EPA^AA-SDSB-88-02

               Technical Report
       In-Use  Performance  of  Daimler-Benz
  Light-Duty Diesel  Particulate  Trap Oxidizers
                       By

                Thomas M.  Baines
                      and
               Philip N. Carlson
                 February 1988
                     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 Sources
           Office of  Air and Radiation
     U.  S.  Environmental  Protection Agency

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                              -2-
               In-Use Performance of Daimler-Benz
          Light-Duty Diesel Particulate Trap Oxidizers
Abstract
     Ten  in-use  1985 Mercedes-Benz  light-duty  diesel  vehicles
equipped  with  particulate  trap   oxidizer   systems  and  with
mileages  between  30,000  and  50,000  miles  were  tested  for
particulate  (PM)  and  gaseous  exhaust  (HC,   CO,  CC-2,  and  NOx)
emissions.   Seven  out   of   ten  vehicles   had   a  first-test
particulate  emission  level  lower  than  a predetermined  cutoff
point of  0.35 g/mi.   (The California PM  certification  standard
for  1985  light-duty  diesel  vehicles is  0.4  g/mi.)   Attempts
were made to regenerate  the  particulate  trap  oxidizers  on the
three vehicles  which exceeded  the  0.35  g/mi PM  level  and the
vehicles  were  retested.   Two  of  the  three  retested  vehicles
passed  the  PM  cutoff level.  The  particulate trap oxidizer was
removed  from the vehicle which  still  exceeded  the PM  cutoff
level   and   it  was   shipped  to  the  vehicle's  manufacturer,
Daimler-Benz, for further analysis.*

Introduction

     Particulate  emissions  from  light-  and  heavy-duty  diesel
engines  are  of  great  interest to EPA for both environmental and
health   reasons.   Because  of  the  concerns  associated   with
diesel   particulate   emissions,   EPA  has  promulgated  tighter
particulate  standards for light-duty diesel  vehicles,  and more
recently,  for  heavy-duty diesel  engines.  To comply with these
new  standards,  manufacturers may  need  to use  particulate trap
oxidizers.

     Until  relatively recently, experience  with trap oxidizers
has  largely  been  confined  to  information  from  laboratory
testing  supplemented  by a very limited number of higher mileage
durability  programs.   This  has left  an  information void with
regards  to this  important diesel  particulate emission control
     MBNA has  indicated  to EPA  that  it is  MBNA's  opinion that
     the program was designed  to  evaluate only the performance
     of  trap oxidizers  and not  include  concurrent  influences
     such  as  improper  maintenance  or isolated  manufacturing
     defects.   This  contrasts with  EPA's  position  that  in-use
     maintenance   and  manufacturing  variabilities  should  be
     included  when  analyzing the  in-use performance   of trap
     oxidizers.   The  EPA  acknowledges MBNA's position.   The
     only  question  from  EPA's perspective  is  the  appropriate
     weighting  factor  to  be  assigned  to  the  individual data
     points, as discussed  in the "Discussion"  section.

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                              -3-


technology.    For  example,  more information  from high  mileage
traps   is   needed   in   the  area   of  mechanical   durability
(especially'  for  relatively  brittle   materials   such  as  the
ceramic wall  flow monolith substrate),  catalyst  poisoning  due
to  sulfur  or other  compounds,   ash  plugging and  other  failure
modes.  One source of this type of information would  be  to test
vehicles from a large fleet  of trap equipped vehicles  such as
production  vehicles.   However,  until  recently,   no  production
vehicles  have  been  equipped with  particulate trap  oxidizers.
In  1985,  Daimler-Benz  introduced  particulate  trap  oxidizer
systems  on  their  300D,   300CD, 300SD  and 300TD  Mercedes-Benz
vehicles  (engine  family  FMB3.OD9KC20)  in the  western  states
served by the Mercedes-Benz California import facility.

     EPA contacted  Mercedes-Benz of North  America to propose a
cooperative  program  to   assess  the   in-use   performance   of
particulate trap  oxidizers.   The final agreement which resulted
from this proposal  included participation  from  EPA,  California
Air  Resources  Board  (GARB),  Mercedes-Benz  of   North  America
(MBNA), and Daimler-Benz  Aktiengesellschaft (DBAG).   In general
terms,  MBNA agreed to procure  the in-use  vehicles on loan from
their  owners, CARB  agreed to  test the vehicles and  DBAG agreed
to  provide   engineering   support.    A  complete  copy  of  the
agreement  is contained  in Appendix  A.   The  purpose  of  this
report  is  to present both the  details  of  this  program and the
test results.

