Public Hearing to Conside

Proposed Amendments to

Transport Refrigeration Unit (T

Airborne Toxic Control Measure 

Sacramento, Ca

October 21, 2
Overview

• Background • Emissions Inventory Update• Proposed Amendments• Economic Impacts• Emissions Impacts• Health Impacts• Recommendation
Background

• Diesel PM identified as TAC in 1998• TRU’s congregate in large numbers at 

distribution centers – Very high near-source risk (> 100/million co

• TRU ATCM adopted 2004• U.S. EPA approved waiver 

January 16, 2009

• 2010 Amendments – Board direction
TRU Applications

• What is a TRU?

– Refrigeration systems powered by integral 

engines 

– Used to control the environment of tempera

sensitive products that are transported in trsemi-trailers, railcars, and shipping contain
Primary Requirements

of Current Regulation

• Web-based registration

– Voluntary for TRUs based outside Californ

• Submit Operator Reports

– California terminals where TRUs are assig

• Meet in-use performance standards

– Affects all TRUs that operate in California– Phased compliance schedule based on 7-

operational life
In-Use

Performance Standard

• Two levels of stringency – Low-Emission TRU (LETRU)

• >50 percent PM emission reduction – Ultra-Low-Emission TRU (ULETRU)• >85 percent PM emission reduction

• Compliance options available now – Repower - engine replacement – Retrofit with verified diesel particulate filte

– Use alternative technology - hybrid electr– Available now for model year 2004 
In-Use Performance Stand

Compliance Schedule

• Engine model year (MY) 2003 and 

– Step 1: Meet LETRU when 7 years old – Step 2: Meet ULETRU when 14 years old

• Engine MY 2004 and newer – Skip LETRU – Meet ULETRU when 7 years old
Implementation Status

• Outreach training, compliance assista• Stakeholder issue meetings• Regulatory advisories• Compliance technology development a

verification

• Technology forums• Web-based TRU registration system• Toll-free helpline
Implementation Status

(Cont.)

• Enforcement

– Registration and in-use requirements– Inspections at:

• Border crossings • Distribution centers • Scales • Ag inspection stations• Ports • Carrier terminals• Intermodal facilities
Implementation Status

(Cont.)

• Compliance Assistance

– Letters to owners registered in ARBER– Emails to TRU List Serve– Developing a List of “100% Compliant Flee
2010 Amendments

• Board approved three amendments ne

the end of 2010

– Added compliance options for MY 2003 en– Addressed flexibility engines– Enhanced OEM Reporting

• Board directed staff to:

– Evaluate request for longer operational lif

• Emissions inventory update• Cost of compliance – economic impacts update• Health risk assessment update
Evaluate Longer Operationa

MY 2004 and Newer Engines

• Impact of extending operational life to 8

years

– Public health risk at existing 7 years is too h– Potential public health impacts from delay 

• Increasing operational life to 8-10 years erodes c

reductions by about 10-40 percent

• Staff recommends maintaining existing 

operational lifetime requirement
Evaluate Longer Operationa

Health Risk at TRU Facilities

• Estimated off-site potential cancer risk from a 

“typical” facility with current 7-year operation

• Activity at “large” distribution centers is high

– Average is about 2,000 hours per week– Highest reported: >8,000 hours per week

Activity 

(Engine Hours Per Week)

Loads Per Week Near-Sou

Cancer Healt

100 40 >10 per m

1000 400 >100 per m
Evaluate Longer Operationa

Health Risk at TRU Facilities (Co

• At least 500 facilities with a potential c

risk above 10/million

• At least 50% of these located near resi

off-site workplaces, and sensitive rece
TRU Emission Inventory Up

• New input data collected since 2003 an

applied to current inventory includes:

Input Data Source

In-state population 2011 ARBERDaily out-of-state population 2010 Truck and Bus RuleEngine load factors Manufacturer input, engine perfor

Annual engine activity, overall 2006 Facility Survey, 2010 Truck 

Rule

Annual engine activity, in-state 2006 Facility SurveyEmission Factors Tier 4 final StandardsGrowth Rate 1990-2010 national engine sales
TRU Emission Inventory Up

(Cont.)

