# Presentation: 334322

## Large Spark-Ignited Workshop

- April 10, 2003

## Background

- EPA Final rule published November 8, 2002
- Certification requirements start for new engines produced after January 1, 2004
- California ARB standards adopted in 1998
- Phase-in before 2004 introduces technology without useful life requirements
- California ARB requirements, nearly identical to EPA, also start  in 2004

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## EPA Contacts

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## Engines Not Covered

- 	Stationary
- 	Competition
- 	Motor vehicles
- 	Diesel engines
- 	Recreational vehicles
- 	Engines under 19 kW
- 	Marine propulsion engines

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## Opt-Out Engines

- Nonroad spark-ignition engines under 1 liter, with power between 19 and 30 kW
- meet Small SI standards instead
- Natural gas engines over 250 kW
- meet nonroad diesel standards instead

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## Covered Engines

- Nonroad spark-ignition engines over 19 kW used in all other applications
- This includes marine auxiliary engines
- Standards apply with special provisions for:
- Severe-duty engines
- High-load engines
- Engines using noncommercial fuels

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## 2004 Requirements

- Certify engines to CO and THC+NOx standards over full useful life
- NMHC measurements ok for 2004 standards
- Measure emissions using C2 and/or D2 steady-state test cycles
- Closed crankcase
- Limit adjustable parameters
- Warranty
- Maintenance instructions
- Emission-related installation instructions
- Engine label

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## Additional Requirements for 2007

- More stringent standards for CO and THC+NOx
- Measure emissions over transient duty cycle
- Standards also apply for “field testing” without defined duty cycle
- Evaporative standards
- Low-permeation fuel lines
- Tank venting
- Fuel boiling
- Diagnostics

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## CERTIFICATION

- Required by CAA before engine is sold, offered for sale, or introduced into commerce.  Yearly.
- Streamlined process  provides information we need to issue a certificate
- Mfrs required to comply with all requirements
- Certificate is issued based on the info in the application and statements made.  We don’t give up authority to review later, other required info

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## Overview of Certification Process

- New mfrs must register to establish EPA’s manufacturer code
- Mfr code - used in engine family name
- Manufacturer Code Entry Form is attached & available at:
- http://www.epa.gov/otaq/cfeis.htm (see "New Manufacturer Information")
- Fax or email form to: Pete Petersen
- email: Petersen.Pete@epa.gov
- fax:  734-214-4869
- The Code is usually assigned within 2 or 3 days
- EPA cert rep will be assigned to each mfr

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## California Harmony

**General**
- EPA cert’n is required for engines mfr’d on or after 1/1/2004
- EPA cert’n is required before intro in commerce in any State
- Early certification is available now
**For 2004 MY**
- 	May choose CA standards (instead of tier 1) and requirements
- 	Send EPA the CA application, instead of 1048.205
**CA-only family**
- 	Send approved CA Exec Order to EPA
- 	Expect minimal additional review for EPA certification
**50-state family**
- 	Must get both CA + EPA certifications
**49-state family**
- 	Apply to EPA per §1048 using EPA’s template

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## For 2005 MY and later

- Follow EPA application requirements per §1048
- (e.g., use EPA’s application template)
- We expect mfrs will conduct both C2 and D2 cycles (and transient testing after 2006)
- If not, then use unique engine labels
- Unique engines (e.g., carbureted vs injection) are expected to be different families, have different DF determinations & emissions data

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## Develop engine families

- Is the basis for certification
- Is the basis for issues related to compliance
- Eng Fam = groups expected to have similar emissions
- §1048.230 lists design features that apply to separate families
- May divide further depending upon ...
- Name families using attached format

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## Develop cert’n emissions data:

**Test data developed by testing engine(s) – data and durability**
- Test Engine Selection: mfr must test configuration most likely to exceed standards emissions
- EPA may choose to measure emissions
**Deterioration factors (DF) must be: (**§**1048.240)**
- Based on emission measurement
- Consistent with good engineering judgement (§1068.5)
- Consistent with any available testing data

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## Develop cert’n emissions data (cont’d):

**EPA will accept DFs that are approved by CARB**
- Must be based on 3500 hr of operation (for tier 1)
- Multiplicative for aftertreatment.  Minimum = 1.000
- Additive for non-aftertreatment.  Minimum = 0.000
**Apply the DFs to the emission test data to determine certification level**
- Round result to the same # of decimal places as the emission standard
- Compare rounded result with standard

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## Develop cert’n emissions data (cont’d):

**Useful life (UL)**
- Is the period during which the engine is designed to properly function without being reman’d
- Defined in units of hrs of operation or cal years
- Basic minimum for LSI is 7 yr/5000 hr
- Mfr must specify longer UL if
- you make/market the engine to last longer or
- the basic mechanical warranty is > 7/5000
- Mfr can request shorter UL if it has docu from in-use engines rarely operate longer

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## Pay the Certification fee

