p.1 

OAR Box 1846 

Prepped by Ollie Stewart 

Document Number: 

80) IV-A-2 

Docket Number: 

A-90-07 

Printed 11/18/2008 7:30:17 AM Sheet 80 of 93 
P.2 

' -

/t-yo-ojSwRI 08-5374-003 

TESTING AND ANALYTICAL SUPPORT FOR REGULATION OF MOTOR 

VEHICLES, ENGINES, FUELS, AND FUEL ADDITIVES 

MOTOR VEHICLE FUEL AND FUEL ADDITIVE 

EMISSIONS GENERATION AND SPECIATION COSTS 

FINAL REPORT 

CONTRACT NUMBER 68-C2-0144 

WORK ASSIGNMENT NUMBER 0-3 

PREPARED FOR 

OFFICE OF MOBILE SOURCES 

U.S. ENVIRONMENTAL PROTECTION AGENCY 

JUNE 1993 fpJXD/TD] 

il xu .' 

ii!.!:1 Mjim l\4 

EPA/..ft DOCKET 

SOUTHWEST RESEARC H INSTITUT E 

SAN ANTONI O HOUSTO N 

DETROI T WASHINGTON , DC 
P.3 

SwRI 08-5374-003 

TESTING AND ANALYTICAL SUPPORT FOR REGULATION OF MOTOR 

VEHICLES, ENGINES, FUELS, AND FUEL ADDITIVES 

MOTOR VEHICLE FUEL AND FUEL ADDITIVE 

EMISSIONS GENERATION AND SPECIATION COSTS 

FINAL REPORT 

CONTRACT NUMBER 68-C2-0144 

WORK ASSIGNMENT NUMBER 0-3 

PREPARED FOR 

OFFICE OF MOBILE SOURCES 

U.S. ENVIRONMENTAL PROTECTION AGENCY 

JUNE 1993 , ; _ , M 

I/3I 

Approved: 

Charles T. Hare 

Department of Emissions Research 

Automotive Products and Emission 

Research Division 
P.4 

INTRODUCTION 

The objective of this Work Assignment was for Southwest Research Institute (SwRI) 

to gather cost data to assist the U.S. Environmental Protection Agency (EPA) in their 

estimation of the cost of implementation of rules proposed under section 211(bX2) of the 

Clean Air Act. This section of the Act will require fuel and fuel additive (F/FA) 

manufacturers to test and submit information on the emissions of motor vehicle fuels and 

additives and their effects on public health and welfare, and on vehicle emission control 

performance. The testing program is expected to require that F/FA combustion and noncombustion evaporative emissions be generated under controlled conditions using appropriate 

vehicles, engines, and/or chambers, and that the chemical content of the emissions be 

characterized according to methods prescribed by the EPA. The program may further require 

that such generated emissions be delivered in a pre-defined manner to animal exposure 

chambers over extended periods of time to assess the health effects of prolonged, low-level 

exposure to these F/FA emissions. SwRI was to gather information on the cost of performing 

the various tasks involved in generation, dilution and delivery, and 

measurement/characterization of emissions by contacting laboratories capable of performing 

at least some of the tasks. The costs involved with the animal testing were not to be 

evaluated. 
P.5 

METHODS USED: PROCEDURES AND STRATEGY 

Because this program depended on the voluntary participation of experts in the field 

of automotive emissions measurement, careful consideration was required for proper design 

of the contact strategy, participant selection criteria, and survey package to be sent to the 

participants. Constraints placed on the study included a limit of nine laboratories to be 

contacted and a limited period to collect the data. 

Several lists of candidate laboratories were first collated, then given an informal 

ranking internally based on SwRFs assumptions of the capabilities possessed by each 

laboratory. This was followed by telephone interviews, in which the program was explained 

and the capabilities of the laboratory and willingness to participate were assessed. 

Laboratories were selected based on the capability of performing as many required tasks as 

possible. 

After the laboratories were selected, a survey package consisting of a cover letter 

(presented in Appendix A), a letter of introduction from the EPA (Appendix B), a response 

form (Appendix C), and a postage-paid return envelope was prepared and sent to each 

participant. The cover letter explained the F/FA testing program and reiterated information 

supplied during the initial telephone communications. It requested their participation and 

included names of telephone numbers for contact persons at the EPA and SwRI. It was 

stated in the letter that the data would not be associated with company names when 

presented, and that the cost data provided would not be considered official business 

quotations. A letter of introduction was prepared by the EPA to assure the participants of 

the authenticity of SwRFs request for cost data (some respondents might have been reluctant 

to supply cost data because, in some instances, SwRI is their competitor). 

The response form was designed to incorporate all the tasks listed in Appendix 1 of 

the Statement of Work, presenting the tasks and related information as concisely as possible. 

It requests identification of commercial prices that would reasonably or customarily be 

charged for each listed service. The basic categories for which costs were requested are: 1) 

vehicle/engine mileage accumulation, 2) emissions generation, collection, and 

characterization, 3) emission generation for biological testing, and 4) miscellaneous testing. 

Considerable effort went into refinement of these documents to ensure that they 

included enough detail to allow correct interpretation of the questions, yet were concise, to 

relieve the respondents from as much burden as possible. Initially, eight supplementary 

documents were to be sent with the package to provide complete details on the proposed 

legislation and methods to be employed for the emissions generation and measurement. 

Investigators at SwRI, with the Work Assignment Monitor at the EPA, however, concluded 

that it would be preferable to make it known that this information was available and to offer 

it rather than include it in the initial mailing. 
P.6 

After the response forms were sent out, each respondent was contacted to confirm 

receipt and determine if any items needed immediate clarification. The respondents were 

then contacted weekly to check the status of their responses and to offer further background 

information. Following receipt of the response form from the participant, additional calls 

were necessary in some cases to clarify a response. 

In addition to collecting cost information from the participating laboratories, SwRI was 

also responsible for evaluating the costs supplied for each task and determining the most 

reasonable price or range of prices. Many of the prices given were based on different 

assumptions regarding such things as set up costs, calibration, and maintenance. These 

assumptions were considered when developing a reasonable price estimate. SwRI has, to the 

extent possible, accounted for significant differences in the costs provided. No judgement is 

made whether any price is too high or low. The most reasonable price is related to the mean 

price, after accounting is made for different assumptions and for obvious outliers. The goal 

for this project was to obtain at least six prices per category; if less than six prices were 

obtained, the reasons are presented. Where no prices were obtained for a particular category, 

SwRI has provided an estimate, and indicated it as such. 

SwRI was also assigned the task of estimating facility modification costs and 

compihng prices of new, American-made engines. Estimation of facility modification costs 

was achieved by interviewing personnel within SwRI and from other companies who have 

experience in equipping faculties for emissions measurement. Prices for new engines were 

gathered by contacting manufacturers' retail outlets or distributors. The results are 

discussed below. 
P.7 

RESULTS AND DISCUSSION 

Each of the nine laboratories contacted returned the survey and all responded to at 

least some of the categories. The information provided by the respondents is presented in 

tables below. Accompanying each table are footnotes for caveats supplied by each laboratory 

or explanations to clarify assumptions made in arriving at the costs. In some cases a range 

of prices was reported. In such cases, the midpoint price was used in the table and the range 

of prices was indicated in the footnote. Where appropriate, prices were rounded to the 

nearest $5 for the average and reasonable price. The identity of the laboratory supplying a 

price has been concealed by randomly assigning a number to each of the nine participants. 

The footnotes with each table are numbered to relate them to the laboratory supplying the 

data. That is, a footnote beginning with the number 5 refers to the Une of data in the table 

above corresponding to Laboratory 5. 

The data are presented in the order requested on the response form. The column 

headings in the tables are abbreviated and are intended to concisely relate the data in that 

column to the question on the survey. To clarify those abbreviations, the questions are listed 

in text before presentation of the data table. Discussion of the data follows. 

VEHICLE/ENGINE MILEAGE ACCUMULATION COSTS 

Respondents were asked to provide the cost per mile of operating a vehicle on a test 

track with a hired driver and the cost per mile or mile-equivalent for accumulating mileage 

using a chassis dynamometer and an engine dynamometer. They were also asked if these 

rates vary depending on number of miles (and if so, how), and to list maintenance and fuel 

costs if they were not included. The results are presented in Table 1 for Light-duty Vehicles 

and in Table 2 for Heavy-duty Vehicles. 

Light-duty Mileage Accumulation 

Discussions with the respondents indicated that several were familiar with operating 

on a set driving route rather than a test track. These data were judged to be comparable and 

are reported without distinction. The total cost ranged from $0.70/mile to $1.25/mile. 

