LINOIS POLLIY’JC” CONTJOe BOuP~

January

31, 197~

if THE MATTE

Or~

RCPOSEL)

AMENDMENTS

TO

HElL.

701

OF

THE

AIR

REGU1~IIOyS,

DIESEL LOCOMOTIVE EMISSION STANDJtRDS

PINION AND ORDER OF THE BOARD

(by Hr. DumelLe).

This Opnion and Order

concerns the Amendme~tsto

~ule

7C~

~E

t~e

~i’

Regulations

adopted by

the 1o~rJ

Jan~ary31, l97~.

IlL matter before us was

the proposed amendment

of portions

or Rule ~O7

Diesel Engine Emission Standards,

~L.lLrt VII,

Ei~ssionStandards

and Limitations

for Mobile Sources,

of

Chapter

2, Air Pollution Regulations

Rule

707 formerly read as

~ollows:

En me Emission Standards

707(a)

The visible emission stanuard

in Rule

706 shall not

apply

to

diesel engines.

707(b)

Diesel

engines manufactured before January

1,

1970,

shall not be operated in such

a manner

as

to emit

smoke

which

is equal

to

or greater than

301 opacity

except for individual

smoke.

Individual puffs

of

smoke shall not exceed 15 seconds

in duration.

707(c) (1)

Diesel

engines

shall

be

operated

only on the specifrc

fuels

as

specified in the engine manufacturers’ speci-

fications for that specific engine, or

on fuels

exceeding engine manufacturer~sspecifications.

707(c) (2)

Persons liable for operating diesel engined fleets

wholly within S~MS.A.

shall furnish to the Technical

Secretary of the Illinois Air Pollution Control Board,

once each year, proof that the fuel purchased and used

in

their operations conforms

to

Rule

707(c) (1),

707(d)

All diesel engines operated on nublic highways

in Illinois coming from out of the State

shalL

conform to Rule 707(b).

---

4-

737(e

1) Diesel

angines

reettc.i by any ra.iroad in tllino.’

snail ‘tpsj

f.&t~~

:

‘.7 S

9,(e

(2) Diesel

an8.z.es t~e~

e

by railroads shall nor

cause a ruisance or

nt

nolljtion when being 4:ored

or on starsd-oy.

chronology of avents

The

ax.’ndments p’oposed concern limitat~rnson emhsions

jt

smoke fror diesel lc~omotiies. A p’oposal was wade originally

K)

the alit

0±5

itail oad Msc4atior (Association) to the Boara on

4arch tO

19fl to amend the Rutes

arv3 Regulations Governing the

.~ontrol o

-ir

Pollutoa

~OLu

i”

egitations),

and

then reppopradct

September 3,

1972

:he Asscciat on

ameadment

reneals Rules 107(5

07(e)(l,, mu 707 e~2) and suost-t.t:es laiguage included on

tne.r

gxnibit

A,

flown be1 w

~/RIP_T

“xhtjst emisci

.~

S(~

diese

•pimered socomotives shalt

~ot

exceact

density

tnt

Er...

t

(30~~

cJacity

excep

ii~c

the

fo lovttg

conditzcn,

s.

‘‘r

‘maxiawn

~i

6C consecut~:esecon.ts durtng

tcct.Jerat o~ar4

dccelex0t a

tI.c~cr

laad.

b.

‘or

a

per

c.d

.0

£

ur

cos.~..ut.re aisanes

when

a

io:omotve

iaded

r;cer

a

ocriid

3f

idle.

c.

For

a

period

of 30 cniecutive ~invteswhen

starting

a

colC

engine

d.

For

periods of tt:ee cbnsecutive and

an

aggregate

cf

not

more

thn

ten minutes in any 60-minute

period

when

a

l~comotiveengine is being tested,

adjusted,

rebuilt,

repaired, or broken in.

e.

A

malfunctton

of

diesel

equipment operating in

interstate commerce which qas been inspected

and

found to be in proper worsin.j order pursuant to

existing federal regulat..orss within the las

30

days.

At the first hearing, February 28, 1973 ii

RccJ’ Isiand, the

Association amended their proposal to

rmke

it more lenient,

Amended Exhibit A, shown below.

---

Bxhaust emissions

froir ~.iesel~poweredlocomotives

shall not

exceed

a

densit~

of

forty

percent

(4O~o) opa~ity

except

under

the

foJlowr~g

conuitions’

a.

For

a

maximum

of

60

consecuLive

seconds

during

acceleration

under

load

±ro~i

a

throttle

positior

other than

idle

to

a

higher

throttle

positior.

b.

For

a period of

4 consecutive minutes when

a

locomotive is loaded afier

a neriod of idle

C,

Fo~r a period of

30 consecutive minutes when starting

a

cold engine.

d

For periods of three consecutive and an aggregate

of not more than ten minutes

in any 60 minute

period when

a locomotive engine

is being

tested,

adjusted, rebuilt, repaired or broken in

e.

For any diesel-powered locomotive which because

of its age

or

design makes replacement

parts

unavailable,

The Illinois Environmental Protection Agency

(Agency)

then

submitted its own proposed amendments, Proposed Amendment to

Part VII

of the Air Regulations, shown below, at the next hearing,

March

16,

1973 in Chicago

PROPOSED

AMENDMENTS TO PART VII

EMISSION STANDARDS AND LIMITATIONS

FOR MOBILE SOURCES

Rule 702: Definitions

Diesel Fueled Locomotive

-

A diesel fueled vehicle designed to

move cars on

a railway.

Emission- The release

into the atmosphere

of contaminants,

-

A condition which renders material partially or wholly

impervious

to transmittance of light,

and causes obstruction

of an observer~sview.

