Case Study: GSWC Fleet Compliance - CA-NV AWWA€¦ · Case Study: GSWC Fleet Compliance –Air...

Case Study: GSWC Fleet Compliance

Air Challenges in the Water WorldOctober 2, 2013

Case Study: GSWC Fleet Compliance – Air Challenges in the Water World

Agenda

2

• Expectations

• Regulatory Background

• Regulatory Overview

• GSWC Project Details and Recommendations

• Q&A


Expectations

3

• Am I complying with all the federal, state and local

regulations applicable to my equipment?

• Am I properly reporting and labeling my

equipment?

• Am I inspecting my equipment over the proper

intervals, and maintaining records?

• Do my operators know not to idle more than five

minutes?

• What is an ECL, and do all my engines still have

their manufacturer label on them?

• Where can I go for more information on a specific

regulation?

• What are the fines if I don’t comply?


Regulatory Background

4

• What is Diesel PM and why is it important?

• In 1998 the California Air Resources Board (ARB)

determined diesel particulate matter (PM) to be

carcinogenic. Compression ignition (CI) engines

are a major source of diesel PM.

• What is an ATCM?

• Airborne Toxic Control Measures (ATCMs) were

promulgated by ARB as required by the California

Diesel Risk Reduction Program (CalDRRP).

• What purpose do ATCMs serve?

• ATCMs were implemented to reduce diesel PM and

criteria pollutant emissions from CI engines (i.e.,

diesel)


Regulatory Overview

5

• Which regulations affect my operations?

• Stationary ATCM - 2004

• Portable ATCM – 2005

• Large Spark-Ignition (LSI) Regulation - 2007

• Off-road Diesel (ORD) Regulation - 2008

• Public Agency and Utility (PAU) Regulation - 2005

• Periodic Smoke Inspection Program (PSIP) - 1999

• Emission Control Label (ECL) Program - 2007

• For a complete list go to:

http://www.arb.ca.gov/diesel/diesel.htm




Regulatory Overview – Stationary ATCM

6

• Applicability: Owners/operators of stationary diesel-

fueled CI engines ≥ 50 brake horsepower (bhp)

• Website: http://www.arb.ca.gov/diesel/statporthome.htm

• Performance Requirements (new engines):

• Prime engines: Must meet current Tier level for NOX,

HC and CO plus 0.01 g/bhp-hr for PM

• If you operate a prime engine, you should also be

concerned with USEPA RICE NESHAP (see

http://www.epa.gov/ttn/atw/icengines/)

• Emergency engines:

• Meet current Tier standards

• Limit maintenance and testing hours

• Enforced by your local air district

• Some districts may have additional requirements

Examples:• Emergency generators

• Prime/emergency pumps

http://www.arb.ca.gov/diesel/statporthome.htm

http://www.arb.ca.gov/diesel/statporthome.htm

http://www.epa.gov/ttn/atw/icengines/

http://www.epa.gov/ttn/atw/icengines/


Regulatory Overview – Portable ATCM

7

• Applicability: Owners/operators portable diesel-fueled CI

engines ≥ 50 bhp

• Website: http://www.arb.ca.gov/diesel/peatcm/peatcm.htm

• Fleet Requirements:

• New engine must meet current Tier standards

• Must meet (or have met) fleet standards as of:

• 1/1/2013, 1/1/2017 and 1/1/2020

• Must report (or have reported) by:

• 3/1/2013, 3/1/2017 and 3/1/2020

• By 1/1/2020 all engines must be:

• Meet Tier 4 standards, or

• Be equipped with a diesel particulate filter

• Capable of 85% reduction (i.e., Level 3)

Examples:• Compressors

• Generators

• Welders

• Pumps

http://www.arb.ca.gov/diesel/peatcm/peatcm.htm




Regulatory Overview – Portable ATCM (continued)

8

• Fleet Requirements (continued):

• Emergency and Low-use* engines

• Not required to meet fleet standards

• Non-certified engines must be replaced with most stringent

Tier by 1/1/2017

• Certified engines must meet one of the following by 1/1/2020:

• Certified to meet Tier 4 standards, or

• Must be equipped with a Level 3 VDECS

• Enforcement:

• Districts reviewing 1 March reporting

• Permitting/Registration:

• ARB PERP

• Local Air District

• Hybrid permit

* Low-use is less than 80 hours per year


Regulatory Overview – What are the Tier standards?

9


Regulatory Overview – Off-road Diesel (ORD) Regulation

10

• Applicability: owner/operators of vehicles with a diesel-

fueled CI engine ≥ 25 bhp that:

• Cannot be registered and driven safely on-road, or

• Was not designed to be driven on-road

• Website:

http://www.arb.ca.gov/msprog/ordiesel/ordiesel.htm

• Requirements:

• Fleet reduction in diesel PM and NOX

• Retrofit, repower, replace or retire

• Five-minute idling limit (medium and large fleets)

• Written idling policy (large fleets)

• Report all vehicles in DOORS

• Restrictions on adding older vehicles

Examples:• Forklifts

• Tractors

• Loaders

• Cranes

EPA GRANTED

APPROVAL ON

13 SEPTEMBER 2013




Regulatory Overview – ORD Regulation (continued)

11

• Requirements (continued):

• Labeling of all vehicles (both sides)

• Disclosure when selling vehicles within CA

• Annual reporting (depends on fleet size)

• Fines:

• Idling –

• 1st Offense: $300 per day per vehicle

• 2nd Offense: $1,000 to $10,000 per day per vehicle

• Reporting – $1,000

• Performance – up to $10,000 per day

• Exemptions:

• Low-use vehicles ≤ 200 hours per year


Regulatory Overview – Large Spark-Ignition Regulation

12

• Applicability: owner/operators of vehicles with a spark-

ignition engine ≥ 25 bhp and > 1 liter in displacement

• Gasoline and LPG

• Website:

http://www.arb.ca.gov/msprog/offroad/orspark/orspark.htm

Only Covers:• Forklifts

• Sweepers/Scrubbers

• Tow Tractors

• Airport GSE

• Fleet Average Emission Level Standards:

• Targets to be met by 1 January 2009, 2011,

and 2013

• Exemptions:

• Low-use – less than 200 hour per year

• Small fleets – less than 3 vehicles

• Fines:

• $500 per vehicle per day




Regulatory Overview – Public Agency and Utility (PAU) Regulation

13

• Applicability: Any municipality/utility that owns, leases, or

operates on-road diesel-fueled vehicles with MY 1960 or

newer engine and a GVWR > 14,000 pounds

• Website:

http://www.arb.ca.gov/msprog/publicfleets/publicfleets.htm

• Performance Requirements:

• Engine certified to 0.01 g/bhp-hr (i.e., some MY 2007,

and all MY 2010)

Examples:• Trucks

• Two-engine sweepers

• Buses

• Retrofit with Level 3 VDECS or retire

• Compliance deadlines began 31 December

2007 through 2012

• Disclosure when selling vehicles within CA

• Fines: $1,000 per vehicle




Regulatory Overview – PAU Regulation (continued)

14

• Labeling:

• For each vehicle, as of December 31, 2007, the municipality/utility must label

appropriately on the door jamb or other easily available location


Regulatory Overview – Emission Control Label (ECL)

15

• Applicability: Any owner/operator of heavy duty diesel- or gasoline-

fueled vehicle, MY 1974 or newer, with a GVWR > 6,000 pounds

• Website: http://www.arb.ca.gov/enf/hdvip/bip/bip.htm

• Requirement:

• ECL , must be affixed

• If cited, must replace in 45-days

• RECORDS!

• Responsibility of the o/o obtain a label from

Manufacturer/Dealer for each missing ECL

• Fines: $300 per missing ECL/$500 for operating

a non compliant engine

http://www.arb.ca.gov/enf/hdvip/bip/bip.htm

http://www.arb.ca.gov/enf/hdvip/bip/bip.htm


Regulatory Overview – Periodic Smoke Inspection Program (PSIP)

16

• Applicability: All heavy-duty vehicles ≥ 6,000 lbs in

fleets of 2 or more AND over 4 years old

• Website:

http://www.arb.ca.gov/enf/advs/advs351.pdf

• Requirements:

• Annual testing with a smoke opacity

meter (SAE J1667)

• Opacity standards:

• 55% for pre-1991 engines; and

• 40% for 1991 and newer engines

• RECORDS!

• Tests, repairs, meter calibration (two consecutive

years)

• Fines: $500 per vehicle per year (up to two years)




GSWC Project

17

Morongo

i

nt

S

• Background:

• Established 1929

• 75 Cities

• 10 Counties

• 42 Water Systems

• 300 Facilities

• 10 Local Air Districts/Boards

• 1 million Customers


GSWC Project

18

• Goal:

• Inventory all affected equipment

• Large vehicles to small equipment

• Assess compliance with all local, state and federal

requirements

• Provide recommendation

• Inventory (Seven Districts):

• Central District

• Coastal District

• Foothill District

• Mountain Desert

District

• Northern District

• Orange County

District

• Southwest District


GSWC Project (continued)

19

• Inventory (continued):

• Stationary engines – 40 surveyed,

22 subject to Stationary ATCM

• Portable engines – 241 surveyed,

34 subject to the Portable ATCM

• ORD vehicles – 27 surveyed for a

total of 1,787 bhp (small fleet)



20


• LSI vehicles – 3 surveyed (small

fleet)

• PAU vehicles – 45 surveyed,

seven (7) subject to the PAU



21


• Lots of pictures



22


• Summarized in a Microsoft Access Database



23




24

• Inventory (continued): Select image to

view full size and

additional photos



25

• Compliance Findings:

• Stationary: No issues

• Portable: Two units operating without proper

permit or registration

• Off-road Diesel: Eleven vehicles not properly

assigned/labeled with equipment identification

numbers (EINs)

• Large-spark Ignition: No issues

• Public Agency and Utility Heavy-duty Trucks:

Seven trucks did not meet BACT (i.e., highest

level VDECS)



26

• Project Conclusions and Recommendations:

• MAINTAIN RECORDS

• Compliance plans through the life of the regulations

• Review of compliance plans on a semi-annual basis and update as required to

accommodate for changes in fleet, and potential regulations

• Consider engine repowers versus vehicle replacements when feasible

• Assess electric replacements for qualified vehicles

• Consider replacement with vehicles fueled with LPG, liquefied natural gas, or

CNG, where possible, to lower the diesel fleet average PM emissions

• Identify any low-use vehicles through annual surveys of vehicles and maintain

annual records of hour usage and mileage to document these exemptions

• Identify additional vehicles that could be retired or planned to be retired, such

as duplicate, old, or defective equipment


Contact Information

27

• Brandy Hancocks

Golden State Water Company

Environmental Quality Manager

(916) 853-3639

[email protected]

• Jorge Rodriguez

URS

Federal Environmental Compliance Manager

(714) 433-7648

[email protected]

mailto:[email protected]

mailto:[email protected]


Q&A

28

Case Study: GSWC Fleet Compliance - CA-NV AWWA€¦ · Case Study: GSWC Fleet Compliance –Air...

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