Although the price reported by Laboratory 9 for mileage accumulation without fuel and 

maintenance was significantly lower than the others, their fuel cost was almost five times 

higher than the other laboratories reporting fuel cost, bringing their total cost quite close to 

the median cost. The various laboratories used slightly different assumptions to arrive at 

fuel and maintenance costs; but because not all respondents reported fuel and maintenance 

costs as separate items, only the total cost can be compared. The cost for mileage 

accumulation on a test track was reported by one laboratory as a range from $0.50 to $1.00 

per mile depending on the nature of the program. One discounted their rate from $1.00 per 

mile to $0.60 per mile over 400 miles. Another offered a 10% discount after 500 miles. 

Assuming that the miles accumulated for this program will be related to conditioning the 
TABLE 1. LIGHT DUTY MILEAGE ACCUMULATION COSTS 

Ln 

LAB 

NUMBER 

1 

2 

3 

4 

5 

6 

7 

8 

9 

MIN PRICE 

MAX PRICE 

AVG PRICE 

REASONABLE 

TEST TRACK, (S/MILE) 

MILEAGE 

ACCUM 

0.70 

1.00 

NR 

NR 

1.00 

0.50 

0.75 

0.80 

0.33 

MAINTX 

COST 

NR 

NR 

NR 

NR 

0.05 

0.10 

incl 

NR 

0.18 

FUEL 

COST 

0.13 

NR 

NR 

NR 

0.075 

0.10 

incl 

incl 

0.47 

•viTQTAL-;:,:. 

COST 

0.83 

1.00 

NR 

NR 

1.125 

0.70 

0.75 

0.80 

0.98 

0.75 

1.125 

0.88 

0.79 

CHASSIS DYNO, ($/MILE) 

MILEAGE 

ACCUM 

1.60 

NR 

NR 

1.00 

1.25 

1.00 

0.75 

NR 

6.00 

MAINT. 

COST 

NR 

NR 

NR 

incl 

0.05 

0.10 

incl 

NR 

0.18 

FUEL 

COST 

0.13 

NR 

NR 

incl 

0.075 

0.10 

incl 

NR 

0.47 

TOTAL 

COST 

1.73 

NR 

NR 

1.00 

1.375 

1.20 

0.75 

NR 

6.65 

0.75 

6.65 

2.12 

1.21 

ENGINE DYNO. ($/MILE) 

MILEAGE 

ACCUM 

1.75 

NR 

NR 

2.00 

1.00 

0.50 

1.60 

NR 

5.00 

MAINT. 

COST 

NR 

NR 

NR 

incl 

0.07 

0.10 

incl 

NR 

0.18 

FUEL 

COST 

0.13 

NR 

NR 

incl 

0.075 

0.10 

incl 

NR 

0.47 

TOTAL 

COST 

1.88 

NR 

NR 

2.00 

1.125 

0.70 

1.60 

NR 

5.65 

0.70 

5.65 

2.16 

1.46 

NR = NOT REPORTED 

incl = included in mileage accumulation price 

(1) Rates were quoted on hourly basis; conversions were made by using 30 mph for test track, and 50 mph for chassis and 40 mph for engine dynos. 

(2) Rate drops to $0.60/mile for 400-50,000 miles. Rate does not include fuel, maintenance, and insurance costs. Fuel rate dependent on fuel selected. Maintenance is 

charged at $75/hr plus parts. 

(4) For the engine dyno prices, this rate assumes a 50,000 mile minimum test plus a set up fee of $5000. 

(5) Cost will decrease with increasing time/miles (amount not specified). Fuel cost based on $1.50/gal at 20 mpg. 

(6) Prices based on 50 mph for mileage accumulation, 40 mph for maintenance. Fuel cost based on $1.00/gal and 20 mpg. Preparation charges depend on vehicle, engine, etc. 

(7) Prices listed for test track and chassis dyno are considered median prices; prices will range from $0.50 to 1.00 per mile depending on nature of program. Also, the cost for 

running on the chassis dyno will not be less than the road cost. Costs decrease 10-30% with increasing time/miles. For engine dyno, rate does not include engine installation, 

which would cost $2,500 to $16,000 depending on the complexity of the engine and modifications required of the test cell. 

(9) Prices are discounted 10% after 500 miles. Prices for test track are based on $10/hour, 30 mph, plus fuel costs figured at 15 mpg, $7.00/gal. LD chassis prices based on $300/hr, 

50 mph. LD engine prices based on $200/hr @ 40 mph. 
TABLE 2. HEAVY DUTY MILEAGE ACCUMULATION COSTS 

a\ 

LAB 

NUMBER 

1 

2 

3 

4 

5 

6 

7 

8 

9 

MIN PRICE 

MAX PRICE 

AVG PRICE 

REASONABLE 

TEST TRACK, ($/mile) 

MILEAGE 

ACCUM 

0.70 

NR 

4.00 

NR 

1.00 

1.00 

1.25 

NR 

NR 

MAINTcost 

NR 

NR 

0.05 

NR 

0.10 

0.15 

incl 

NR 

NR 

FUEL 

COST 

0.40 

NR 

0.40 

NR 

0.30 

0.20 

incl 

NR 

NR 

TOTAL 

COST 

1.10 

NR 

4.45 

NR 

1.40 

1.35 

1.25 

NR 

NR 

1.10 

4.45 

1.91 

1.28 

ENGINE DYNO. ($/mile) 

MILEAGE 

ACCUM 

1.75 

NR 

2.75 

2.50 

1.00 

1.00 

2.30 

NR 

NR 

MAINT. 

COST 

NR 

NR 

0.05 

incl 

0.15 

0.15 

incl 

NR 

NR 

FUEL 

COST 

0.40 

NR 

0.40 

incl 

0.30 

0.20 

incl 

NR 

NR 

TOTAL 

COST 

2.15 

NR 

3.20 

2.50 

1.45 

1.28 

2.30 

NR 

NR 

1.28 

3.20 

2.15 

2.15 

NR = NOT REPORTED 

incl = included in mileage accumulation rate 

(1) Rate for test track is based on $21/hr @ 30 mph. For engine dyno, rate is based on $70/hr, 40 mph. Fuel cost is 

based on $2/gal and 5 mpg. 

(3) Test track rate is decreased to $3.50/mile for greater than 10,000 miles. For engine dyno, rate for light- and 

heavy-HD is $3.00/mi. 

(4) For the HD engine dyno rate, this assumes 50,000 miles per test; the rate therefore includes $10,000 set up fee. 

(5) HD fuel cost is based on $1.50/gal at 5 mpg. 

(6) Mileage accumulation cost is based on 50 mph equivalent. Fuel cost is based on $1/gal at 10 mpg. Preparation charges 

are dependent on vehicle/engine. Engine dyno rates range from $0.50 to $1.50 per mile; rate shown is average. 

(7) For the HD engine dyno, the rates vary tremendously depending on nature of the research. For the following classes of 

of heavy-duty engines, the rates range as follows: Light HD 0.85-2.75, Medium HD 1.00-3.25, Heavy HD 1.15-3.75 

Engine installation is extra and can range from $2,500 to $16,000 depending on complexity. Rates for test track 

range from $1.00 to $1.50 per mile. Rates shown are averages. 
P.10 

engine/fuel system for the particular F/FA to be used for emission generation, the rates for 

programs on the order of 4000 miles are most appropriate for estimating the reasonable cost. 

On that basis, one can select the low price from the ranges reported (or apply the discounts 

offered) to arrive at $0.79/mile as a reasonable cost. 

There was a very large variation in costs reported for mileage accumulation using a 

chassis dynamometer, ranging from $0.75/mile to $6.65 per mile. Laboratory 9 reported 

$6.65 per mile, which was based on $300/hour at 50 miles per hour (mph). Their fuel and 

maintenance costs were also rather high. Their reported fuel price was $7.00 per gallon, 

which suggests they were likely assuming the use of specialty fuels. Because the cost 

reported by Laboratory 9 is more than two standard deviations greater than the median 

price, it was not used in formulating the reasonable price. Factoring in the various discounts 

for 4000 miles, $1.21 per mile is estimated to be a reasonable price. 

Prices for engine dynamometer mileage accumulation followed a similar pattern: costs 

reported by Laboratory 9 were more than two standard deviations greater than the mean 

price. That cost is again considered an outlier and was not considered in arriving at the 

reasonable price of $1.46 per mile. 