Input 2011 Compared to 20

In-state population 20 percent lowerDaily out-of-state population 10 percent lowerEngine load factors 13 percent lowerAnnual engine activity, overall 15 percent higher, per unitAnnual engine activity, in-state 8 percent lowerEmission Factors Future emission factors lower to r

standard

Growth Rate 50 percent lower
TRU Emission Inventory Up

Statewide PM Emissions
TRU Emission Inventory Up

Statewide PM Emissions
Economic Impacts Updat

Actual Compared to 2003 Staff Re

• Actual capital costs increased• Operating and maintenance costs refine• Compliance methods actually used

– VDECS retrofits (20%) – Engine repowers (70%)– Unit replacements (10%)– Alternative Technologies (< 1%)

• Cost-Effectiveness changed

– $83 per pound PM (originally estimated $10 to $2

pound) 
Proposed Amendment

• Extension of ULETRU compliance date 

some MY 2003 and older engines

• Provide flexibility• Improve enforceability• Improve compliance rates• Clarify existing requirements
Proposed Amendment

Extension for MY 2003 and Older En

• Model year 2003 and older, if met LETRU

– Extend ULETRU compliance date 1 year– MY 2001 and older, if met LETRU by 12-31-0

results in 2 year ULETRU extension 

• Extends operational life• Restores competitive fairness for emiss

reduction actions taken

• Negligible emissions and risk impacts
Proposed Amendment

Administrative Extensions 

• Up to one-year extension if complying 

technology is not available

– Application required before deadline– Demonstrates no suitable filter or engine ava

• Up to four-month extension if delivery o

installation are delayed

• Case-by-case consideration
Proposed Amendment

Provide Flexibility

• Use of unit manufacture year instead of 

engine model year - extends operationa

• Use of unique equipment identification 

numbers instead of ARB’s

• Exemptions

– Obviously nonoperational equipment– Non-diesel-powered refrigeration systems– TRUs used during certain emergencies
Proposed Amendment

Improve Enforceability

• Clarify recordkeeping requirements for h

electric TRUs

– TRU engine operation eliminated at nonretail facilitie

(distribution centers)

– Electric power plugs must be available– TRU engine operation limited to less than 30 minutes 

delivery points 

• Automated electronic tracking and repo

phased in, starting 2013

– Small initial capital cost– Significant labor savings – expected payback less th
Proposed Amendment

Improve Compliance Rates

• Hired or contracted carriers must dispa

compliant TRUs

– Brokers, shippers, and receivers must demo

due diligence 

– Contract with carrier must specify use of AR

compliant equipment

• Minimizes unfair competition created by 

noncompliant equipment
Proposed Amendment

Improve Compliance Rates (Con

• TRU manufacturers and engine rebuilde

– Provide registration information documents 

supplemental engine labels

• Dealers and repair shops

– Pass registration information documents to 

party in chain (ultimately to the end-user)

• TRU manufacturers that use flexibility e

– Notify ARB– Provide supplemental labels and written dis
Proposed Amendment

Clarifications

• Repowering with a new replacement or 

engine

– Effective model year determines when it mu

the in-use standards

• Noncompliant equipment

– Flexibility for dealers to possess, sell, and m

noncompliant units

– Seller must disclose noncompliant status to 

• Requirements for lessors and lessees• Engine rebuilders 

– Rebuild to a cleaner configuration 
Economic Impacts

2011 Amendments

Proposed Amendment Statewide 

Cost or 

ULETRU Extension for < MY 2003 Timely LETRU 

Compliance ($35Electronic Recordkeeping for Hybrid Electric/Electric Standby ($3.9 Compliance Verification for Responsible Parties $11 Exemption of TRUs Used During Emergencies ($34Use of TRU Manufacture Year ($21 Supplemental Labels and Registration Information $1.6 Net Total Cost or (Savings) ($13 m
Emissions Impacts

Proposed Amendments
Health Impacts

Proposed Amendments

• Small annual reductions deferred seve

years

– Combined emissions impacts for all propo

amendments totals 0.21 tpd (2009 to 2018)

• Emission reductions continue• Public health risk reductions at distribu

centers continues
Compliance Options

• Several options for complying with standards• Engine or unit replacement

– Chosen for 80% of units, readily available

• Retrofits 

– Chosen for 20% of units– Availability of Level 3 retrofit (>25 hp MY 2004)

• One fully verified Level 3 retrofit available now•

2nd expected to be verified and available fall 2011

– Amendments allow Executive Officer to extend com

deadline for availability, delivery, and installation de
Staff’s Suggested Modificat

to Proposed Amendment

• OEMs provide disclosure document wit

that are equipped with a flexibility engin

• Dealers notify the end-user that unit is e

with a flexibility engine and provide the written disclosure

• Provide OEM the flexibility to develop 

alternatives to providing registration information documents with each unit
Recommendation

• Adopt the proposed amendments• Direct staff to:

– Continue outreach efforts– Continue working with brokers, shippers, 

receivers on compliance assistance tools

– Administratively implement the Executive 

extension authority for MY 2004, if necess

– Continue to work with electronic tracking

system suppliers

– Evaluate alternatives to enable

TRUs rated at less than 25 hpto comply with ULETRU