UPDATES ON CARB'S REGULATIONS FOR DIESEL ENGINES IN DRINKING WATER UTILITIES' FLEETS

UPDATES ON CARB’S REGULATIONS FOR
DIESEL ENGINES IN DRINKING WATER
UTILITIES’ FLEETS

PORTABLE PUMPS, GENERATORS & AIR COMPRESSORS
STATIONARY PUMPS & GENERATORS
ON-ROAD HEAVY DUTY TRUCKS

CA-NV AWWA ANNUAL FALL CONFERENCE
OCTOBER 24, 2018

Neil McQueen - McQueen Environmental Consulting
361-765-4445, mcqueenenviro@att.net

DISCLAIMER

    The types of engines, regulatory requirements and
  compliance strategies discussed in this presentation
  fit those of an average California drinking water utility
   and may not fully represent your utility’s situation or
             the best approach for compliance.

 Every utility should perform a thorough review of CARB
       and local Air District regulations and rules to
       determine which requirements apply to their
    particular engines and fleets, and the best way to
                  meet those requirements.

WHY?

PORTABLE ENGINES
   CARB regulations:
     Airborne Toxic Control Measure (ATCM) for Diesel
      Particulate Matter from Portable Engines Rated 50
      Horsepower and Greater (CCR, Title 17, Section 93116)
     Statewide Portable Equipment Registration Program
      (CCR, Title 13, Section 2450)

   Air compressors
   Booster pumps
   Generators

CHANGES IN THE PORTABLE DIESEL REGS

Amendments to the ATCM for Diesel Particulate Matter from Portable Engines
Rated at 50 Horsepower and Greater and the Statewide Portable Equipment
Registration Program Regulation (PERP) were approved on September 24, 2018,
and will go into effect November 30, 2018.

   Changed the options for compliance vs. the 2011 version of the ATCM.

Exempt:
 Portable diesel engines less than 50 horsepower.
 Emergency-use engines – Permit or Statewide registration states the engine is
   to be used only during emergencies.
 Low-use engines - Permit or Statewide registration states the engine is to be
   operated 200 hours or less in a calendar year.
 Engines equipped with a verified Level 3 diesel particulate filter (85% or greater
   reduction in PM).

ATCM FOR DIESEL PM FROM PORTABLE ENGINES
RATED 50 HORSEPOWER AND GREATER

   Small fleet – Total horsepower of 750 bhp or less under common
    ownership on June 30, 2019
   Large fleet – Total horsepower over 750 bhp under common
    ownership on June 30, 2019
   Flexibility engine - Engine that was built by an engine manufacturer
    to a less stringent emission standard after a new tier of emission
    standards went into effect. The purpose was to provide equipment
    manufacturers with some lead time to redesign their equipment
    for the newer, more stringent, engines.
   Electrification in lieu of operating a portable diesel – Provision for
    reducing the fleet’s average when calculating PM emissions.

ATCM FOR DIESEL PM FROM PORTABLE ENGINES
RATED 50 HORSEPOWER AND GREATER

ATCM FOR DIESEL PM FROM PORTABLE ENGINES
RATED 50 HORSEPOWER AND GREATER

   Deadlines for designating* engines as low-use or
    emergency-use:

            Engine Tier       Small fleet –    Large fleet -   Engines >750
                              Engines 50 to    Engines 50           bhp
                                750 bhp        to 750 bhp
                 1               7/1/19          7/1/19           7/1/21
          2 (built before        7/1/22          7/1/21           7/1/24
              2009)
        2 (built 1/1/09 or         N/A             N/A            7/1/26
               later)

* If the Permit or Statewide registration does not already state low-use or emergency
  use, you will need to get it amended by the Air District or CARB.

ATCM FOR DIESEL PM FROM PORTABLE ENGINES
RATED 50 HORSEPOWER AND GREATER

   Option 1 – Engines cannot operate in California on or after:

          Engine Tier            Small fleet -      Large fleet -    Engines >750
                                Engines 50 to      Engines 50 to          bhp
                                  750 bhp            750 bhp
                1                  1/1/20             1/1/20             1/1/22

     2 (built before 2009)         1/1/23             1/1/22             1/1/25

    2 (built 1/1/09 or later)        N/A                N/A              1/1/27
     3 (built before 2009)         1/1/27             1/1/25               N/A

    3 (built 1/1/09 or later)      1/1/29             1/1/27               N/A

       1, 2 & 3 Flexibility     December 31 of the year that is 17 years after the
            engines             date of manufacture.

ATCM FOR DIESEL PM FROM PORTABLE ENGINES
RATED 50 HORSEPOWER AND GREATER

   A fleet can get 2 year extensions on the dates in the previous
    table if:
   Its weighted averages of PM emissions meet:
        Engines 750 hp
                                  hp
         0.18 g/bhp-hr        0.08 g/bhp-hr        0.08 g/bhp-hr
                                       ∑(bhp x PM emissions in g/bhp−hr)
     Weighted average PM emissions =                ∑ bhp
   The company/utility sends a written statement of compliance to CARB by
    1/29/19. The statement must include a list of all engines, permit or
    registration numbers, engine family names, serial numbers and years of
    manufacture.
   Also a 1 year extension for a Tier 3 engine if a Tier 1 is removed
    from service by 1/1/19 or a Tier 2 is removed from service by
    1/1/21.