Heavy-duty Mileage Accumulation 

Only five laboratories reported prices for this category. As was seen above for chassis 

and engine dynamometers, for heavy-duty mileage accumulation via test track, there was one 

price which was two standard deviations higher than the mean for the group. Rates can vary 

tremendously with the program requirements. However, there being no other explanation, 

the $4.45 price was excluded. A reasonable price for heavy-duty mileage accumulation by 

test track of $1.28/mile was estimated by selecting prices based on 4,000 miles, as above. 

The price spread for heavy-duty engine dynamometer mileage accumulation was large, 

but not so great as the previous three cases. While there were costs greater and less than 

one standard deviation above and below the mean, the costs were distributed such that there 

were none which were obvious outliers. Thus, by selecting prices based on 4,000 miles, the 

average price of $2.15/mile was estimated to be a reasonable price for heavy-duty engine 

dynamometer mileage accumulation. 
P.11 

EMISSION GENERATION AND COLLECTION 

Light-duty Combustion Emission Generation 

Respondents were requested to supply the following: 

• Price to perform one driving cycle (LA-4 + 505), collect three bags of emissions 

• Price to run consecutive modal cycles reasonably equivalent to the LA-4 and 

collect emissions 

• Price to perform modified FTP (Federal Test Procedure) to allow for the 

collection of particulate and semi-volatile emissions for subsequent 

measurement of particulate matter and analysis of PAH (polynuclear aromatic 

hydrocarbons) and NPAH (nitrogenated polynuclear aromatic hydrocarbons) 

• Price to generate emissions at steady state and collect emissions for 

subsequent analysis. 

The responses are presented in Table 3. 

Prices to perform one driving cycle consisting of the LA-4 + 505 (labeled FTP in the 

table) ranged from $350 to $1,045, the average being $790. The maximum price was three 

times the minimum. However, five of the remaining six samples were reasonably close to the 

average of $790. Laboratory 7 reported a range of $400-$600. If the two extremes are 

dropped, then the average shifts to $820, which is judged to be a reasonable price. 

To run consecutive modal cycles on an engine dynamometer reasonably equivalent to 

the LA-4, the prices ranged from $250/hour to $1,200, with most of the prices grouped around 

$900-$ 1,100. The low figure was the only one that was quoted per hour. Laboratory 7 

reported $500, which was also substantially lower than the main group; however, this was 

reported as a range of $400-$600. The price used for Laboratory 6 is their rate for the sixth 

and subsequent tests (the first through fifth tests cost significantly more). Laboratories 4, 

6, 7, and 8 charge a substantial additional sum to install and set up the engine on the test 

stand. Dropping the $250 price as an outher, the average shifts to $930, which is considered 

a reasonable price. 

The case for the FTP modified to allow collection of particulate and semi-volatile 

emissions for subsequent measurement of PM, PAH, and NPAH is similar to that for the 

unmodified FTP. That is, with the exception of the highest and lowest price, the remainder 

groups closely together. Deletion of the two extremes shifts the average only slightly, making 

$1,145 a reasonable price. 

Reported costs for generating emissions at steady state and collecting emissions for 

subsequent analysis varied tremendously - from $75 to $1,000. The $75 figure was a definite 

outher (this price was verified). The $1,000 price was also deemed an outlier. Deleting those 
10 

TABLE 3. EMISSION GENERATION AND COLLECTION COSTS 

LAB 

NUMBER 

1 

2 

3 

4 

5 

6 

7 

8 

9 

MIN PRICE 

MAX PRICE 

AVG PRICE 

REASONABLE 

LIGHT-DUTY COMBUSTION GENERATION 

FTP 

$1,045 

$985 

NR 

$800 

$900 

$875 

$500 

$350 

$865 

$350 

$1,045 

$790 

$820 

MODAL CYCLES 

(Engine Dyno) 

$895 

NR 

NR 

$1,000 

$1,050 

$1,200 

$500 

$250 

NR 

$250 

$1,200 

$815 

$930 

MOD. FTP 

PM. PAH. NPAH 

NR 

$1,400 

NR 

$1,150 

$1,250 

$1,000 

$620 

$1,175 

NR 

$620 

$1,400 

$1,100 

$1,145 

STEADY STATE 

($/HOUR) 

$225 

$320 

NR 

$700 

$75 

$1,000 

$550 

$400 

$800 

$75 

$1,000 

$510 

$400-$600 

LIGHT-DUTY 

EVAP. GEN 

MOD FTP 4 BAGS 

$330 

$450 

NR 

$400 

$1,350 

$500 

$500 

$540 

$1,500 

$330 

$1,500 

$700 

$450 

HEAVY-DUTY COMBUSTION 

FTP 

NR 

NR 

$1,000 

NR 

NR 

NR 

$2,100 

$3,000 

NR 

$1.000 

$3,000 

$2,030 

$1215-$2850 

MOD. FTP 

PM, PAH, NPAH 

NR 

NR 

$2,000 

NR 

NR 

NR 

$2,225 

$3,100 

NR 

$2,000 

$3,100 

$2,440 

$1970-$2920 

NR = NOT REPORTED 

(2) Price for FTP on LD combustion includes methane analysis, with test being performed using emission test gasoline. 

(3) HD combustion cost does not include setup cost of $4,000. 

(4) For engine dyno, add $10,000-20,000 setup per powertrain; auto transmission only. 

(6) FTP includes analysis of CO, C02, HC, NOx, fuel economy. Price to run modal cycles: $2,000 for first, $1,500 for 2nd-5th, 

$1,200 for subsequent; engine setup extra. 

(7) Prices vary with complexity and length of program, and assume engine is already mounted, checked out, etc. Prices listed 

are midpoints of price ranges: $400-$600 for FTP and Modal Cycles, $520-$720 for modified FTP, $450-$650 for Steady State, 

$1,500-$2,700 for HD FTP, and $1,600-$2,850 for HD modified particulate. Add $2,500-$16,000 to install engine. 

(8) For engine dyno, add $3000 set up fee; the price of $250 is per hour. 

• 
P.13 

two extremes shifted the mean price only $10. However, because the variabiUty in the 

reported prices was so great, the reasonable price is uncertain and is expressed as the range 

$400-$600. 

Evaporative Emission Generation (Light-duty Only) 

Respondents were asked to report a price to generate evaporative emissions according 

to specified procedures: SHED to be equipped with sampling port and sampling pump for 

collection of emissions into Tedlar® bags, and four bags of emissions collected for analysis 

(one bag each collected at the beginning and end of the diurnal test and hot soak test). The 

responses to the above are presented in Table 3. 

For the light-duty evaporative generation, there was a tremendous spread in the 

reported costs. Yet, in this case, the distribution of reported costs indicates that the top two 

costs are separated from the third highest by $810. If the two top prices are excluded, the 

average cost drops to $450 and the standard deviation is drastically reduced as well. Thus, 

a reasonable price is estimated at $450. It should be noted that one respondent remarked 

that the logistics of handling the fuel for the evaporative generation could easily become a 

major undertaking in itself, because the procedure would generate large quantities of waste 

fuel. This waste fuel would have altered composition and vapor pressure and would likely 

have to be re-blended or re-refined. 

Heavy-duty Combustion Emission Generation 

Respondents were asked to report the following: 

• Price to perform exhaust portion of FTP, as described in 40 CFR 86 subpart N, 

and collect one bag and one filter of combustion emissions during the cold start 

segment and one bag and one filter during the hot start segment of the 

transient cycle 

• Price to perform modifications of above procedure to collect particulate and 

semi-volatile emissions for PAH and NPAH measurements (as described for 

light-duty above) 

The response to the above section is also presented in Table 3. 

Prices to perform the FTP for heavy-duty combustion emissions were reported by only 

three laboratories and ranged from $1,000 to $3,000, with the middle laboratory reporting 

a range of $l,500-$2,700. This reflects the true variabiUty of actual costs to perform this 

procedure. ReaUstically then, a reasonable price for this procedure is in the range 

$l,215-$2,850 (the mean ± one standard deviation). 

The modified FTP for heavy-duty combustion emissions to allow for coUection of 

particulate and semi-volatile emissions, for subsequent analysis of PM, PAH, and NPAH, 

ranged from $2,000-$3,000, with one laboratory reporting a range of $l,600-$2,850. Because 

10 
P.14 

the variabiUty of the true costs to perform these procedures is dependent on a number of 

different factors, it is realistic to report a range of $l,970-$2,920 (the mean price ± one 

standard deviation) for the reasonable price. 

CHEMICAL CHARACTERIZATION 

Combustion and Evaporative Emissions Characterization 

The respondents were asked, for the samples coUected above, to give prices for 

performing chemical analyses for the foUowing parameters: 

• Concentration of regulated emissions (40 CFR Part 86) for vapor phase and 

particulate phase emissions for gasoline vehicles, Diesel vehicles, and methanol 

vehicles. 

