ILLINOIS POLLUTION CONTROL BOARD
May 21,
1992
IN THE MATTER OF:
)
)
JOINT PETITION OF DETROIT
)
AS 92-4
DIESEL CORPORATION, NAVISTAR
)
(Adjusted Standard
INTERNATIONAL TRANSPORTATION
)
CORPORATION, CUMMINS ENGINE
)
COMPANY
AND
THE ENGINE
)
MANUFACTURERS ASSOCIATION
)
FOR ADJUSTED STANDARD FROM
)
35 ILL. ADM. CODE 240.141
)
ORDER OF THE BOARD
(by
3.
Anderson):
On Nay
4,
1992 Detroit Diesel Corporation (DDC), Navistar
International Transportation Corporation,
(Navistar),
Cuinmins
Engine Company
(Cununins),
and the Engine Manufacturers
Association
(EMA)
filed a petition for adjusted standard pursuant
to 35
Ill. Adm. Code 106.Subpart G seeking opacity standards
alternative to those of Section 240.141 for certain classes of
heavy duty diesel engines.
On May 12,
1992, petitioners filed
the proof of publication required by 35 Ill.
Adm. Code 106.712.
This petition generally meets the information requirements
of 35
Ill. Adm. Code 240.141(d),
and is accordingly accepted for
hearing as requested by petitioners.
To facilitate the Board’s
prompt determination of the merits of this petition, the parties
are directed to address the following issues and questions at
hearing:
1.
DDC is requested to provide a copy of the California
opacity standard and the exemption from it granted by
the California Air Resources Board
(CARB), as well as
any rationale for the exemption given by CARB.
2.
Navistar and Cununins are directed to explain:
a.
How many engine families are manufactured by each
company?
What percentage of engine families
(to
total produced by any company)
are represented in
this petition?
Approximately how many vehicles
represented in this petition are in service?
b.
How do these engine families differ from other
engine families manufactured by your company or
other companies, such that an adjusted standard is
required for compliance?
C.
How can an enforcement authority distinguish
between an properly maintained engine from a
133575
2
malmaintained engine from the same family with an
adjusted standard?
Will the malmaintained engine
always exceed the adjusted standard opacity level?
d.
What specific adjustments must be made to ensure
compliance with the generally applicable standard?
What is the cost per engine?
e.
Several times in the petition,
a “deterioration
factor
(DF)” was applied to calculate the adjusted
standard.
Please provide a description of what
this factor represents and the method by which it
is determined or calculated.
f.
A quality control factor of
2 standard deviations
was added to the snap idle estimate to calculate
the adjusted standard.
How and why was this
factor chosen?
g.
The petition requests adjusted standards that
reflect a 2
error of commission
(only
2
of
properly maintained and certified vehicles will
fail the snap idle test).
Please estimate the
percent error of omission (the percentage of
vehicles that are not properly maintained or
certified that will pass the snap idle test)
that
will come about due to these adjusted standards.
h.
Please describe the requirements of the FTP.
How
many engines in each family are tested?
Are
quality control factors such as 2*SD and a
deterioration factor applied when certification
is
assessed?
What is the error of commission of the
FTP?
i.
Where is the engine identification number located?
j.
If the snap-idle testing conditions are not
encountered under normal driving conditions,
is
such a test an adequate measure of the peak smoke
opacity emitted?
If not, why was this information
not provided during the R90-20 proceedings?
k.
In this adjusted standard, specific engine
families or classes are targeted based on the
testing that has been carried out.
Will
additional testing reveal that there are other
classes or engine !amilies that might also fail
the Board’s snap-idle opacity standard and require
adjusted standards?
I
33—576
3
1.
The reasoning provided in DDC’s petition is the
failure of the electronic emission control
software to account for the rapid acceleration in
a snap-idle test.
What is the believed reasoning
for the failure of the engines included in
Navistar’s and Cummins’ adjusted standard?
in.
Several terms are used in the petition which are
used in the setting of the adjusted standard.
Please define or provide clear explanations of the
following terms:
1)
EPA FTP integrated smoke “C” values
2)
EPA FTP strip chart peak
3)
Critical parts lists
3.
The parties, particularly the Agency,
are directed to
address the question as to whether there is any nexus
at all between the SIP requirements and the diesel
exhaust opacity standards, particularly in relation to
PM1O.
IT IS SO ORDERED.
I, Dorothy M. Gunn, Clerk of the Illinois Pollution Control
Board,
hereby certify tb~atthe above order was adopted on the
~/-~day
of
(12’)
~—~---i
,
1992, by a vote of
7—
&
.
7/
Dorothy M.4unn,
Clerk
Illinois ~llution
Control Board
133-577