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OAR Box 1132 

Prepped by Candice Davis 

Document Number: 

12) ll-C-10 

Docket Number: 

A-86-03 

Printed 4/18/2008 2:24:46 PM Sheet 12 of 122 
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.ft-03 jr-t'io 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

OFFICE OF 

AIR AND RADIATION 

y.r. Thomas C. Young 

Fxecutive Director 

Engine Manufacturer*; Association 

One Illinoi.3 Center 

111 Past Wacker Drive 

Chicago, II 60C01 

Dear Mr, Younq: 

• , Tnank you for your letter describing your concern vith 

c'iesel fuel sulfur and its effect on coriDliance with the 1991 

and 1994 particulate standards. Briefly recapping our efforts 

in this area tc elate, in June of 1986 we distrihutei fcr 

conar.«»nt a preliminary report on the effects of diesel fuel 

cjalitv on emissions ane performance. Vie have been analyrinc 

t>e cedents received on tnis reoort, ana in addition have feen. 

nrenarinn r*.cre detailed analvses of sone oi 

c-3 tn«r effect of 

rolfur die:ide to 

sulfur 

sulfate 

on 

in 

enome wea: 

the Hey issue.- such 

tne conversion of 

tne atmosphere ane the eftcct of 

culf'ir content cn recuirec engine control technology and cost. 

Cne&fc analyses will be compiled into a study to be completed 

near the em! of tnis year. P. decision to r rocee<5 with a formal 

rulemaking aimed at regulating diesel fuel cuality will be pade 

upon completion of this study-. 

One of the r.ore difficult aspects of this study is our 

evaluation of tne types of technologies t.'iat woulc1- he y-ed to 

reet tne 1991 <:nci i?9i heavy-cuty diesel particulate standards 

or. current fuM versu= <-, ios—sulfur fuel an^ any resultant cost 

-''.ifferer.-iai. We nave requester detailed projections oo tnis 

iasue rror all or tbe neavy-outv engine iranufacturers in our 

r.eotir.ns on trap development efforts. To date, a nurcoer of 

risnufacturern nave submitted general statements concerning the 

effect of low sulfur fuel on potential compliance. However, 

little detailed information supported by complete test dat* has 

been received. Such information is critical if EPA i3 to 

accurately quantify the effect of diesel fuel sulfur control on 

the heaw-duty diesel industry, ancl determine the 
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inou^try1 saMl it y to ir-eet th? 1901 anr 100 4 standards with and 

without sulfur control. Thus, any assistance EMA could provide 

in contacting ter.ber companies and encouraging the:n to rrovide 

this infornjetion to FPA as soon as possible would be very 

nclpful. 

In r.unwviry, wo are pushing ahesd v/ith our study, on tne 

basis cf our own analyses and the inforrration we have received 

to d*te. Thnn'". you again for providing your perspective on the 

ircportar-ce cf reoucinq sulfur levels in diesel fuel. I assure 

you cir.-st your coiT^Pts will receive careful consideration in 

our deliix,-ration on tnis issue. 

Sincerely yours, 

ORIGINAL SIGNED EY 

RICHARD D.WILSON 

Richard D. Kilsor 

Director, Office of Moc-ilc Sourcoc 

ir>cc: T. Darlington, SDSB 

J. Anderson, SDSD 

Z\ SpriK, SDSB 

CDf,!s: Darlington: Parsons: 256 5 Plymouth Rd. :X473: 7/2/87 : ID' 

Last reviewed by Cnarles Gray:7/13/87 

AR 8935 
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* I xS^J \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

jgy^ L ^ WASHINGTON, D.C. 20460 

JUN I 3 I9S7 OFFICEOF 

V W I

 AIR AND RADIATION 

Hr. John B. Curcio 

President and Chief Executive Officer 

Hack Trucks, inc. 

ixecutive Offices 

Box H 

Allentown, PA 18105-5000 

Dear Mr. Curcio: 

Thank you for your letter describing your current testing 

and development efforts. We are pleased that significant 

reductions in engine-out particulate emissions are being raaoe, 

and look forward to receiving the results of your testing 

programs, including your recent development work in achieving a 

1991 low mileage target of 0.17 g/BHP-hr with low sulfur fuel. 

and without aftertreatment. While this data will be important 

in evaluating compliance strategies for the low sulfur case, we 

would like to reiterate tliat we also need to know the projected 

compliance strategy(ies) Mack would use for 1991 with current 

sulfur levels. This information is of vital importance in 

comparing the cost of particulate reductions on the vehicle 

(through further reductions in engine-cut emissions, and 

aftertreatment) to the cost of particulate reductions through 

fuel controls. If this could be provided along with the 

compliance demonstration on low sulfur fuel, it would be very 

helpful to our analysis. 

Thank you again for your significant efforts in studying 

these issues and reporting the results to EPA. 

Sincerely, 

(Sgd] J. Ciaig Me i 

J. Craig Potter 

Assistant Administrator 

for Air and Raciation 
annum mininr ' 

UNITED S~fES ENVIRONMENTAL PROTECTION A"C Y 

"i;;tf" ) • . a.: 

ft-8l-ozjr~a-i2-

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JUL f 7 (987 

Mr. John D. Winters 

Vice President 

Caterpillar, Inc. 

1000 N.E. Adams 

Peoria, II 61629 

Dear Mr. Wintersi 

Thank you for supplying additional information on the 

effect of diesel fuel sulfur on particulate emissions from your 

engines. We look forward to meeting with you in Ann Arbor in 

the near future to iiscuss future Caterpillar technology. 

We appreciate your transmittal of the Chevron and Radian 

papers. We were aware of them and, in fact, our own study is 

aimed at resolving some significant uncertainties which we 

perceive to be present in each of them. One omission of both 

of these estimates of the cost effectiveness of diesel fuel 

sulfur control is that they do not take into account the 

"credit" associated with reducing or eliminating the use of 

exhaust aftertreatment controls. This credit is estimated as 

the difference in compliance cost (with either the 1991 or 1994 

standards) between current and low sulfur fuels. In order to 

estimate this value, EPA must project the future compliance 

strategies engine manufacturers are contemplating both with and 

without low sulfur fuel. Any specific information you could 

provide in this area would be very helpful. 

Sincerely, 

JL'CLXYFOR 

J. Craig Potter 

Assistant Administrator 

for Air and Radiation