## Appendix L

Requirements of Two-Engine CranesL-1

I. R EQUIREMENTS FOR TWO - ENGINE CRANES A. Two- Engines Cranes Staff is proposing to address issues regarding two- engine on-road and off-road cranes by making both engines of two-engine cranes subject to the In-Use Off-Road Diesel Vehicle regulation and to remove the upper engines from the Portable ATCM regulation performance requirements. These issues facing the crane operators are related to safety and feasibility of repowering or retrofittin g crane engines, and the complexity and unnecessary cost associated with complying with mul tiple regulations without any appreciable emission benefits.

Two-engine cranes are defined as mobile diesel-powe red machines with a hoisting mechanism mounted on a specially constructed truck chassis or carrier; one engine provides motive power, and a secondary engine is us ed to lift and move materials and objects. There are three general categories of two -engine cranes: lattice boom (conventional), all terrain or truck mounted. All terrain and truck mounted crane are very similar and can be categorized as truck mounte d hydraulic cranes. The motive or drive engine is on-road engine. The secondary engi ne is off-road engine.

B. Issues Concerns by crane operators regarding on-road crane s raised late during the off-road regulatory development process and could not be eva luated and workshopped in time to include them in the off-road regulation. The cr ane owners and operators requested that the two-engine cranes be included in the In-Us e Off-Road Diesel Regulation. Please refer Chapter VII, Diesel Emission Reduction Regulations, of this document more information. The following were identified as reasons to support their request:

• Compliance with more than one regulation

• Replacement and retrofit of secondary Tier 0 engin e feasibility

• Manufacturers’ approval, technical support and ava ilability for modifications

• Compliance creates safety and design concerns

• OSHA and Cal-OSHA re-certifications

• Costs

Two-engine cranes would fall under two regulations: one applying to the motive engine and another to the secondary engine. Generally, th e motive engine would be subject to either the proposed On-Road Regulation, the Off-Roa d Regulation, or the Cargo Handling Equipment Regulation, depending on whetherthe engine is an on-road or offroad engine and where the crane operates. The seco ndary or upper engine of a twoengine crane is considered a portable engine and wo uld be subject to the Portable ATCM Regulation if the engine is greater than 50 ho rsepower. Crane owners and operators can opt to register their secondary engin e into PERP, which allows statewide equipment registration instead of individual air di strict permits or registrations (ARB, 2007a). State fees associated with PERP on Tier 1 and 2 resident engines range fromL-2

$30 to $5,000 and district inspection and service f ees ranged from $30 to $500 for non TSE cranes.

The Portable Equipment ATCM Regulation requires ret irement of all Tier 0 portable engines on January 1, 2010 and replacement with eng ines meeting the latest engine standard (Tier 3 engines for 75 to 750 horsepower). Additional portable engine PM emission reduction is achieved by engine exhaust re trofits or engine replacements, repowering, to meet PM emission fleet average based on engine horsepower. The compliance dates are January 1, 2013; January 1, 20 17; and January 1, 2020 respectively (ARB, 2007b).

The Portable ATCM Regulation would require crane ow ners and operators to buy new cranes instead of used units due to the issues with repowering, retrofitting and safety discussed later in the document. In comparison, th e Off-Road Regulation exhibit a smoother transition and spreads out vehicle replace ments, allows fleets to clean-up other fleet vehicle engines to offset emissions, ad dresses safety issues, addresses replacement availability, and usage and flexibility provisions are already included in the Off-Road Regulation.

For single-engine cranes where the motive engines s erve a dual purpose of motive and lifting power, the proposed Statewide Truck and Bus Regulation would apply, since most single-engine cranes are equipped with an on-r oad engine. In cases where the single-engine crane is equipped with an off-road en gine, the Off-Road Regulation will apply. However, if a crane operates at any time at a port of intermodal rail yard in California, the propulsion engine is subject to the Cargo Handling Equipment Regulation, regardless of whether the engine is on- road or off-road or whether the crane has only one engine or two (ARB, 2006). Many crane operators own cranes that are brought onto the port or intermodal rail yard facil ities on an as-needed basis. These cranes would be required to comply with the Cargo H andling Equipment Regulation, whereas, they would otherwise be required to comply with the proposed On-Road Regulation or the Off-Road Regulation, along with r est of the owners’ fleets.

