Engine Certification Organization www.enginecert.com

Large Spark Ignited Engine Certification

Mike DeGain

Operations Manager

Sedale Turbovsky

Legal Research Analyst

sturbovsky@enginecert.com

916.435.2378x4

August 18, 2014

Summary:

ECO has developed a system to address the complex issue of engine certification and provide engine

manufactures with a clear path to emissions compliance.

This analysis deals with the process of Engine Certification for Large Spark Ignited Engines.

Engine Certification can be a dizzying and time consuming process. ECO is here to help you with any and

all of your engine certification needs. Please contact us should you have any questions about this document.

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Engine Certification Requirements The engine and equipment manufacturing industry face heavy regulation from two

main government bodies. The US Environmental Protection Agency (EPA) and the

California Air Resource Board (ARB) both regulate emissions from mobile and

stationary sources. Regulatory devices include extensive testing and application

procedures in order to legally market and sell engines, equipment and technology

in the United States.

In order to comply with the requirements engine manufacturers must follow strict

testing procedures to demonstrate or certify that their engine or vehicle meets the

engine emissions standards while operating in a specific service class (test cycle and

weight restriction). An engine cannot be placed in a vehicle and operated outside

its service class designation. Emission standards are set for a variety of service

classes including new passenger cars (PC), light-duty trucks (LDT), medium-duty

vehicles (MDV), heavy-duty engines (HDE) and vehicles (HDV) including urban buses

(UB), on- and off-road motorcycles (ONMC and OFMC), all-terrain vehicles (ATV),

and electric golf carts (eGC).

Large Spark Ignited Engines EPA Certification Categories:

EPA certification of Large Spark Ignited engines excludes engines with less than

19kW maximum power output, Marine engines, On-highway engines, Locomotive

engines, and all Compression Ignition engines.

The EPA has defined two clear and very distinct sets of requirements for Large

Spark Ignited engines including stationary and nonroad mobile categories. It is

critical that each ECO client that produces certified industrial engines is aware that

the distinction between these categories is not always as simple as it might seem.

Bulldozers are literally mobile equipment. Mobile equipment can also be engines,

pumps, generator sets, and PTO’s which are intended to be transported from one

location to another and include such features as wheels, skids, carrying handles,

dolly, trailer, or platform.

Stationary engines are often permanently installed to a site both indoors and

outdoors. The stationary category applies to engines, pumps, generator sets, and

PTO’s as well. The stationary category also applies to equipment intended to be

transported from one location to another if it is not actually removed within 12

months.

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Additionally, some mobile engine applications are federally preempted from

statewide regulation; where stationary engines are subject to varying additional

state and local jurisdiction.

ECO has significant experience helping our clients to combine the testing

requirements for multiple applications in order to maintain a single engine family

approved for both mobile and stationary use. This eliminates any potential use

restrictions and the need to control the sales of your products.

EPA field inspectors reviewing stationary engines need to ensure that the correct

standard is satisfied, or if the engine is not laboratory certified for stationary use

that the owner or operator has performed a site certification.

EPA LSI Emissions Standards:

EPA emissions standards for Large Spark Ignited (LSI) engines are regulated by 40

CFR Part 1048. The LSI certification category applies to both mobile and some

stationary engines.

In this category the minimum useful lifetime is 5000 hours of operation and engines

must satisfy the standards at their full regulated lifetime.

EPA Tier 2 LSI exhaust emissions standards apply to certified LSI engines beginning

in the 2007 model year. The Tier 2 HC+NOX standard is 2.7 g/kW-hr and the

Tier 2 CO standard is 4.4 g/kW-hr.

The EPA Tier 2 standards for LSI engines also include an optional sliding scale

allowing certified engines to satisfy the equation (HC+NOX) × CO0.784 ≤ 8.57.