ATCM FOR DIESEL PM FROM PORTABLE ENGINES
RATED 50 HORSEPOWER AND GREATER

   Option 2 (Available for Large Fleets only):
       Compliance Date     Fleet PM Emission Standard
           1/1/20                0.10 g/bhp-hr
           1/1/23                0.06 g/bhp-hr
            1/1/27               0.02 g/bhp-hr

   To qualify:
      All engines in the fleet, including low-use and emergency-use, must be
        registered in the Statewide Portable Equipment Registration Program by
        6/30/19.
      All engines added after 6/30/19 must also be registered in Statewide
        PERP.
      The company/utility must send a written request to CARB by 6/30/19
        with a list of all engines and their details.

ATCM FOR DIESEL PM FROM PORTABLE ENGINES
RATED 50 HORSEPOWER AND GREATER

   Option 2 (Available for Large Fleets only):
   Alternative fueled engines are those that run on gasoline, natural gas,
    propane, LPG, etc.
      If operated for 100 or more hours per year, alternative fueled engines
        may be included in the fleet emission calculations with an emission rate
        of zero for Option 2.
      If operated for 100 or more hours per year and added to the fleet before
        2009, they may be counted twice in the fleet emission calculations.

   Tier 4 Interim and Tier 4 engines may be counted twice in the fleet emission
    calculations for 1/1/20 and 1/1/23.

ATCM FOR DIESEL PM FROM PORTABLE ENGINES
RATED 50 HORSEPOWER AND GREATER

   Selling a portable diesel engine:
   Must provide the buyer with a written disclosure in the ATCM stating that the
    engine may be subject to retrofitting or accelerated retirement.
   Cannot sell to a California buyer after the following dates:
              Engine Tier               50 – 750 bhp           >750 bhp
                   0                        Never                 Never
                   1                       1/1/20                1/1/22
        2 (built before 2009)              1/1/23                1/1/25
       2 (built 1/1/09 or later)             N/A                 1/1/27
        3 (built before 2009)              1/1/27                 N/A
       3 (built 1/1/09 or later)           1/1/29                 N/A
      1, 2 & 3 Flexibility engines   December 31 of the year that is 17 years
                                         after the date of manufacture.

   No restrictions on selling an engine to a buyer outside California.

ATCM FOR DIESEL PM FROM PORTABLE ENGINES
RATED 50 HORSEPOWER AND GREATER

   Recordkeeping and reporting:
   Maintain annual records on emergency-use, alternative-fueled, low-use
    engines, and electrification in lieu of portable diesel operation.
   Keep all records for 5 years.
   Submit a report to CARB every March 1st with the low-use engine hour meter
    readings and permit or registration numbers.
   For Large fleet owners that choose Option 2, submit a statement of
    compliance by March 1, 2020, 2023 and 2027.

STATIONARY DIESEL ENGINES
   CARB regulation: ATCM for Stationary Compression
    Ignition Engines (CCR, Title 17, Section 93115 )
   Emergency standby generators
   Gear head drives for pumps

STATIONARY DIESEL ENGINES
   Air Toxic Hot Spots (AB 2588) & Stationary Diesels
   AB 2588, the Air Toxics "Hot Spots" Information and Assessment Act,
    requires air pollution control and air quality management districts (districts)
    to prioritize facilities to determine which facilities must perform a health risk
    assessment.
   CARB and the California Air Pollution Control Officer’s Association (CAPCOA)
    finalized the “Risk Management Guidance for Stationary Sources of Air
    Toxics” in 2015.

STATIONARY DIESEL ENGINES

STATIONARY DIESEL ENGINES

STATIONARY DIESEL ENGINES

STATIONARY DIESEL ENGINES
Air Districts can choose whether or not to follow the CAPCOA guidelines.

Diesel engine exhaust, Diesel engine exhaust particulate matter and
Diesel engine exhaust total organic gas are parameters listed in
Appendix B, List of Substances for Emission Quantification

Facility Prioritization requirements
Air Districts are required to designate high, intermediate and low priority facilities:

High                      Total facility score is 10 to 100
                        (10 = 100 cancer risks in a million)
Intermediate

Low                        Total facility score is below 1

STATIONARY DIESEL ENGINES
When conducting facility prioritizations, Air Districts must consider:
 Potency, toxicity, quantity & volume of hazardous materials released.

 Proximity to potential receptors (i.e. hospitals, schools, daycare
  centers, worksites and residences).
 Any other factors that may indicate that the facility may pose a
  significant risk to receptors.

Health Risk Assessment
 Within 150 days of a high priority designation, facilities must prepare and
  submit a health risk assessment prepared per Health & Safety Code Section
  44361.