1. Feasibility of Repowering and Retrofitting Any changes to the crane requires the manufacturers to approval those changes. The willingness of manufacturers to approve such change s is limited or unlikely and would be cost prohibitive. Crane manufacturers assume a huge financial risk for a failure of their product. They are reluctant to assume liabil ity for a California market requirement which represents low sale volume of cranes worldwid e. Some OEM crane manufacturers are no longer in existence since ther e has been a contraction in the number of companies producing cranes.

Crane’s secondary engines are frequently controlled by electronic control systems and software unique to the crane make, model and model year (Sierra, 2007). Reprogramming the control system to accept a differ ent model or model year engine would require technical support of the crane manufa cturer. Crane manufacturers wouldL-3

have to update the operation/safety manuals to docu ment the affect of any of the changes.

The repowering or retrofitting of the secondary eng ine has considerable feasibility issues not present for most portable engines includ ing other two-engine vehicles. Since the engine and the diesel particulate filter, DPF, could be physically larger than the original engine, this fact could lead to space limi tations. The engine compartment may be too small to physically fit the new engine or al low for proper air circulation in a confined area and require modification to the cooli ng system. Repowering to a Tier 3 and Tier 4 engine would require the use of electron ic fuel injection and an electronic control module, ECM. Modification to the existing wiring harness or a new wiring harness would be necessary to connect the ECM to en gine function sensors and other electrically controlled devices to monitor/control engine performance. Modifications to the exhaust system may be required to accommodate e xhaust exit and DPF locations.

2. Safety and Design The design complexity of cranes and modifications t o the original design cannot be easily accomplished. Cranes manufacturers would ha ve to engineered the changes and design/specify parts to ensure safe crane opera tions. For example, the repowering or retrofitting secondary engine creates safety and design concerns. The secondary engine is part of the counterweight system of the c rane. A small weight change could have a significant impact on a crane’s lifting capa city and interfere with the electronic controls programmed into the crane’s positioning sy stem year (Sierra, 2007).

3. Certifications Cranes manufacturers certify their equipment to OSH A and ANSI requirements to ensure safe operation and to prevent damage to the crane. Any modification, alteration or change to a crane which affects its original des ign, and not authorized and approved by the crane manufacturer is strictly prohibited an d voids any manufacturer warranties. Repowering or retrofitting secondary crane engines will first require crane manufacturers’ approval and secondly require recert ification by OSHA and Cal-OSHA (Sierra, 2008 and Sierra 2007).

Even with crane certifications, accidents do occur. There were 72 fatalities in 2006 and average of 78 fatalities per year from 2003 to 2005 associated with cranes in construction (US BLS, 2008). Crane fatalities can be caused crane tip-over, struck by the load or cab/counterweight and boom/cable failur es.

4. Cost The crane cost curves were developed from Machinery Trader.com. A limited number of two-engine truck mounted hydraulic/all terrain cran es and truck lattice boom cranes were for sale and listed with the necessary engine or horsepower information. The price curves developed were in dollars per horsepow er since the off-road model utilizes cost data in this format. These cost curves are lo cated in Appendix. I. Besides age ofL-4

the crane, cost will vary based on lifting capacity and boom length of these cranes. Both types of cranes are expensive compared to most other vehicles.

C. Emission Impact Thirteen crane owners and operators provided us wit h fleet information. Fleets included off-and on-road cranes powered by single off- or on -road motive engines, and off-road two-engine cranes powered by off- or on-road motive engines with off-road secondary engines. The different crane types listed in vario us fleets included: all terrain, lattice boom, crawler, and rough terrain. The fleets were either medium or large fleets based on their total horsepower which included the motive and secondary engines.

The off-road model was utilized to determine fleet actions and the off road inventory was used to calculate the PM and NOx emissions for 2010 through 2030 for both offand on-road motive and secondary engines. The off- road model is able to calculate emissions for on-road engines since it has both on- and off-road emission factors. Hours of usage, emissions and load factors from the off-road model were used in the emission calculations.