**Final rule is currently being developed**
- Estimated publication = August 2003.  Actual effective date 60 days thereafter
- Expected to be based on the date of receipt of a _complete_ application
**We project:  all applications received after 10/01/03 will require fee payment**
- Fee is not based on model year but on application date
- Projection for LSI:  $827 per engine family
**Filing form on web has instructions & will be updated for LSI**
- http://www.epa.gov/otaq/fees.htm
**Pay fee before our review process**

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## Complete the certification application

- Our application template supplies a min amount of necessary info and data
- Filemaker® software:  Template is a guide to the limited info we need
- Filemaker is not required, but others currently use it ...
- Facilitates processing & allows a database ...
- Also:
- Describe the emission control system
- Describe the evap emission controls (starting 2007)

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## Complete the cert’n app (cont’d)

- Describe the diagnostic system
- Installation instructions for OEMs (§1048.130)
- Placement of catalyst, evap system requirements ....
- In 2007, state steps necessary to prevent activation of engine protection modes (§1048.101 d)
- Describe any special or alternate test procedures
- Identify any high-cost warranty parts
- Statements required in §1048.205
- Some are in our sample statement of compliance
- Others can be provided in the application

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## Complete the cert’n app (cont’d) 

- Submit the info we ask for in our template.  We have authority to acquire & review other info later
- Confidential Business Information (§1068.10)
- Mfr must clearly identify information that is CBI
- We handle CBI in accordance with 40 CFR Part 2
- Info not labeled CBI may be released
- Regarding the Cert Application:
- Before certification, we hold the complete cert app as CBI
- After certification, info not labeled as CBI may be released
- EPA’s cert app has provisions for marking items “CBI”

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## Include a statement of compliance

**States mfr compliance wrt reqrmts & commitments to future actions ...**
**Signed by authorized company official**
**See sample language attached**
**Statements required in **§**1048.205**
- Some are in our sample statement of compliance
- Others can be provided in the application

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## Send all certification application documents (including electronic or hardcopy) to:

- Mr. Richard Deadwyler
- Engine Programs Group (Mail code 6403J)
- Certification and Compliance Division
- Environmental Protection Agency
- Deadwyler.Richard@EPA.GOV
- Phone: (202) 564-9294
- Office/Express Mail (before late 2003*):
- (Mail Code 6403J)
- 501 3rd Street, NW
- Washington, DC 20001

- Office/Express Mail (after late 2003*):
- (Mail Code 6403J)
- 1310 “L” Street, NW
- Washington, DC 20005
- Mailing Address:
- (Mail Code 6403J)
- 1200 Pennsylvania Ave. NW
- Washington, DC 20460
- * Stay tuned for our re-location

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## EPA’s Review

- EPA will review
- cert app, statement, AECD descriptions & other necessary info for compliance w/requirements
- Certificate issued upon compliance
- See attached sample draft
- Changes after certification:
- Called “running changes” during the production year
- Subsequent-year certifications
- Certification is required on yearly basis
- New families require new test data
- Can “carry-over” data + information when no changes made to engine design that affects emissions
- Current process for other industries may take up to 1 to 2 months depending upon issues

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## Files
Base file (Family and Test info)
Models file
Parts file                                                                                                                                                                                      
Base file      DATABASE
Models file  DATABASE
Parts file      DATABASE 

- Base file (Family and Test info)
- Models file
- Parts file
- Base file      DATABASE
- Models file  DATABASE
- Parts file      DATABASE

- Use these to
- prepare your
- application

- Use these to
- setup your
- database

- FileMaker Pro Forms

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## Data entry
–Fill out all 3 forms
Data in the Models and Parts files is copied to the appropriate pages of the base file
Function buttons included to minimize data entry:  automatically create Carryover applications, delete records, check for errors, etc.

- –Fill out all 3 forms
- Data in the Models and Parts files is copied to the appropriate pages of the base file
- Function buttons included to minimize data entry:  automatically create Carryover applications, delete records, check for errors, etc.

- FileMaker Pro Forms

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## FileMaker Pro Forms

- Use the Application files for creating new records; use the DATABASE files for storage only
- Never change the names of the files. When you’re finished preparing a new record, use the “Save a copy as” command to save the copy you’ll send to EPA.
- The files provide a means to submit the whole application electronically EXCEPT the compliance statement; you have to sign/submit this on paper.
- We’re trying to coordinate with CARB so you don’t have to fill out a separate application for CARB certification.
- If anyone would like to take a copy of the template home and experiment/comment on it, please let me know. This would help me identify any problems prior to sending it out.

