FAQ - EPA


What we need to know!

 


  1. Introduction
  2. Engines built before the new-engine standards take effect
  3. Engines required to participate in the Marine Remanufacturing Program
  4. Responsibility for all covered engines
  5. Remanufactured systems and how to know if one has been certified for your engine
  6. When is a certified remanufacture kit considered available?
  7. Rolling Rebuild kit requirements
  8. If a kit is Not available today?
  9. Anyone can certify a marine remanufacture kit, by applying to EPA for certification.
  10. Exemptions apply for special situations Revenue-Based Deferral

 

 

The U.S. Environmental Protection Agency (EPA) has adopted a new emission control program for marine diesel engines that, for the first time, includes emission standards for certain engines already in operation. (* Ref epa.gov/otaq/regs/nonroad/marine/ci/420f09003.htm)

 

 

Introduction:

Marine diesel engines are significant contributors to ambient levels of ozone and particulate matter (PM) pollution in our nation’s ports and along our rivers and coastal waterways. When fully phased-in, EPA’s latest emission standards for new engines will result in substantial reductions of nitrogen oxides (NOx) and P emissions from marine vessels.

 

 Engines built before the new-engine standards

take effect, however, will continue operating with higher emissions for a long time. Like locomotives, the service life of many of these engines can be 30 years or more. The Marine Remanufacture Program will provide early air quality benefits by reducing PM emissions from the legacy fleet sooner than would be the case through the normal turnover of the fleet to vessels with new engines.

 

 

Engines Required to participate in the Marine Remanufacture Program

 

  •            It is installed on a vessel that is flagged or registered in the United States.

  •            It is a commercial marine diesel engine

  •            It was manufactured between 1973 and the last Tier 2 model year. 1(footnotes)

  •            It has power at or above 600 kilowatts (Kw). 2(footnotes)  

  •            It has a displacement of less than 30 liters per cylinder.3(footnotes)


Responsibility for all covered engines

Essentially, if your commercial marine diesel engine is covered by the Marine Remanufacture Program, you are required to use a certified remanufacture system when you remanufacture your engine, if one is available. These terms and criteria are described in more detail below. Remanufacturing, for the purpose of this program, is the removal and replacement - including re-qualifying of all cylinder liners, either all in a single maintenance event or over a period of five (5) years or less. If your cylinder replacement/re-qualifying schedule takes longer than five years, EPA does not consider this to be remanufacturing under this rule. As used here, “re-qualifying” means to inspect a cylinder that may have been recently replaced due to a failure, to make sure it qualified for continued use. Even though an engine may be “remanufactured” during a rebuild event, not all rebuild events and not all maintenance events are considered to be remanufacturing. A rebuild may include extensive maintenance that increases the service life of the engine, however it will not be considered to be remanufacturing unless all of the cylinder liners are replace, either at once or over a period of 5 years.

 

Remanufactured systems and how to know if one has been certified for your engine

A remanufacture system, commonly referred to as a “remanufacture kit,” is a process for making an engine meet certain emissions criteria – in this case, a 25 percent reduction in PM emissions. The kit may consist of instructions, specifications, limitations and/or engine components. In most cases, a kit is expected to consist of “better” versions of parts normally replaced at rebuild and should not adversely affect engine reliability, durability, or power. For example, a kit could include different fuel injectors or different piston rings to reduce oil consumption. However, in some cases it may consist of only instructions for tuning to engine or calibrating adjustable features. If there are several remanufacture systems certified for your engine, you may chose amount them.

 

In addition to engine-based kits, EPA will allow certification of fuel-based kits. These would consist of a process of reducing the PM emissions by changing fuel or using a fuel additive. However, owners of engines covered by fuel-based kits will not be required to use them. Instead, they may be used as an alternative to the use of certified engine-based kits.

 

EPA maintains a list of certified remanufacture systems for marine diesel engines. Visit EPA’s web site at http://www.eap.gov/otaq/certdata.htm to see if a kit has been certified for your engine.

 

When is a certified remanufacture kit considered available?

A remanufacture kit is generally considered to be available 120 days after it is certified. When you visit EPA’s web site at http://www.epa.gov/otaq/certdat.htm, you will see both the certificate issuance date and the date of availability.

 

There are two other important criteria that determine if a kit is available for your engine;

 

First, you must be able to obtain the kit in a timely manner according to normal remanufacturing practices. For example, a kit would not generally be considered to be available if you would need to remove the engine from your vessel and send it to a factory to be remanufactured.