Table 1 and Table 2 contain details of the two-en gine cranes used in emission calculations. Table 1: Two-Engine Crane Types

Crane Type Quantity Truck Mounted Hydraulic 59 Truck Mounted Lattice Boom 34 Total 93

Table 2: Two-Engine Crane Engines

Crane Type Off-Road Drive Engine On-Road

Drive Engine Off-Road

Secondary Engine Truck Mounted Hydraulic 6 53 59 Truck Mounted Lattice Boom NA 34 34

Currently, PERP has approximately 262 crane seconda ry engines registered in their program. The California Department of Motor Vehicl e (DMV) 2006 database had 2,113 cranes registered as passenger vehicle. The inform ation provided by the crane owners and operators had 227 DMV registered cranes. Ninet y three of them were two-engine cranes or 41 percent (93 divided 227). Using this percentage and applying it to the DMV database information, staff estimates that ther e are 866 two-engine cranes. Staff used 93 two-engine cranes in their analysis using t he off-road model to estimate the emissions benefits of the proposed changes. The re sults was scaled up by a factor of 9.31 (866 divided by 93) to reflect the total emiss ions from the cranes affected. The results are compared to the emissions expected with normal replacement and theL-5

expected benefits from the Portable Equipment ATCM Regulation and the Off-Road Regulation.

It appears that a minority of crane owners and oper ators registered their secondary or portable engine in PERP and they instead opt to reg ister or permit with the appropriate local air quality districts.

Staff used the off-road model to determine baseline emissions with all existing regulations applied to the crane operator fleet equ ipment. First, the baseline emissions were calculated by determining the normal replaceme nt cycle expected to be used by the individual fleets analyzed. Second, staff esti mated the emissions reductions from two engine cranes that would have occurred from eli minating the operation of uncontrolled (Tier 0) secondary engines starting Ja nuary 1, 2010 and by calculating the PM reductions expected from the portable ATCM requi rements phased in from 2013 to 2020. Secondary engines in lattice boom cranes are exempt until 2020 and no reductions from these engines are estimated until 2 020 when few are expected to remain operational. Third, staff calculated the em issions reductions expected from all of the off-road drive engines subject to the off-road vehicle regulation. Since the off-road vehicle regulation does not have engine replacement requirements for fleets with less than 2501 hp there were no NOx benefits expected fr om a number of the fleets. The new baseline was then calculated by subtracting the benefits expected from the OffRoad Regulation and the Portable Equipment ATCM fro m the emissions expected without regulation.

As shown in Figure 2 and Table 3, there is a slight increase in NOx emissions in 2010 through 2013 from the current proposal compared to emissions with existing regulations, but there is a considerable benefit af ter 2013.

Figure 1: NOx Emissions Benefits of Staff Proposal

0.00 1.00 2.00 3.00 4.00 5.00 6.00 7.002010201120122013201420152016201720182019202020212022202320242025NOx (tpd) Existing Regulations Staff ProposalL-6

Table 3: Statewide NOx Emissions Reductions from Pr oposed Regulation

NOx Emissions (tons per day) Projected Reductions Calendar Year Baseline With the Regulation (tons per day) Percent from Baseline 2010 6.0 6.2 -0.2 -3% 2014 5.0 4.7 0.3 6% 2017 4.1 3.2 0.9 22% 2020 3.3 2.0 1.3 38% 2023 2.9 1.8 1.0 36%

As shown in Figure 1 and in Table 4 the PM emission s would be slightly higher in 2010 and 2011, but would be substantially better thereaf ter. The baseline emissions with existing regulations, shows a considerable drop in 2018 because many of the crane fleets would be considered small fleets in the off- road vehicle regulation and would not need to replace engines or install PM retrofits unt il 2015. Because of normal replacement, most fleets in 2015 would meet the PM average and would not need to install a significant number of exhaust PM retrofit devices until 2018 and 2019.

