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tru -- Warning on use of Tier 2 repower engines to comply with the TRU ATCM

Posted: 03 Dec 2009 14:09:18
California and federal laws require that a new replacement engine
must be at least as clean or cleaner than the original engine and
must be the the cleanest engine (meet the most current emissions
standard possible) that will physically fit and perform in the
equipment. 

The California Air Resources Board’s (ARB) Transport
Refrigeration Unit (TRU) Airborne Toxic Control Measure (ATCM)
requires all TRUs that operate in California to meet in-use
performance standards by December 31st of the seventh year after
the engine model year.  Several compliance options are available,
such as retrofitting the engine with the required level of
verified diesel emission control strategy or using an Alternative
Technology in a way that eliminates the TRU engine operation at
all facilities.

So far, however, the majority of TRU owners are electing to
repower their TRUs with a new engine.  Repowering a TRU with a
new or remanufactured engine just resets the compliance
requirements and compliance deadline to seven years after the
replacement engine’s model year (MY).  

State and federal laws require that a replacement engine must be
at least as clean or cleaner than the original engine.  In fact,
the engine manufacturer must be able to show that the replacement
engine is the cleanest engine available with the appropriate
physical or performance characteristics to repower the equipment.
 The engine manufacturer or their agent (e.g. original equipment
manufacturer or dealer) must take possession of the original
engine and confirm that it has been destroyed.

For the purposes of complying with the TRU ATCM, a new or
remanufactured replacement engine that meets Tier 2 off-road
standards has a 2007 effective model year, which is the last year
that Tier 2 was in effect.  The effective model year of a Tier 2
replacement engine is not the year the replacement engine was
manufactured or the year of the repower.  Since the Tier 2
replacement engine has an effective model year of 2007, this
engine must meet the TRU ATCM’s Ultra-Low-Emission TRU (ULETRU)
In-Use Performance Standard by December 31, 2014, which is now
only five years away.  Please be aware that the useful life for a
Tier 2 engine repower is shorter than the useful life of a
repower that uses an engine that meets the current interim Tier 4
(Tier 4i) standards.  ARB will soon publish a TRU Advisory that
further clarifies the issues related to using prior-tier
replacement engines that are used to comply with the TRU ATCM.

ARB’s Equipment Registration (ARBER) system will be upgraded to
calculate the correct “Compliant Until” date where Tier 2
replacement engines have been used.  Affected owners will then be
notified of the correct ULETRU compliance date.

Also be aware that all TRUs that operate in California that are
equipped with MY 2002 and older engines must meet the
Low-Emission TRU (LETRU) In-Use Performance Standard or use an
Alternative Technology by December 31, 2009.  ARB will begin
enforcement of the LETRU In-Use Performance Standards after
December 31, 2009.  TRUs that are found to be noncompliant with
the in-use standards will be subject to penalties up to $500 per
violation.  There will be no grace periods for late ordering.

Please call the TRU Help Line at 1-888-878-2826 if you need
further assistance.

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