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Transport refrigeration unit (TRU) owners need to be aware that
the engine replacement compliance option expires for model year
(MY) 2008 and newer TRU engines. 

Repowering a TRU ceases to qualify as a compliance option when
the replacement engine is no cleaner than the old engine being
replaced.  Title 13 California Code Regulations (13 CCR), section
2477.5(i) stipulates that a replacement engine shall meet a more
stringent emissions standard than the engine being replaced.  To
evaluate if this limitation applies to their TRUs, TRU owners
need to determine what emission standard tier is met by the
in-use engine being replaced and compare that to the tier
standard that is met by the cleanest replacement engine that will
fit and perform in the TRU.

Examples follow:

1.	Trailer TRUs or TRU generator sets equipped with MY 2008
through 2012 Tier 4i in-use engines rated at 25-50 hp: The only
replacement engine that will fit and perform is another Tier 4i
replacement engine, which does not result in a cleaner
replacement engine. Therefore, the repower compliance option for
MY 2008 to MY 2012 25-50 hp trailer TRU and TRU gen set engines
fails to qualify in 2015.

2.	TRUs equipped with MY 2008 and newer Tier 4 in-use engines
rated at less than 25 hp: The only replacement engine that will
fit and perform is another Tier 4 less than 25 hp replacement
engine, which does not result in a cleaner replacement engine.
Therefore, the repower compliance option for MY 2008 and newer
less than 25 hp TRU engines fails to qualify in 2015.

Please be aware of possible cases where TRUs manufactured in 2008
could still use the replacement engine compliance option if they
are equipped with Tier 2 engines:

Case 1:  During the first quarter of 2008, TRU manufacturers may
have installed MY 2007 engines that were manufactured in the last
few months of 2007, which met Tier 2 emission standards.  This
lag is allowed for normal production, shipping, and inventory
practices.

Case 2:  TRU OEMs may have installed “flexibility engines” into
TRUs manufactured during the remainder of 2008 and possibly 2009
for a limited number of engines.  Flexibility engines that were
installed in TRUs manufactured in 2008 and 2009 have an effective
model year of 2007 and met Tier 2 emission standards. 
Flexibility engines have emissions labels that include the
following text:  “SELLING OR INSTALLING THIS ENGINE FOR ANY
PURPOSE OTHER THAN FOR THE EQUIPMENT FLEXIBILITY PROVISIONS OF 40
CFR 1039.625 MAY BE A VIOLATION OF FEDERAL LAW SUBJECT TO CIVIL
PENALTY.”

In-use engines that met Tier 2 can be replaced by replacement
engines that meet the cleaner Tier 4i emission standards to
qualify as a compliance option under 13 CCR section 2477.5(i). 

It should also be noted that the engine replacement compliance
option is not very attractive for TRUs manufactured in 2008 that
are equipped with MY 2007 engines or flexibility engines that
have an effective model year of 2007 that must comply by the end
of 2015.  Those replacement engines’ effective model year is
2012, so the ULETRU compliance deadline would be December 31,
2019, which only results in about four years of compliance before
the ULETRU in-use performance standard has to be met.  For
example, if a trailer TRU that was manufactured in 2008 is
equipped with an MY 2007 original engine, the compliance date is
December 31, 2015 (based on the unit manufacture year).  If the
owner chooses to repower the TRU with a Tier 4i replacement
engine, the effective model year of the replacement engine is
2012 (the last year that Tier 4i was in effect), and compliance
with ULETRU in-use standard would then be required by December
31, 2019 (seven years after the effective model year).  In this
example, the operational life of the replacement engine would
only be about four years (from late 2015 to the end of 2019).
What compliance options remain?  Retrofitting with a Level 3
Verified Diesel Emissions Strategy (VDECS) may be something to
consider because Level 3 VDECS meet the TRU Regulation’s ULETRU
In-Use Performance Standard.  Another option is to replace the
unit with a new unit.

A Q&A to this effect has been added to TRU Advisory 13-18
(starting on page 7) at:
http://www.arb.ca.gov/diesel/tru/documents/advisory_13_18.pdf .

Where can I get more information?

For general information about the TRU Regulation, the TRU Website
is at:
http://www.arb.ca.gov/diesel/tru/tru.htm

Information about Level 3 VDECS for TRUs is at:
http://www.arb.ca.gov/diesel/tru/tru.htm#mozTocId341892

TRU Advisories are listed at:
http://www.arb.ca.gov/diesel/tru/advisories.htm

The ARBER registration website is at:
http://www.arb.ca.gov/arber/arber.htm

ARBER Registration Help pages are at:
http://www.arb.ca.gov/arber/trureg/trureg.htm

Sign up for the TRU List Serve at:
http://www.arb.ca.gov/listserv/listserv_ind.php?listname=tru

If you have questions about in-use performance standard
compliance or registration in ARBER, please call the TRU Help
Line at 1-888-878-2826 or call 1-916-327-8737.

Background:  TRUs are refrigeration systems powered by integral
diesel internal combustion engines designed to control the
environment of temperature-sensitive products that are
transported in trucks, trailers, shipping containers, and
railcars.  The emissions from these units are a source of
unhealthful air pollutants including particulate matter, toxic
air contaminants, nitrogen oxides, carbon monoxide, and
hydrocarbons, that all pose a potential threat to both public
health and the environment. These units often congregate in large
numbers at California distribution centers, grocery stores, and
other facilities where they run for extended periods of time to
ensure their perishable contents remain cold or frozen. These
distribution and loading facilities are often in close proximity
to schools, hospitals, and residential neighborhoods.  In 2004,
the TRU Airborne Toxic Control Measure (ATCM) was adopted by the
Board to reduce diesel particulate matter emissions from TRUs and
TRU gen set engines.  Amendments were adopted by the Board in
November 2010 and October 2011.



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