Experimental Details

     Test  Vehicles  -  The  procurement  of  the  vehicles  was
performed by  MBNA.   They  acquired  a list  of  all vehicles from
EPA Certification Engine  Family FMB3.0D9KC20  (M-B models 300D,
300CD,  300SD and  300TD)   for model  year  1985  which  were sold
from  three  dealerships  (none  of which were  owned by  DBAG or
MBNA)  located  within  30   miles  of  the  Carson,  California MBNA
vehicle  preparation center.  From  this  list  of  852 vehicles,
every  fourth  one  was  selected  (a total of 213  vehicles) and a
solicitation  letter  (a copy of  which  is  in Appendix B) was sent
to  the  owner.    Fifty  persons   responded   as  being  willing  to
participate  in the program.    Of these  50,  16  vehicles  were
identified  as being within the target mileage  range of 30,000
to  50,000 miles and as never having  used  diesel-fuel additives
not  authorized  by Mercedes-Benz.   (The fuel additive selection
criterion   was   part  of   the   basic  program   agreement  and
compliance   with   it   was    determined   by   reviewing   the
questionnaire which accompanied the  solicitation  letter.)  EPA
then    randomly  ordered   the   16    available    vehicles   for
procurement,  from which MBNA procured 10 vehicles.   One owner
later  refused to  participate in this  program  when contacted by
MBNA  and  the owner of the .eleventh  identified vehicle was then
contacted.    The   vehicle  information   for   the  10  vehicles
included  in this  program  is presented  in Table l.

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                                 -4-
                               Table 1

          1985 Mercedes-Benz Light-Duty  Diesel  Trap  Oxidizer
                   Test Program Vehicle Information
Test Vehicle Vehicle
I.D. Number Model
1
2
3
4
5
6
7
8
9
10
300 D
300 D
300 SD
300 D
300 SD
300 D
300 D
300 SD
300 D
300 D
VIN
1231331A225300
1231331A251352
1261251A117247
1231331A229753
1261201A119072
1231331A257615
1231331A231890
1261201A138038
1231331A189535
1231331A242239
Engine Number
61795212093728
61795212103206
61795112671387
61795212095851
61795112071582
61795212106241
61795212096212
61795112071569
61795212085531
61795212099776
Odometer*
(miles)
36444
49948
33462
35159
33849
32743
33450
34077
35470
36056
Upon check-in at Mercedes-Benz dealership.

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                              -5-


     Upon  receipt  of the  vehicles at  MBNA's dealership,  MBNA
was  allowed  to  reject  a  vehicle  for  any  of  the  following
reasons:

     1.    Insufficient operating fluid levels,

     2.    Obvious  abuse or misuse  of  the vehicle  evidenced by
           vehicle    damage   or  information   from   maintenance
           records,

     3.    Mileage  of vehicle could not be verified,

     4.    Obvious  tampering on the emission control system, or

     5.    Obvious  usage  of unauthorized diesel  fuel  additives
           (which was also a pre-selection criterion).

     None  of  the  vehicles  were rejected by  MBNA  upon receipt
for any of the above reasons.

     Upon  acceptance of  the  vehicle   at the dealership,  the
vehicle was  driven to MBNA's  vehicle  preparation center.   MBNA
recorded  essential  vehicle information  and  made checks of the
electrical  system,  exhaust system, and transmission.   The fuel
tank was drained and filled with certification test diesel fuel
and was then driven to  the GARB  test  facilities over the same
route  as   for  "Title 13"  testing   purposes.   "Title  13"   is  a
California  enforcement  program designed to  check  production
line   vehicles  for  compliance   with  California   emissions
standards.  A copy of the  MBNA fuel properties  is included in
Appendix C as well as the "Title 13" road route.

     Upon  arrival,  CARB visually and  functionally inspected the
vehicle to assure the integrity  of  the  following  items:

     1.    Tires
     2.    Brakes
     3.    Exhaust System
     4.    Cooling System
     5.    Drive Train
     6.    Electrical System
     7.    Transmission
     8.    Emission  Control System  (check for  obvious tampering)

     If  CARB  deemed the  vehicle safe  for  testing, as  all the
vehicles  were,  the  rear  wheels of  the vehicle were replaced
with  slave tires  to prevent  the stress  of  dynamometer testing
on the  vehicle owner's tires.

     Test  Procedure  -  All ten of the vehicles were tested  under
the following federal test procedures:

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                              	g	


     1.     Fuel  drain and  fill.   A copy of the  fuel  properties
           is included in Appendix C.

     2.     Preconditioning cycle  (40  CFR Part  86.132-82 (a)(2)).

     3.     Soak  (40 CFR Part 86.132-82 (b)).

     4.     Cold  FTP (40  CFR Part  86.135-82  through 86.137-82).

     5.     EPA Highway Fuel Economy (40 CFR Part 600 Subpart B).

     If  the test was not voided for test procedural reasons and
the vehicle's particulate  emission rate results  did  not  exceed
0.35 g/mi,  the  vehicle  was returned  to MBNA.   The  0.35  g/mi
particulate emission rate  cut point  was specified by DBAG.   (If
a vehicle failed to meet HC, CO,  or NOx emissions standards,  it
was MBNA's  intention to  repair  the  vehicle to  bring it  into
compliance  with the  certification  standards  before  releasing
the vehicle back  to  the  owner.)   If  the  test  was  voided for
procedural  reasons,  the  entire  test  sequence  was  completed
before a  second test seguence was started.   Finishing the  test
sequence is required to obtain comparable  trap  oxidizer loading
levels prior to  the start of a test sequence.

     Vehicles which exceeded 0.35 g/mi PM were  to be subjected
to the following analytical procedure:

     1.     Back   pressure  in front  of  the  trap  oxidizer  was
           measured.

     2.     Vacuum for EGR and air bypass valve were checked.

     3.     Vehicle  was  driven in  an attempt to  regenerate the
           particulate trap oxidizer.

     4.     Restorative maintenance  activities were carried out
           by a DBAG  representative  if  it  was , believed  such
            actions would reduce engine out PM.

