,  the derived  NOx/particulate
relationship  was   extrapolated  to obtain  the  low. NOx  levels.
The  1984  California  standard  is at  a  1.0/1.2  g/mi  NOx level,
allowing  the  opportunity  to  examine the particulate  emission
levels  of certified  LDDVs  and  LDDTs  at  these  NOx standards.
Without accurate estimates,  it is not  possible  to  project what
the  manufacturers'   corporate  average   particulate   standard
levels will be  with  a 1.0/1.2  g/mi NOx standard.   Nor will it
be possible to judge  just how  many vehicles  will require traps
for  this  scenario.  This  report will  examine  the  accuracy of
the estimates and  the resulting projections.

II.  Previous Methodology

     In order  to   estimate particulate  standard  levels under  a
NOx  standard  of  1.0  g/mi  for  LDDVs  and  1.2 g/mi  for  LDDTs,  a
NOx/particulate relationship was developed  through the use of
NOx/particulate  tradeoff  curves.   The  data  for  these curves
were supplied  by  1983 model  year  low mileage  levels.  (Test
results   from  1982  were  used when  1983   results  were  not
available.)   Light-duty diesel  vehicles were divided into three
categories  based   on   engine  size:    1) small  (1.6-4.3 liters
displacement), 2)  medium  (2.0   to  2.8  liters  displacement)  and
3) large  (3.0 to 5.7  liters  displacement).   The  tradeoff curves
for  these engine sizes resulted in three  respective slopes for
NOx  values  less  than  1.35  g/mi:   1)  -.033,  2) -.201,  and 3)
-.400 g/mi particulate/g/mi  NOx.  Light-duty diesel trucks were
divided into only  two  categories:   1) small  (1.6  to 2.5 liters
displacement), and 2)  full-size (6.2  liters  displacement).  The
slopes 'for  LDDTs   are  the same  as  for small  and  large LDDVs,
respectively.

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                              -2-

     The  low-mileage  LDDV particulate  and NOx  emission values
are  listed  in Table  1;  the  LDDT  data are -in Table  2.  These
values  were  projected  by using  the  known   1983  certification
emission  data  for  each  engine, family  and  the  appropriate
NOx/particulate  tradeoff  curve   slope   (applied  down  to  a
low-mileage NOx level of 0.90 g/mi).

     The  standard  levels  for both  NOx  and   particulates  were
determined by  multiplying  the  low-mileage  emission  levels  by
their  deterioration  factors  (DF) - and  the safety  factor.   The
deterioration  values  (DF) were  the  certification  DFs  for  the
1983 model year.   A safety  margin of  10  percent was  used  for
this  study.    The  estimated  LDDV particulate standard levels
under the 1.0  g/mi NOx standard are  listed in Table 3,  the LDDT
values are included in Table 4.

III. 1984 Certification Levels

     The  methodology  just  described  is  potentially  biased  in
its  accuracy  of  predicting  particulate  standard levels at  low
NOx  levels because the  emission  data that were used  in the  DPS
were 1983  certification  values  (i.e.,  emission values  under  a
1.5/2.3 g/mi  NOx  standard).  At  the  time of the  study, there
were no  other data  available,  nor  was  the  effect  technology
changes would  have on  the NOx/particulate  relationship known.
Since that time, the  1984 California standards of  1.0 g/mi  NOx
for LDDVs and  1.2 g/mi for some LDDTs have gone into effect and
the projections can be  evaluated.   It should  be  noted that  the
majority  of  the  LDDV  engine  families  that  were  certified
federally  in  1983  were  not  certified in 1984  in  California.
Only those 1983 federal engine families which had identical, or
nearly identical, 1984 California  counterparts were included in
this evaluation.

     The  certification  levels  were  obtained  from  the  1984
summary  sheets of  the  California  and 50-state  certification
applications.  The  actual emission  levels  listed  in  Tables  1
and  2  were calculated  by dividing  the certification  emission
levels by  their  DF's and  adjusting  for  the  10  percent safety
factor.

     It's difficult  to  make  a comparison of  these particulate
values to the  estimated particulate  emission  values because  the
actual  NOx   emission   levels  are   less   than  the    .9  g/mi
low-mileage  level  of a  1.0  g/mi  NOx  standard  for  LDDVs.   In
order  to  make  a  comparison it  was  necessary  to  adjust  the
actual emission  levels  so  that  the  NOx   low-mileage  level  was
also   equal   to   0.90   g/mi.    To   do   this,  ideally,   new
NOx/particulate  tradeoff  curves  should  be  plotted   and  new
slopes measured  from the  1984 emission  data.   This  procedure

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-3-
Table 1
Comparison of LDDV Low-Mileage,
Low-NOx, Particulate Emissions (g/mi)
Estimated - DPS
Mfr.
CM
GM
Isuzu
Isuzu
Mercedes
Benz
Nissan
Peugeot
Volks-
wagen
Volks-
wagen
Engine
Disp.
1.8L
4.3L
1.8L
1.8L
3.0L
1.7L
2.3L
1.6L
1.6L
ConfigU--
ration
M5,2500
L3*,3500
M5,2750
A3 ,2750
A4,4000
M5,2500
A3, 3500
M5,2250**
5A,2250
NOx
Test Level
.90
.90
.90
.90
.90
.90
.90
.90
.90
Particulate
Test Level
.18
.33
.19
.17
.51
.23
.32
.19-. 23
.18
Actual
NOx
Test Level
.56
.74
.72
.70
.80
.52
.69
.65-. 90
.87-. 9
Particulate
Test Level
.18
.26
.21
.24
.50
.23
.34
.13-. 28
.15-. 18
Volvo     2.4L  M4***3500       .90          .38         .65         .27
*    The transmission of the 1984 GM 4.3L is L4.
**   The inertia weight  of the 1984 1.6L, MS  Volkswagen varies
     from 2375-2500.
***  The transmission of the 1984 Volvo is L4.