For the purposes

of these regulations,

11

—213

---

he ±ollo~ingequir~ler~e~‘~weer~opacity and

.

iugelt

r~

~all

be

employed~

40

2~0

3,0

4~0

100

Small gas-borne narticles re.~ultingfrom incomplete

combustion,

consisting predominantly cut ret

exclusively

of

carbon,

ash

and

other

conoustible

mater~al,

that

for~

a

‘isible plume

on

LflO

air

707(b)

~

the et:on

of Pule ~

diesel engines manufactu~ed

before January

1

1970,

s

all

rocie operated in such

a manner as

to

emit smoke which

is

eo’ a

to or 0reater than 30

opacity except

for ind~ividualsmoke puffs

Individu~L.puffs

of

smoke

shall not

exceed

15 seconds

in doration.

707(e)

disual

Emission

Icanuards and Limitations for Diesel

~oce~trves~

(I)

No person shalL

~ause or allow the emission of s~noke

rem any dieslL

fueled locomotive in the

State

of 1111 io~

having

an o~ac~tvgreater

t1-an

30

for more than

i.renty

(20

consecutive

~conds

(2)

“ule

7c7(~

1

shall

not

aup~y to:

A

Smoke which

is

caused solely by

the

presence

of water coudensote.

B.

Emissions while

the engine

is being operated for

testing incident

to repai:, break-in, and adjustment

PROVIDED

THAT:

(i)

The

lLesel

locomotive

is not being tested

within an enclosure such as

a repair

shops

(ii)

Any person who causes

or

allows the operation

of

a diesel fueled locomotive during

a test

period which would otherwise cause a violation

of

~u1e

707(e)

shall notify the Agency of the

intended test.

Thereafter,

any such person

shall comply with all reasonabia directives of

the Agency with respect

to the intended test,

In addition,

any person subject to this Rule

shall maintain such records and make such reports

as may be required in procedures adopted by the

Agency pursuant

to

Rule 107

of

Part

I of this

Chapter and;

---

(iii)

The

granting

of

perirJ ssiox

to

~perate

during

test

period

~hall

b~. praira

facie

defense

lL

an

elLorc~rent

iet

on allL;ing

a

vie

t~o~r

of

Rule

707(e).

Rule

709’

Determination

e..

Tiolation

~ny

aiolations

of

a~z orovision

lL

Park

J

shall

be

determined.

(1)

by

visuai

obcervaLion,

or

(2

hy

the

use

of

a

ca1 ibrated

smos~ e”o~’.ct~on devioe

approved

by

the

kgency

as

q~alafied

by

fule

106

of

Part

I

of

this

Chapter’

or

(3)

by

a test procedure employing an opacit~i.easuremcnt

system

as

qualified by Rule 106

of lLrt

r this Chapter

~hc ~emainirg hearings, March

21,

1973,

in Granite

~rty

April

6,

973

an Chicago,

and April

16,

1973 in Chicago,

~eve therefore

held on the

esis

of considering both the Ass ciation Ai~ended

~xhibit A

srn’ the Ngency Proposed Amendments

to Part VTI.

The fo lowing summary puts the vorrous uroposals

perspective

Basoc Regulation

~cetions

raginal

smoke shall

be less

individual

uffs

Pegulation

than 30

opacity

not

to exceed

15

seconds

duration

Association

smoke scull not

exceed

a)

o0

second

period

Exhibit A

30

opacity

during acceleration

and

deceleration

h)

4 minute period

following

idle

c)

30

~ninute

period

for cold start

d)

3

minute

period

for

testing and maintenance

e)

malfunction when

engine had been

inspected within past 30

days and found to

conform with federal

regulations

11

—215

---

Association

smoke

shall not exceed

a)

60 second period duri~

Amended Exhibit A

40

opacity

acceleration

b)

same as Exhibit A

c)

same

as

Exhibit

A

d)

same as

Exhibit

A

e)

locomotives

for which

replacement parts

are

not

available

Agency

smoke

shall

not

exceed

I)

puffs

not

to

exceed

Proposal

30

opacity

20

seconds

duration

2)

~‘smoke”

composed

solely

of water vapor

3)

locomotive

testing

provided

certain

conditions

are followed

The issue therefore concerned both the steady state or basic

level

of visible emissions

to be permitted plus

the

type and

number of exceptions

to the rule,

Both the Association and

the

Agency agreed that some modification to the existing regulation was

required,

the Association claiming that the technology was not

available

(R.

3/21 p.

128)

and the Agency saying

that they could

not support

it

(R.

3/21

p.

131).

In both cases the proposals were

more

lenient than the existing

regulation with the Association~s

proposal being the most lenient.

The Agency also proposed

a new Rule

709, Determination of

Violation,

that would allow determination of emission level

in

terms

of either opacity or Ringelmann number with or without

the use

of measuring devices

or

aids.

After reviewing the record the Board on December 6,

1973

ordered the publishing

of the following

as

a Proposed Final Draft,

Written comments on the Draft were invited until January 15, 1974.

Rule

702 Definitions

A~TT~Tlo~Tng definitions:

Diesel

Locomotive

-

A diesel engined vehicle designed

to

~arsonarailwa,

Opacity

-

A

condition

which renders material partially or

wholly

impervious

to

transmittance

of

light,

and causes

obstruction

of

an

observer~s

view,

11

—216

---

Rule 707(b)

-

Revise

as follows:

With the exce tion of Rule 707 &

,

diesel engines rianufactured

be ore January 1,

1970,

shall not be operated in such

a manner

as

to emit smoke which is equal

to or greater than 30

opacity

except for individual smoke puffs.

Individual puffs

of smoke

shall not exceed 15 seconds in duration,

Rule 707(e) (1)

and

707(e)(2)

-

Delete these rules

and add new

rules

as follows:

707

(e) (I)

No person shall cause or allow the emission of

A,

Smoke

resultin

from

startin

acold

locomotive;

for

a

eriod

o

time not

to excee

30 minutes,

~

under load from a

t

rottle settin

ot e~than

i

le

to

a

i

er

t rottle

settin

;

for

a

eriod of time not

to exceed 40 secon

s

Smo

e emitte_~~pp~Jp~comotive

ba

in~g ollowing

i

le; for

~

t ~

D.

