UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

 National Vehicle and Fuel Emissions Laboratory

                              2565 Plymouth Road

                    Ann Arbor, Michigan 48105-2498

											OFFICE OF

										      AIR AND RADIATION

September 26, 2008

MEMORANDUM

FROM:  	Todd Sherwood

Assessment and Standards Division, US EPA

TO:	   	Docket ID No. EPA-HQ-OAR-2005-0047

SUBJECT:	Meeting with Eaton

EPA staff met with representatives of Eaton on July 29, 2008.  Eaton had
provided a list of questions in advance of the meeting.  Those questions
and the answers we provided are attached.

Attachment

Attachment

Questions from Eaton and EPA responses

1.	What is the latest OBD regulation for heavy duty engines used for
highway application (model year 2011 and beyond)? Where is it located on
epa.gov? Does that include particular requirements on diesel
aftertreatment? If so, is that the only requirement source for
aftertreatment?

	8500-14000# Vehicle	8500-14000# Engine	>14000# Engine

	EPA existing	§86.1806-05	§86.005-17	None

	EPA proposed & soon final	§86.1806-07

§86.1806-10	§86.010-17	§86.010-18	  HYPERLINK
"http://www.epa.gov/obd/regtech/heavy.htm" 
www.epa.gov/obd/regtech/heavy.htm 



CARB existing	CCR 1968.2 (OBDII)	CCR 1971.1 (HDOBD)	  HYPERLINK
"http://www.arb.ca.gov/msprog/obdprog/hdobdreg.htm" 
www.arb.ca.gov/msprog/obdprog/hdobdreg.htm 

  HYPERLINK "http://www.arb.ca.gov/msprog/obdprog/obdregs.htm" 
www.arb.ca.gov/msprog/obdprog/obdregs.htm 



Note:  >8500# = Heavy-duty for EPA; 8500-14000# = Medium-duty for CARB;
>14000# = HD for CARB.

Both the CARB and EPA regulations noted above have similar requirements
for diesel aftertreatment.

2.	Other than the current OBDs for highway application, what are the
regulations for non-road applications (2012+)?

No one in North America has OBD requirements for HD diesel nonroad.  We
hope to work on that in a future rule.  We do have some OBD requirements
for spark-ignition nonroad.  Talk to Alan Stout of EPA at 734-214-4805.

3.	What is the EPA process to get certificate on passing the OBD and
Emissions? Time frame (when should we have the certification before the
production? And how long it will take for certification process)? Will
that process also depend on the production volume?

These are questions that should be posed to a certification
representative.  For >14000# OBD certification questions, contact Jason
Gumbs at 202-343-9271.  For <14000# OBD certification questions, contact
Jason Gumbs or Arvon Mitcham at 734-214-4522.

4.	For performance monitors of each catalysts (reformer, LNT, DPF, SCR
in our case), what are the major requirements? What about sensor aging?
Any requirements on monitoring the sensor aging (particularly dynamic
response variations)?

This requires discussion and study of the regulatory language.

5.	Requirements on the diagnostics trouble code (DTC: triggering and
storing?)? MIL/DTC handling and light on process?

These specifics are detailed in the regulatory language and in SAE/ISO
standards.

6.	Requirements on the service? Communication protocol?

Regarding service information availability requirements, contact Holly
Pugliese at 734-214-4288.  Regarding communication protocol, either SAE
J1939 or ISO 15765 are required.

7.	OBD testing and validation process? Any EOL requests?

For >14000#, the testing requirements are detailed in the regulatory
language.  “EOL” is not a term I know.  If it means “end of
line”, then there are production engine testing requirements for
>14000#, some of which are expected to be done at the end of the
production line.  These are detailed in the regulatory language.

8.	What are the mileages and time periods that each Catalyst is
considered useful life?

Useful life mileages are 110K, 185K, and 435K miles, depending on weight
class.  Required aging of aftertreatment devices for emissions purposes
is being developed by Jason Gumbs and others in the Certification
Division.  Required aging for OBD purposes is being developed within the
context of our soon to be final rule.

9.	Separation requirements on the aged catalysts and UL catalysts?

10.	Due to the nature of this new technology, for some components we
won’t be able to have vehicle aged parts, what is the regulation on
thermally aged catalysts which can be considered equivalent to vehicle
aged parts?

See #8.

11.	Balance of functional monitoring and component based monitoring?

?

12.	OBD requirements for dosing?

Any active reductant/injection system must be monitored as detailed in
the regulatory language.

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