     The  vehicle  was  retested  under  the  same   federal  test
procedures  explained earlier.   If  the foregoing  measures did
not  result in  lowering the  PM  emission  below  0.35  g/mi,  the
trap  oxidizer was  replaced by DBAG  with  a new  trap oxidizer.
The removed trap oxidizer underwent further analysis by DBAG.

     All  of the  testing followed  this predetermined sequence
except  for  vehicle  9.    During  the   initial  testing of  this
vehicle,  it  was   observed  that  the  flow  rate  through  the
particulate  sampler  dropped below  the  five  percent variance
limit specified by  the Federal Test  Procedure,  thus voiding the
test.    The  testing  was   finished   and   the   data  processed
nevertheless.   The  unofficial   particulate   results   were  0.41
g/mi, which indicated a problem with the vehicle.

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                              -7-


     An  analysis  of  the  test  vehicle  by  DBAG  confirmed  a
vehicle  EGR system  malfunction which  had  been  identified  by
MBNA during  the  initial vehicle  inspection.  This  malfunction
was  caused by  an intermittent  contact  of  a pin in the  plug
connecting the coolant temperature  sensor to the microprocessor
because  the pin was  not fully  pushed  into  its  socket.   (MBNA
feels  that this probably  occurred  during  vehicle  assembly.)
Without  a  temperature signal, there is  no EGR valve opening and
no EGR flow to the engine.   Although this malfunction was noted
by   DBAG  prior   to  testing,  the  agencies  (EPA  and  GARB)
determined  that  testing would  be  conducted  to  determine  its
impact.

     After  the initial  testing  of  vehicle 9, the pin was pushed
into its  socket  and  the connection was found to  work properly.
However,  with  the  pin thus repaired, the vehicle was no longer
in  the desired  "as  received"  condition.   Since  it  was  judged
impractical  to  try to simulate  an  intermittent  problem,  it was
decided  to  test the  vehicle  one  time   with  the  temperature
sensor  connected and one  time  without  the  temperature  sensor
connected.   The  emission  results  so  generated  would  then
represent  the  range  between  which  the vehicle probably operated
when it had the  intermittent pin contact  problem.

     Vehicle  9  failed the particulate  criterion  on  its  second
test  with  the temperature  sensor  connected.  Vehicle  9 passed
the   particulate  criterion  on  the   third  test   with   the
temperature   sensor   disconnected.   An  attempt  was  made  to
regenerate  the  trap  by driving  the vehicle on  the road  and
vehicle  9  was  then  tested  a  fourth time  with  the temperature
sensor connected.

Experimental Results

     Of  the 10  vehicles tested,  seven vehicles  had first-test
particulate  results  below  the 0.35  g/mi  criteria  level  and
three  were  above  the criteria  level.    Upon  trap regeneration
and  retesting,  two  of  the  three  vehicles  which  initially
exceeded the particulate criteria  level,  were retested  and the
results  were  below  the  0.35  g/mi  criteria  level.   The  one
remaining  failing vehicle had its trap  replaced  by DBAG and the
trap was  sent to Germany for analysis.

     To  further  break down the  same particulate data, three of
the  10 vehicles had  first-test  results  of  0.10  g/mi  or less,
six  vehicles had  first-test results of  0.20 g/mi  or less  and
nine of  the  vehicles had  first-test   results  of 0.40  g/mi or
less.  All  of the particulate data  are presented  in Table 2.

     Of  the 10 vehicles tested, two had  first-test HC emissions
greater   than  the   0.46  g/mi  HC   level  to  which  they  were
certified.   None  of  the  vehicles had   first-test  CO  or  NOx

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                                   Table 2

                            Vehicle  Test  Results
Test Vehicle Test Test Odometer
I.D. Number Number Date (Miles )1


















1
2
3
4
5
6
1 1 4/22 36518
2 1 4/22 50023
3 1 4/23 33549
4 1 4/29 35240
5 1 4/29 33932
5 2 5/1 33975
6 1 4/30 32814
6 2 5/1 32854
7 1 5/5 33522
8 1 5/5 34150
9 I3 5/6
9 24 5/8 35602
9 35 5/12 35640
9 44 5/13 35684
10 1 5/12 36130
(CA Certification Standards)
Mean of All Tests6
Standard Deviation6
Mileage at start of test.
Exceeded range of measurement.
Test voided because the flow rate
Temperature sensor was connected.
PM
0.24
0.08
0.10
0.18
0.38
0.33
0.49
0.22
0.09
0.12
-
0.40
0.29
0.40
0.14
0.4
0.22
0.15

Emissions, q/mi
HC
0.18
0.26
0.41
0.26
0.23
0.22
> 0.492
0.22
0.29
> 0.462
-
0.25
0.18
0.29
0.26
0.46
0.317
O.ll7

tolerance was


CO
2.3
1.9
1.8
2.9
1.6
1.6
6.0
1.3
2.9
4.1
-
1.6
1.1
1.5
1.9
8.3
2.7
1.4

exceeded

C02
443
449
435
454
425
426
480
467
441
430
-
463
445
453
451
-
447
16

in bags

NOx
0.9
0.9
0.9
0.8
0.9
0.9
0.7
1.2
0.8
0.8
-
1.0
1.7
0.9
0.9
1.0
0.9
0.1

1 and 2.