Smo

e emitted

urin

locomotive

testin

,

maintenance,

a

‘ustrnent

rebuil in

re airin

or breakin

in;

or

a

2~1o~otim~~bottolLxce~_3consecutive minutes and an

a

re ate of 10 minutes in an

60 mi~~Ti~dT~

B,

Smo

e emitted

b

a locomotive which because of its

a

e

or

esi n

ma es

re

lacement or retrolit

arts necessar

to

ac ieve smoke reduction unavailable.

These locomotives

shall

be ret~ed at the ~ssible

time

Comments were received from two citizens during the comment

period.

Neither the Association nor

the Agency submitted additional

material.

Diesel

Locomotive Desi~

Before

discussing

the

issues

a review of diesel locomotive

design is necessary.

The locomotive units are more properly

called diesel electric units

since they are comprised of

a diesel

engine

connected

to

an electrical generator which in turn provides

power

for the electric drive or traction motors.

It is the diesel

engine portion of the locomotive which emits

the smoke and causes

the visual pollution.

These engines

are large size, multicylinder

diesels, having horsepower ratings in the range of 1000 to

3600.

They operate without

a spark plug; depending on the compression

of the air in the cylinder to reach the ignition temperature.

The

fuel and air are provided to each cylinder by

a fuel injection

nozzle operating along with

a turbocharger or Roots blower which

forces air into the cylinder.

Both

2

cycle and

4 cycle diesel

11

—217

---

-8

engine

are used

tie

d-ffererc

be ag

he

cr

2

cycl... erg ne

e en rev lb

icr

t

the e~g

le

~rc

-es

p0

er stroke, wier a

w:,...

cv

-

‘LJ-.~esevery

o~~et

r

i.tin_

:z .jde~s

owe

st os

Th.

~ar con.pressora attacie

t

I- cr~,inesare dirt. t

connec~.edt

t a engine cra

I’-

at

jr the cas

of th

P

ut

bowe-s

drivv

by tie

exrau’

gact.~

x

t e ce e

~‘

the

turbor arg

Operationsfli, the loconc

t

t

is

—

oc~wi

estuer

a contiruotsly v riaole sped contv 1

one

tat La0

a f~ni

r1un’b~rol

n-i

te settir’-

~rotl.tes

pi ally tie settn

inclu

•

rotcl’e

1

tiroigt

natch

ben’

Ic iraxrn.r nowe-

~t

is,

ujix.,

f’1’

ad

cyntac

bracirg

~‘°

ic

i

set

n~.

est~ii

I

ie no

Lt

of fuel that is supj.Jied by Ui~fw

tr.iect r

‘he c

-

.rders (R 4~6

p.

8

and

thue tIe spee

an1 pow~routp’ t fr m the cuesel eng..ne

Locomc.t ye

car

be c assified as eit cr hue raul eng..ne

or switci engnes, wit

sn’ca ergines being sxailex

and

of’e

older

units

tR

4/6 p.

38

Approximateli

15’ of the loccrot

in Illinois are switch engines

(It.

2 23 p.

20

In t

ni’s of total

nturDer~

of locomoti es

the1c. are

r ug I

2087 units operating in Illinois cn a given day

CR.

2/28

~

)

3

of which would be the older model switci

engines

(ibid).

Ir

statistical tens it is estimated that about 15,400

locomotives

could enter the state during the course of a year

CR.

3/2: p

19) and

thus be governed by the Board regulations.

At present there

are only two manufacturers of locomotives in the United States,

the Electromotive Divison (EMD)

of General Motors, and the General

Electric

Corporation

(GE)

fR.

2

28

p.

15)

and

the relative

numbers

of locomotives manufactured are

78

EMD, 7.5

GE, and 14.5

others

CR. 3/21 p

16)

Operating Characteristics

The visible emissions from locomotives are caused by the

operating characteristics of diesel engines and by poor maintenance.

Much testimon- was given as to the smoke producing operational

characteristics and the need for exemptions based on the following

characteristics:

a)

Acceleration

-

The problem concerns turbocharger

lag.

The turDocharger is not directly connected to the diesel

engine but is uowered by the thermal energy in the exhaust gas.

The amount of air charged into the cylinder and available for

combustion deuends on the work performed by the turbocharger

which in turn depends on tne energy in the exhaust as mentiorec

11—218

---

1

r

cc~leretingthe lccmoti

e, tn~ooeratoi

a

etch

settLiL

whict

imae~ia~

c~ine

the

or ou~t

~

red

teroegh

t1e

tu~1

r

ec~or

T

ancu~~lL

1

cJ

bo~ever,

depends

on

th

out~ct

~

turboccarger

an

i.

a

required

becor~ the

turbociarge

s~eed

~ ic~easc~

t~ wa~c

tne

increase

i

engine

.

p

ed

ilL

o

this

tame

tIe

at

supu

.i

U

ca

the

turbochareer

is

c

i~

~r~r

in

term:

of

tire

amount

of

a

lL

surpl

LC

fn~a~t re

t

a

ho

e

eel

rica

so

that

an_omplete

comb’

st_on

oc

ii

i

s

-a

~e

is

emitte~

Ire

the bocomotiae,

In addrton

there

arc

o

rio

s

during acclLe~’~ir

when

electrical

circuits

are

snite

rcd

La

inc

a

monentar

unloading

of

the

engine

and

pilLfs

of

siioh

)

Id~e

-

~

idlirg

loc~~iotivc uue~

T1~t

Lid

rtain

t

erg

n~ cemperatures

ieccs~~rv

fui

~ic

~smolelLss

combustion

Unburnee combustIbles inc~udp.

carbon

(soot)

tenc

to ac~1imu1atein the erCan~anc

en aust

nanifo~ds

Then when the engine

lL accele

2te

these con-

tat’nants are emitted as smoke until the

:yLuders

clean out

aid ope .ating temperatures are attained,

The duration of

SfOKiflL

following adle depends primarily on

the duration of idirng

d

t

e ambien

temperature.

c)

Cold

start

-

Cold

start

~eers

to

starting

a

d1ese

bocomotire

follow~ng

a

period

of

uor~-~unnin5s~ch that

the

terroer

turo of

the engine

is essentially that

o.

the ambient

As

mentioned previously,

the diesel depends

on compression of the

air

in

the cylinder by the piston to raise the temperature past

the

ignition

point.

