Replacement Engines for Rail Vehicles David E. Brann Electro-Motive Diesel, Inc. UNIFE Diesel Experts Group 16 November 2009

Directive 97/68/EC provision Replacement engines must meet emissions limits appropriate to their date of placing on the market. Problem: Low-emitting engines depend heavily on off-engine systems (e.g., the vehicle cooling system) for emissions limit compliance; therefore, putting a Stage IIIA or Stage IIIB engine in an older rail vehicle entails major, non-cost-effective vehicle modifications.

How has this problem been solved elsewhere? US EPA locomotive rules (40 CFR parts 92 and 1033): Set emissions standards appropriate to the date of original manufacture and the configuration of the locomotive. Older locomotives, and those without low-temperature charge air cooling, are subject to less stringent emissions standards. But: EPA locomotive rules are “equipment rules;” Directive 97/68/EC is an “engine rule,” so EPA locomotive rule example is not entirely appropriate.

How has this problem been solved elsewhere? (Continued) US EPA compression-ignition marine rules (40 CFR parts 94 and 1042) are “engine rules.” EPA rules allow replacement of engines with engines meeting earlier, or no, emissions standards under limited circumstances: No engine meeting current emissions standards and appropriate to the vessel is produced by any manufacturer; and The record of such determination must be made and kept for eight years. Burden is placed on the manufacturer of the replacement engine.

What must the record contain? Explanations of: Why current standard engine cannot be used, if it’s because of difference in power or speed Why current standard engine cannot be used, if it’s because of difference in size or weight Accounting for compatibility with vessel components not being replaced: Transmissions or reduction gears, drive or propeller shafts, propellers, cooling systems, controls or electrical systems. Why would it be unreasonable to replace those components? For multi-engine installations, accounting for compatibility with other engines.

Record, Continued Assessment must include every Tier of emissions standards, and replacement must be engine of highest Tier that will fit the boat. EPA must be notified when a replacement engine not meeting current standards is supplied. Engine being replaced must have been manufactured prior to the effective date of the current standards.

Engines must be labeled. If engine being replaced meets no emissions standards: "THIS ENGINE DOES NOT COMPLY WITH U.S. EPA NONROAD EMISSION REQUIREMENTS. SELLING OR INSTALLING THIS ENGINE FOR ANY PURPOSE OTHER THAN TO REPLACE A NONROAD ENGINE BUILT BEFORE JANUARY 1 [Year when the earliest tier of standards began to apply to engines of that size and type] MAY BE A VIOLATION OF FEDERAL LAW SUBJECT TO CIVIL PENALTY.“ If engine being replaced was certified to earlier Tier than current: "THIS ENGINE COMPLIES WITH U.S. EPA EMISSION REQUIREMENTS FOR [Year when the applicable tier of emission standards for the replaced engine began to apply] ENGINES UNDER 40 CFR 1068.240. SELLING OR INSTALLING THIS ENGINE FOR ANY PURPOSE OTHER THAN TO REPLACE A NONROAD ENGINE BUILT BEFORE JANUARY 1 [Year when the next tier of emission standards began to apply] MAY BE A VIOLATION OF FEDERAL LAW SUBJECT TO CIVIL PENALTY."