The following table includes possible Tier 2 emissions standards that satisfy this

requirement:

Table 1 of §1048.101—Examples of Possible Tier 2 Duty-cycle Emission Standards

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CARB LSI Emissions Standards:

Not all mobile certified engines are subject to CARB standards. Mobile engines

used for construction equipment as well as agricultural equipment may be federally

preempted from state regulation and as a result CARB is unable to impose

additional more stringent standards. A complete list of preempted equipment

application can be reviewed at:

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

Mobile generator sets are not preempted and CARB certification is mandatory to

sell any mobile generator sets or individual engines to the state of California.

CARB emissions standards for Large Spark Ignited (LSI) engines impose more

stringent emissions standards effective for the 2013 model year. Present CARB

certified LSI engines are subject to the same EPA Tier 2 standards above.

2013+ CARB certified engines require compliance with the HC+NOX standard 0.8

g/kW-hr and the CO standard of 20.6 g/kW-hr.

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EPA Stationary Emissions Standards:

EPA emissions standards for Stationary engines are regulated by 40 CFR Part 60.

Any stationary engine that operates on NG must satisfy the following emissions

standards:

Table 1 to Subpart JJJJ of Part 60—NOX, CO, and VOC Emission Standards for

Stationary Non-Emergency SI Engines ≥100 HP (Except Gasoline and Rich Burn LPG),

Stationary SI Landfill/Digester Gas Engines, and Stationary Emergency Engines >25

HP

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Optional Paths for Stationary Engine Certification:

Site Certification:

Stationary only Natural Gas fueled engines can be sold uncertified. Uncertified

engines may be installed by owners and operators and fall subject to site

certification procedures. This requires each and every individual engine to perform

emissions testing and site certification application and approval. Site certification is

generally the approach used for engines that operate on landfill and digester

gasses where the operation fuel properties have a large variation from site to site,

and laboratory testing cannot represent the operation fuel.

Laboratory Certification:

Site certification of pipeline NG stationary engines is not likely to be attractive to

potential buyers. A better option is to perform laboratory based certification.

Certified engines that operate on pipeline NG may be sold and installed and

operated without a need for your customers to perform additional testing or pay

additional fees. In case of laboratory certification, manufacturers must carefully

evaluate their installation requirements and develop literature needed to instruct

owners and operators how to install engines represented by the laboratory testing

that are covered by the EPA certificates.

CARB Stationary Emissions Standards:

CARB does not regulate stationary engines. EPA certified stationary engines can be

sold in all 50 states including California. However, California has developed many

individual air districts that have local ordinances that apply to stationary engines.

Great care must be taken to ensure potential local air district requirements are

satisfied. Site certification may be needed depending on the location of operation.

ECO has performed some research on different California Air Quality Management

Districts and this activity is presently lead directly by our President Josh Pietak.

Additional Certification Considerations:

Deterioration Factors:

The EPA will allow small volume manufacturers to use assigned DFs. Small volume

manufacturers must satisfy one of the following definitions:

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(1) An engine manufacturer with U.S.-directed production volumes of engines subject

to the requirements of this part totaling no more than 2,000 units in any year. This

includes engines produced by parent or subsidiary companies.

(2) An engine manufacturer with fewer than 200 employees. This includes any

employees working for parent or subsidiary companies.

CARB no longer allows the use of assigned DF’s by any LSI engine manufacturer.

CARB certification will typically involve running a half-life service accumulation

program to determine deterioration factors.

Useful Life:

In this category the minimum useful lifetime is 5000 hours of operation and engines

must satisfy the standards at their full regulated lifetime.

For engines designed to operate for longer periods before overhaul is required, a

longer useful lifetime period is required.

Field Testing Performance:

In addition to regulated emissions standards from the weighted composite test cycle,

engines are also subject to field testing standards. Any potential operation point

must directly satisfy the following requirements:

Table 3 of §1048.101—Examples of Possible Tier 2 Field-testing Emission

Standards

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Noncommercial Fuels:

Typically, Mobile and Stationary NG engines are tested and certified to operate

on Pipeline NG only. Pipeline NG is delivered by municipal supply and has very

tightly controlled composition and properties. Pipeline NG typically has a heating

value of about 1050 BTU/SCFM.

