p.1 

OAR Box 1194 

Prepped by Candice Davis 

Document Number: 

73) ll-C-2 

Docket Number: 

A-90-15 

Printed 5/13/2008 10:52:15 AM Sheet 73 of 89 
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| J5ft\ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Jl 'C'jL 

\*Ul6£j ANN ARBOR. MICHIGAN 48105 

GotM^ fi~?° 'if OFFICE OF 

_ , - AIR AND RADIATION 

^ 6 1990 !' ; 

SEP ! P 

Dr. Mark Levin 

Manager, Technology Planning & Development 

Fuel Products Group 

Lubrizol Business Development Company 

29400 Lakeland Boulevard 

Wickliffe, OH 44092-2298 

Dear Dr. Levin: 

Enclosed for your information is the response we received 

from NHTSA concerning the VW iron-based diesel additive as well 

as our letter transmitting this to VW, which we are sending to 

the public docket. NHTSA suggested that we request an analysis 

from VW on the area of crash safety. Note that your submittal 

on the Lubrizol copper-based diesel additive included somewhat 

more information in this regard than the VW submittal, in your 

presentation to EPA dated May 7, 1990, it is stated that "The 

precautions that are required when handling diesel fuel are 

adequate for handling the additive." However, no specific 

supporting evidence for this statement is cited. Also, the 

Material Safety Data Sheet provided as Appendix H of . your 

report lists TLV's of 0.2 mg/n.3 for copper fume and 1 mg/rn*^ 

for copper mist, but there is no indication of how these relate 

to possible direct exposures to the additive. 

The Lubrizol information is just now being sent to NHTSA, 

so we do not know what the response will be. The response on 

the VW additive may not necessarily be the same as what the 

response will be for the Lubrizol additive, but I wanted to 

alert you that we are inviting NHTSA's comments. 

Sincerely yours, 

Phil Lorang, Chief 

Technical Support Staff 

Enclosures 
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A-^O-15 

ir-C- Z 

'i UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

MAR 8 |989 

OFFICE OF 

AIR AND RADIATION 

MEMORANDUM 

SUBJECT: American Public Transit Association Petition to Modify 

the 1991 Particulate Emission Standards for Urban Buses 

FROM ; / ^ Charles N. Freed, Director "72&~ r /fiul 

y~ Manufacturers Operations Division ^7°~~~\ 

TO: Richard D. Wilson, Director 

Office of Mobile Sources 

My staff and I have reviewed the American Public Transit 

Association's (APTA's) Petition to modify the 1991 particulate 

emission standard for urban buses. We have devised an alternative 

which may be acceptable to APTA. This alternative consists of: 

1. Maintaining the 1991 urban bus particulate matter standard, 

2. Offering Nonconformance Penalties (NCPs) for that standard 

based on a catalyzed particulate trap, and 

3. Reducing the amount of the NCP by a varying percentage 

based on the degree of a manufacturer's participation in 

the particulate emission reduction programs suggested in 

the APTA petition. 

We are currently discussing this alternative with the Office 

of General Counsel and the Emission Control Technology Division to 

determine their reaction to it. 

pa. 
P.4 

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I A- 0*

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US Department 

of Transportation 

National H: jryay 

Traffic Safety 

Administration 

400 Seventh Street. S.W. 

Washington. D.C. 20590 

JUt f m 

JUL 2 7 

Mr. Richard D. Wilson 

Director, Office of Mobile Services 

U.S. Environmental Protection Agency 

Washington, DC 20460 

Dear Mr. Wilson: 

We have reviewed the material you sent us on Volkswagen's (VW) information 

on a new iron-based diesel fuel additive and particulate trap system for 

which it plans to seek EPA approval for use in light-duty diesels. 

You asked that we review this material related to the potential direct 

human exposure to the additive in the event of a crash resulting in the 

rupture of the storage tank. We have no motor vehicle safety standards or 

safety research related to this issue. We suggest that you request VW to 

perform a risk analysis on this proposal. The risk analysis would cover 

such issues as the likelihood of a spillage occurring in the event of a 

crash, the quantity of chemicals, the type and toxicity of the chemicals, 

the volatility of the chemicals, inhalation hazards, flammability hazards, 

and other hazards. 

We would be most pleased to review this new material after it is 

completed. If you would like to H-jgraigg this matter further, please 

contact Mr. Daniel Oahen of my staff on 366-4909. 

Sincerely, 

Barry Felrice 

Associate Administrator 

fon-J^emaking 

0> i

y 

SAFETY BELTS SAVE LIVES 

AUTO SAFETY HOTLINE 

(800)424-9393 

Wasn. D.C. Area 366-0123 

ft** 2.