Background: The California Air Resources Board (“CARB”) Regulation for the Verification Procedure for In-Use Strategies to Control Emissions from Diesel Engines was created and adopted in May, 2002. These regulations will be referred to herein as the “Verification Rules”, or the “Rules”.
The Rules set out a comprehensive process for the “Verification” of diesel emission control strategies (“DECS”), which are technologies that reduce diesel particulate matter (“PM”) and/or nitrogen oxides (“NOx”) emissions. The objective of the Rules was to provide a practical way for operators of older diesel equipment to comply with the new lower emissions targets, without having to replace all their vehicles with brand new equipment, all at the same time. Only the newest equipment comes with OEM emissions control systems that meet the current emissions requirements. To avoid such a huge capital outlay, the Rules allowed operators to retrofit their older vehicles with CARB-verified DECS and keep these vehicles on the road, in full compliance with the latest California emissions standards. This emission control regime was phased in over several years, with 2014 being the year when all pre-2007 trucks in California had to be retrofitted with a diesel particulate filter (“DPF”) in order to remain in compliance.
It is important to keep in mind that the Verification Rules were designed to be a temporary system, which would simply fade away, as older equipment gets replaced with newer engine models, which already have the latest OEM emission control systems, right from the factory. This has been the case for new heavy duty diesel engines sold in California, since 2010.
Even after 15 years, there is much confusion and misinformation about the Rules, which this White Paper will try to address, in the following series of questions and answers.
Are the Verification Rules a good thing?
Of course they are. PM and NOx are toxic emissions, which should be regulated and reduced, by forcing diesel equipment operators to use the best available control technology (“BACT”). Older, high-emission producing equipment should be retired and replaced with newer, certified low-emission equipment, wherever possible and in a cost-effective manner. And where it is not practical or cost-effective to replace older equipment immediately, it makes perfect sense to give operators the option of retrofitting with DECS, until they can replace older engines. The real objective is to reduce emissions and give operators a clear path to compliance, not to scrap perfectly good engines that can be retrofitted, rather than replaced.
Are the Verification Rules mandatory, or optional?
The Verification Rules are optional. Equipment owners do not have to retrofit with a Verified DECS. They are free to replace old engines with new ones. Only after choosing to keep their older engines in-service do the Rules apply to operators, by regulating which retrofit DECS they can use. Operators must use DECS that are Verified under the Rules, or face penalties for not meeting the latest emissions standards with their older equipment.
The Verification Rules are also optional for manufacturers of DECS. There is no obligation for a DPF manufacturer to go through the Verification process, even to sell into California. But any buyer in California will probably demand only Verified DECS, because that is the only way buyers can comply with the latest emissions rules while continuing to use their older equipment. So for manufacturers, the decision of whether or not to Verify their DECS under the Rules is more of a business or marketing decision, not a legal requirement in the strict sense. But once a decision is made to sell Verified DECS, the manufacturer must comply with the Rules, or face penalties.
What are the penalties?
Section 2711 of the Rules spells out the Compliance provisions. Paragraph (a) prohibits the sale of any Verified DESC unless all of the Rules are met. This paragraph can only apply to manufacturers or suppliers of the Verified DECS and not to end-users. It does not come right out and prohibit the sale of un-verified DECS in California, as many people still assume.
Paragraph 2711(b) then sets out the penalty for violating the Rules, as the possible cancellation of an existing verification. This can only apply to manufacturers of Verified DECS, that have chosen to follow the Rules and then act in a way that violates them. Such a manufacturer could also face civil penalties of up to $10,000 per day under the Health and Safety Code, Section 39674 (b). This paragraph (b) and penalty do not apply to an end-user of the Verified DECS.
Paragraph 2711(c) prohibits anybody from misrepresenting that a DECS is Verified under the Rules, unless it truly is. There is no specific penalty set out for such misrepresentations, as in Paragraph 2711(b). But we might assume that a vendor, or end-user, of a DECS, who misrepresents it as being Verified under that Rules, could potentially face those same civil penalties of up to $10,000 per day, under the Health and Safety Code.