When

the

engine

is

coJ~, much of

the heat

generated by

this

compression

goes

into

the

cylinder

walls

and

head,

resulting in

a loi~ertemperature during ignition and

a

lower combustion efficiency.

In addition,

the cold wall

causes

the

flame

to be quenched when

it reaches the cylinder

wall so that some of the

fuel

does

not ignite.

Therefore during

the exhaust cycle,

this unburned

fuel Is emitted

as

a

whitish

smoke,

(R.

3/21 p.

166).

The quantity

of

smoke decreases

as

the engine warms up

to its operating temperature,

and the

time

required for warm up depends primarily on the initial temperature

of

the engine.

The above operating characteristics

are cited by the Associ-

ation

as requiring the first three exceptions listed

in

Amended

Exhibit

A.

The other two exceptions

in

the Exhibit pertain

to

periods

of maintenance and the lack of available parts.

~ableoacit

The first issue

to be decided is the opacity to be permittea

for the visual emissions under steady state operation

The

Association proposed an opacity not

to exceed 40

(Amended ExhibiL

A) while

the Agency proposed an opacity not to exceed

30

(EPA

Ex i);the-existin~regulation stated that the opacity shall be

less than 30

(Air Regulations, Rule 707(b),

70~(e)(l)). An

11—219

---

-10-

explanation of opacity is included later in this opinion.

It

is

enough

for

now

to

know that opacity is a measure of

the

number density of particulates

and

droplets in the smoke.

Opacity is given in tens of

the percentage of incident light

that is blocked by the smoke so that 30

opacity means

30

blockage or 10

transmission.

The Association witnesses presented somewhat conflicting

testimony as to the necessity for a 40

opacity limit.

Testimony

was

received

from

several

witnesses that the railroads could

not

comply

with

the

existingregulations,

but’ could,

in

almost

all

cases

meet

the

Association proposal

CR.

2/28 p. 18;

75;

R.

3/16 p.

43-44; 128-131).

However, cross examination

revealed

that

the

main

problem with

the

regulation

had to do with the transient periods of operation where excess

smoke is emitted for the reasons described previously.

Dr.

Burkhard of GE thought that a 30

opacity limit would be appropriate

for

GE

engines

in

Illinois

CR.

3/16 p.

88) and had previously

suggested

this

figure,

withi exceptions, during hearings in Connecticut

CR.

3/16

p.

51).

Dr.

Burkhard, however, felt that the Agency

proposal,

30

opacity

with

exceptions

of

20 seconds duration,

could

not be met by GE engines during acceleration, based on tests

conducted at the Marion facility

CR.

3/16 p.

60).

Mr. Smith

stated that “under steady state conditions

a large percent

of

locomotives

could

meet

the

EPA

proposal,”

and

further,

“I am referring to some of the older locomotives which would

not be able to meet them.”

CR. 4/6, p.

33).

Mr. Smith also

discussed the combination of a 30

steady state opacity limit with

exceptions:

Q.

Then

taking the railroads proposed amendment,

would

it be agreeable to you if everything was changed except

the

40

was

changed

to

30

and

the

same

exceptions

listed,

then

do

you

think every railroad could meet a standard such

as

this?

A.

Looking at the locomotive fleet that is on most

railroads, and I am general1~familiar with what other people

have, we could not meet the standard, particularly

with the

older locomotives.

Q.

The older are the ones with these five exceptiofls,

if that exception was included, exempting the older locomotives,

could the regulation be met, 30

A.

No, not at all times, no sir.

Q.

What

times wouldn’t it be able to?

A.

At higher attitudes and a change of loading...

CR. 4/6,

p.

11 —220

---

Mr, Adik spoke of the operation of suburban locomotives,

that is, those used for hauling commuter trains.

These-

locomotives also pull an auxiliary power unit to supply

electricity and air conditioning to

the passenger coaches,

It

is his opinion that the main locomotive used in suburban

operations would be able

to meet

a

30

opacity limit on

a steady state basis but that the auxiliary unit could

not

(R,

4/6 p~ 92-95),

The Agency position

on

the

30

opacity limit

is based

on emission tests conducted by the Southwestern Research

Institute

(SWRI)

on

three locomotives

(EPA

Ex,

2)

,

The

tests of visual emissions,

summarized by the Agency in EPA

Exhibit

11,

showed

that

over duty cycles consisting

of

idle,

eight

notch settings, and dynamic breaking, no steady state

emission

level

exceeded

30

opacity

and no transient period

of

excess

smoke

exceeded

a

duration

of

20 seconds.

Summary

results

of

the

SWRI

tests

are

given

in the following two tables,

TABLE

1

SUMMARY

OF

LOCOMOTIVE

STEADY-STATE SMOKE DATA

(Ref.

Table

8

of

EPAEx.

~2)

Average

Opacity

Average

Opacity

Average

Opacity

END

Line

Haul

GE

Line

Haul

Condition

END

Switch

Engine

Transverse

Longitudinal

~

Idle

1.5

1.7

2.2

3.7

6.7

Dynamic Brake

———

2.0

3.8

4.0

8.2

N?