• Individual species of hydrocarbons with 12 or fewer carbon atoms. 

• Individual species of aldehydes and ketones with 7 or fewer carbon atoms. 

• Individual species of alcohol and ether compounds with 6 or fewer carbon 

atoms. 

• Individual species of PAH (semi-volatile and particulate phases) 

• Total NPAH (semi-volatile and particulate phases) 

The results are presented in Table 4 for the vapor and semi-volatile phases, and Table 5 for 

the particulate phase. 

Vapor Phase 

Costs for regulated emissions in the vapor phase for gasoline engines ranged from 

$150-$1,200, averaging $800. The $150 price was an obvious outher, $450 less than the next 

highest price. Excluding it drives the average to $930, a reasonable price. 

Regulated emissions for Diesel engines were priced from $500-$ 1,400. The 

distribution was such that prices were separated by $225-$250 increments. For that reason, 

no prices were excluded and the average price of $995 is deemed reasonable. 

For methanol-fueled engines, regulated emission characterization costs were reported 

from $450-$l,600, averaging $1,065. The price reported by Laboratory 7 includes total 

hydrocarbons, carbon monoxide, carbon dioxide, oxides of nitrogen, methanol, and 

aldehydes/ketones. The $450 price was significantly lower than its nearest neighbor. 

Excluding it yields an average of $1,170, a reasonable price. 

The distribution of costs for hydrocarbon speciation indicated one possible outher. The 

top cost of $1,500 was $300 higher than the next lower price. The overaU range was $800 

to $1,500, averaging $1,075. If the top price is excluded, then the mean shifts only $70 

downward. A reasonable price is estimated to be $1,005. 

11 
hfTABLE 4. EMISSION CHARACTERIZATION. VAPOR AND SEMIVOLATILE PHASES 

LAB 

NUMBER 

1 

2 

3 

4 

5 

6 

7 

8 

9 

MIN PRICE 

MAX PRICE 

AVG PRICE 

REASONABLE 

VAPOR PHASE 

REGULATED EMISSIONS 

GASOLINE 

NR 

$985 

$1,000 

X .7:NRX::7 

: $150 

•:• • $87 5 

X X $600 

•V:..::NR-':-

:

;X" 

$1,200 

; v :•:•'* $15 0 

•.".x$i:;200 

$800 

$930 

DIESEL 

NR 

$1,250 

$1,000 

NR 

$500 

$1,475 

$750 

NR 

NR 

$500 

$1,475 

$995 

$995 

METHANOL 

NR 

$1,510 

$1,000 

NR 

$450 

$950 

$1,600 

$750 

$1,200 

$450 

$1,600 

$1,065 

$1,170 

HC 

$1,160 

$1,100 

NR 

NR 

$1,500 

$975 

$800 

$1,200 

$800 

$800 

$1,500 

$1,075 

$1,005 

ALDEHYDES 

KETONES 

NR 

$365 

NR 

NR 

$500 

$500 

$600 

$950 

$800 

$365 

$950 

$620 

$620 

ALCOHOLS 

ETHERS 

NR 

$400 

$1,000 

NR 

$425 

$400 

$400 

$750 

$800 

$400 

$1,000 

$595 

$530 

SEMI VOL PHASE 

PAH 

NR 

NR 

NR 

NR 

$500 

NR 

$700 

$950 

NR 

$500 

$950 

$715 

$775 

NPAH 

NR 

NR 

NR 

NR 

$900 

NR 

$700 

$900 

NR 

$700 

$900 

$830 

$775 

NR = NOT REPORTED 

(1) Price for HC speciation per bag is $290. This assumes four bags. 

(2) Methane analysis included in regulated emissions for gasoline. 

(3) Price for regulated emissions includes analysis of particulate phase. 

(7) 'Methanol includes HC, CO, C02, NOx, CH30H, and Aldehydes/Ketones. 

Prices vary greatly with nature of program. Prices range from $400-$ 1,000 for PAH, NPAH. 

• 

• . -
H* 

TABLE 5. EMISSION CHARACTERIZATION, PARTICULATE PHASE 

LAB 

NUMBER 

1 

2 

3 

4 

5 

6 

7 

8 

9 

MIN PRICE 

MAX PRICE 

AVG PRICE 

REASONABLE 

PARTICULATE PHASE 

REGULATED EMISSIONS 

GASOLINE 

NR 

$265 

NR 

NR 

$350 

$400 

$189 

$500 

NR 

$189 

$500 

$340 

$340 

DIESEL 

NR 

$265 

NR 

NR 

$350 

$400 

$189 

NR 

NR 

$189 

$400 

$300 

$340 

METHANOL 

NR 

$265 

NR 

NR 

$350 

$400 

$189 

$500 

NR 

$189 

$500 

$340 

$340 

PAH 

NR 

NR 

NR 

NR 

$500 

NR 

$700 

$950 

NR 

$500 

$950 

$715 

$785 

NPAH 

NR 

NR 

NR 

NR 

$900 

NR 

$700 

$950 

NR 

$700 

$950 

$850 

$785 

NR = NOT REPORTED 

(7) Price is per sample. Prices vary with nature of program. Prices listed are midpoints of price ranges: 

$50-$75 for particulates (assumes three samples required), $400-$1,000 for PAH and NPAH. 
P.17 

Analysis of aldehydes and ketones was priced from $365-$900. The distribution of 

prices was fairly regular. Even if the two extremes are dropped, the median price does not 

shift appreciably. A price of $620 is deemed reasonable for analysis of aldehydes and 

ketones. 

Prices for analysis of alcohols and ethers ranged from $400-$l,000. However, three 

laboratories reported $400 and one reported $425, indicating a bias toward the lower end of 

this range. Excluding the top price, which is separated from its nearest neighbor by $200, 

the average becomes $530. This could be considered a reasonable price because the second 

and third highest prices were clustered at $800 and $750 and were thus included. 

For the remainder of the procedures to be discussed, except Ught-duty preconditioning, 

the goal of six responses was not met. The non-responding laboratories chose not to supply 

or project prices for these categories because they felt they did not have sufficient experience 

to respond. 

Semi-Volatile Phase 

Prices for PAH ranged from $500-$950, with Laboratory 7 reporting a range $400-

$1,000. The situation for NPAH was sinular, with a range of $700-$900. Laboratory 7 again 

reported the range $400-$l,000. Because there were so few data points, it was not considered 

appropriate to exclude any price. In addition, the analyses for PAH and NPAH should not 

differ significantly. To address the discrepancy in the average prices for the two categories, 

aU prices were factored together to arrive at a median, reasonable price of $775. 

Particulate Phase 

For gasoline, Diesel, and methanol fueled engines, the prices to evaluate particulate 

emissions foUowed a similar pattern. The prices were spaced fairly evenly from $189 to $500. 

(For Diesel the range was $189-$400; one less laboratory reported prices.) Because there is 

no obvious outlier, nor a substantial difference in procedure, the average price of $340 for 

gasoline and methanol is reported as the reasonable price for _dl three categories. SwRI does 

not beUeve the price for Diesel particulate measurements should be lower than for gasoline 

or methanol. 

The situation for PAH and NPAH in the particulate phase was nearly identical to that 

for the semi-volatile phase. The range of prices for NPAH ranged from $750-$950. The same 

logic was used to arrive at the reasonable price. That value shifted upward by $10 because 

of the broader range for NPAH for the particulate phase. The reasonable price for PAH and 

NPAH for the particulate phase is estimated at $785. 

14 
P.18 

Special Analysis for Atypical Fuels and Fuel Additives 

A hypothetical situation was presented in which the respondents were asked to 

assiune they had a sample of gasoline fuel mixed with an additive containing copper and 

chlorine. They were then asked: 

• What kind of procedure would be needed to detect and measure copper and 

chlorine? What is the cost? 

• Once detected, what procedures might be used to identify the actual chemical 

compounds which contain these elements. What is the cost? 

Only four of the nine respondents repUed to this section. Their responses foUow below: 

Response One: 

"For the chlorine we wiU use a "U.O.P. 779 Method" and for copper we would possibly 

use either UV or spectrometer methodology. However, a specific method is needed in 

order to detennine between these two theories. For chlorine, the cost is $125 per 

sample, and a period of 3-5 working days is needed for results. Method information 

is needed for the copper detection cost proposal. 

"A typical equation based on the reaction of oxygen and it's [sic] reaction to the 

associated elements. Cost is $100-150 per sample, based on necessary elements in the 

result." 