HWFET
(MPG)
27.2
27.4
28.6
27.0
29.6
29.7
25.2
27.3
25.8
27.7
-
27.1
28.9
27.3
26.8
-
27.2
1.3



Temperature sensor was disconnected.
The mean and standard deviation
are
based on
only the
.first
valid test
of ea
vehicle.
The HC values of 0.49 and 0.46  g/nii  were used for  vehicles  6 and 8,  respectively,
in calculating the mean and standard deviation.

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                              -9-
levels  in  excess of  the level  to which  they were  certified.
These data are also  summarized  in Table 2.   The complete set of
emission test  output  from GARB  for  each vehicle  are presented
in Appendix  D along  with the  injection time  and engine  idle
speeds which were taken  after  the emissions test  procedure  was
completed.

     The emission  results of  the retested vehicles  which  did
not  pass  the   predetermined    cut-off  level  of   0.35   g/mi
particulate  are  also  contained  in  Table  2.   The  particulate
from both  vehicles  5 and  6  dropped below  the  0.35  g/mi  level
upon  retesting,  however, vehicle 9 remained  above  0.35  g/mi.
The particulate from vehicle 5 decreased from 0.38 g/mi to 0.33
g/mi,  and  the particulate  from  vehicle  6 decreased from 0.49
g/mi to 0.22 g/mi.

     Table 3 is a summary of the  repairs which  were  made to the
three vehicles that  exceeded  the predetermined cut-off level of
0.35 g/mi particulate.  The trap  back  pressure,  EGR vacuum,  and
air  bypass  measurements  are  also presented  in  Table  3.   The
trap  back  pressure  was  taken  between the  first   and  second
tests.  However,  vehicles 5 and 6  were driven  about three miles
prior to the trap  back  pressure  test.  The short drive,  which
consisted  of heavy  accelerating  and braking,  is  likely to have
affected the condition  of  the  particulate  trap oxidizer  and
thus  the  back  pressure  measurement  on  vehicles   5  and  6.
Vehicle 6 had thick, black oil in the  fuel  injection pump.  The
oil  was drained  and was  replaced during  the subsequent vehicle
operation.    (Vehicle  6  had only  had  three oil  changes instead
of  the recommended  seven oil  changes.  See Table  3, footnote
2.)   The  air  filter  was  removed, cleaned  and  reinstalled on
vehicle 6,  also.  Based on its  service record,  DBAG feels that
vehicle  6  is not   representative of the  vehicle  population
utilizing  trap oxidizers.  It was tested,  however,  to see what
the  effect  of such  in-use  lack-of-maintenance  is in  terms of
emissions.

Discussion

     The objective  of this program was to  acquire data on trap
durability.   In  this regard,  a  few observations can  be  made.
Of  the 10  vehicles  tested,  there were no  gross trap  failures,
since  none  of  the  vehicles exceeded the  California  particulate
standard  level  of  0.4  g/mi   except   one,  and  it  passed  after
maintenance  and trap regeneration.   Yet   such  an   observation
could   mask   some   underlying   problems.    The   50,000   mile
certification  test  results  (low mileage  plus   deterioration)
were 0.12  g/mi  particulate for  the 300 D  and 300  CD and  0.14
g/mi particulate for  the 300  TD  and 300 SD.   Thus,   it would be
reasonable  to  expect that vehicles  would  emit  less  than about
0.15 g/mi   particulate   at  the  average 36,000  miles  at  which
these  vehicles were tested.   Yet on  the  first test,  only  five

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                                 Table 3

                  Repairs Made to Failing Test Vehicles
                     -and Back Pressure, EGR Vacuum
                    and Air Bypass Measurements (bar)
  Vehicle
  Number
Actions Taken/
 Repairs Made           Back
  to Vehicle          Pressure

- Vehicle driven        0.75
  2-3 miles1

- Vehicle driven        0.65
  3-4 miles1

- Black, thick
  oil drained out
  of injection pump2
  (approx. 3/4 cup)

- Dirty air filter
  was cleaned and
  reinstalled

- Plug to coolant       0.65^
  temperature sensor
  was reconnected4

- Vehicle driven        0.804
  about 6 miles1'4
 EGR
Vacuum

 0.30
                                                     0.29
                                                     0.273
 Air
Bypass

 0.70


 0.72
            0.753
1    On-Road  driving  consisted   of  heavy   acceleration   and
     breaking.
2    Vehicle 6 had  only  had three oil changes  (at  2439,  11978,
     and  20825  miles)  instead of   the  seven  recommended  oil
     changes at  1000,  5000,   10000,  15000,  20000, 25000,  and
     30000 miles.
3    After second test.
4    After third  test.

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                              -11-
vehicles had  particulate  emissions at  such a  low  level.   This
could indicate some level  of trap failure.