 

Second, the kit must not be too costly, in terms of dollars spent for each ton of PM reduced. EPA considers a kit to be too costly if it exceeds a marginal cost threshold of $45,000.00 per ton of PM reduction. The marginal cost of a kit is the added cost of using the kit over and above the cost of manufacturing the engine conventionally, divided by the total amount of PM reductions expected over the useful life of the remanufactured engine.

 

We expect that kits will not be certified if they cannot be obtained in a timely manner or if they exceed the cost limit. However, your conditions may be unique. For example, a vessel with external keel cooling may not be able to achieve specified cooling levels required by the kit without extensive modifications to the vessel hull. If you think a kit is not available for your engine for either of these reasons, you should contact EPA

 

Rolling Rebuild kit requirements

A rolling rebuild typically refers to the practice of replacing and upgrading parts incrementally over many years. If you are doing a rolling rebuild and your schedule includes replacing/ re-qualifying all your cylinder liners over five years or less, you are remanufacturing your engine according to this program. In the case of a rolling rebuild, the clock that determines your deadline for complying with the rule starts on the date when the first set of cylinder liners is replaced, after a kit is available. This compliance clock stops on the date of replacement of the last set of cylinder liners that completes the remanufacturing, even if this is less than five years from when the clock started. If the components of your kit are compatible with your engine’s current configuration, you may install them incrementally at your discretion. However, the latest a certified remanufacture kit must be applied to your engine is when the last set of cylinder liners is replaced, as determined from the clock start date described above.

 

If a kit is Not available today?

If a certified remanufacture kit is not available for your engine, you must continue to comply with the otherwise applicable engine rebuilding requirements in 40 CFR Part 94 when you rebuild your Category 1 or Category 2 marine engine.

 

Also, before a schedule cylinder liner replacement, you should check EPA’s web site at http://www.epa.gov/otaq/certdata.htm to see if a kit has become available for your engine.

 

Anyone can certify a marine remanufacture kit, by applying to EPA for certification.

You must submit test results showing that the kit will reduce PM emissions as required by the rule. Your application must also show whether owners may obtain and install the remanufacturing kit in a timely manner for a total cost that is less than $45,000.00 per ton of PM reduced. The details on submitting an application can be found at 40 CFR Part 10452, Subparts C and I. You should contact EPA with any questions on your application.

 

Due to similarities between the Marine Remanufacture Program and the Locomotive engine Remanufacture program, we have a streamlined process to allow locomotive kits to be used with marine engines. You should contact EPA if you think your kit qualifies for this process.

 

Exemptions apply for special situations Revenue-Based Deferral:

You do not have to use a certified kit when you remanufacture your engine, if you can show that your gross annual sales revenue (including all revenues from any parent company and its subsidiaries) was less than $ 5 million in 2008 dollars 4(footnotes), during the calendar year prior to the remanufacture event (or the compliance date in the case of a rolling rebuild). Although you do not need to apply to EPA to receive this deferral, you should keep records of your calculations for each year that you qualify.

 

State Program Exemption:

You may qualify for an exemption if you install emission controls before January 1, 2017 on your covered marine engine as part of a retrofit program through your state or local government. You must apply to EPA for this exemption before you remanufacture your engine.

 

Hardship Exemptions:

There are two ways to qualify for a hardship exemption under this program. You must apply to EPA for either of them.

 

EPA may approve an exemption if you demonstrate that circumstances out of your control prevent you from meeting all the requirements of this rule. You must submit a compliance plan, explaining how much more time you need to comply.

 

EPA may approve an exemption if you can show that a remanufacture kit is not “available” for your vessel (see “When is a certified remanufacture kit considered available?,” above).



footnotes

footnote1   Depending on engine size, this could be 2008,2011,2012, or 2013. Information about the standards to which an engine is certified is located on the engine label. For help identifying your engine’s tier, contact the engine manufacturer or EPA.

 

footnote2   This is roughly equivalent to 800 horsepower(hp). This information is also on the engine label.

 

footnote3   This program does not apply to Category 3 marine engines. There is a separate existing program for Category 3 marine diesel engines; you may contact EPA for more information about that program.

 

footnote4   Visit www.bls.gov for the Producer Price Index to calculate the equivalent 2008 dollars for another year.