Response Two: 

"For copper use same method as particulate trapping, and ICP for copper analyses. 

For chlorine run mass spec, on bag sample to obtain total chlorine. Particulate 

trapping $350 for FTP. ICP on samples $80 per phase. Mass spec -$300 to $500 per 

bag. 

"Copper - Ion chromatography of trapped particulates. $420 for aU three phases. 

Organic Chlorine - Mass spec. $300-$500 per bag. Inorganic chlorides - Ion 

chromatography of trapped particulates. $420 for aU three phases." 

Response Three: 

"Analysis of copper and chlorine by X-ray fluorescence. Collection cost as particulate 

on Pallflex filters runs $40 + $60 weighing for particulate matter confirmation. 

Analysis costs $50-$72, depending on quantity. Total cost is then $150-$172. 

"Several methods would have to be tried to identify the actual chemical compounds 

which contain these elements. PossibiUties include mass spectroscopy, PIXE (Protoninduced X-ray Emission, IR (infra-red), and wet chemical methods. Cost could run 

from $150-$1,000 per sample depending on method selected and quantity." 

15 
P.19 

Response Four: 

"Several methods are currently available for analysis of trace metals. Inductive [sic] 

coupled plasma (ICP) is a mature methodology and wiU accomplish detection of these 

metals at ppm levels. Detection itself is inexpensive, however, successfully collecting 

the emission can increase the cost of the procedure. 

"GC-HaU detector of GCMS will identify the actual chemical compounds. The cost is 

somewhat more involved to predict. Range ($200 - $600)." 

EMISSION GENERATION FOR BIOLOGICAL TESTING 

The respondents were asked to provide the potential total costs for performing the 

tasks described previously, given the various hardware scenarios described as foUows: 

Emissions are to be generated over a lengthy period, passed through a dilution 

system, and delivered to animal inhalation exposure cages. All parts of the 

dilution system should be constructed of stainless steel. Either a constant 

volume sampling (CVS) system (40 CFR Part 86) or a constant concentration 

sampUng (CCS) system might be used. Combustion emissions are to be 

generated using chassis or engine dynamometers. Evaporative emissions are 

to be simulated by heating a chamber containing the fuel or additive/fuel 

mixture (rather than using a vehicle and SHED), such that the evaporated 

emissions are withdrawn at a constant rate. The streams are then diluted 

with clean filtered air and administered to test animals via three branches, 

each flowing at a different dilution rate. A control stream consisting of clean 

air, shall also be administered to the test animals. 

Estimates were requested for the total combined cost of generation, dilution, and delivery of 

the emissions to the animal cages. Respondents were instructed not to attempt estimation 

of the animal exposure costs. The responses are presented in Table 6 for Ught-duty and 

Table 7 for heavy-duty and evaporative generation. 

In general, the prices for the categories under emission generation for biological 

testing showed a very large range. It is likely that this is due to lack of experience in 

performing such procedures. Only about half the respondents addressed the Ught-duty 

portion of this section; even fewer repUed to the heavy-duty and evaporative generation 

sections. One respondent dechned to respond because of strong community opposition to 

animal testing. They did not wish to even approximate costs for this section. The responses 

from laboratory 9 are projections. 

To run consecutive cycles on the light-duty chassis dynamometer, reported costs 

ranged from $720-$ 1,880 per day. Three of the prices clustered around $750 per day and the 

16 
y-j 

TABLE 6. EMISSIONS GENERATION FOR BIOLOGICAL TESTING. LIGHT DUTY 

LAB 

NUMBER 

1 

2 

3 

4 

5 

6 

7 

8 

9 

MIN PRICE 

MAX PRICE 

AVG PRICE 

REASONABLE 

LIGHT DUTY COMBUSTION EMISSIONS 

CHASSIS DYNO, CONSECUTIVE CYCLES 

X PAJLY-X 

COST 

$750 

$1,880 

NR 

NR 

$720 

NR 

$750 

NR 

$1,560 

$720 

$1,880 

$1,130 

$880-$1,380 

5-DAY 

WEEK 

NR 

NR 

NR 

NR 

NR 

NR 

NR 

NR 

NR 

•': 7^DAYi 

WEEK 

NR 

$13,560 

NR 

NR 

NR 

NR 

NR 

NR 

NR 

: 

CHASSIS DYNO, ONE SPEED ENGINE OUT 

DAILY 

COST 

$1,350 

$1,200 

NR 

NR 

$300 

NR 

$600 

NR 

$1,560 

$300 

$1,560 

$1,000 

$750-$1,250 

5-DAY 

WEEK 

NR 

NR 

NR 

NR 

NR 

NR 

NR 

NR 

NR 

7-DAY 

WEEK 

NR 

$8,800 

NR 

NR 

NR 

NR 

NR 

NR 

NR 

ENGINE DYNO, CONSECUTIVE CYCLES 

DAILY 

COST 

$615 

NR 

NR 

NR 

$300 

NR 

$600 

NR 

$1,560 

$300 

$1,560 

$770 

$880-$ 1,380 

5-DAY 

WEEK 

NR 

NR 

NR 

NR 

NR 

NR 

NR 

NR 

NR 

7-DAY 

WEEK 

NR 

NR 

NR 

NR 

NR 

NR 

NR 

NR 

NR 

NR = NOT REPORTED 

Costs for 5- and 7-day weeks reported only if different from multiple daily cost. 

(1) Engine dyno price is average of range of $480-$750 per day. 

(5) Plus fuel & setup costs 

(7) Assumes no exotic fuels, no large consumption engine, facility calibrated & approved; does not include facility amortization. 

(9) This is a projection. 

-
TABLE 7. EMISSIONS GENERATION FOR BIOLOGICAL TESTING, HEAVY DUTY & EVAPORATIVE 

oo 

LAB 

NUMBER 

1 

2 

3 

4 

5 

6 

7 

8 

9 

MIN PRICE 

MAX PRICE 

AVG PRICE 

REASONABLE 

HEAVY DUTY COMBUSTION EMISSIONS 

ENGINE DYNO, TRANSIENT 

DAILY 

COST 

$750 

NR 

NR 

NR 

XVNR- X 

NR 

$1,000 

NR 

NR 

$750 

$1,000 

$875 

$750-$1,000 

5-DAY 

WEEK 

NR 

NR 

NR 

NR 

NR 

NR 

NR 

NR 

NR 

7^-pAY 

WEEK 

NR 

NR 

NR 

NR 

:

7.-:--NR'XS. 

NR 

NR 

NR 

NR 

ENGINE DYNO, ONE SPEED ENGINE OUT 

DAILY 

COST 

$480 

NR 

NR 

NR 

$300 

NR 

$700 

NR 

NR 

$300 

$700 

$495 

$330-$655 

5-DAY 

WEEK 

NR 

NR 

NR 

NR 

NR 

NR 

NR 

NR 

NR 

7-DAY 

WEEK 

NR 

NR 

NR 

NR 

NR 

NR 

NR 

NR 

NR 

EVAP. EMISSIONS GENERATION 

EVAP. GENERATION CHAMBER 

DAILY 

COST 

$1,050 

$600 

NR 

NR 

$150 

NR 

$1,000 

NR 

NR 

$150 

$1,050 

$700 

$680-$1,085 

5-DAY 

WEEK 

NR 

NR 

NR 

NR 

NR 

NR 

NR 

NR 

NR 

7-DAY 

WEEK 

NR 

$4,600 

NR 

NR 

NR 

NR 

NR 

NR 

NR 

NR = NOT REPORTED 

Costs for 5- and 7-day weeks reported only if different from multiple daily cost. 

(5) Plus fuel & setup costs 

(7) Assumes no exotic fuels, no large consumption engine, facility calibrated & approved; does not include facility amortization. Price for 

engine dyno one speed is midpoint of $600-$800 range. 

ho 
P.22 

other two were more than twice that, at $1,560 and $1,880 per day. Obviously two 

laboratories felt this would be much more expensive than the other three. Laboratory 7, 

which was one of the lower three, did not include long-term faciUty costs. There being no 

obvious outliers, and so little experience in this work, the reasonable cost is reported as a 

range. The standard deviation for the costs reported was almost $500. A range based on the 

median price ± one standard deviation this large would not be very useful. Therefore, the 

range limits were set based on the median ± one half the standard deviation, yielding a 

reasonable range of $880-$l,380 per day. 

The distribution of costs for steady-state chassis dynamometer ranged from $300-

$1,560 per day. In this case three prices were clustered together at the high end (but still 

with significant spread between them). Again, because there is Uttle experience in this area, 

the reasonable price is reported as the range $750-$ 1,250 per day. As in the previous case, 

the standard deviation was about $500, so the range was again computed as the median ± 

one half the standard deviation. 