     It has  been reported that  'gasoline-fueled vehicle ceramic
monolith catalysts frequently  undergo some  level  of mechanical
failure.    Yet  there   is   sufficient  mechanical   structure
remaining  to  give  good  catalytic   activity,   even  at  high
mileages.    The same thing may  be occurring with  these traps.
The  traps   are made of basically the  same material  -  i.e.,
honeycomb  cordierite.   The   results   of  this  program  seem  to
point to mechanical  failure  in  that  five  of  the  vehicles  had
particulate  emissions   exceeding  0.15  g/mi.   This  thought  is
further bolstered  by  the  results from  vehicle  9, which  was
tested with  and  without the  temperature sensor connected.  With
the  temperature  sensor  connected,  the  EGR  should  function
properly,   giving  lower  NOx  emissions  and higher  engine-out
particulate   emissions  (about  0.55   g/mi  for   this  vehicle
according  to MBNA).    With the  temperature senor disconnected,
the EGR will not function  properly, resulting  in higher NOx and
lower  particulate.   In reviewing  the data  one sees  that  the
temperature  sensor  did have  the predicted  influence on  NOx   -
i.e.,  no   EGR led to  high  NOx  and  visa versa.   However,  the
trap-out particulate emissions changed  in the  same direction as
the engine-out particulate emissions.   If the trap  oxidizer was
mechanically   intact,   little  change   in  trap-out   particulate
emissions  should have been  seen from  a change  in engine-out
particulate  levels.   But  since  trap-out  particulate emissions
did change by an appreciable amount as a function of engine-out
emissions  it would indicate some mechanical  failure  of the trap.

     The  other  observation  that  can  be made  about  the trap
oxidizer is its usefulness  as an aftertreatment device to meet
various  emissions  standards.   The  Federal  emission standards
are  50,000 mile  standards which  combine  low  mileage emission
results with  deterioration  factors  to project  a  50,000 mile
emission rate which must  be below the  standard.   The vehicles
which  were tested in  this program should  have had  particulate
emissions   below  the   emission  standard   to  which they  were
certified,  since they  had not reached  50,000  miles (with one
exception).   Thus,  for a  0.4 g/mile  particulate standard,  all
but  one of  the  vehicles  were at  or  below  the  standard  level.
(One  poorly  maintained vehicle  exceeded the  0.4 g/mi standard
level  but   was tested   below  this  level  after  maintenance  and
trap regeneration.)

     However,  the  testing took  place  at about 36,000 miles and
not  50,000 miles.   If  there is additional  deterioration in the
emissions  behavior  of  these vehicles, then  by  50,000 miles some
of the  vehicles  may fail the  0.4 g/mi  standard.

     The   emission  control  system employed by DBAG   for  the
Mercedes-Benz vehicles  tested  was  designed  specifically  for
those vehicles'  engines and  for  0.4 g/mi particulate standard.

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                              -12-


Never-the-less,   some    have   considered    the    particulate
trap-oxidizer  system  employed by  DBAG  to  be an  appropriate
technology for  a 0.2 g/mi  particulate standard as  well.   This
is  due   in  part   to  the  fact  that  the  DBAG  50,000  mile
certification particulate results were  0.14  g/mi  or  less,  which
is considerably  lower  than a 0.2 g/mi standard level.  However,
at the  test  mileage  of  about 36,000  miles,  only 7  of the  10
vehicles  had particulate at or below  0.2  g/mi.  This indicates
the possibility  of  excessive  in-use  deterioration  which  would
have  to be remedied  to make  this  technology usable for  a 0.2
g/mi particulate standard.

     The  above discussion  focused on the  number  of  vehicles
whose  first-test  particulate  results were above  or  below  a
certain  level  and  did  not differentiate  between vehicles  of
various   maintenance   levels,   completeness   of  assembly  at
manufacture  or other  such variables.  Thus,   the results from
each  vehicle  were  evaluated  on  a  equal  basis,  or  weighting
(i.e.,  O.l).   This  was done  because  the  sample was,  with some
constraints,   randomly   chosen  and  such  a   sample  selection
process is based on the  assumption  that the resultant data will
be representative of the whole population.

     Some  would  argue that not all of  the  vehicles  are in fact
representative of the whole  population at  a weighting factor of
0.1, but  rather  some  vehicles (for example, a  poorly maintained
vehicle)  should  have  a weighting factor of  less  than 0.1.  EPA
has  no data upon  which to  assign a weighting factor  of other
than  0.1,  but  others  may have such  data.   For  their  purposes
they  may  want to  assign  different  weighting factors to the
vehicle data.

     MBNA  has  indicated to  EPA  that  it is  MBNA's opinion that
the  program was  designed  to  evaluate only the  performance of
trap  oxidizers  and  not  include  concurrent influences  such as
improper  maintenance or  isolated manufacturing  defects.   This
contrasts  with  EPA's   position  that  in-use  maintenance  and
manufacturing  variabilities  should  be included  when analyzing
the in-use performance  of  trap oxidizers.   The EPA acknowledges
MBNA's  position.  The  only question  from  EPA's  perspective is
the   appropriate  weighting  factor  to  be  assigned   to  the
individual data  points,  as  discussed  in the  previous paragraph.

Conclusions

     The  following conclusions can be  drawn  from this project:

     -     MBNA   and   DBAG  were  cooperative  and   technically
           thorough  in the  vehicle  acquisition portion  of the
           program.

           CARB's  El  Monte test  facility  appeared  to   do   a
           technically  correct job  of  testing  these vehicles.

