Volvo Powertrain North America, a division of Mack Trucks, Inc.

Supplement to Request for Reduced Maintenance Interval, US10 SCR 1

REDACTED VERSION

Mr. Karl SimonDirector, Compliance and Innovative Strategies DivisionUS Environmental Protection Agency1310 L Street NWWashington, DC, 20005

Dear Mr. Simon:This supplement to Volvo Powertrain’s submittal, Volvo Powertrain Request for Administrator A

Intervals: Refill of Diesel Exhaust Fluid Tanks Utilized with HDOH SCR-Based Emissions 

is intended to offer supplementary information with respect to the minimum maintenance with SCR Diesel Exhaust Fluid refill.

Regulated emissions intervals of 150,000 miles / 4,500 hrs would roughly equate to a DEF tank 

common highway vehicle with fuel capacity of 200 gals and achieving 6.5 miles per gallon this size is terribly irrational if not impossible to package on a modern vehicle. When full wweigh well over 8500 lbs, which represents a grossly significant impact to total cargo cap

Vehicle fuel efficiency would be impacted as well, carrying this significant additional weighcargo weight, which translates to higher CO2 emissions for each ton-mile transported. Band observations, the need to have a reduced interval for DEF refill is more than obvious

When considering more frequent intervals, there are various critical factors that must be consid

redesign of the vehicle, tank sizes much smaller than that which provides a 150,000 mile 

fact, DEF tank sizes resulting in DEF/fuel refill ratios in the range of 2:1 or 3:1 can have simplications. This means that establishing the minimum tank size and associated ratio reimpacts, including total cost, weight and vehicle length, must be limited to a level that minwhile at the same time providing for a refill interval that the infrastructure can support, and integrate into his operation.

If Volvo were required to implement a higher minimum ratio of 5:1, there would be an even grea

and utility. To achieve the 5:1 ratio on the CML-77 vehicle shown on page 10, for exampinstalled. This would bring an additional weight impact of 148 lbs. The weight of the add

up to 5:1 on the VNM chassis on slide 4 would come to 195 lbs, with a tank weight increa325 lbs. Keep in mind that the additional supported weight means a nonlinear increase in bracketry to keep the system stable. The unit on slide 8 would have to sacrifice fuel volum
Volvo Powertrain North America, a division of Mack Trucks, Inc.

Supplement to Request for Reduced Maintenance Interval, US10 SCR 2

REDACTED VERSION

Attached are several discrete examples showing that there are significant chassis modifications required wh

range of 2.3:1 to 2.5:1. These analyses were performed assuming vehicles operating on the upper en

consumption rate.

Centrally fueled vehicles, usually local ‘vocational’ type applications, can easily maintain a supply of DEF in 

supply. Volvo Powertrain proposes that it should be acceptable for the purchaser of a vehicle within th

little as 1:1 ratio to reduce the weight impacts of larger tanks, thereby allowing him to maximize the re

Certain markets require that a minimum of vehicle status information is made available to vehicle operators 

sometimes deleted.). For SCR applications, this translates to a request not to include a DEF gage on 

the absence of the gage presents uncertainty concerning the status of the DEF tank, Volvo Powertrain 

DEF/fuel refill ratio is the minimum necessary.

Very truly yours,Steve BerryDirector, Government RelationsVolvo Powertrain
Volvo Powertrain North America, a division of Mack Trucks, Inc.

Supplement to Request for Reduced Maintenance Interval, US10 SCR 3

REDACTED VERSION

100gRound

Vert DPF 4 Batt Box

US07 Reference Vehicle

Fuel capacity: 200 gal (100gal + 100gal)
Volvo Powertrain North America, a division of Mack Trucks, Inc.

Supplement to Request for Reduced Maintenance Interval, US10 SCR 4

REDACTED VERSION

125 gallon (round)

70L Urea

3 Batt. Box

US10 Version

Fuel capacity: 200 galRepackage as 125gal + 75galSCR system (+219 to 255 lb)DEF tank & fluid: 18.5 gal (+273 lb)DEF / fuel refill ratio: 2.31Eliminates option for 4 batteriesRequires 2” wheelbase increase (+ 6 lb)
Volvo Powertrain North America, a division of Mack Trucks, Inc.

Supplement to Request for Reduced Maintenance Interval, US10 SCR 5

REDACTED VERSION

66GRound

Ve

US07 Reference Vehicle

Fuel capacity: 66 gal
Volvo Powertrain North America, a division of Mack Trucks, Inc.

Supplement to Request for Reduced Maintenance Interval, US10 SCR 6

REDACTED VERSION

66GD SHAPE

27L DEFTANK

H

US10 Version

IN FRAME AIR TANKS

Fuel capacity: 66 galForces “D” shape fuel tank (adds 13lb, $SCR system (+219 lb)DEF tank & fluid: 7.13 gal (+105 lb)DEF / fuel refill ratio: 2.31Requires In-frame air tanks (adds $
Volvo Powertrain North America, a division of Mack Trucks, Inc.

Supplement to Request for Reduced Maintenance Interval, US10 SCR 7

REDACTED VERSION

93gRound

Vert 

4 Batt Box

US07 Reference Vehicle

Fuel capacity: 186 gal
Volvo Powertrain North America, a division of Mack Trucks, Inc.

Supplement to Request for Reduced Maintenance Interval, US10 SCR 8

REDACTED VERSION

93gRound

4 Batt Box

70L Urea tank

Fuel capacity: 186 galSCR system (+219 lb)DEF tank & fluid: 18.5 gal (+273 lb)DEF / fuel refill ratio: 2.5Fuel volume to be sacrificed to accept a larger DEF tank

US10 Version
Volvo Powertrain North America, a division of Mack Trucks, Inc.

Supplement to Request for Reduced Maintenance Interval, US10 SCR 9

REDACTED VERSION

US07 Reference Vehicle

3 Battery Box

93 gallon (Round)

Fuel capacity: 93 gal
Volvo Powertrain North America, a division of Mack Trucks, Inc.

Supplement to Request for Reduced Maintenance Interval, US10 SCR 10

REDACTED VERSION

3 Battery Box (Space Saver)

93 gallon (DShape)

33L Urea Tank

In-Frame Air Tanks

Fuel capacity: 93 galRequires “D-shape” fuel tank (adds $ 18 lb)SCR system (+219 lb)DEF tank & fluid: 8.7 gal (+125 lb)DEF / fuel refill ratio: 2.3Requires In-frame air tanks (adds $Requires “space saver” configuration battery box (adds $ 

US10 Version
Volvo Powertrain North America, a division of Mack Trucks, Inc.

Supplement to Request for Reduced Maintenance Interval, US10 SCR 11

REDACTED VERSION

Cc: (by e-mail)Khesha T. ReedManager, Engine Programs GroupU.S. Environmental Protection AgencyCISD DivisionOffice of Transportation and Air Quality1310 L Street NWWashington, DC 20005Jason GumbsU.S. Environmental Protection AgencyCISD DivisionOffice of Transportation and Air Quality1310 L Street NWWashington, DC 20005David DickinsonAttorney AdvisorUSEPA Headquarters Ariel Rios Building 1200 Pennsylvania Avenue, N. W. Mail Code: 6405J Washington, DC 20460