Costs reported for the engine dynamometer running consecutive cycles foUowed the 

same range as the previous case, from $300-$l,560 per day. The average was lower, however, 

because one less laboratory reported a price for this category. SwRI does not beUeve that an 

engine dynamometer can be run less expensively than a chassis dynamometer, so the 

reasonable cost was judged to be the same as for a chassis dynamometer running consecutive 

cycles, $880-$l,380 per day. 

So few laboratories reported costs for heavy-duty dynamometer, transient or steady 

state, that the reasonable prices are reported as a range of median price ± one standard 

deviation. For heavy-duty engine dynamometer transient cycles, the reasonable range is 

$750-$ 1,000 and for heavy-duty engine dynamometer one speed, the range is $330-$655 per 

day. 

The range of costs for the evaporative generation chamber is even larger, from $150 

per day to $1,050 per day. Because the $150 price was less than one-fourth the next higher 

price, it was excluded as an outher. The reasonable cost is reported as the range $680-$l,085 

per day, based on the median price ± one standard deviation. 

MISCELLANEOUS COST ITEMS 

The respondents were asked to provide a price to complete one pre-conditioning 

sequence for light-duty and heavy-duty vehicles/engines, and to perform a Reid Vapor 

Pressure (RVP) measurement on an additive/fuel mixture. Results are presented in Table 

8. 

Light-duty preconditioning prices ranged from $60-$500. The two extremes were 

excluded as outliers because they were so far away from the remaining costs. The reasonable 

19 
TABLE 8. MISCELLANEOUS COST ITEMS 

LAB 

NUMBER 

1 

2 

3 

4 

5 

6 

7 

8 

9 

MIN PRICE 

MAX PRICE 

AVG PRICE 

REASONABLE 

PRE-CONDITIONING 

LIGHT DUTY 

$165 

$150 

NR 

NR 

$130 

$350 

$200 

$60 

$500 

$60 

$500 

$220 

$200 

HEAVY DUTY 

$165 

NR 

NR 

NR 

NR 

NR 

NR 

$250/hr 

NR 

$165 

$250 

$205 

$205 

RVP 

$80 

NR 

NR 

NR 

$47 

$68 

$31 

$40 

NR 

$40 

$80 

$53 

$47 

PORTABLE DYNO RENTAL 

LD CHASSIS 

$1,680/DAY 

NR 

NR 

NR 

NR 

NR 

NR 

NR 

NR 

HD CHASSIS 

NR 

NR 

NR 

NR 

NR 

NR 

NR 

NR 

NR 

to 

O NR = NOT REPORTED 

(6) Price for pre-conditioning dependent upon procedure selected; price is midpoint 

of $200-$500 range. RVP prices range from $50 (Grobner) to $85 (Herzog), midpoint price is used. 

(7) Price for pre-conditioning dependent upon procedure selected and ranges from $100-$300, midpoint price is used. 
P.24 

price is thus the revised average, $200, which is not too far from the average of all samples. 

Prices for heavy-duty preconditioning did not range so greatly. The reasonable price is the 

same as the average, $205. 

Prices for Reid vapor pressure ranged from $31-$80. The $80 appeared to be an 

outher. Excluding it brought the reasonable price to $47. 

The respondents were further asked if they had ever had reason to rent a portable 

light-duty chassis dynamometer or a portable heavy-duty engine dynamometer, and if so, 

what the cost was. Only one laboratory had any experience in renting such equipment. They 

reported $1,680 per day for the portable chassis dynamometer. 

Acquisition and Construction Costs for Emissions Testing Systems 

SwRI researched the cost of purchasing, fabricating, and constructing equipment and 

systems needed for various tasks that may be required under the F/FA testing program. 

These data are presented in the following paragraphs, starting with the cost for new, 

American-made engines, continuing with portable dynamometers and portable test cells, and 

concluding with faciUty modification costs. 

Dealers in the South-Central Texas area were contacted to obtain price estimates for 

new, highway-certified engines. Based on five price estimates, the average price of a new, 

heavy heavy-duty Diesel engine is $18,550. Using estimates from each of the "Big Three," 

the average price for a mid-size Ught-duty gasoline engine is $3,438. The figures are 

presented in Table 9. 

Several manufacturers of dynamometers were contacted to determine availabihty of 

portable Ught-duty chassis and heavy-duty engine dynamometers. It must be stated that the 

use of the term "portable" conveys only transportable in this case. The systems, along with 

the control equipment, dilution and sampling trains, and data acquisition equipment, would 

be very large, extremely heavy, and would require connection to external utihties. The 

makers do not generaUy market their systems as portable, yet they provided estimates. One 

maker had one that could be mounted on a semi tractor trailer if stiffening supports were 

added. It has a capacity of 250 road horsepower and 120 mph, with a purchase price of 

approximately $20,000 (not including the price of the semi tractor trailer). A system 

configured with variable inertia flywheels would be substantiaUy more, on the order of 

$90,000, and would need a substructure to support it. Another maker estimated $45,000 to 

$57,000 for a portable chassis dynamometer, depending on data acquisition equipment. This 

manufacturer estimated from $6,000 to $21,000 for engine dynamometers (no controls) with 

capacity ranging from 600 to 1500 horsepower. 

Another manufacturer which is marketing "IM 240 machines" was contacted. These 

machines are light-weight, above-floor roll dynamometers designed specificaUy for use in 

21 
TABLE 9. NEW ENGINE COSTS 

MIDMANUFACTURER 

CHRYSLER 

FORD 

GENERAL MOTOR 

AVERAGE PRICE 

SIZE LIGHT-DUTY GASOLINE 

MODEL 

3.5 L V-6 

3.0 L V-6 

3.1 L V-6 

HORSEPOWER 

RATING 

214 

140 

140 

A - PRICE X 

ESTIMATE 

$4;290 

$3,200 

$2,825 

$3,438 

HEAVY, HEAVY-DUTY DIESEL 

MANUFACTURER 

CUMMINS 

CUMMINS 

CUMMINS 

DETROIT DIESEL 

DETROIT DIESEL 

AVERAGE PRICE 

MODEL 

33E SELECT 

N14 SELECT 

N14 SELECT 

SERIES 60 

6V92A 

HORSEPOWER 

RATING 

330 

330 

430 

300-450 

300-375 

PRICE 

ESTIMATE 

$18,000 

$19,500 

$21,250 

$18,000 

$16,000 

$18,550 

to 

to 
P.26 

State emissions testing programs. A price range of $25,000 to $40,000, depending on 

quantity, was reported. They also produce a smaller, Ughter machine for repair shops to use 

which wiU seU for under $10,000. It is a simpler machine with limited capabiUties. No 

technical details were available yet. This company estimated that a portable heavy-duty 

chassis dynamometer could be produced for $40,000. 

Conversations with firms having experience with operating and designing 

transportable test ceUs (complete systems including dynamometer, CVS, data acquisition, 

etc.) yielded the foUowing information. For a turn-key, transportable, steady-state engine test 

ceU, the cost would be approximately $1.7 million. Transient capabiUties would drive the cost 

to about $2.7 milUon. Interviews held with a company that acquired one in the 1971-73 time 

frame revealed that it cost in excess of $1 milUon at that time. Thus, the estimates to build 

one today seem plausible, if not low. 

SwRI was also assigned to formulate a rough cost estimate for the faciUty 

modifications necessary to equip a biological testing laboratory with emission 

generation/dilution/deUvery capabiUties. The foUowing estimates are based on previous 

experience of SwRI in constructing emission test facUities. For instaUation of a complete, 

"fully dressed" transient engine test ceU including dilution tunnel, dynamometer, controllers, 

etc., and the dilution and delivery set up, (not including the animals, cages, or animal care) 

the cost would be approximately $1.3'million. For a steady-state test faciUty, cost would be 

approximately $0.8 milUon. These estimates assume that the building already exists and the 

equipment is to be instaUed adjacent to the animal area. Also not included is the cost of the 

engine. That adds about $21,000, in addition to $4,000 to $16,000 to install the engine, 

caUbrate and approve the test ceU. 

23 
P.27 

CLOSING 

SwRI has collected and compiled the cost data for the tasks requested in the statement 

of work. The data was collated and reported to account for, as much as possible, any 

differences in the underlying assumptions associated with those prices. The cost data for 

each category were then reviewed and where it seemed appropriate, certain costs were 

excluded to formulate a reasonable cost or range. It is our hope that these data wUl be 

helpful to the Agency in achieving its goals. 