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                   -13-


There  appeared   to   be  indication   of   mechanical
failure in  a portion  of  the  traps  on the  vehicles
tested.

Relative  to  the 0.4  g/mi  particulate  standard  to
which the vehicles were certified,  nine vehicles had
first-test   emission  results   below  this   level.
However, the  tests took place at about  36,000 miles
and  if  additional trap performance  deterioration  is
experienced,  more vehicles  will probably exceed the
0.4 g/mi particulate level  if they were to be tested
at 50,000 miles.

The    trap    system   used  by   DBAG   was   designed
specifically  for the  1985  model year Mercedes-Benz
vehicles  and  a  0.4  g/mi   particulate  standard.
Never-the-less,  the  certification  particulate  test
results for  these vehicles were 0.14 g/mi  or less.
The  has  lead  some  to conclude  that this technology
would  be  appropriate  for   a 0.2  g/mi  particulate
standard.  However,  at about 36,000 miles, only 7 of
the  10  vehicles  tested  had   particulate  emission
levels at or below  0.2 g/mi.  Thus, deterioration of
this   emission  control   system  will  have   to  be
controlled   to   enable   it   to  meet   a  0.2  g/mi
particulate  standard.

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              Appendix A

Original Cooperative Agreement Between
	EPA, GARB, MBNA and DBAG	

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                            A 2
          RCED
                 c
                       February  18,  1987
Mr. Charles Gray
Mobile Source Air Pollution. Control
Environmental Protection Agency
2565 Plymouth Road
Ann Arbor/ Michigan  48105

Mr. Tom Cackette
Assistant Executive Officer
California Air Resources Board
P. 0. Box 2815
Sacramento, CA  95812

Mr. K. D. Drachand, Chief
Mobile Source Control Division
California Air Resources Board
9528 Telstar Avenue
El Monte, California 91731


Subject:  In-Use Testing of Trap Oxidizer Equipped LD
          Diesel Vehicles

Gentlemen:

In accordance with recent discussions and correspondence with MBNA
regarding the above referenced test program,  we would like to
propose the following program outline to EPA and CARB:

A.  General Program Definitions

    1.   The, test program is a cooperative effort between EPA,
         CARB, MBNA and DBAG.

    2.   Test data derived from this program will not be used
         directly as the basis for any emission related recall
         activities.

    3. '  MBNA will be responsible for vehicle procurement and
         shipment to and from the CARB test site.

    4.   CARB will be fully responsible for the vehicles while
         at the' CARB test site.

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                           A 3
    5.    EPA and  CARB will  be responsible for  carrying out  the
         emissions  testing  of these'vehicles  and will  share all
         data derived from  these  tests  with MBNA and  DBAG.

B.   Detailed Program Outline:

    1.    The program is designed  to sample and test in-use  PM
         emissions  of Daimler-Benz light-duty  diesel  vehicles
         equipped with the  Engine Family FMB3.0D9KC20  trap
         oxidizer system.

         Ten randomly selected vehicles equipped with Engine
         Family FMB3.0D9KC20 (MY  85)  and a mileage between
         30,000 and 50,000  miles  will be made  available by
         MBNA for this purpose.

     2.   MBNA will  solicit  participation of  owners for this
         program through a  mail-out.   The customers to whom
         the mail-out will  be sent will be chosen as follows.
         MBNA will  identify all purchasers of MY 85 Engine
         Family FMB3.0D9KC20 from three dealerships in the
         Los Angeles area.   After compiling  this list in a
         random order, MBNA will  send a letter to the first
         150 customers soliciting their participation and
         outlining  incentives for participation.  MBNA will
         offer limited incentives (appropriate leaner cars,
         full tank, etc.)  to insure a sufficient supply of
         appropriate vehicles.  Every effort  will be made,
         however, to acquire the randomly selected vehicles
         once identified and in-line with the foregoing
         incentives.  When  positive responses to the MBNA
         letter have been received, MBNA will  review the
         responses  in the same order as randomly arranged
         originally in an attempt to obtain  the 10 test
         vehicles.   If 10 test vehicles are  not obtained from
         this first group of letters, additional mail-outs
         following  this same procedure will  be undertaken
         until 10 vehicles  are available.  A  complete record
         of contacts with customers will be  maintained by
         MBNA.

    3.    To limit the expenses of vehicle procurement, approx.
         2-3 vehicles will  be scheduled per  week. The duration
         of the program should not exceed 5  weeks.

    4.    The in-use test vehicles will be delivered to MBNA
         dealerships by their owners or representatives. Prior
         to acceptance of these vehicles they will be visually
         inspected  by iXENA  personnel or their representatives.
         Any cars showing obvious mistreatment will.be rejected
         at the dealership  and will not participate in the  test
         program.

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                        A 4
     Reasons for rejection are:

          Insufficient operating fluid levels (i.e.  engine
          oil level above or below maximum/minimum marker
          on dipstick),

          Obvious abuse or misuse of vehicle evidenced by
          vehicle damage or information from maintenance
          records,

          Mileage of vehicle cannot be verified
          (i.e.  odometer disconnected or replaced).

          Obvious tampering on emission control system
          (e.g.  removed or disabled emission control
          devices, disconnected vacuum lines and/or
          electrical connections) .

