Approval Details

Valid E.O.


This Executive Order approved the specified parts on on March 29, 2006.
As of Wednesday, October 23rd, 2019 this Executive Order has not been overturned or superceeded.

Approved Parts

Part NumberModels
801601996-2006 model-year off-road compression-ignition engines

This Executive Order may be listed as:
  • C.A.R.B.E.O. D-605U
  • Executive Order 605U / D605U
  • ARB # D-605U
  • Executive Order No: D-605U
  • C.A.R.B. No. D-605U
  • Resolution D-605U
For Free CARB Executive Order Status verification, email an image of the device Executive Order label as well as the Year/Make/Model and Test Group # of the vehicle to [email protected]

Download: Executive Order D-605U PDF

D-605U Document:

                                    State of California
                               AIR RESOURCES BOARD

                             EXECUTIVE ORDER D—605U

                              Relating to Exemptions under
                    Sections 38390 and 38391 of the Vehicle Code

                               Emissions Technology, Inc.
                              Combustion Catalyst System

Pursuant to the authority vested in the Air Resources Board by Part 5, Division 26 of the
Health and Safety Code and Sections 38390, 38391, and 38395 of the Vehicle Code;

Pursuant to the authority vested in the undersigned by Sections 39515 and 39516 of the
Health and Safety Code and Executive Order G—02—003;

IT IS ORDERED AND RESOLVED: That installation of the Combustion Catalyst
System, manufactured by Emissions Technology, Inc. of 3620 East Wier Avenue,
Phoenix, Arizona 85040, has been found not to reduce the effectiveness of the
applicable engine emission control system, and therefore, the Combustion Catalyst
System is exempt from the prohibitions in Sections 38390 and 38391 of the Vehicle
Code for installation on 1996—2006 model—year off—road compression—ignition engines.

Combustion Catalyst System part numbers 80160, 80162, 80165, and 80174 are
exempted under this Executive Order.

This Executive Order is based on emission testing Emissions Technology, Inc.
conducted with the Combustion Catalyst System. Testing showed that the Combustion
Catalyst System does not increase engine emissions.

If evidence provides the Air Resources Board with reasons to suspect that the
Combustion Catalyst System will affect emissions with prolonged use, Emissions
Technology, Inc. shall be required to submit additional emission data to show that the
Combustion Catalyst System does not increase emissions of regulated pollutants or any
other pollutants that might contribute to formation of toxic air contaminants.

This Executive Order is valid provided that installation instructions for the Combustion
Catalyst System do not recommend tuning the engines to specifications different from
those of the engine manufacturer.

Changes made to the design or operating conditions of the Combustion Catalyst
System, as exempt by the Air Resources Board, which adversely affect the performance
of the engine‘s pollution control system, shall invalidate this Executive Order.

Marketing of the Combustion Catalyst System using identification other than that shown
in this Executive Order or for an application other than that listed in this Executive Order
shail be prohibited unless prior approval is obtained from the Air Resources Board.


This Executive Order shall not apply to any Combustion Catalyst System advertised,
offered for sale, sold with, or installed on an off—road engine, vehicle, or equipment prior
to or concurrent with transfer to an ultimate purchaser.

This Executive Order does not constitute any opinion as to the effect the use of the
Combustion Catalyst System may have on any warranty either expressed or implied by
the engine manufacturer.

No claim of any kind, such as "Approved by the Air Resources Board," may be made
with respect to the action taken herein in any advertising or other oral or written

In addition to the foregoing, the Air Resources Board reserves the right in the future to
review this Executive Order and the exemption provided herein to assure that the
exempted add—on or modified part continues to meet the standards and procedures of
California Code of Regulations, Title 13, Section 2474, et seq.