The Verification Rules mention fuel additives in several places. Clearly, fuel additives meet the definition of DECS. But for some reason, many people to jump to the conclusion that fuel additives must be Verified under the Rules, before they can even be sold in California. As explained above, there is no general requirement that all DECS be Verified. And the Rules do not have a more specific requirement that all fuel additives must be Verified. Therefore, as long as the fuel additive is EPA Registered under 40 CFR Part 79, it is legal for on-road use in all 50 States, including California.
The closest the Rules come to actually regulating fuel additives is in Paragraph 2706(c), which covers situations where somebody applies for Verification of a fuel additive, either on its own, or as part of a DECS together with a hardware device. The Rules do not expressly prohibit the sale or use of non-verified fuel additives, as many people seem to think. You can see proof of this from the large selection of over-the-counter, packaged fuel additives being sold by retailers throughout California. The manufacturers of these fuel additives look at the Rules and decide it’s not worth the investment of going through the Verification process, because the products can be sold anyway. And buyers of fuel additives are not relying on these products as their primary DECS, in order to achieve compliance under the Rules. This is why buyers of fuel additives do not demand a Verified product, as they do with DPF’s.
What is the ARB’s position on fuel additives?
The California ARB’s Compliance Division issued its Advisory Number 379 in August 2008, dealing with alternative fuels and fuel additives in engines equipped with DECS. This 2-page document was likely issued in an attempt to clarify something which the Rules did not address – the legitimate concern that some aftermarket fuel additives might be causing DPF malfunctions. But rather than digging deeper into this problem and getting a better understanding of which fuel additives should or should not be used, the Advisory simply makes the sweeping declaration that the “Use of any alternative fuels and or fuel additives not specifically listed in the verification Executive Order is illegal and strictly prohibited.”
Does the ARB’s position on fuel additives make sense?No, it doesn’t. The position set out in Advisory Number 379 was not supported by the Rules in 2008. And even when the Rules were revised in 2011, none of this questionable language from the Advisory was adopted into law. The current Rules only require that an applicant for Verification specify the fuel and oil requirements for its DECS. There was a new Paragraph 2706(c) added in 2011 that deals with fuel additives, as part of a Verified DESC. But there is still nothing in the Rules that expressly prohibits an equipment operator from using a non-verified fuel additive, unless he misrepresents the fuel additive as being a Verified DECS. And there is no reason why he would do that, if he already has a Verified DPF.
Why is my DPF service provider so negative on fuel additives?
That CARB Advisory from 2008 was very alarming, using words like “illegal and strictly prohibited” and spells out the significant daily fines. But the truth is, the Advisory only applies to suppliers of DECS and not to the buyers and users of these hardware devices. Clearly, a vendor or manufacturer selling a Verified DECS runs the risk of losing its market-protected status and faces civil fines by not following every detail of the Rules. These vendors will point to the 2008 Advisory document and tell you not to use any aftermarket fuel additive, because it is the easy answer -- “All fuel additives must be bad. The CARB Advisory even said so.”
Now stop and think for a moment. You are hearing these dire warnings, about the dangers of fuel additives, from the very same supplier that charges you $400 to $600, every single time your DPF needs to be serviced. And that doesn’t seem right. Especially when there is solid evidence and testing for one commercially available and EPA Registered fuel-borne combustion catalyst, which is proven to reduce soot formation, inside the combustion chamber and upstream of your DPF. This product reduces the soot load going into your Verified DPF and allows it to function at peak performance levels and with longer intervals between those costly cleanings. It’s no wonder your DPF service company wants to prolong the confusion and prevent you from using fuel additives. Their lucrative DPF service business is being threatened. And they are responding by putting their own financial interests ahead of yours.