Pipeline NG certified engines are not approved to operate on noncommercial fuels

including but not limited to oil field wellhead gas, landfill gas, digester gas,

synthetic gas, and other similar fuels with varying properties.

Special laboratory certification is also possible for engines designed to operate on

Wellhead NG from oil wells. In case Wellhead NG operation is required, ECO has

experience to develop laboratory testing procedures to test a range of fuel

properties and to eliminate a need to perform site certification for installations that

comply with the range of fuel properties evaluated.

Resulting noncommercial fuel certification is limited to a specific range of fuel

properties selected by the manufacturer and demonstrated during emission testing.

Additionally such engines are permitted to include user adjustments to properly set

up engines for the specific fuel properties at ach installation site.

Evaporative Emissions:

Engines that run on a volatile liquid fuel (such as gasoline), must meet the following

evaporative emissions standards and requirements:

1. Evaporative hydrocarbon emissions may not exceed 0.2 grams per gallon of fuel

tank capacity when measured with the test procedures for evaporative emissions.

2. For nonmetallic fuel lines, MORs must specify and use products that meet the

Category 1 specifications in SAE J2260.

3. Liquid fuel in the fuel tank may not reach boiling during continuous engine

operation in the final installation at an ambient temperature of 30 °C. Note that

gasoline with a Reid vapor pressure of 62 kPa (9 psi) begins to boil at about 53°C.

The regulations allow MORs to use design-based certification instead of generating

new emission data.

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Delegated Assembly:

Manufacturers that do not supply the full contents of their certified engine bill of

material are required to utilize delegated assembly provisions. Delegated

assembly allows for a 3rd party to source components to the certifying

manufacturer’s specifications, but also require the certifying manufacturer to control

and audit such operations.

Diagnostics:

Mobile certified engines are required to detect significant malfunctions in the

emission-control system using the following protocols:

1. If the emission-control strategy depends on maintaining air-fuel ratios at

stoichiometry, an acceptable diagnostic design would identify malfunction whenever

the air-fuel ratio does not cross stoichiometry for one minute of intended closed-

loop operation. MORs may use other diagnostic strategies if EPA approves them in

advance.

2. Use a malfunction-indicator light (MIL). The MIL must be readily visible to the

operator; it may be any color except red. When the MIL goes on, it must display

“Check Engine,” “Service Engine Soon” when required.

Adjustable Parameters:

Adjustable parameter means any device, system, or element of design that

someone can adjust (including those which are difficult to access) and that, if

adjusted, may affect emissions or engine performance during emission testing or

normal in-use operation. This includes, but is not limited to, parameters related to

injection timing and fueling rate. You may ask us to exclude a parameter that is

difficult to access if it cannot be adjusted to affect emissions without significantly

degrading engine performance, or if you otherwise show us that it will not be

adjusted in a way that affects emissions during in-use operation.

Engines must satisfy all emission criteria with any adjustable parameters set to any

possible position, or manufacturers must employ tamper resistance methods

sufficient to protect such adjustments from tampering.

Crankcase Emissions:

Crankcase emissions may not be discharged directly into the ambient atmosphere

from any engine throughout its useful life.

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Torque Broadcasting:

Electronically controlled engines must broadcast their speed and output shaft torque

(in newton-meters). Engines may alternatively broadcast a surrogate value for

determining torque. Engines must broadcast engine parameters such that they can

be read with a remote device, or broadcast them directly to their controller area

networks. This information is necessary for testing engines in the field. Small-volume

engine manufacturers may omit this requirement.

AECD’s:

Auxiliary emission-control device means any element of design that senses

temperature, motive speed, engine rpm, transmission gear, or any other parameter

for the purpose of activating, modulating, delaying, or deactivating the operation

of any part of the emission-control system.