28

2.1

2.3

4.9

8.9

N2

3.2

4.5

5.2

14.8

28.0

N3

2.7

11.2

22.8’

15.1

29.2

N4

2.0

11.1

22.0

12.1

25.8

N5

2.0

12.1

21.4

9.8

19.5

N6

1.9

9.1

18.4

6.4

13.0

N7

2.2

5.5

11.2

4.6

9.0

N8

2.8

6.4

10.0

4.8

9.2

Notes:

N

refers

to

notch

setting.

For rectangular stacks transverse and longitudinal refe~

to the short and long dimensions- respectively.

Idle values

are averages of

24 data points,

the remainii

values are averages

of

8 data points.

11

—221

---

2

Table

~.

L000)CTIVE

JISSIOdS

DURI1VG ACCELEBAflCW TRANSsTS

(ref.

Table

13

of

‘A

Zz

2

-

‘ut

Ratio

-c

Peak

ajue

to

Viral

Value

Peak Duration

Seconds

(1)

—

(2)

.?m

Stitch

Engine

5

2s1) ~aneHaul Fngine

4

GE

Line Haul

Engine

tO

16

(1

~eak

alue en

nti~J.Jy1(0

~paci y

(2.

Duration

in

ecce’s

of

.

-eady—:tae

o2acity.

n

terms

of

aprli.abitity

of

tne teit data for the three

locomotives

tic,

ge..’z witness sta ~.dthat the tests

ch

nty hard

La

avaiabb.

c~nceni&gvisual

eniJsiors

and

t~’t

1;

FMD

in

‘‘s4~d

£

the

oiC.

tv~

:erics

o

engines

r

)cucel

at

rascnt

by

:zc

(it.

4/16

p

9,

94~

r

t

nit:

~

a

~

t.

iisnta

~“c

‘he

PM)

e-,tth

,1’

~

as

over

oICe’

‘

~

~tcmLr

, tu~

EMt

~

h..u

a4i.:

zt.s

~

:

“i,a.l a’

-r~e” ‘.a

~

4ad

jrai~tenance per

uinc..

Jart,a~

~972

an

t”,

.‘~

.

e

U~

haó

•nain-’iance

pet

neo

t the

egi’ining

‘r

~

cst

£

~ Arr”idix

B).

I’i

idc.Itior

to

tir

WPI

t

cts.

~ne

Agency

presente’

inform

lion

frxi

EMP

-o’tc’ni

p

locrrccive

enis

‘i.

reduction

~rograI

Ext

Tx

1’

is

‘rogr.t

invovee

develo i.g

low

ea s~w

r.cudtg

~

ss~b1e

emission

engine components

~-

.~tr~.fit1r4g them ta

;I’e EMD

uni

r

The sve’ific improv

.tefl’

cing r.tx’fitte~.

and

used in

r

new urts include

.‘liztt:

TC

.~

ha’

ig larger intake

r~

-s

for more efficient

tit

~i.ate,

~cc:ignedpistons (fire

ring)

that alYow .,ettex

.x)tstlL;,

aImd

improved (low sa

fuel iiiector ron es tht

e’’ease the amount of unburned

or partially burced luel (EPA Pt.

9).

The visible

emitcions

resulting from Ella) testing at teear McCook, tllino~sheaaouarters

reveals the tollowing existirg ‘nd anticipated smoke emassicn

data

at

full

power

for

both

tl’e

icots

blown

and

turbocha

ged

locomotives.

1.

Roots blown engines

Visual Emission

Equiva.ent ~.1

Year

Improvement

(Ringelmann

Noj

Qpacity ()

1971

1.5

19

1972

large port cylinder

1.2

liners

mid

1972

low sac injectors

0.8

10

1973

fire ring ptstc:is

0.3

4

Si

•~

---

-

13-

2.

Turbocharged engines

Visual Emission

Equivalent

(1)

Year

~rovement

(Ringelmann

No.)

Opacity

()

1971

1.0

12

1972

large

port

cylinder

0.8

10

liners

1972

low sac injectors

0•.5

6

1975

f-ire ring pistons

0.3

4

Note:

(1) Equivalent opacity derived from Ringelmann Number

using the following relation reported by EMD in petitioner’s

exhibit

16.

Ringelmann

Equivalent Opacity

0

0

12

2

26

3

37

These improvements developed by EMD for their current production

models can be retrofitted to earlier model engines built by

EMJ~(R.

2/28 P.

91).

The conclusion we find from the previous evidence

is that

most of the engines on a steady state basis can meet an opacity

limit of 30 percent, the exception being some older units manufactured

by neither GE nor EMD used mainly for switching operations where

in

any case there

is very little steady state operation

(R.

3/16

p.34).

We therefore require locomotives

to meet the 30

opacity

limit proposed by-the Agency.

to

the

~Q~cit~Limit

Exceptions

a)through

c)in

the

Association

proposal

pertain

to operating characteristics

of diesel electric locomotives.

The Association witnesses stated that these exceptions

were necessary.

However, documentation was sparse

as

to specific

needs.

11

—223

---

-14-

a)

Cold starts- The exception requested for cold starts

specifies

a duration of 30 minutes, however, no data was

presented documenting the need for

30 minutes.

Dr. Burkhard

knew of no correlation between the ambient temperature and the

length of time for cold start, but was

of the opinion that

30 minutes would be

a fair estimate of the warm up period

required at

zero degrees ambient temperature

(R.

3/16 p.

95-96).

Mr.

Williams

discussed

the

problem

of

starting

a

cold

engine

and

said

that

“in

all

likelihood

if

youtre

out

in

a

zero

ambient,

it

would

not

start

at

all.”