A number of benefits flow from this improved combustion efficiency, including reduced soot formation, reduced maintenance requirements and reduced engine and exhaust temperatures. Engines with retrofit DECS are prone to several operating problems, including increased downtime and maintenance costs, higher fuel consumption and even higher NOx emissions. This is why many maintenance managers are not big fans of retrofit DPF’s. Unlike the OEM DPF’s, which are engineered to work with that particular engine, retrofits are more of a one-size-fits-all. And they are installed on dirty, older engines, which were not even designed to have a DPF.
CleanBoost is available, in California, as an over-the counter diesel fuel additive. It is EPA Registered and legal for on-road use throughout the U.S.A. It is being used nationwide, in a variety of vehicles, including heavy-duty truck fleets, light-duty vehicles and school buses. It has a proven track record in the marketplace for over 20 years. By choice, CleanBoost is NOT a Verified DECS under the Rules.
Will using CleanBoost void my DPF warranty?No. That would be illegal. New engines equipped with a DPF are subject to the standard OEM engine warranty. Using CleanBoost does not void these warranties. Some engine manufacturers have provided a letter of non-objection, which confirms that the mere use of a CleanBoost will not void their warranty. This has never happened with CleanBoost. And its manufacturer has sufficient product liability insurance to cover any denied warranty claim, in the unlikely event it ever happens. This insurance coverage will apply in California and elsewhere.
If the DPF is a California retrofit, the Rules set out the minimum warranty provisions in Section 2707. To protect buyers of Verified DECS, it is very difficult for warranty claims to be denied by the manufacturer. Even if the operator fails to perform scheduled maintenance or keep maintenance records, this will not automatically be grounds for disallowing a warranty claim. Depending on the type of vehicle, the retrofit DPF warranty can range from 2 to 5 years, or from 60,000 to 150,000 miles, whichever comes first. Therefore, most retrofit DPF’s are already out of warranty by 2017. Check your warranty documentation to find out.
Any talk of “voiding” your retrofit DPF warranty, simply for using CleanBoost, is just not true. Keep in mind that your supplier has a vested financial interest in this. He wants to keep his ongoing DPF cleaning service revenues. You should ask for written proof that using fuel additives is prohibited in their warranty, their Verification Executive Order, or the Verification Rules. We are not aware of any such provisions.
The Verification Rules provide a sensible mechanism for reducing PM and NOx emissions from older engines, keeping them in-service until they can be replaced.
DPF’s are clearly the best available technology for reducing PM from diesel engines. But they can be expensive to maintain. CleanBoost fuel catalyst technology can safely improve the performance of DPF’s and allow longer intervals between expensive, off-road cleanings. It complements the use of DPF’s, whether OEM or retrofit.
Despite the negative things you may hear about fuel additives, some really do work. And they can be used in California, even without CARB Verification.
Southwest Research Institute - SAE J1321 Fuel Consumption Test Evaluation of a Diesel Fuel Additive Product
At the request of Combustion Technologies, the Southwest Research Institute (SwRI®) Fleet and Field Evaluations Section conducted fuel consumption tests utilizing three class-8 diesel trucks. Fuel consumption was measured during a baseline segment with commercially available #2 diesel fuel. The purpose of the program was to determine possible fuel savings benefits of a diesel fuel additive product, CleanBoost™, added to the diesel fuel compared to the baseline condition.
The procedure chosen for this evaluation was the SAE J1321 "Joint TMC/SAE Fuel Consumption Test Procedure Type II". This recommended practice provides a standard test procedure for comparing in-service fuel consumption of one or more vehicles operating under two conditions. An unchanging control vehicle is run in tandem with the test vehicle(s) to provide reference fuel consumption of one vehicle in two different test conditions.
CleanBoost diesel fuel additive has been tested for increased lubricity in today's ULSD fuels. HFRR testing ASTM D-6079 shows a large reduction in friction over diesel fuel alone, which in return will increase the life of fuel system components and engine life.
