10-4 Magazine - For Today's Trucker

Tech Tips and Tid-Bits

EMISSION REGULATIONS REVIEW
By James Moran – Certified Smoke Opacity Tester

In recent years, the California Air Resources Board (ARB) has implemented several programs aimed at reducing the emissions of diesel powered vehicles. The ARB has stepped up enforcement in the last year by adding additional field inspectors and auditors. In the past, the ARB has relied on the associations within the transportation industry to make sure that their members were aware of the various programs and regulations, but they have been discovering that not all of the associations are making a good effort to educate their members. They are also finding that a lot of small fleets and owner operators do not belong to an association.

I have been performing the Smoke Opacity Test since 1999, and I am CCDET certified. In that time, I have come to realize that a lot of small fleets and owner operators are unaware of these programs and regulations until they either get inspected under the Heavy Duty Vehicle Inspection Program (HDVIP) or they are visited by an ARB auditor. The ARB does not accept being unaware as an excuse for non-compliance, and with the stepped up enforcement, they are now issuing more citations instead of warnings for non-compliance. I agreed to write this article to help inform the small fleets and owner operators out there about these programs. Because of the limited space available for this article, I will just briefly describe each of these programs. I will tell you how to get more information on all these programs and regulations at the end of the article.

The ARB implemented its Heavy Duty Vehicle Inspection Program (HDVIP) on 6/1/1998. Under this program, ARB staff inspection teams inspect heavy duty diesel powered trucks and buses for excessive smoke, tampering, the mechanical condition of the engine and all required labels. These inspections take place at border crossings, CHP scale facilities, randomly selected roadside locations and fleet facilities. Assembly Bill 1009 of 2004 modified this program to require all trucks entering California from Canada, Mexico and other states to be in compliance by 1/1/2006.

The Periodic Smoke Inspection Program (PSIP) began on 7/1/1998. This program requires the owners of all diesel powered vehicles (including government and military) with a gross vehicle weight rating (GVWR) of 6,000 pounds or more, in a fleet with two or more diesel powered vehicles, to have their engines tested for smoke opacity according to SAE J1667 specifications, and shown to be in compliance every twelve months. The fleet owner can purchase their own test equipment ($5,000 or more) and then send one or more of their employees to a certification course and self test, or they can have an outside tester do it each year. These PSIP records need to be kept on-site, in the vehicle files, for two years.

Testing requirements for the PSIP are based on the model year (MY) of the engine, not the truck. Engines are exempt from periodic testing for the first four years (for example, in 2006 all 2003-2006 MY engines would be exempt). All engines become due on January 1 of the fifth year (for example, all 2003 MY engines will become due on January 1, 2007). All 1990 or older engines are allowed a maximum of 55% opacity, while 1991 and newer engines are only allowed 40%. If an engine fails the test, it must be repaired and retested within 45 days. I personally suggest that if an engine passes but is within 10% of the maximum allowable percentage (30% on an engine allowed 40%, 45% on an engine allowed 55%) that you try to lower the amount of smoke emission. An engine that passes with 50% out of 55% allowable could fail if tested at a roadside inspection a month or two later.

Some of the causes that will make an engine fail are any one or more of the following maintenance problems: dirty air filter; dirty, worn or defective injectors; fuel pump worn, out of calibration or altered (tampered with); worn or defective turbocharger; defective smoke puff limiter; defective MVT; etc. In addition to causing an engine to smoke excessively, any of the defective items listed above will adversely affect the overall condition, performance and fuel mileage of the engine. With the price of diesel fuel soaring through the roof and with ARB fines starting at $300, not having your engine(s) properly tuned and maintained can be very expensive.

ARB policy requires that the tester (person) performing the test is CCDET certified. This certification is given to testers that attend and pass a one day hands-on course at one of five community colleges in California. The course teaches the students about diesel exhaust emissions and the procedures for performing the test. The ARB has a list of Certified Smoke Testing Facilities (in PDF format) on its website (www.arb.ca.gov/msprog/hdvip/certstf07_06.pdf).

The Emissions Control Label (ECL) is required to be attached to the engine. This label certifies that the engine complies with the Federal EPA and/or California EPA standards for the model year of that engine. Effective 1/1/2006, the ARB has stepped up enforcement of this requirement. If an engine is checked by the ARB and the ECL is missing, the owner can be fined $300. If the ECL for your engine is missing, you will need to take your vehicle to an authorized dealer for that engine and request that they order a new label. They will need to look at the engine before ordering a new label. If a 1990 or earlier engine does not have a legible Emission Control Label attached at the time of testing, it must be tested as if it is a 1991 engine.