          Obvious usage of unauthorized diesel fuel
          additives.

     MBNA will keep complete records regarding all vehicles.
     inspected and the basis for any vehicle being rejected.

5.   EPA and CARB will attempt to return the vehicles to MBNA
     at the CARB test facility within five working days after
     receipt of the vehicle.

6.   After acceptance of the vehicle by MBNA at its dealer-
     ship, it will be driven by MBNA personnel or their
     representatives to MBNA's vehicle preparation center
     and the following activities will be performed:

          Recording of essential vehicle information
          (model type, VIN, engine no., mileage,
          maintenance records, etc.),

          Functional check of electrical system
          (switches, battery, pre-glow system),

          Visual check of exhaust system for leakages,

          Functional check of transmission
          (i.e.  shift points).

   •  -    The vehicle tank will be drained and filled
          with certification diesel fuel.  Fuel samples
          from the vehicle tanks will be taken for later
          analysis if necessary.  In addition, one sample
          of the certification fuel will also be taken.

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                       A 5
          This procedure should ensure that the fuel system
          is properly conditioned with diesel fuel of known
          quality prior to emission testing.

     EPA and/or CARB personnel are invited to observe these
     activities if so desired.

7.   The vehicles will then be driven on the road (same route
     as used for Title 13 purposes) by MBNA personnel or their
     representatives to the CARB emission test facility and
     delivered to EPA/CARB personnel.

     Upon delivery the rear wheels of the vehicle will be
     replaced with slave wheels and tires to prevent the stress
     of dynamometer testing from the customer's tires.  Slave
     wheels and tires will be supplied by MBNA.

8.   EPA/CARB will perform one routine test sequence
     consisting of:

               fuel drain and fill
               preconditioning cycle
               soak
               cold FTP 78
               HWFET.

     If the test results are not voided for test procedure
     reasons and the vehicles do not exceed 0.35 g/m PM, the
     vehicle will be returned to MBNA personnel.  If a test is
     void, the test sequence will be finished before a 2nd
     test sequence is started.  No retesting will be performed
     on a vehicle if the only reason for a test failure is that
     the vehicle exceeds emission standards for HC, CO/ or NOx.

9.   MBNA will have no obligation to adjust and/or  repair any
     vehicles, even if they failed in one or more emission
     constituents.  However, it is the intention of DBAG to
     bring all vehicles into specification before returning
     them to their owners.  Records regarding any MBNA actions
     in this respect will be available to review by EPA and/or
     CARB.

10.  Vehicles exceeding a PM value of 0.35 g/mi as  a result of
     a FTP-78 test will be subjected to the following
     analytical procedure:

          Test back-pressure in front of TO,

          Check vacuum for EGR and air bypass valve.

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                       A 6
          In case the back-pressure level exceeds the
          Service Manual  limit of 1.3  bar at 4,000 rpm
          (high idle, gear shift lever in "P" position)  an
          attempt will be made to regenerate the trap by
          driving an appropriate cycle on the dynamometer
          or highway.  In addition, restorative maintenance
          activities will be carried out by DBAG if it
          believes such actions would reduce engine out  PM
          emissions.

          If the foregoing measures do not result in the PM
          emissions of the vehicle being below 0.35, the TO
          will be replaced with a new TO by and at the
          expense of DBAG and sent to DBAG for further
          analysis.

11.  TOs sent to DBAG for further evaluation will receive one
     or more of the following checks as deemed appropriate:

          Initial visual  inspection,

          Removal of insulation shells and partial
          regeneration in an oven at 750 degrees C.

          Alternatively the TO might be installed on an
          engine and operated on an engine test stand at
          full throttle for 15 min.

          Back pressures will be measured under laboratory
          conditions before and after all regeneration
          procedures.

          Finally the filter might be cut open to perform
          in-depth analysis consisting of:

          0    Visual examination under a microscope,

          0    X-ray fluorescence spectroscopy,

          0    Qualitative and quantitative analysis with
               respect to ashes found in the TO cells,

          0    Mechanical testing of substrate,

          0    Examination of the structure of welding
               seams.

12.  A summary cf these findings will be provided to EPA and
     GARB.

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                            A 7
We would appreciate your  review of the foregoing  test program.
If you agree with the provisions noted above, please sign a copy
of this letter and send it to me.  As soon as all parties have
signed indicating agreement on the program,  it will take MBNA
approximately 6-8 weeks to organize vehicle  procurement.
                                   'incerely
                                         Po0.z,  Manager
                                  'Emission  Control
HP/jl
Agreed  to:
 Charles  Gray  fcxf
 Environmental Protection  Agency
                               Date:
                                        7 - - -"
To"m TTackette,  for
California Air Resources  Board
                                           Ixi
                               Date:
K.D. Drachand, for
California Air Resources  Beard

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                        Appendix B
Vehicle Solicitation Letter Sent by MBNA to Vehicle Owners

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                      B 2
                      February 1987
Dear Mercedes-Benz Owner:

Mercedes-Benz of  North America  is  participating in  a
joint program with  the  Environmental  Protection Agency
and  the  California  Air  Resources  Board  to  obtain
valuable   information    for    engine   research   and
development/   and  to  help the  agencies  in  evaluating
present and future emission control  strategies.