Figure 2: PM Emissions Benefits of Staff Proposal

0.00 0.05 0.10 0.15 0.20 0.25 0.30 0.352010201120122013201420152016201720182019202020212022202320242025PM (tpd) Existing Regulations Proposed RegulationL-7

Table 4: Statewide PM Emissions Reductions from Pro posed Regulation

PM Emissions (tons per day) Projected Reductions Calendar Year Baseline With the Regulation (tons per day) Percent from Baseline 2010 0.312 0.326 -0.013 -4% 2014 0.251 0.177 0.074 29% 2017 0.224 0.106 0.118 53% 2020 0.134 0.067 0.066 50% 2023 0.112 0.062 0.050 45%

D. References ARB, 2006. Air Resources Board. Regulation for Mo bile Cargo Handling Equipment at Ports and Intermodal Rail Yards. December 2006.

ARB, 2007a. Air Resources Board, Regulation to Est ablish a Statewide Portable Equipment Registration Program. September 27, 2007

. http://www.arb.ca.gov/regact/2007/perp07/froreg.pdf

ARB, 2007b. Air Resources Board. Airborne Toxic C ontrol Measure for Diesel Particulate Matter From Portable Engines Rated at 5 0 Horsepower and Greater. September 12, 2007. http://www.arb.ca.gov/portable/perp/peatcm091207.pd f

ARB, 2008. Air Resources Board. Regulation for In -Use Off-Road Diesel Vehicles. June 15, 2008. http://www.arb.ca.gov/regact/2007/ordiesl07/frooal. pdf

US BLS, 2008, US Bureau of Labor Statistics. Crane Related Occupational Fatalities Fact Sheet July 2008.

MachineryTrader, 2008. Machinery Trader. Construc tion Equipment for Sale: Crane. October 5, 2008. www.machinerytrade.com

Sierra, 2008. Sierra Research. Letter From Gary R ubenstein of Sierra Research to Tony Brasil of ARB with attachments. March 14, 200 8.

Sierra, 2007. Sierra Research. Letter From Allan Daly to Clerk of the Board of ARB of ARB with attachments. March 21, 2007.L-8 Sierra Research 2007L-9L-10L-11L-12L-13L-14L-15L-16L-17

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Email: docket-customerservice@epa.govL-20 Sierra Research 2008L-21L-22L-23L-24L-25 Emission Benefits

CY Total Nox TPD No Rule All Engines Total Nox TPD

Off Road Rule Upper & Drive Engines Nox

Reduction TPD ATCM Rule Upper Engine Nox

Reduction TPD Off Road Rule Drive Engine Nox TPD

Net Benefit Nox %

Net Benefit CY 9.31X

Scaled Baseline Nox TPD 9.31X

Scaled OffRoad Rule Nox TPD CY 9.31X

Scaled Nox TPD Net Benefit Average

Nox TPD 2010 0.647893 0.638169 0.030540 0.000610 -0.021425 -3% 2010 6.032 6.231 2010 -0.199 -0.130 2011 0.644393 0.622010 0.032895 0.000626 -0.011138 -2% 2011 5.999 6.103 2011 -0.104 2012 0.615869 0.591812 0.035673 0.001151 -0.012766 -2% 2012 5.734 5.853 2012 -0.119 2013 0.575626 0.549508 0.035891 0.000543 -0.010317 -2% 2013 5.359 5.455 2013 -0.096 2014 0.532712 0.467304 0.027673 0.004681 0.033053 6% 2014 4.960 4.652 2014 0.308 0.847 2015 0.492167 0.411966 0.024546 0.007408 0.048248 10% 2015 4.582 4.133 2015 0.449 2016 0.470984 0.365102 0.022374 0.012039 0.071469 15% 2016 4.385 3.719 2016 0.665 2017 0.443090 0.304467 0.022227 0.016714 0.099683 22% 2017 4.125 3.197 2017 0.928 2018 0.426081 0.275418 0.020704 0.014005 0.115955 27% 2018 3.967 2.887 2018 1.080 2019 0.367785 0.221082 0.009371 0.021179 0.116153 32% 2019 3.424 2.343 2019 1.081 2020 0.353574 0.183434 0.006642 0.028922 0.134576 38% 2020 3.292 2.039 2020 1.253 2021 0.311082 0.163597 0.007075 0.022192 0.118219 38% 2021 2.896 1.796 2021 1.101 2022 0.303903 0.157305 0.007557 0.020635 0.118404 39% 2022 2.829 1.727 2022 1.102 2023 0.308561 0.167239 0.008098 0.022854 0.110370 36% 2023 2.873 1.845 2023 1.028 2024 0.293607 0.167522 0.008722 0.024468 0.092896 32% 2024 2.733 1.869 2024 0.865 2025 0.289411 0.166875 0.007280 0.015749 0.099507 34% 2025 2.694 1.768 2025 0.926 2026 0.276511 0.158615 0.007695 0.014034 0.096167 35% 2026 2.574 1.679 2026 0.895 2027 0.252758 0.158022 0.006110 0.008944 0.079683 32% 2027 2.353 1.611 2027 0.742 2028 0.245726 0.157766 0.006145 0.009528 0.072288 29% 2028 2.288 1.615 2028 0.673 2029 0.235109 0.152322 0.006231 0.004361 0.072195 31% 2029 2.189 1.517 2029 0.672 2030 0.233823 0.151475 0.003906 0.010224 0.068218 29% 2030 2.177 1.542 2030 0.635

