p.1 

OAR Box 1194 

Prepped by Candice Davis 

Document Number: 

72) ll-C-1 

Docket Number: 

A-90-15 

Printed 5/13/2008 10:52:15 AM Sheet 72 of 89 
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i £ * \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Km. y 

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Docket &9°*t5 

ANN ARBOR. MICHIGAN 48105 

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f EPA AIR DOCKET 

OFFICE OF 

AIR AND RADIATION 

Dr. Mark D. Levin 

Manager, Technology Planning and Development 

Fuel Products Group 

Lubrizol Business Development Company 

29400 Wickliffe, OH 44092-2298 

Dear Dr. Levin: 

This is to advise you of the status of your request for an 

EPA reaction to and some type of preliminary approval of the 

Lubrizol copper based diesel fuel additive for use in 

particulate trap-equipped medium and heavy duty trucks, busses, 

and light duty diesel vehicles and trucks. it is 

understandable that you would like to know at this stage EPA's 

reaction to your additive so that you can approach companies 

that might use it to meet EPA standards. 

When you first met with us in Ann Arbor in August 1989, we 

discussed the type of test data you should collect and the 

issues that would need to be addressed by Lubrizol for EPA to 

consider allowing use of the copper additive system. Based on 

those discussions plus those with other interested parties such 

as the California Air Resources Board, you then collected data 

on emissions, exposure, and health effects. This information 

was compiled and presented to us in Ann Arbor (and 

simultaneously to EPA's Field Operations and Support 

Division). 

From the information you have supplied to us, the copper 

additive used in conjunction with a suitable trap appears to 

produce large reductions in diesel vehicle particulate 

emissions relative to use without trap and additive. Also, we 

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would be low due to the low concentration of additive in the 

fuel. The health related analysis you presented also appeared 

encouraging. However, we need to obtain further input to 

verify your facts. 
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According to your analysis and data, regulated and 

unregulated emissions are not increased by the additive, except 

for copper oxide emissions, and the copper oxide emission rate 

is so low even with a high use scenario that human exposures 

would be negligible compared to normal diet intake. If all 

that you told us is true, and we see no errors from our own 

reading of your document, then I would see no reason for EPA to 

object to the use of this or a similar additive. Indeed, it 

seems to represent a very useful approach to particulate 

control. 

The next step is for us to allow review on a very informal 

basis of all your information by other parts of EPA (such as 

the Office of Research and Development and the Office of Toxic 

Substances), the National Highway Traffic Safety 

Administration, and interested public parties. To facilitate 

the public review we plan to place all the information into a 

public docket and announce the availability of the information 

in the Federal Register. We will be surprised if substantive 

adverse comments are received. 

The review process to be followed for the Lubrizol 

copper-based additive is the same process that we have been 

following for the iron-based diesel fuel additive system 

developed by Volkswagen. However, as accounted for in your 

analysis, the potential quantities of copper additive to be 

used are greater than those from the near term use of the iron 

additive. This is because the copper additive is intended for 

use in the large number of trap-equipped heavy duty diesel 

vehicles possible with the 1994 EPA particulate regulations, 

whereas the VW iron additive is currently only intended for use 

in light duty trap-equipped diesel vehicles, which constitute a 

much smaller number and have much lower average fuel 

consumption, and thus less additive usage. 

Each manufacturer applying for certification of an engine 

family that relies on the Lubrizol copper additive would have 

to show that the facts presented by Lubrizol were applicable to 

it, but not necessarily by such complete testing. In 

particular, data or analysis would need to be presented 

indicating that the additive composition(s) to be used would 

not differ from the composition used in your testing in a way 

that could substantially affect the emissions, exposure, or 

health effects. Also, we might like to see some copper 

retention data on each significantly different trap design for 

comparison to the 97% retention rate found in your testing. 

Also, if a light duty vehicle manufacturer or especially a bus 

engine manufacturer wanted to use your additive, we might like 

to see exposure modeling done for a parking garage scenario, 

since this was not done in your analysis for heavy duty trucks 

because such a scenario is not very appropriate for such 

vehicles. 
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As we discussed in the meeting on May 7, final EPA 

approval would consist of granting a certificate of conformity 

to each vehicle or engine using the copper additive. Of course 

all normal certification requirements will have to be met and 

an application for certification submitted before EPA can 

officially consider certification. Also, as with any EPA 

certification, EPA approval would be for only one year at a 

time, and might not be renewed if new evidence regarding the 

possibility of unreasonable risk came to light. Also, if it 

should happen that so many manufacturers adopt a similar system 

on such a large number of vehicles that public exposure would 

be projected to be much more substantial than now expected, a 

rulemaking would not be necessary to cease granting approvals 

if EPA determined that an unreasonable risk were posed. Any 

decision to cease granting approval would need to weigh the 

appropriateness of providing lead time notice to the 

manufacturers against the gravity of any health effects concern 

that might be identified before concluding how quickly 

approvals should be stopped. 

I hope this information is helpful to you and my staff 

look forward to any future discussions with you on the use of 

this additive. 

Sincerely yours, 

Charles L. Gray, Jr. 

Director 

Emission Control Technology Division 

cc: Robert Maxwell, Certification Division 

James Caldwell, FOSD