We invite you to participate in this program by filling
out  the   attached   questionnaire  at   your  earliest
convenience and returning it to:

             Mercedes-Benz of North America
             1 Mercedes Drive
             Montvale/ N.J.  07645

             Attn:  Product & Service Engineering

as  indicated on  the  addressed  and  stamped  envelope
enclosed.

The  information  we receive  will  be  checked  against
certain  key  criteria needed  for  this  program  and  all
vehicles  meeting  these  requirements  will be  eligible
for a random drawing determining the participants.

If your vehicle is  selected  in the  random drawing,  one
of  our  local Zone  representatives will  get  in touch
with you  to  make  all  necessary arrangements.  You will
then bring your car to  a  local MB dealership,  where we
will provide you  with  a  current model  year Mercedes-
Benz  leaner   car  free  of  charge  to  you.   When  you
receive your car back it will be washed and have a full
tank of  fuel.   In  addition,  the next  scheduled major
service on your vehicle performed  at an  authorized MB
dealership will also be free of charge.

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                       B 3
While  in  the program,  your car  will be  tested on  a
vehicle  dynamometer  at  the California  Air  Resources
Board and MBNA labs.  We  anticipate  that  the tests  and
measurements will take about 5-10  business  days and we
anticipate that  less  than 250  miles will be  added to
your car by  the  program.   All  parts  and  labor required
during these tests will be  free of charge  to you.   You
will only  be required  to  sign an  authorization  form
permitting representatives of MBNA, EPA and the CARB to
drive  and  test  the car  and  replace  any part deemed
necessary to perform the task of the program.

Please be assured that our technicians will handle your
car with utmost  care.   Further, Mercedes-Benz of North
America will assume responsibility for the condition of
your car while it is in our custody.

We appreciate your help in conducting this program.   If
there are  any  questions  regarding the  program, please
contact Mr.  Carl Partyka, Los  Angeles  Zone, Telephone
#213-835-8315.    Thank you  for  your  assistance  and we
look forward to receiving your questionnaire.

                                  Sincerely,

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                         Appendix C
Properties of Test Program Fuel and "Title 13" Driving Route

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                           C 2 '
Laboratory Test  Report
  PHILLIPS 66 COMPANY
  A SUBSIDIARY OF PHILLIPS PETROLEUM COMPANY
  eARTLESVILLE. OKLAHOMA 74O04
                        0-2 DIESEL CONTROL FUEL
                  VoU
LOT G-668

Results
45.8 .
353
407
424
450
470
488
504
522
541
563
592
623
639
641
g/ 100ml 0.71
35.4
0.36
34.2
s 2.5
161
11 1.5
+ 10
+ 5
1
•
19,250
2,778
46.9

EPA

Test
Specification* Method
43-47
345-375

400-440


495-525

580-610

630-660
1.5 Max.
33-36
0.2-0.4
29 - 35
2.2-3.2
130 Min.
15 Max.
15 Max.

3 Max.
~~

2750-2806
43 - 47
0 613
D 86 .


RECEIVES


FEB 25 1987
LOS ANGELES
EMISSION TEST LABORATO



D 287
D 3120
D 1319
0 445
D 93
D 2276







    Test

Cetane Number

Distillation Range. OF

    IBP
    5%
     10
    20
    30
    40
    50
    60
     70
    80
    90
    95
     OP
     EP

Oxidation Stability, mg/lOOml
Gravity, OAPI
Total  Sulfur, WT%
Aromatics (FIA),
Kinematic Viscosity, cs
Flash  Point  (PM, OF)
Particulate Matter, mg/1
Cloud  Point, OF
Pour Point, °F
Corrosion
Net Heat of Combustion,
     BTU/lb
Carbon Density, grams
     carbon/gal.
Cetane Index

30 ptb of Du Pont FOA #11 antioxidant enhances the stability of this fuel
   *D1esel Fuel as  described in Chapter One-Environmental Protection Agency,
   subsection 86.113-78, of the Federal  Regulations.

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             C 3
               Table C-l
'Title  13" Vehicle  Route  Description from
	Mercedes-Benz to  CARS	
Bonita Street
223rd Street
405 Freeway
7 Freeway
91 Freeway
605 Freeway
10 Freeway
Rosemead Blvd.
Telstar Ave.
N
E
S
N
E
N
W
S
E
 0.2 miles
 0.8 miles
 3.6 miles
 3.5 miles
 5.0 miles
15.5 miles
 4.0 miles
 0.2 miles
 0.6 miles
Total Mileage
        33.4 miles

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                           Appendix D

            Detailed Emissions Test Output from CARS


     Due  to  the   large  amount  of  paper  associated with  the
vehicle tests, the  complete  results are not included  with  this
report.   If  it is  necessary to obtain  a copy of  the complete
results,  they are  available from  EPA.   Please    phone  Thomas
Baines at (313) 668-4366 for further information.

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          D 2
             Table D-l

Injection Time and Engine Idle Speed
          of Test Vehicles
Vehicle I.D.
Number
1
2
3
4
5
6
7
8
9
10
Injection
Time (degrees)
23.5
24.0
24.0
24.0
23.0
24.0
24.0
22.5
24.5
24.5
Engine Idle
Speed (rpm)
710
720
710
720
700
720
730
720
800
705

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