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

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