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## Slide 27

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## Slide 28

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## Slide 29

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## Slide 30

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## Slide 31

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## Slide 32

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## Slide 33

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## Production Line Testing (PLT)

- PLT verifies that a manufacturer can mass produce Cert engine
- Minimum test rate from formula
- Test 2 engines per quarter to determine sample size
- Maybe 1 engine for carry-over families as early as 2006
- Manufacturer may request an alternative program under1048.301(d)
- Maximum test rate not to exceed:
- 30 engines
- 1% of U.S. directed annual production
- Testing on steady state or transient cycle
- CARB
- May use CARB data for 50 state families

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## Production Line Testing (PLT)

- Pass/Fail
- Fail if action limit exceeded for two consecutive tests
- Engine families which fail PLT have certificate suspended
- Any failed engines must be brought into compliance before sale
- Reporting Requirements
- Required quarterly
- No approved electronic format yet
- Selective Enforcement Audits (SEAs)
- EPA may conduct SEAs as necessary

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## Manufacturer In-Use Testing

- In-use testing by the manufacturer
- Effective for 2004 model year engines
- EPA identifies up to 25% of engines families in any model year
- Manufacturer has one year to develop test plan, two years to complete testing
- Minimum sample is 4 engines per family
- Minimum sample is 2 engines if:
- Selected engine family is less than 500 or
- Total production for all families is 2000 or fewer

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## Manufacturer In-Use Testing

- In-use testing on the dynamometer
- Test over applicable test cycle(s)
- For Tier1 engines, compare results to in-use standards
- For Tier 2 engines, compare results to duty cycle standards
- Field testing
- May be done instead of dyno testing
- Testing done in equipment
- Use procedures in §1048-515
- Meet in-use testing standards for Tier 1
- Meet field testing standards for Tier 2
- If all of selected engines meet the standards, testing is complete
- For each engine which fails, test two additional engines up to a maximum of 10 per family

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## Manufacturer In-Use Testing

- Failing engines
- If the average emissions level for the engine family exceeds the standard, report results within 15 days.
- Otherwise report results with 3 months.
- Determine the reason each engine exceeds emissions standard.
- Any defect which causes a failure must be corrected during future production.
- EPA will consider the following information to determine if remedial action is necessary:
- Failure rates
- Average emission level
- Defects
-  Other information

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## Defect Reporting and Recall

- Manufacturers analyze available data to determine if a defect exists in an engine family
- Defect investigations are triggered by:
- Warranty claims
- Parts shipments for unscheduled maintenance
- Defects discovered before engine reaches ultimate purchaser
- Other information such as hot line complaints or dealer feedback
- Thresholds for conducting an investigation differ for :
- Engines rated above 560 kW have lower thresholds
- Catalytic converters and aftertreatment devices
- Other emissions related components

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## Defect Reporting and Recall

- During the investigation phase, manufacturer determines if defect reporting threshold is reached.
- Not all warranty claims or parts replacements are defects
- Defects corrected before engine reaches ultimate purchaser do not count towards defect reporting threshold.
- Defect reporting thresholds are lower than investigation thresholds.
- Thresholds vary by rated power and component

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## Defect Reporting and Recall

- Reports on investigations must be sent mid-year and end of year even if they don’t trigger defect reports.
- Recall
- If EPA determines a substantial number of properly maintained and used engines do not conform to regulations, the manufacturer submits a plan to remedy the nonconformity.
- EPA has 15 days to approve/disapprove remedial plan
- Owner notification requirements
- Manufacturer must label recalled engines
- Manufacturer can request hearing to contest need for recall

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## Rebuilding Requirements

- A rebuild is a major overhaul which replaces pistons or power assemblies or makes other  changes which significantly increases service life of the engine.
- A certified engine must be rebuilt to have the same emissions performance
- Based on reasonable technical basis
- Rebuild to original certified configuration

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## Rebuilding Requirements

- All emissions related components must be checked, cleaned, adjusted, repaired, or replaced according to manufacturers recommended practice.
- O2 sensors
- Catalysts
- Clean or replace fuel system components
- Rebuilder is required to keep records for two years after rebuild.

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## Exemptions and Exclusions

- Exemptions
**Testing** used for research,investigations,studies, demonstrations, or training.
**Manufacturer-owned** used for product development, asses production methods, or promote products
**Display**
**National Security**
- Armored or equipment with permanently attached weapons are exempt
- Other equipment may be exempted.The request must be endorsed by a federal agency.

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## Exemptions and Exclusions

- Exemptions
**Export** engines meant for use out side the U.S.
**Competition**
**Replacement engine** exemption allows building new uncertified engine.
- Must be a certificate holder
- No certified engine will fit in the equipment
- Certificate holder must take possession of the old engine
**Hardship** exemptions
**Equipmen**t manufacturer exemption
- Engine exempted under this provision
- Most exemptions have labeling requirements

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## Imports

- Imported may take the previously discussed exemptions plus:
**Identical configuration** exemption
- Own engine for one year
- Do not transfer ownership
- Evidence to show engine is in same configuration as a certified engine
**Repairs and alterations** exemption allows temporary importation
**Diplomatic or military** exemption allows temporary importation while holding either status
- Most temporary exemptions require a bond

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