24 
P.28 

APPENDDXA 

SwRI Cover Letter 
P.29 

SOUTHWES T RESEARC H INSTITUT E 

6220 CULEBRA ROAD • POST OFFICE DRAWER 28510 • SAN ANTONIO. TEXAS. USA 78228-0510 • (210)684-5111 • TELEX 244846 

Date 

Name 

Address 

City 

Subject: Request for participation in "Motor Vehicle Fuel and Fuel Additive Emissions 

Generation and Speciation Costs," SwRI Project 08-5374-003, Work Assignment 

0-3 under Contract 68-C2-0144 

Dear 

As I discussed with you during our telephone conversation on March _th, Southwest 

Research Institute (SwRI) is working under contract to the U.S. Environmental Protection Agency 

(EPA) to gather data on costs for performing various tasks which may be included in an 

upcoming EPA final rule. The objective of the contract is to gather sufficient data to allow the 

EPA to estimate the cost to implement the rules proposed under section 211 (b)(2) of the Clean 

Air Act. The EPA has prepared a letter of introduction that explains the program and requests 

your cooperation. The letter from the EPA is attached. 

The proposed rules will require fuel and fuel additive (F/FA) manufacturers to test and 

submit information on the emissions of motor vehicle fuels and additives, their effects on public 

health and welfare, and their effects on vehicle emission control performance. The testing 

program is expected to require the generation of F/FA combustion and noncombustion 

evaporative emissions under controlled conditions, using appropriate vehicles, engines, and/or 

chambers. In addition, the chemical content of the emissions will be characterized according to 

methods prescribed by the EPA. The program may further involve the delivery of such generated 

emissions in a pre-defined manner to animal exposure chambers over extended periods of time 

(i.e., 6 hours per day for up to two years) to assess the health effects of prolonged, low-level 

exposure to these F/FA emissions. 

We acknowledge that the preparation of a reply will be time consuming. To encourage 

companies to provide refined cost data, a copy of the EPA approved final report will be given 

to each participating company at the conclusion of the work assignment (the participating 

companies will not be identified in the report). This report will provide an equal set of data to 

all participants. 

S A N ANTONIO . TEXA S 

HOUSTON. TEXAS • OETROIT. MICHIGAN • WASHINGTON. DC 
Southwest Research Institute is an independent, not-for-profit organization providing 

research and development services in a variety of areas on a contract basis. We are accustomed 

to providing confidentiaUty in all aspects of our work and will handle the price information 

gathered in this program accordingly. Neither the EPA or SwRI will make public the names of 

any included companies in connection with any specific price information, nor will the prices 

supplied be considered official business quotes or estimates. 

This package contains a "fill in the blank" form on which you are to provide your 

responses. Background information can be provided at your request. Copies of the draft rules 

and detailed descriptions of the methods and equipment called for in the procedures are available. 

Finally, there is a postage-paid envelope in which to return your response form. 

The EPA realizes that few, if any, laboratories will be able to provide all the services 

required by the proposed rules. Therefore, we request that you focus your response on the 

sections for which you can provide services presently or may potentiaUy provide at a future date. 

If you do not provide a service for which a cost estimate is requested, but you are able to project 

what you might reasonably charge for the additional procedure should you obtain the needed 

equipment and expertise, please do so and indicate that it is a projection. 

Should you have any questions or comments for me, please caU me at 210/522-5422 

(8:00-5:00 Central Time) If I am not at my desk, kindly leave a detailed message on my voice 

mail. The representatives within the EPA to contact are Sheri Dunatchik (313/668-4387) and 

Robert Johnson (313/668-4393). I will greatly appreciate it if you can return your response 

within one week. Please let me know if there is anything I can do to help. Thank you for your 

participation. 

Very truly yours, 

Patrick M. Merritt 

Research Scientist 

Department of Emissions Research 

enclosures (3) 
P.31 

APPENDIX B 

EPA Letter of Introduction 
P.32 

^ *«>«•*_ 

w UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

ANN ARBOR. MICHIGAN 48105 

%«***> 

» ^ ANN AKBUK. MILHIbAN 4B1U3 CCD 1 7 PQO 

OFFICE OF To Whom It May Concern: AWA^^AD-ATION 

The United States Environmental Protection Agency (EPA) is in 

the process of developing final regulations for the registration of 

motor vehicle fuels and fuel additives (F/FAs) as required by 

Section 211 (b) (2) of the Clean Air Act (CAA) . This section 

requires F/FA manufacturers to test and submit information on the 

emissions of motor vehicle fuels and additives and their effects on 

public health, public welfare, and vehicle emission control 

performance. A Notice of Proposed Rulemaking was previously 

published in the Federal Register on April 15, 1992 (57 FR 13168). 

The testing program to be promulgated under Section 211(b)(2) may 

possibly involve the controlled generation of F/FA combustion and 

non-combustion ("evaporative") emissions using appropriate 

vehicles, engines, and/or chambers, and the characterization of the 

chemical content of these emissions according to methods prescribed 

by EPA. 

As part of the final rulemaking, EPA is required to assess and 

make public the estimated costs of the program. To assist this 

effort, we have requested Southwest Research Institute (SwRI) to 

identify typical commercial prices associated with various aspects 

of the generation and characterization of combustion and 

evaporative emissions, as well as the controlled dilution and 

direct delivery of such emissions to animal exposure chambers for 

health effects testing. The laboratory services for which we have 

requested commercial prices are currently only under consideration 

for inclusion in the program, and will not necessarily be required 

under the final regulations. 

We wish to emphasize that SwRI is conducting this work at our 

request Tinder an existing contract with EPA (Contract No. 68-C2-

0144, Work Assignment 0-3) . SwRI is not attempting to obtain this 

information for its own business interest. A copy of the EPAapproved final report will be distributed to participating 

companies; however, the participating companies will not be 

identified by name. 

Your company's cooperation in this project is entirely 

voluntary, but would help to improve the accuracy of our program 

cost estimates and would be greatly appreciated. If there are any 

questions or concerns related to this matter, please contact Sheri 

Dunatchik (313-668-4387) or Robert Johnson (313-663-4393) of the 

U.S. EPA National Vehicle and Fuel Emissions Laboratory. 

Sincerely yours, 

Chester/J. France, Director 

Regulation Development and Support Division 
P.33 

APPENDK C 

Response Form 
P.34 

RESPONSE FORM 

Motor Vehicle Fuel and Fuel Additive Emissions Generation and Speciation Costs 

The tasks for which the EPA has requested SwRI to obtain cost estimates are listed below. "Cost estimate" 

means the commercial price which would reasonably or customarily be charged to a customer requesting the particular 

service. A price range may be given where appropriate. Any assumptions underlying the cost estimates should be 

indicated. 

In some cases, separate cost estimates are requested for different basic scenarios, e.g., light-duty vs heavy-duty 

vehicles, and/or chassis vs engine dynamometers. If the price of a given task is unaffected by these different 

scenarios, only one set of data should be given. However, please indicate if this is the case. 

The basic tasks are organized into three categories: 1) vehicle/engine mileage accumulation requirements, 2) 

emission generation and chemical characterization procedures, and 3) emission generation requirements for biological 

testing purposes. In addition, a fourth category of miscellaneous cost data is requested. A table of contents is 

presented below to aid in locating sections of interest. 

Vehicle/Engine Mileage Accumulation 

Light-Duty 2 

Heavy-Duty 2 

Associated Costs 3 

Emission Generation and Chemical Characterization 

Light-Duty Combustion Emission Generation 4 

Heavy-Duty Combustion Emission Generation 4 

Evaporative Emission Generation (Light-Duty Only) 5 

Emissions Characterization 6 

Special Analysis for Atypical Fuels and Fuel Additives 7 

Emission Generation for Biological Testing 

Combustion Emissions fl 

Evaporative Emissions fl 

Miscellaneous Cost Items 9 
P.35 

page 2 

VEHICLE/ENGINE MILEAGE ACCUMULATION 

(Please provide cost to accumulate miles on vehicle/engine for method proposed) 

A. Light Duty (Gasoline) 

1. Vehicle operated on a test track, hired driver 

a. Cost/mile 

b. Does this rate vary depending on the number of miles? If so, how? 

2. Chassis or engine dynamometer 

a. Cost/mile or cost per mile-equivalent (specify method used to convert from hourly rate) 

Chassis: 

Engine: 

b. Does this rate vary depending on the number of miles? If so, how? 

Chassis: 

Engine: 

S. Heavy Duty (Diesel) 

1. Vehicle operated on a test track, hired driver 

a. Cost/mile 

b. Does this rate vary depending on the number of miles or the heavy-duty engine class?1 If so, 

how? 