He

further

was

of

the

opinion

that

a

cold

start

exemption

of

30

minutes

would

be

necessary

at

ambient

temperatures

below

30

degrees

(R.

2/28

p.

92-94).

In

discussing

suburban

type

operations,

Mr.

Adik

said

that

on

a

cold

day,

as

much

as

20

minutes

would

be

required

to bring the

locomotive up to its

operating

condition

(R.

4/6

p.

86).

The question is not strictly how much time is required

to

reach

operating

conditions

but,

rather, how 1~ngdoes

it take following

a cold start before excess smoking

clears up.

On this point the railroad witnesses were vague.

The

smoke

emissions

decrease from start

as the engine warms

up but after the

30 minute period the emission level is

in question

(R.

4/6 p.

127).

The opacity could be greater

than normal during

the

entire

30

minute

period

(R.

4/6 p.

41).

The

Agency

did

not

attempt

to

rebut

the

cold

start

issue

except through the cross examination of Association witnesses.

One important consideration concerning cold starts

is

the frequency of occurrence.

A diesel engine

is frequently

left idling when not

in use.

The reason for this was explained

by

Mr.

Kotnour

(R.

3/16 p.

159-160). “Well,

I think that there

is more damage in shutting them down... .the contraction and

expansion

is

so

great

that

we

have

leaking

heads

or

leaking

seals.

And

secondly,

I

have

yet

to

see

a

diesel

get

cold,

a

locomotive

get

cold

that

you

can

start.”

Very

often

a

locomotive

will

run

continuously

for

a

month

(R.

ibid);

in

addition,

leaving

the

engine

running

keeps

the

batteries

charged

and

the

air

brakes

set

(R.

2/28

p.

39-40).

Testimony

from

the

Burlington

Northern

was

that

they

hardly

ever

shut

down

an

engine

except

for

maintenance

(R.

3/16

p.

132).

The

conclusion

on

cold

starts

therefore

is

that

the

situa-

tion

infrequently

occurs,

especially

during

cold

months,

but

th~~

some

allowance

should

be

made

for

excess

smoke

when

cold

starts

do

occur.

As

far

as

the

specific

duration

of

time

to

be

allowed,

the

Association

testimony

seems

to

support

a

duration

of

31)

minutes,

a duration not successfully rebutted by the

Agen~..;;.

ich

we

therefore

adopt.

11 —224

---

-15-

b)

Acceleration

-

Another Association exception would

allow 60 seconds of excess smoking when accelerating a locomotive

except from idle. Mr.

Smith testified that there are

normally eight notches so that if the engine accelerates

through the notches, with two or three seconds to stabilize

the engine in each notch, then 16 to 24 seconds are required to

reach speed on a notch by notch basis.

He then stated

that observations showed that 52 to 58 seconds were required

before the smoke cleared

(it.

2/28 p.

38,39).

The difference

between the 16 to 24 second figure

and

the

52

to

58

second

range

is however not clear from the recqrd.

Dr. Burkhard in

testimony to other states suggested an exemption period

of

40 seconds during acceleration-for GE locomotives, rather

than the 60 seconds proposed by the Association

(it.

3/16 p.

39).

He was uncertain about the period the turbocharger lags

behind the engine but stated that GE is working on a retrofit

device to change the turbocharger lag; and in addition the

fuel governor so that the engine does not get excess fuel

(it.

3/16 P. 69-71).

When

accelerating a regularly loaded train out of a

yard,

the operator normally

runs

the engine at the maximum throttle,

notch 8, until speed is reached and then backs off on the

throttle

(it. 3/16 p.

147).

The emissions could be reduced

by accelerating at a slower rate but the sjeed reduction

required to reduce the emissions to 30

opacity is not

known

(it.

3/16 p.154).

Itwas also felt to be impractical to reduce

emissions during acceleration of a commuter train by gradually

increasing the throttle from notch to notch rather than

accelerating at

maximum

power

(it.

4/6 p.

87-89).

The type of engine makes a diffetence during acceleration.

All EMD turbocharged engines have mechanical linkages such

that at

low

engine speed the turbocharger is directly connected

to the engine.

As the engine speeds up the turbocharger

declutches and then runs off the engine exhaust

(it. 4/16 p.

147).

This tends to decrease the turbocharger lag during acceleration.

In addition, Roots blown engines emit lower opacity smoke

(during

acceleration) than turbocharged engines because the lag between

engine and compressor is reduced

(it.

4/16 p. 142).

The SWRI test data for secjuential operation showed that

no periods of excess smoke during transients between notches

exceeded 16 seconds

and

that emissions within a notch did

not exceed 30

opacity.

The duty cycle is shown in Table 3

~

this opinion.

11-225

---

-16-

Table

3

LOCOMOTIVE

EMISSSIONS

TEST

SEQUENCE

(ref.

Table

1 of EPA ex.

2)

Notch

or

Notch

or

Notch

or

Mode

Condition

Mode

Condition

Mode

Condition

Idle

9

N7

17

N5

2

Ni

10

N8

18

Dynamic

Brake

3

N2

ii

Idle

19

Idle

4

N3

12

Dynamic Brake

20

N4

5

N4

13

Idle

21

N3

6

Idle

14

N8

22

N2

7

N5

15

N7

23

Ni

8

N6

16

N6

24

Idle

The

record

indicates

that

an

excess

smoking

period

of

between

16

and

60

seconds

duration

can

occur

during

acceleration.

We

find

that

a

reasonable

compromise

is

40

seconds

based

on

Dr.

Burkhard’s testimony and the SWRI testing.

c)

Loading following locomotive idling

-

This

proposed

exception

is

necessary

according

to

the

railroads

to

allow

the

clearing

from

the

cylinders

of

the

material

collected

due

to

inefficient

and

incomplete

combustion

caused

by

the

cooling

of

the

engine

during

idle

(R.