Since 2007, the EPA has regulated #1 and #2 Diesel Fuel to have no more than 15ppm of sulfur to help with the lubricity of the fuel. Before this mandate diesel fuel could have up to 500ppm of sulfur to help the lubricity of the fuel which keep fuel system components and fuel injectors running healthy. Wih todays 15ppm fuel, fuel components fail every day causing thousands in repair as well as stranded vehicles and equipment with major downtime issues.
Testing Link on CleanBoost lubricity ULSD fuel: Click Here
CleanBoost Diesel™ promotes the combustion of unburnt fuel. There is little effect if the combustion catalyst is used in highly-efficient, well-tuned engines running under laboratory test conditions.
On the other hand, CleanBoost Diesel™ is active and very effective when inefficient combustion occurs, as is often the case in the real world. The inefficient combustion may result from either a poorly maintained (or designed) engine or from the use of poor quality fuels.
In laboratory tests of CleanBoost Diesel™, the engines were run under less than ideal operating conditions to simulate the normal stress placed on an engine under actual field conditions.
CleanBoost has been tested and proven not to affect Cetane or Cetane Index of diesel fuels.
When fuels contains more Btu's they are able to deliver more power per gallon. This is critical to diesel engine fuel economy. The higher the Btu rating a diesel fuel has, the greater power yield per gallon; thus, higher mpg will result. The same principal applies to coal; increased BTU's of coal creates less ash residue thus a more complete burn of the hydro-carbon. CleanBoost has been shown to stabilize Cetane and increase BTU's as much as 2250 per gallon of fuel.
Dr. Reuther states on page 15 of the Battelle report on the Evaluation of CleanBoost Diesel™ as a Diesel Engine Combustion Additive:
"The advanced diesel engine used had been designed to minimize particulate emissions and carbon burnout problems. To offset this situation, the diesel test engine was operated at an off-peak load (85 percent), which maximized the amount of particulates it emitted."
Standardized tests were conducted by Battelle Columbus Division in a production diesel engine (Superior Model 2406D/Mitsubishi Model S6U-PTA). This 4-stroke, 6-cylinder, 4300 cubic-inch diesel engine is rated at 1,400 brake-horsepower and 1,200 r.p.m. at full load, but was run at 85% load to artificially create a particulate emissions problem.
The measurable and reproducible results of adding Clean Boost Diesel™ to conventional No. 2 diesel fuel are as follows:
With most emission control technologies based on fuel or engine modifications, there is an apparent trade-off between NOx and particulates. The U.S. National Research Council (NRC), considered the magnitude of this trade-off and estimated that a 50 percent reduction in NOx emissions will probably be accompanied by a 30 to 100 percent increase in particulates.
Moreover, the NRC also estimated that a 50 percent reduction in NOx would be accompanied not only by a 30 percent or more increase in particulates, but also by a 50+ percent increase in HC emissions and a 7 percent or more penalty in fuel consumption.
CleanBoost Diesel™ offers a unique, cost-effective means by which to reduce diesel engine particulate emissions without aggravating NOx emissions or diminishing fuel economy.
Unlike most aftermarket products aimed at reducing DPM emissions, but which also impose a stiff fuel penalty (such as particulate filters or traps),CleanBoost Diesel™ actually rewards operators by reducing fuel consumption. Field tests conducted by Ontario Power Generation at the Gull Bay remote generation station confirmed the Battelle results on emissions reductions and also quantified these fuel savings at 3 to 5 percent. The tests involved diesel gensets ranging in size from 130 kW to 250 kW (Detroit Diesel 2-cycle, Caterpillar 3406TA and 3406B) under actual operating conditions over a period of weeks.
In summary, CleanBoost Diesel™ appears to be a viable additive for stationary and mobile diesel engines for both environmental and economical reasons.