2. Engine dynamometer 

a. Cost/mile equivalent (specify method used to convert from hourly rate) 

'The three diesel heavy-duty engine classes are: 1) light heavy-duty (useful life = 110,000 miles), 2) medium heavy-duty (useful 

life = 185,000 miles), and 3) heavy heavy-duty (useful life = 290,000 miles). 
P.36 

page 3 

b. Does this rate vary depending on the number of miles or the heavy-duty engine class? (See 

footnote 1.) If so, how? 

C. Associated Costs 

1. Are maintenance and/or fuel costs included in the mileage accumulation costs given above? yes/no 

(circle one) 

2. If so, which costs are included? Maintenance/fuel/both (circle one) 

3. For those costs not included, please fill in the chart below. (For fuel costs, in addition to providing 

cost/mile, please also provide the miles/gallon and $/galion rates.) 

Cost 

Mileage 

Accumulation 

Method 

Vehicle 

(Test Track) 

Chassis 

Dynamometer 

Engine 

Dynamometer 

Maintenance Cost 

(Cost/mile) 

Light-Duty Heavy-Duty 

77.-.\.y-.:,iA;AA7,]7-

Fuel Cost 

(Cost/mile, mile/gallon, $/gallon) 

Light-Duty Heavy-Duty 

. •Ss*'1 . ; " •» '|x x ",*„ ,'" ^ \XJSJ& 
P.37 

page 4 

EMISSION GENERATION AND CHEMICAL CHARACTERIZATION 

/. Emission Generation 

A. Light-Duty Vehicle Combustion Emission Generation: 

1. Price to perform one driving cycle, consisting of the standard LA-4 + 505 portions of the FTP, and 

collect three sample bags of emissions for subsequent analysis. (Chassis Dynamometer) 

2. Price to run consecutive modal cycles reasonably equivalent to the LA-4, and collect emissions for 

subsequent analysis. (Engine Dynamometer) 

Price to perform a modified F P to allow for the collection of particulate and semi-volatile emissions 

for subsequent measurement of particulate matter (PM)2 and for analysis of PAH and NPAH3. The 

PM collection method specified in the F P is to be used, with the addition of a porous polymer bed 

immediately downstream from the particulate filter for capture of semivolatile emissions. 

4. Price to generate emissions at steady state and collect emissions for subsequent analysis. (Specify 

time period, e.g. per hour.) 

B. Heavy-Duty Engine Combustion Emission Generation 

1. Price to perform the exhaust portion of the F P as described in 40 CFR 86 subpart N, collecting one 

bag and one filter of combustion emissions during the cold start segment and one bag and one filter 

during the hot start segment of the transient cycle. 

2

 Measurement of particulate matter in light-duty exhaust emissions will become standard beginning in 1994; 

3Polycyclic aromatic hydrocarbons (PAH) means the class of hydrocarbons whose molecular structure includes more than one 

aromatic ring. Nitrated polycyclic aromatic.hydrocarbons (NPAH) means the class of compounds whose molecular stmcture is the 

same as that of PAH except for the addition of one or more nitrogen compounds on the molecule. 
P.38 

page 5 

2. Price to perform the modifications of the above procedure to collect the particulate and semi-volatile 

emissions for PAH and NPAH measurements, as described in #3 above for light-duty. 

C. Evaporative Emission Generation (Light-Duty Only) 

Price to generate evaporative emissions according to the FP, with the following modifications: 1) The 

vehicle's evaporative emission control equipment shail be disconnected and unplugged when it is inside the 

SHED. 2) Four Tedlar bags of emissions shall be collected for analysis: one bag each collected at the 

beginning and end of the diurnal test and hot soak test. This will require that the SHED be equipped with 

a sampling port and sampling pump (preferably, a teflon diaphragm pump). 
P.39_ 

page 6 

//. Emission Characterization 

The required analyses include the determination of the emission rate of regulated emissions (including PM for both 

light- and heavy-duty) and the speciation of volatile hydrocarbons (HCs), aldehydes, ketones, ethers, alcohols, 

polycyclic aromatic hydrocarbons (PAH), and nitrated polycyclic aromatic hydrocarbons (NPAH). In addition, for fuels 

and additives containing atypical elements4, the chemical fate5 of the atypical components must be determined. 

Please provide a cost estimate for speciating emissions (to be performed on the samples collected in I, above) for the 

following: 

•A TI^AAKA. TMQM^^% 

1) Regulated Emissions 

a) Gasoline Vehicles 

(Total HC, NOx, CO) 

b) Diesel Vehicles 

(Tot. HC, NOx, CO, PM) 

c) Methanol Vehicles 

(OMHCE, NO,, CO) 

2) Hydrocarbon Speciation 

(C12 and less) 

3) Aldehydes and Ketones 

(C7 and less) 

4) Alcohols and Ethers 

(C6 and less) 

5) PAH Speciation 

6) NPAH (Total) 

Vapor Phase Emissions 

';.

 : XX, \ 

[ " "* "'*\ 7t%"x 

Semivolatile Phase 

Emissions 

Particulate Phase 

Emissions 

4Atypical elements are generally defined as those other than carbon, hydrogen, oxygen, nitrogen, and sulfur. 

determining the chemical fate of atypical elements means determining the identity and concentration of individual emission 

products containing such atypical elements. 
P.40 

page 7 

C. Special Analyses for "Atypical" F/FAs (see Footnote 4) 

1. Assume an additive containing copper and chlorine is added to gasoline. 

a) What kind of procedures would be needed to detect the presence of and measure the emission 

rates of these elements in the combustion emissions? 

b) What is the cost for these procedures? 

2. Once the copper and chlorine have been detected in the emissions, what kinds of procedures might 

be used to identify the actual chemical compounds which contain these elements? What is the cost? 
P.41 

page 8 

EMISSION GENERATION FOR BIOLOGICAL TESTING 

Emissions are to be generated over a lengthy period of time, passed through a dilution system, and delivered 

to animal inhalation exposure cages. AH' parts of the system should be constructed out of stainless steel, not 

plastic, PVC, or other similar materials. Either a constant volume sampling (CVS) system (40 CFR Part 86) or 

a constant concentration sampling (CCS) system might be used. 

Combustion emissions are to be generated using chassis or engine dynamometers as indicated below. The 

exhaust stream is then diluted with clean filtered air and administered to test animals via three branches, each 

flowing at a different dilution rate. In addition, a control stream (consisting of clean air) shall be administered to 

test animals. 

The generation of evaporative emissions is to be simulated by heating an evaporative emission generation 

chamber containing the fuel or additive/fuel mixture, rather than using a vehicle and SHED. The dilution/delivery 

system should be designed such that the evaporated emissions are withdrawn at a constant rate, diluted with 

air and directed into three separate but parallel streams for delivery to test animals. 

Estimates are requested for the total combined cost of generation, dilution, and delivery of the emissions to the 

animal cages. Do not attempt to estimate the animal exposure costs. 

COMBUSTION EMISSIONS 

LIGHT DUTY 

chassis dynamometer, 

running consecutive 

(automated) UDDS driving 

cycles (LA-4) 

chassis dynamometer, one 

speed engine out 

engine dynamometer 

consecutive modal cycles 

equivalent to LA-4 

HEAVY DUTY 

engine dynamometer, 

running consecutive 

transient cycles 

engine dynamometer, 

running at one speed 

EVAPORATIVE 

EMISSIONS 

evaporative emission 

generation chamber 

COST PER DAY6 

Assume 6 Hrs of emission 

generation per day 

COST PER WEEK (Only if different from multiple daily cost) 

5-day weeks 7-day weeks 

TTMMIA^ \- T IA '." XX-.'" ^^x&'-x x TAT'ATA '•AAATTA 

'• 

'.A. ' '" —, '•

 >!"" ~ A ' * <* "• 

- \< ~ .: - X ~ X ' - " " •*' <- X*X- X *C A 7*. ,- ;7 

Specify weekday vs. weekend rates if different 
P.42 

page 9 

MISCELLANEOUS COST ITEMS 

I. Cost of intermediate pre-conditioning for light-duty and heavy-duty vehicles/engines, to permit one vehicle to be 

used to generate emissions for more than one F/FA. 

Light-duty cost: 

Heavy-duty cost:_ 

II. Cost for Reid Vapor Pressure (RVP) measurement for fuels/fuel additives: 

If you have ever had reason to rent any of the following items, please indicate what it was used for and how 

much it cost. 

1. portable light-duty chassis dynamometer 

2. portable heavy-duty engine dynamometer