3/16

p.

40).

The

4

minute

duration

specified

in

the

exception

is

based

on.

conducted

tests

according

to

Dr.

Burkhard

(R.

ibid)

but

no

data

was

produced.

Mr.

Smith testified that during switching operations,

normally

short

periods

of

idle

occur

and

so

1oading~after

idle

would

cause

heavy

smoke

for

around

5

to

10

seconds

(R.

3/16

p.

215).

Testimony

concerning

suburban

operations,

where

locomotives

normally

pull

under

load

following

periods

of

idle,

was

that

on

very

cold

days

it

could

take

several

minutes

for

the

engines

to

reach

reasonable

operating

temperatures

(R.

4/6

p.

81-83),

while

on

warm

summer

days

little temperature decrease

would

occur

during

idle.

The

Agency

did

not

directly

attempt

to

rebut

this

proposed

exception.

The

inference

is

that

the

SWRI

tests

included

idle

periods

in

the

duty

cycle,

Table

3

of

this

opinion,

and

as

no

transient

periods

of

excess

smoke

emission

exceeded

16

seconds,

the

Agency

proposal

of

20

second

excursions

was

reasonable.

The

one basic problem with the SWRI tests,

however,

is that they

were

conducted

in

San

Antonio,

Texas

in

April

1972,

a

combi.r~ation

of

place

and

time

not

representative

of

Illinois

in

the

wirt~.r.

In

fact,

according

to

Apendices

A,

B,

and

C

of

EPA

exhib~t

-

11 —226

---

-17-

the

ambient

temperatures

were

in

the

range

of

70

to

100°F.

so that during idle

the engines probably did not cool off

much.

Our conclusions

about the tests

is

that the data

is

applicable

to steady state and acceleration conditions but

not for cold start or loading following idle.

We

therefore conclude, lacking more specific information,

that exception

(c) proposed by the Association for loading

following idle should have

a duration of two minutes.

d)

Maintenance

-

Both the Association and Agency

proposed that an exception be granted to locomotive emissions

during repair, break in,

and adjustment.

The Association

specifies time durations while

the Agency would require

notification and adherence with Agency directions prior

to testing.

The locomotives undergo periodic maintenance

at minimum intervals of

a month

(petitioners

ex.

4) but no

evidence was given as

to specific periods of excess

smoking

that occur during testing for maintenance.

The exception

presented is that contained in the statement of

Dr. Burkhard

to the State of Connecticut

(EPA

F

7) but was not supported

with data by the Association.

The Agency proposal seems

unworkable

to us because we cannot

see them having the

manpower

to oversee and make suggestions before every locomotive

undergoes maintenance testing.

We therefore adopt

the Association’s proposed exception for

maintenance periods.

e)

Lack of replacement parts

-

The issue here concerns

the older locomotives used mainly in switch yards.

Much

testimony concerned the retrofitting

of improved parts

to

achieve reductions

in emissions.

Thelocomotives today

generally operate with lower emissions than those several

years

ago, lower emission levels being

a by-product of improve-

ments made

in the efficiency of operation.

In other words,

improvements made to get lower fuel consumption by increased

combustion efficiency have resulted in reductions in emissions

(R.

4/6 p.

98)..

Owners of locomotives not manufactured by EMD

or GE cannot get retrofitted parts

since

the manufacturers

are

no longer in business.

In some

cases there are no replacement

parts either so that if the engine breaks down it cannot be

repaired.

Our order exempts those locomotives which are unable

to retrofit

to reduce their emissions.

These locomotives

are

to be removed from service

as soon as feasible.

We do not

intend that this exception protect smoky engines used instead

of retrofitting other units

or purchasing new units

as necessary.

11

—227

---

-18-

Enforcement

Much time was spent on

a discussion of the enforcement

of the regulation.

The

Association

proposal

is

based

on

per-

cent opacity while

the Agency proposal bases

the standard on

opacity

but

would

allow

equivalent

Ringelmann

readings

to

be

substituted.

The

Ringelmann

chart

that

has

traditionally

been

equated to equivalent opacity

is the following:

Ringelmann

Number

Equivalent Opacity

0

0

1

20

2

40

3

60

4

80

5

100-

However,

according

to

E~’flJ the

SWR~,

through

tests,

has

established

the

following

equivalence

between

opacity

and

Ringelmann

Number

(petitioners

cx.

l6)~

Ringçlmann

Number

~&iiiva1ent

Opacity

0

0

1

12

2

26

3

37

This relationship according to

Mr.

Williams of EMD has

been found to relate extremely well

in the

low end of the

smoke

scale

(R.

4/16

p,

196),

The

Ringelmann

chart

was

developed

for

varying

shades

of

gray

smoke.

According

to

Dr.

Chuan

‘~asmoke

which

is

completely

black

would

have

one

set

of

correspondence

between

Ringelmann

Scale

and

opacity

while

a

white

smoke

would

have

a

different

set

of

correspondence.”

(R.

4/16

p.

27).

Thus

a

locomotive engine which produces white

smoke

when

the

engine

is

cold

due

to

unburned

fuel

droplets

---

-19-

and black

smoke

due

to pyrolytic cracking of the fuel in

fuel rich areas

(R. 4/16 p.

75), could not be regulated

based on a single equivalence bitweón

Itingelmann

and

opacity.

In fact, the Agency would object to the use

of

Ringelmann

alone since it would not allow enforcement

of white smoke which emits from cold engines

CR.

4/16 p. 95).

Opacity of a plume refers to the blocking of light

transmission th~oughthe plume.

In genpral the opacity

is related to the number density

and

size distribution

of particulates and liquid droplets in the pluine~

It is

also related to the path length of the transmitted light,

which is why the

SWRI

test results for rectangular stacks

varied with the direction of measurement.