Diesel fuel also went through a change in 2006. We have been using Low Sulfur Diesel (500 ppm) since 1993, and last year we began using Ultra Low Sulfur Diesel (15 ppm) for all diesel powered engines on September 1, 2006 in California, and October 15, 2006 for the rest of the country. This new fuel is expected to cause a 1% drop in power, which may also affect fuel mileage. In 1993, when the low sulfur fuel was first introduced, there were many reports of fuel system leaks and other problems, due to the fact that the sulfur is used as a lubricant for the fuel system. The new Ultra Low Sulfur Diesel fuel has lubrication additives included in it to help avoid the 1993 problems.

The Solid Waste Collection Vehicle Program was approved in September of 2003. This program applies to vehicles with a GVWR over 14,000 pounds such as rubbish trucks, roll-offs and other trucks that are used to collect or haul residential and commercial solid waste. The program requires the owners of these vehicles with engine model years 1960 to 2006 to use Best Available Control Technology (BACT) for reducing diesel particulate matter, following a phase-in schedule, between 2004 and 2010. The compliance date is determined by the engine model year. On most trucks, this modification requires replacing the standard muffler with an approved Particulate Trap (around $7,000). The ARB enforcement teams have been setting up inspection sites near the entrances of land fills and transfer stations, so be on the lookout and get your truck in compliance.

The Transportation Refrigeration Units (TRU) program went into effect back on 12/10/2004. This program requires that all 2001 and earlier diesel powered refrigeration or gen set units on trucks, trailers, shipping containers and railcars used in California must meet Low Emission Standards by December 31, 2008. Units made in 2002 have until December 31, 2009 to comply, while 2003 and newer units were manufactured to meet the Low Emission Standards. All transportation refrigeration units have to start meeting Ultra Low Emission Standards beginning in 2010.

The currently approved technology for meeting the low emission standards for 2002 or earlier units is to replace the existing engine with a new engine that meets the current Low Emission Standards ($7,000-$10,000). The manufacturers of these units hope to have less expensive exhaust after-treatment solutions for the 2002 and earlier units certified and available by late 2007, and for the 2003 and later engines before 2010. There are also reporting requirements for the facilities where the refrigerated units are loaded, unloaded or parked with the units running.

The Commercial Vehicle Idling Restriction went into effect on 2/1/2005. This regulation restricts the idling of diesel engines in commercial vehicles, with a GVWR over 10,000 pounds, to five minutes, with some exceptions. You may idle the engine if it is being used to power a heater or air conditioner while you are resting in the sleeper berth, provided the truck is over 100 feet away from a school or residential housing. Many truck stops have adopted policies of limited or no idling. Some truck stops have already installed a special heating and air conditioning system that connects to the window of the truck. There are also idling restrictions for school buses, transit buses and other types of buses.

The Software Upgrade for Diesel Trucks (Reflash) Regulation (also called the Low Nox Upgrade) went into effect on 3/21/2005. This Regulation requires the owners of most 1993-1999 diesel powered trucks, buses and motor homes registered in California, as well as interstate vehicles entering California, to have the software in the Electronic Control Module (ECM) on their engine upgraded. A Sacramento Court ruling at the end of October 2006 caused the ARB to temporarily suspend enforcement of this regulation, pending a final ruling. The upgrade is still required at the time of an engine rebuild.

Highway transportation is not the only industry being affected by new and tougher programs and regulations from the ARB. There are programs either in effect or that will be in effect over the next few years for all diesel-powered engines including off-road vehicles, marine vessels, portable equipment and stationary engines.

To get more information on any of these programs and/or regulations, you may go to my website (www.moranservice.net) or visit the ARB directly (www.arb.ca.gov). For information over the phone about the Heavy Duty Vehicle Inspection Program, the Commercial Vehicle Idling Restrictions or for a list of Certified Smoke Testing Facilities, contact Debra Wiemer at (626) 450-6161. For information over the phone about the Periodic Smoke Inspection Program or the Solid Waste Collection Vehicle Program, contact Michele Burns at (626) 350-6490. And, finally, for details about the Software Upgrade for Diesel Trucks (Reflash) Regulations or to report an excessively-smoking truck, call 1-800-END-SMOG.

I hope this article has been helpful and that you take these programs and regulations seriously. Knowing the regulations and getting your truck in compliance with them as soon as possible is your responsibility. The longer you wait the more chances you have of getting a citation and a costly fine. So don’t wait - just do it!