AECD Device Descriptions must be included with certification applications and shall

be reviewed as potential defeat devices.

Maintenance Instructions:

Manufacturers are required to give the ultimate purchaser of each new engine

written instructions for properly maintaining and using the engine, including the

emission-control system. The maintenance instructions also apply to service

accumulation on emission-data engines.

Critical emission-related maintenance. Critical emission-related maintenance includes

any adjustment, cleaning, repair, or replacement of critical emission-related

components. You may schedule critical emission-related maintenance on these

components if you meet the following conditions:

Demonstrate that the maintenance is reasonably likely to be done at the

recommended intervals on in-use engines. We will accept scheduled maintenance as

reasonably likely to occur if you satisfy any of the following conditions:

1. You present data showing that, if a lack of maintenance increases emissions, it

also unacceptably degrades the engine's performance.

2. You present survey data showing that at least 80 percent of engines in the field

get the maintenance you specify at the recommended intervals.

3. You provide the maintenance free of charge and clearly say so in maintenance

instructions for the customer.

4. You otherwise show us that the maintenance is reasonably likely to be done at

the recommended intervals.

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You may not schedule critical emission-related maintenance more frequently than

the following minimum intervals:

1. For catalysts, fuel injectors, electronic control units, superchargers, and

turbochargers: The useful life of the engine family (5,000 hours).

2. For gaseous fuel-system components (cleaning without disassembly only) and

oxygen sensors: 2,500 hours.

Recommended additional maintenance. You may recommend any additional amount

of maintenance, as long as you state clearly that these maintenance steps are not

necessary to keep the emission-related warranty valid. If operators do the critical

maintenance specified above, but not the recommended additional maintenance,

this does not allow you to disqualify those engines from in-use testing or deny a

warranty claim. Do not take these maintenance steps during service accumulation on

your emission-data engines.

Special maintenance. You may specify more frequent maintenance to address

problems related to special situations, such as substandard fuel or atypical engine

operation. For example, you may specify more frequent cleaning of fuel system

components for engines you have reason to believe will be using fuel that causes

substantially more engine performance problems than commercial fuels of the same

type that are generally available across the United States. You must clearly state

that this additional maintenance is associated with the special situation you are

addressing.

Maintenance that is not emission-related. For maintenance unrelated to emission

controls, you may schedule any amount of inspection or maintenance. You may also

take these inspection or maintenance steps during service accumulation on your

emission-data engines, as long as they are reasonable and technologically

necessary. This might include adding engine oil, changing air, fuel, or oil filters,

servicing engine-cooling systems, and adjusting idle speed, governor, engine bolt

torque, valve lash, or injector lash. You may perform this non emission-related

maintenance on emission-data engines at the least frequent intervals that you

recommend to the ultimate purchaser.

Production Line Testing:

Manufacturers must select engines from the production line quarterly for PLT testing.

PLT testing is required by manufacturers for every engine family with an

anticipated production volume of 150 units per year. Manufacturers that produce

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more than 150 engines can choose to test 1% of production or to satisfy a cumsum

statistic

Measured emissions levels of PLT test engines are deteriorated and compared to

the standard (1%) or subjected to statistical significance calculations (cumsum) to

determine if the quarterly testing is completed or if additional engines must be

tested.

In-Use Testing:

Any certified LSI engine family must comply with the emissions standards on the

prescribed certification test cycle. Additionally, certified LSI engines must also

comply with the emissions standards when operated in-use. The EPA has developed

an audit function to ensure that engines continue to meet the certified emissions

standards in-use. Any certified engine family is subject to in-use testing. At any

time, a manufacturer may receive a request from the EPA to perform in-use testing

on any certified engine family.

If an in-use test order is received, a manufacturer will have one year to prepare a

list of engines in the requested engine family and determine the actual operating

hours and usage and prepare a test plan to test a minimum of 2 engines within 2

years of the date the test plan is approved by the EPA.