The

attractive

features of opacity are

the

tie-in with emission density

and the fact that opacity applies to emissions of all colors

(R.

4/16 p.

118).

Unfortunately opacity also results from the pre-

sence of water vapor which should be distinguished from that

due to other materials

CR.

4/6 p. 184-185).

The

Agency

would .probably use

the

Ringelmann chart

for black smoke or caSes where there is a question concerning

water vapor sjnce the

Ringelmann

system neglects the

presence of water vapor

(It.

4/16 P. 97),

and. would use opacity

for white smoke.

It seems to us that the regulation should

be based solely on opacity readings since they relate to

quantity (actually density) of emissions.

We recognize also that,

except for cold engines, the presence of water vapor contributes

little to opacity readings so that its effect is minimal.

A related issue concerning enforcement is the measuring

device to be employed.

The Association in their proposal

did not specify a mpasuring device but during the hearings

a railroad witness mentioned optical transmission meters as

the best known means of measuring opacity

(R.

4/16 p.

25).

These

instruments would have an accuracy of one percent

and

thus

would minimize problems of enforceability

(R.

4/16 p.

31).

The problem with

such

an

instrument

is

that

for

moving

locomotives it would have to be mounted on the locomotive

exhaust stack or else measurements could only be made on

stationary locomotives

(R.

4/16 p.

34).

The only other possibility

according to Dr.

Chuan

would be a lasar radar device which

would allow

remote

measurements

(R. 4/16 p.

36).

The

Agency

testimony was that certified smoke readers,

that is, those that have attended

and

passed a course in smoke

reading, are competent to judge the opacity of smoke.

These

observers are trained both on white smoke and black smoke to

determine

the opacity directly (R.

4/16 p.

179) without the use

of aids such as a Ringelmann chart.

The Ringelmann system

11-229

---

-20-

white

plumes

were

being

observed

CR.

4/16

p.

180).

To

pass

the

school

the average error for

50 readings,

25 white plumes and 25

black plumes cannot exceed

7.5 percent with no single reading

in error by more than

20 percent

(R.

4/16 p.

177).

Our finding is

that opacity measurements should be

made preferably with an opacity meter but that visual

observations by trained and certified smoke readers would

be acceptable.

Specific Amendments

With the foregoing discussion in mind,

the specific rule

changes adopted by the Board can be summarized as follows:

Rule

702 Definitions

Definitions of diesel locomotive and opacity are necessary

to set the regulations

involving locomotives apart from other

visual

emission

regulations.

Rule 707(b)

The language added separates regulations involving locomotives

from regulations involving diesel engines.

Rule

707(e)

(1)

This new ru~esets

the visual emission limit

at

30

opacity

for locomotives.

Rule 707(e) (2)

This

new Rule establishes exceptions~

to

Rule

707(e)

(1)

found

necessary

by

the

Board.

Rule

709 Determination of Violation

mr~T~T~:ET~ries

measui~~iit

either

by

trained

observc~-

or

opacity

measuring

device.

The

rule

is not intended

to include

the

traditional

Ringelmann

charts

due

to

the

uncertainty

in

the

record

of

the relation between Ringelmann number

and

percent

opacity

for

various

colors

of

smoke,

11

—230

---

-21-

ORDER OF THE BOARD

The Pollution Control Board,

after examining the Association’s

and Agency’s proposed

amendments,

the transcripts

of

the five

hearings,

and comments submitted on the Proposed Final Draft,

finds

that an amendment to Emissions Standards and Limitations for Mobile

Sources,

Chapter

2,

Part VII, Air Pollution Regulations

is warranted.

Therefore,

the

Board

orders

the

following

amendments

to

Chapter

2,

Part

VII.

(Underlining

indicates

the

amendments.)

Rule

702

Definitions

Add

the

following

definitions:

Diesel

Locomotive

-

A

diesel

engined

vehicle designed to move

cars

on

a

railway.

Opacity

A

condition

which

renders material partially or

wholly impervious

to the transmittance of light,

and causes

the

obstruction

of

an

observer’s

view.

Rule

707(b)

-

Revise

as

follows:

With

the

exception

of

Rule

707(e),

diesel engines manufactured

before January

1,

1970,

shall

not

be

operated

in

such

a

manner

as

to

emit

smoke

which

is

equal

to

or

greater

than

30

opacity

Pxcept

for

individual

smoke

puffs.

Individual

puffs

of

smoke

~iali

not

exceed

15

seconds

in

duration.

Rule

707(e)

(1)

and

707(e)

(2)

-

Delete

these rules and

add

new rules

as follows:

707(e~flJ~_personshall

cause or

allow the emission of

~i~6~:efrom any diesel locomotive

in the Staté~5TTllinois to

exceed thirty percen~(~~opacity.

707(e) (2) Rule

707(e) (1)

shall not apply

to:

_e;~i~ra

B.

Smoke_emitted

while

accelerating

under load from

a

~

t h rot t 1 e

sett I~

C.

Smoke

emitted

upon

locomotive

loading

following idle;

for

a~ioc~

time

not

to

exceed

2

minutes.

U,

Smoke

emitted

during

locomotive

testing,

maintenance,

adjustment,

rebuilding,

repairing

or

breaking

in;

for

a

period of time not

to exceed

3

consecutive

minutes

and

an

aggregate of

lD minutes

in any 60 minute ~ri~

B.

Smoke emitted by

a

locomotive

which

because

of

its

age

or

~sign

makes

replacement

or

retrofit

parts necessary to

acThieve

smoke

reduction

unavailable,

These

1oE6~n~TTvessall

b~~etired

at

the

earliest

possible

time,

11

--231

---

-22-

I, Christan

L. Moffett, Clerk of the Illinois Pollution Control

Board, hereby certify the above Opinion and Order were adopted on

the _________day of January, 1974 by

a vote of

~

Illinois Pollution

C

trol Board