Violation of any of the above conditions shall be grounds for revocation of this Executive
Order. The Executive Order may be revoked only after a ten—day written notice of
intention to revoke the Executive Order, in which period the holder of the Executive
Order may request in writing a hearing to contest the proposed revocation. If a hearing
is requested, it shall be held within ten days of receipt of the request, and the Executive
Order may not be revoked until a determination is made after a hearing that grounds for
revocation exist.

Executed at El Monte, California, this Z?flday of March 2006.

                                        Mobile Source Operations Division


                                      EVALUATION SUMMARY

Manufacturer Name: Emissions Technology, Inc.

Name of Device: Combustion Catalyst System

       Emissions Technology, Inc. (ET1) of 3620 East Wier Avenue, Phoenix, Arizona 85040
has requested exemption of its Combustion Catalyst System (CCS) from the prohibitions in
Section 38391 of the California Vehicle Code (VC). The engine application includes 1996
through 2006 model—year off—road compression—ignition engines.

       Grant exemption to ETI as requested and issue Executive Order D—605U. The
exemption covers CCS part numbers 80160, 80162, 80165, and 80174.

Device Description:
        The Combustion Catalyst System is designed to inject aerosol catalysts into the intake
air stream of diesel engines. The aerosol catalysts are claimed to enhance combustion and
reduce exhaust emissions. The system consists of a bottle containing an aqueous solution of
catalytic saits, an electric pump, and a connection hose. Using engine vacuum and pump,
vacuum is pulled on the bottle. An air hole at the top of the bottle feeds air to the bottom of the
aqueous solution. As vacuum is pulled from the top and through the bottle, air bubbles form at
the bottom of the solution and travel up through the solution, picking up the catalysts. The
catalysts in the bubbles are then introduced into the intake air stream. The system is designed
to introduce 3 to 6 millimeter diameter bubbles at a rate of 3 to 4 bubbles per second. The
bottle measures approximately 7" H x 5" L x 2.5" D and contains 700 milliliter of catalytic
solution. For a typical application, one bottle is designed to last approximately 400 hours. The
system includes a timer which records the elapsed time since system installation and since the
last bottle replacement. At the end of 400 hours, a warning light alerts the user, indicating the
time for bottle replacement.
        ETI offers four different catalyst formulations. The formulations vary in catalytic metals,
their amounts, and types and amounts of carriers and stabilizing agents. The base solution is
either de—lonized water or propylene glycol. The final catalyst solution is manufactured to ETI
specifications by Heraeus Metal Processing, Inc. in Santa Fe Springs, California. The
formulations are identified by part numbers 80160, 80162, 80165, and 80174. Any one of the
formulations can be offered in one of the four following CCS models:
1.      DC—100 designed for engines with fuel consumption rate less than 15 gallons per hour
        (GPH) (one catalyst bottle)
2.      DC—101 is DC—100 with different packaging
3.      DC—100M is DC—100 without the protective box (for applications with space constraints)
4.      DC—200 designed for engines with fue! consumption rate less than 30 GPH (two catalyst
Multiple units are used on engines with fuel consumption rate greater than 30 GPH and on
engines with more than one air intake duct.
       ETI recommends installing the system as close to the engine or turbocharger as
possible but away from exhaust or extreme heat.

Discussion/Basis for the Recommendation:
        ETI was required to conduct testing to demonstrate no adverse impact on emissions.
Testing requirements were twofold: (1) test the CCS on a representative engine and compare
the exhaust emissions to new engine certification standards and (2) analyze the particulate
matter (PM) sampled from the certification test for chlorine/chloride and compare the levels with
and without the CCS. Testing was performed on a 2005 MY Cummins, Inc. QSM11—C engine
certified to Tier 3 emission standards (engine family 5CEXLOGG1AAF; 10.8 liter; 400
horsepower). The engine was tested using the new engine certification test (8—mode test cycle

    for variable speed engines). ETI was required to run duplicate tests in each configuration (e.g.
    two baseline tests, two CCS tests) to minimize test—to—test variability. ETI performed three tests
    in each configuration. Tests were conducted at California Environmental Engineering (CEE)
.   located in Santa Ana, California. Data are presented below:

                                       8—mode Test Cycle Emissions (g/kW—hr)
             Test            NMHC          co       NOx      NMHC+NOx            PM

           Baseline 1        0.2579      1.3933    3.7516       4.0095         0.1281

           Baseline 2        0.2722      14322     3.7507       4.0229         0.1227
           Baseline 3        0.2607      14244     3.6924       3.9532         0.1231

         Avg. Baseline       0.2636      14167     3.7316       3.9952         0.1246

         Formulation A1      0.2404      1.3711    3.5662       3.8066         0.1302
         Formulation A2      0,.2718     14305     3.6398       3.9116         0.1308
         Formulation A3      0.2685      1.4177    3.6068       3.8753         0.1256
             Avg. A          0.2602      1.4064    3.6043       3.8645         0.1289
          % Difference         1.3         ~0.7     —3.4          ~3.3           +3.4

         Formulation B1      0.2596       1.3959   3.5593       3.8190         0.1283
         Formulation B2      0.2623       14329    3.5685       3.8308         0.1249
         Formulation B3      0.2568       14396    3.5886       3.8454         0.1251

‘            Avg. B          0.2596       14228    3.5721       3.8317         0.1261

          % Difference         1.5         +0.4     4.3           421            +1.2

         Formulation C1      0.2579       1.3947   3.6020       3.8599         0.1283
         Formulation C2      0.2457       14150    3.6491       3.8949         0.1310
         Formulation C3      0.2602       14365    3.6363        3.8965        0.1274

             Avg. C          0.2546       14154    3.6291        3.8837        0.1289

          % Difference         —3.4        —0.1     —2.7          —2.8           +3.4

         Formulation D1      0.2638       1.3473   3.5335        3.7971         0.1280

         Formulation D2      0.2678       1.3766   3.5793        3.8473         0.1305
         Formulation D3       0.2713      1.3948   3.5890        3.8603         0.1306
             Avg. D           0.2676      1.3729   3.5673        3.8349         0.1297

          % Difference         +1.5        ~3.1      4.4          ~4.0           +4.1

           Standards            n/a         3.5      n/a           4.0           0.20

     1      EngineT break—in period was approximately 135 hours. All tests were performed immediately following

    2       '?":se:‘s(-wére conducted using California ultra low sulfur diesel (sulfur content < 15 ppmw).
'   3       Particulate matter was sgmplgd over the entire test cycle using a singlg filger.
    4       CEE reported the emissions in grams per brake horsepower—hour. Emissions were converted to
            grams per kilowatt—hour.
     5      Formulation A = 80160; Formulation B = 80162; Formulation C = 80174; Formulation D = 80165.
    6       Original equipment manufacturer deterioration factors were zero for all pollutants.

        As shown, emissions for each of the CCS formulations were below the new engine
certification standards. They were also comparable to baseline emissions. Similar results are
expected when any of the four CCS formulations is used on any of the engines included in the
Executive Order.
       The catalysts used in CCS contain metals and chlorinated compounds. Though they are
not listed in the Air Resources Board‘s Toxic Air Contaminant (TAC) list, the large amounts of
chlorine used in the catalyst solutions pose the potential for emissions of chlorinated dioxins and
chlorinated dibenzofurans (collectively known as "dioxins"), which are listed as TACs
possessing extremely high carcinogenic potency. As a result, ETI was required to quantify the
organic chlorine and inorganic chlorides emitted during the certification test and show that the
chlorine/chloride levels with the CCS are not significantly higher than the levels without the
CCS. The limit was set at four times the baseline levels (without CCS). The PM filters were
shipped from CEE to Southwest Research Institute (SwRI) in San Antonio, Texas for analyses.
       The PM filters were analyzed for inorganic chioride and total chlorine. The method
required halving each filter, using one—half for inorganic chloride analysis and the other half for
total chlorine analysis. One—half of each filter was dissolved in de—jonized water (25 mL) to
extract the inorganic chloride. The other half of the filter was fused with sodium carbonate then
dissolved in de—lonized water (50 mL) for total chlorine determination. The sample solutions
were analyzed using ion chromatography. The instrument reporting limit was 0.1mg/L or
0.1ug/mL. This corresponds to limits of detection (LOD) of 5 ug/filter and 10 ug/filter for
inorganic chloride and total chlorine, respectively. Organic chlorine was determined by
calculating the difference between the total chlorine and the inorganic chloride, and the LOD
was established at 10 ugffilter. Sodium carbonate (99.999% Na;CO;) used for the fusion
contained a small amount of chlorine. This amount was determined by dissolving the sodium
carbonate amount used in the fusion (2 grams per fusion) in 50 mL of de—lonized water and
analyzing it for chlorine content. Two measurements were made. The average concentration,
approximately 10 ug/filter, was subtracted from the sample results to correct for the additional
chlorine introduced by the sodium carbonate. Results are presented below:

                                       Chlorine/Chloride (ug/filter)
                              Total             Inorganic              Organic
                            Chiorine            Chloride               Chlorine
      Baseline 1              117                  99.0                  18.0
 Duplicate Baseline 1         109                  103                   <10

      Baseline 2              126                  81.4                 44.6

    Formulation A1            80.2                 86.7                  <10
    Formulation A2            98.4                 79.2                  19.2

    Formulation B1            127                  87.7                  39.3
    Formulation B2            106                  86.3                  19.7

    Formulation C1            75.1                 61.2                  13.9
    Formulation C2            78.1                 79.0                  <10

    Formulation D1            91.6                 90.0                  <10
    Formulation D2            56.2                 72.3                  <10

        Blank 1               110                  101                   <10
        Blank 2               120                  108                   12.0
        Blank 3               92.6                  102                  <10

1 Limit of detection (LOD) for total chlorine was 10 ug/filter. LOD for inorganic chloride was 5 ug/filter.
    LOD for organic chiorine was 10 ug/filter.
2   To minimize chlorine input, High Efficiency Particulate Air (HEPA) filter was installed in the intake air
    line. Lube oil, oil filter, and fuel filter were changed before baseline tests and again before testing
    each of the CCS formulations. HEPA filter was changed before testing each of the CCS formulations.
3   Same batches of test fuel and lube oil were used for all the tests.
4   Glass fiberfilters were used for PM sampling.

        The chlorine levels varied widely from filter to filter. Compared to the levels found on
baseline filters, data did not show significant increases with the CCS, as might be expected
based on the large amounts of chlorine used in the CCS. However, the levels found on many
CCS filters were also lower than the levels found on blank filters. As presented, the
chlorine/chloride data are inconclusive, primarily due to the high levels of chlorine found on the
blank filters. Minimal or no increase in chlorine levels with the CCS might indicate that no
significant catalytic reaction is taking place. This is supported by the emission data, which
showed no significant emission reduction.
        As noted earlier, ET! ran triplicate tests. The filters from the third tests were analyzed by
SwRI for metals content (ICP and ICP—MS analyses). Many of the active catalysts were below
detection limits, further suggesting the absence of any catalytic reaction (see application file for
         Based on the above, staff expects no adverse emissions impact when any of the four
CCS formulations is used on the engines for which ETI is requesting exemption. Staff
concludes that ETI‘s four CCSs meet the requirements for a conditional VC 38395 exemption
for the engines listed in the Executive Order. !f in the future, staff is provided with evidence
which suggests that the CCS might affect emissions with prolonged use, ETI will be required to
submit additional emission data to show that the CCS does not increase emissions of regulated
pollutants or any other pollutants that might contribute to formation of toxic air contaminants.

Document Created: 2006-05-12 11:21:52
Document Modified: 2006-05-12 11:21:52

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