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

Supplement to Request for Reduced Maintenance Interval, US10 SCR 1

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.

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

tanks in the range of 2.3:1 to 2.5:1. These analyses were performed assuming vehicles o

estimated DEF consumption rate.

Centrally fueled vehicles, usually local ‘vocational’ type applications, can easily maintain a supp

their normal fuel supply. Volvo Powertrain proposes that it should be acceptable for the pmarket to spec a vehicle with as little as 1:1 ratio to reduce the weight impacts of larger tamaximize the return on his investment.
Volvo Powertrain North America, a division of Mack Trucks, Inc.

Supplement to Request for Reduced Maintenance Interval, US10 SCR 2

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

gages are sometimes deleted.). For SCR applications, this translates to a request not to incdashboard. Recognizing that the absence of the gage presents uncertainty concerning the s

Powertrain proposes that a 3:1 minimum 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

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

125 gallon (round)

70L Urea

3 Batt. Box

US10 Version

Fuel capacity: 200 galRepackage as 125gal + 75galDEF tank: 18.5 galDEF / fuel refill ratio: 2.31Eliminates option for 4 batteriesRequires 2” wheelbase increase (adds 6 lb)
Volvo Powertrain North America, a division of Mack Trucks, Inc.

Supplement to Request for Reduced Maintenance Interval, US10 SCR 5

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

66GD SHAPE

27L DEFTANK

H

US10 Version

IN FRAME AIR TANKS

Fuel capacity: 66 galForces “D” shape fuel tank (adds 13lb, $DEF tank: 18.5 galDEF / 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

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

93gRound

4 Batt Box

70L Urea tank

Fuel capacity: 186 galDEF tank: 18.5 galDEF / fuel refill ratio: 2.5Fuel volume would have 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

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

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)DEF tank: 18.5 galDEF / 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

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