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-4-
Table 2
Comparison of LDDT Low-Mileage,
Low-NOx, Particulate .Emissions (q/mi)
Estimated
Mfr.
GM
GM
Isuzu
Isuzu
Mitsu-
bishi
Mitsu-
bishi
Nissan
Toyota
Toyo-
Kogyo
Engine
Disp.
6.2L
6.2L
2.2L
2.2L
2.3L
2.3L
2.5L
2.4L
2.2L
Trans-
mission
L4
L4
M4
M5
M5
M5
M5
M5
M5
NOx
Test Level
1.08
1.08
1.08
1.08
1.08
1.08
1.08
1.08
1.08
Particulate
Test Level
.51
.53
.27
.26
.39
.37
.30
.27
.27
Actual
NOx Particulate
Test Level Test Level
1.16
1.60
.68
.76
.60
.70
.68
.68
.75
.46
.34
.28
.26
.30
.22
.16
.20
.14

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                              -5-

was  not  followed  because  there were  not  enough  data  points
available; the slopes from  the  1983  N0x/part"iculate curves were
used to, adjust the emission  levels.  The  particulate standard
levels under a 1.0  g/mi NOx standard were  calculated using the
1984 DFs and  the  safety  factors;  these  values are  listed  in
Table  3.  A  similar  procedure  was  followed   for   LDDTS;  the
results are listed in Table 4.

IV.  Comparison

     The  difference  between   the estimated  and  the  adjusted
actual LDDV  particulate standard levels  is listed  in  terms  of
percent  for  each engine  family  in  Table  3;  the  corresponding
percentages for LDDTs are  presented  in Table  4.  The estimated
LDDV particulate  levels  are  greater  than  the values  derived
from the  1984  low NOx data for all  but three  engine families.
The  range is  quite  large,  varying from  a  five  to a  fifty
percent  difference;  the  comparison  of  the   two   particulate
levels for LDDTs is similar.

     From  this analysis  it  is  clear  that  the  DPS generally
overestimated the  manufacturers' corporate  average  particulate
standard  levels at  low  NOx standards for both  LDDVs and LDDTs,
based  on  the  1983   standard   levels.   The  difference  is  an
average  of approximately  5  percent  for  LDDVs  and  nearly  25
percent  for  LDDTs.   For LDDTs,  the  differences   occur  nearly
entirely  with  small  LDDTs.   (The projection  for  the GM  6.2L
engine  was  very   accurate.)    It follows  that the  projected
number of vehicles requiring  traps  for  this  scenario  is  also
overestimated,   particularly  for  LDDTs,  if   the  same  engine
families  and the  same  number  of engine families  are certified
under  a  1.0/1.2  g/mi national  NOx  standard  as were certified
for  the   California  and  the  50-State  standard  in  1984.   The
estimated  values   in  the  DPS  should,  thus,  be  considered  as
somewhat  conservative  for  LDDVs,   but  very   conservative  for
LDDTs.

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                       -6-

                          Table 3

     Comparison of Estimated vs.  Adjusted "Actual" LDDV
Particulate Standards Levels Under the 1.0 g/mi NOx Standard
Mfr.
GM
GM
Isuzu
Isuzu
MB
Nissen
Peugeot
VW
VW
Volvo
Engine
Disp.
1.8L
4.3L
1.8L
1.8L
3.0L
1.7L
2.3L
1.6L
1.6L
2.4L
Conf ig.
M5,2500
L3,3500
M5,2750
A3, 2750
A4,4000
M5,2500
A3, 3500
M5,2250
SA,2250
M4,3500
Est. Particulate
Standard (g/mi)
.21
.37
.23
.21
.57
.29
.36
.21-. 29
.21
.47
Adjusted "Actual"
Particulate
Standard (g/mi)
.20
.24
.24
.27
.51
.31
.34
.14-. 36
.18-. 21
.24
Percent
Difference
-4.8
-35.1
+4.3
+28.6
-10.5
+6.9
-5.6
-33.3-+24.1
-14.3-0.0
-48.9

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-7-
Table 4
Comparison of Estimated vs. Adjusted "Actual" LDDT
Particulate Standard Levels Under the 1.2 g/mi NOx Standard
Mfr.
GM
GM
Isuzu
Isuzu
Mits
Mits
Nissan
Toto
Toko
Engine
Disp.
6.2L
6.2L
2.2L
2.2 L
2.3L
2.3L
2.5L
2.4L
2.2L
Trns.
M4
L4
M4
M5
M5
M5
M5
M5
M5
Est. Particulate
Standard (g/mi)
.56
.59
.34
.33
.43
.41
.37
.30
.30
Adjusted "Actual"
Particulate
Standard (g/mi)
.54
.61
.32
.30
.31
.23
.18
.25
.14
Percent
Difference
-3.6
+3.3
-5.9
-9.1
-27.9
-43.9
-51.4
-16.7
-53.3

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1983
                              -8-



                          References



     1.     "Diesel Particulate  Study,"  U.S.  EPA,  ECTD,  October

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