The California Air Resources Board’s (CARB) 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, most 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. The engine manufacturer must be able to show the replacement engine is the cleanest engine available with the appropriate physical or performance characteristics to repower the equipment. The engine manufacturer or its agent (eg, original equipment manufacturer or dealer) must take possession of the original engine and confirm that it has been destroyed.
To comply 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 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 Dec 31, 2014—five years away.
The useful life for a Tier 2 engine repower is shorter than the useful life of a repower that uses an engine that meets current interim Tier 4 (Tier 4i) standards. ARB will soon publish a TRU advisory that further clarifies issues related to using prior-tier replacement engines 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.
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 Dec 31, 2009. ARB will begin enforcement of the LETRU In-Use Performance Standards after Dec 31, 2009. TRUs found to be non-compliant with the in-use standards will be subject to penalties up to $500 per violation. There will be no grace periods for late ordering.
Call 1-888-878-2826 for further assistance.