CY Total PM TPD No Rule All Engines Total PM TPD

Off Road Rule Upper & Drive Engines PM

Reduction TPD ATCM Rule Upper Engine PM

Reduction TPD Off Road Rule Drive Engine PM TPD

Net Benefit PM % Net

Benefit CY 9.31X

Scaled Baseline PM TPD 9.31X

Scaled OffRoad Rule PM TPD CY 9.31X

Scaled PM TPD Net Benefit Average

PM TPD 2010 0.033563 0.032050 0.002794 0.000161 -0.001441 -4% 2010 0.312 0.326 2010 -0.013 -0.009 2011 0.033198 0.030533 0.002817 0.000353 -0.000505 -2% 2011 0.309 0.314 2011 -0.005 2012 0.031231 0.026363 0.002885 0.000583 0.001401 4% 2012 0.291 0.278 2012 0.013 0.055 2013 0.029248 0.020427 0.002825 0.001283 0.004713 16% 2013 0.272 0.228 2013 0.044 2014 0.026917 0.014911 0.002592 0.001475 0.007939 29% 2014 0.251 0.177 2014 0.074 2015 0.025449 0.010859 0.002633 0.001876 0.010081 40% 2015 0.237 0.143 2015 0.094 2016 0.024720 0.007738 0.002762 0.002386 0.011835 48% 2016 0.230 0.120 2016 0.110 2017 0.024082 0.004689 0.003073 0.003660 0.012660 53% 2017 0.224 0.106 2017 0.118 2018 0.023073 0.003844 0.003150 0.003226 0.012853 56% 2018 0.215 0.095 2018 0.120 2019 0.015755 0.003109 0.002256 0.002689 0.007701 49% 2019 0.147 0.075 2019 0.072 2020 0.014345 0.002266 0.002425 0.002541 0.007113 50% 2020 0.134 0.067 2020 0.066 2021 0.013344 0.001815 0.002640 0.002312 0.006577 49% 2021 0.124 0.063 2021 0.061 2022 0.012050 0.001741 0.002645 0.002341 0.005323 44% 2022 0.112 0.063 2022 0.050 2023 0.012021 0.001619 0.002600 0.002398 0.005404 45% 2023 0.112 0.062 2023 0.050 2024 0.009550 0.001563 0.002606 0.002259 0.003122 33% 2024 0.089 0.060 2024 0.029 2025 0.009829 0.001573 0.002315 0.001836 0.004106 42% 2025 0.092 0.053 2025 0.038 2026 0.008709 0.001565 0.002168 0.001882 0.003093 36% 2026 0.081 0.052 2026 0.029 2027 0.007202 0.001562 0.002059 0.001797 0.001784 25% 2027 0.067 0.050 2027 0.017 2028 0.006899 0.001569 0.002064 0.001196 0.002070 30% 2028 0.064 0.045 2028 0.019 2029 0.006503 0.001558 0.001964 0.001051 0.001930 30% 2029 0.061 0.043 2029 0.018 2030 0.006452 0.001558 0.001758 0.001063 0.002073 32% 2030 0.060 0.041 2030 0.019L-26