STATIONARY DIESEL ENGINES
SJVAPCD
     Foresee using a streamlined approach for risk prioritization, probably in
      2019 or later.
     Waiting for CARB to complete industrywide screening methods for
      facilities with stationary diesels only.
     On their website, CARB lists the following industrywide guidelines:
         Completed in 1997 - Aerospace, automobile refinishing, chrome
                                 plating & degreasing
         In progress – Dry cleaners

         Listed but no status given – Gasoline service stations & stationary
                                         diesel engines

STATIONARY DIESEL ENGINES
SCAQMD
     Currently reviewing 2017 emission inventories but have not contacted
      facility owners about a risk prioritization yet.
     If a facility is on SCAQMD’s radar, the owners have already received a
      notice about an AB 2588 fee.
     AB 617– Community Air Protection Program (passed in 2017) may
      affect facilities located in low income EJ communities.
     http://www.aqmd.gov/home/rules-compliance/compliance/toxic-hot-
      spots-ab-2588/iws-facilities/dice
     Digging deeper:
       http://www.aqmd.gov/home/rules-compliance/compliance/toxic-
        hot- spots-ab-2588/iws-facilities/dice/estimating-overall-facility-risks

  “Under the current CARB proposal, “Diesel Engine-Only” facilities that reduce their
  total operating hours and amend their permits for their diesel engines to less than 20
  hours per year combined total for all engines (for non-emergency operations) are not
  subject to the AB2588 requirements.”

STATIONARY DIESEL ENGINES

The end result may be an overall facility risk estimate and the requirement
to replace an old engine with a Tier 4 or retrofit the existing engine with a
VDECS.

HEAVY-DUTY DIESEL VEHICLES
   CARB programs:
      Periodic Smoke (Opacity) Inspection Program

      Engine Labeling Certification Requirement

   All diesel powered vehicles with a manufacturer’s gross vehicle
    weight rating (GVWR) over 6,000 pounds

HEAVY-DUTY DIESEL VEHICLES
   Manufacturer’s gross vehicle weight rating (GVWR) indicates
    how much weight a vehicle can transport without causing
    damage to itself or the road. It includes the chassis, body,
    engine, fuel, accessories, passengers and cargo, but not a
    trailer.

HEAVY-DUTY DIESEL VEHICLES
Proposed Amendments to the Heavy-Duty Vehicle
Inspection Program (HDVIP) and the Periodic Smoke
Inspection Program (PSIP)

Public comment ended September 26, 2018

PERIODIC SMOKE INSPECTION PROGRAM (PSIP)

Currently:
   All trucks more than 4 years old in fleets of two or more vehicles
      Engine Year        GVWR         In Ozone Attainment?           Test
      1997 or older   6K – 14K Lbs.           N/A             Yearly opacity test

     1998 or newer    6K – 14K Lbs.           Yes            Biennial opacity test

     1998 or newer    6K – 14K Lbs.           No             Biennial smog check

        All years      >14 K Lbs.             N/A             Yearly opacity test

   Society of Automotive Engineers (SAE) J1667 test procedure
   Approximately $50 per test
   51% opacity acceptable for pre-1991 engines; 40% opacity for 1991 &
    newer engines
   Any vehicles that are non-compliant must be repaired and retested.
   Keep records for at least 2 years

PERIODIC SMOKE INSPECTION PROGRAM (PSIP)

In an Ozone Attainment area?

PERIODIC SMOKE INSPECTION PROGRAM (PSIP)

Proposed:
   Annual opacity tests
   In lieu of opacity testing on engines 2013 and newer, owners can conduct
    an annual review of the on-board diagnostics (OBD) systems data for fault
    codes:
        Fuel system monitoring / Misfire monitoring / Exhaust gas recirculation system monitoring /
        Boost pressure control system monitoring / Non-methane hydrocarbon converting catalyst
        monitoring / PM filter monitoring / Exhaust gas sensor monitoring / Variable valve timing
        and/or control system monitoring / Cold start emission reduction strategy monitoring / Engine
        cooling system monitoring / Crankcase ventilation system monitoring / Comprehensive
        component monitoring

   Any vehicles that are non-compliant must be repaired and retested.
   Starting in 2023, fleet owners will need to submit annual reports with
    opacity test results and/or OBD systems data for the previous year.
   Keep records for 2 years.

PERIODIC SMOKE INSPECTION PROGRAM (PSIP)

Proposed:
   5% opacity acceptable for 2007 and newer engines, and those equipped
    with a Level 3 Verified Diesel Emission Control System (VDECS) regardless
    of engine year
   20% opacity acceptable for 1997-2006 engine, and those equipped with a
    Level 2 VDECS regardless of engine year
   30% opacity acceptable for 1991-1996 engine
   40% opacity acceptable for a pre-1991 engine

EMISSION CONTROL LABEL

   Emission Control Label sticker or nameplate must be present in the
    engine compartment and must not have been tampered with.
   The wording varies by manufacturer: "This engine conforms to US EPA
    and California regulations applicable to xxxx model year heavy-duty diesel
    engines…"

UPDATES FROM CARB ON REGULATIONS
public.govdelivery.com/accounts/CARB/subscriber/new

Neil McQueen, CHMM
McQueen Environmental Consulting

     mcqueenenviro@stx.rr.com
        Cell: 361-765-4445