todd.
r.
hendrickson@
Cummins.
com
02/
07/
2005
10:
40:
06
AM
To:
Alan
Stout/
AA/
USEPA/
US@
EPA
cc:
Subject:
Re:
Follow­
up
on
request
of
EPA:
Clarify
E3
Cycle
is
Appropriate
for
Prop
Curve
Aux
Engines
Alan
­

Thank
you
for
the
quick
reply!
Upon
initial
review,
I
believe
EPA's
proposed
language
provides
the
clarity
needed.
I'll
let
you
know
if
there
are
additional
concerns.

Thanks
again,
Todd
­­­­­
Forwarded
by
Alan
Stout/
AA/
USEPA/
US
on
02/
07/
2005
11:
08
AM
­­­­­

Alan
Stout
EPA­
OAR,
OTAQ,
ASD
02/
07/
2005
09:
59:
05
AM
To:
todd.
r.
hendrickson@
Cummins.
com
cc:
Subject:
Re:
Follow­
up
on
request
of
EPA:
Clarify
E3
Cycle
is
Appropriate
for
Prop
Curve
Aux
Engines
Todd,
We
have
reviewed
this
issue
internally
and
have
written
up
the
attached
modification
to
94.105(
b)
to
clarify
that
propeller­
law
auxiliary
marine
engines
should
operate
over
the
E3
cycle
for
EPA
certification.
This
language
clarifies
our
understanding
of
the
best
way
to
interpret
the
current
regulatory
language.

I
expect
that
this
change
will
be
part
of
the
final
rule
for
the
technical
amendments
later
this
year.

Let
me
know
if
you
have
any
questions
or
concerns
with
this
approach.

Alan
_____________

(
b)
General
cycle.
Propulsion
engines
that
are
used
with
(
or
intended
to
be
used
with)
fixed­
pitch
propellers,
propeller­
law
auxiliary
engines,
and
any
other
engines
for
which
the
other
duty
cycles
of
this
section
do
not
apply,
shall
be
tested
using
the
duty
cycle
described
in
the
following
Table
B
 
1:

todd.
r.
hendrickson@
Cummins.
com
02/
07/
2005
09:
36:
10
AM
To:
Alan
Stout/
AA/
USEPA/
US@
EPA
cc:
Jean­
Marie
Revelt/
AA/
USEPA/
US@
EPA
Subject:
Follow­
up
on
request
of
EPA:
Clarify
E3
Cycle
is
Appropriate
for
Prop
Curve
Aux
Engines
Alan,

Please
recall
our
discussion
the
afternoon
of
January
27th
regarding
Cummins
(
and
EMA's)
request
regarding
marine
auxiliary
engines
which
operate
on
a
prop
curve.
Per
EMA
comments
to
the
Technical
Amendment
Package,
we
request
that
Part
94
be
clarified.
Or,
at
a
minimum,
that
EPA
accept
our
interpretation
that
certification
to
the
E3
cycle
is
acceptable
for
such
engines.
IMO
regulations
are
clear
on
this
point,
but
EPA
regulations
are
not.

Per
your
request,
I
have
included
additional
information
to
support
our
position.
I
have
included
an
attachment
with
Cummins
summary
of
the
issue
and
copied
text
below
which
was
prepared
by
Cummins
Marine
providing
application
examples
and
descriptions
of
operation.

Note
that
Cummins
is
now
finalizing
engine
hardware
selections
for
2007
Tier
2
certification
platforms
(
turbochargers,
injectors,
etc.).
It
is
important
that
we
close
this
issue
quickly
in
order
to
select
the
appropriate
hardware
and
avoid
a
costly
redesign.

In
summary,
this
request
is
appropriate
given
that:
These
auxiliary
engines
operate
on
a
prop
curve
in­
use.
The
E3
cycle
better
represents
the
in­
use
operation
than
the
C1
cycle.
The
engines
are
not
designed
to
operate
in
the
C1
area.
[
Note
that
Cummins
does
not
allow
C1
operation
for
these
engine
designs.]
C1
8­
mode
and
C1
NTE
design
and
certification
is
not
appropriate.
This
would
compromise
engine
designs
and
unnecessarily
waste
engineering
resources.
Part
94
clarification
provides
harmony
with
IMO.

I
would
appreciate
any
feedback
on
this
request
given
our
current
situation
with
Tier
2
product
development.
Please
call
me
with
any
questions
at
812­
377­
4235.

Thanks
and
regards,
Todd
Todd
R.
Hendrickson
Cummins
Inc.

============================================================
Examples
of
applications
and
operation
provided
by
Cummins
Marine:
Cummins
Marine
engines
can
be
used
in
variable
speed
auxiliary
applications.
These
are
typically
used
to
drive
liquid
pumps
of
some
sort,
either
water,
petroleum,
hydraulic
fluid,
or
other
liquid.
Some
examples
of
these
engine
applications
are
as
follows:

BJ
Services
builds
cement
pumper
machinery
in
Texas,
for
use
on
offshore
drilling
rigs.
They
use
a
QSK19
engine
to
drive
a
cement
pump
which
isused
to
inject
liquid
cement
into
an
oil
well
as
it
is
being
drilled,
to
form
a
protective
core
for
the
drill.
BJ
Services
has
provided
data
which
shows
that
the
engine
operates
at
or
slightly
below
our
standard
3.0
prop
curve
at
all
conditions,
with
an
overall
duty
cycle
of
less
than
40%.
Cummins
Southern
Plains
in
Texas
sells
a
number
of
KTA19
engines
as
liquid
cargo
pumps
on
barges.
These
may
pump
petroleum
or
other
liquids
out
of
the
barge
storage
tanks.
Cummins
China
has
some
KTA50
engines
in
sand
dredges.
These
engines
drive
water
pumps,
which
in
turn
drive
ejector
pumps
which
suck
a
sand/
water
mixture
from
the
bottom
of
a
channel.
Frank
Mohn
A.
S.
in
Norway
uses
KTA19
engines
to
drive
liquid
cargo
pumps
on
barges.
The
engine
may
drive
the
cargo
pump
directly,
or
may
drive
a
hydraulic
pump
which
in
turn
drives
the
cargo
pump.

These
are
typical
of
variable
speed
auxiliary
applications.
Cummins
Marine
Application
Engineering
reviews
all
potential
installations
to
ensure
that
the
engine
cannot
be
loaded
above
the
typical
3.0
propeller
curve,
since
the
engine
ratings
are
developed
with
this
loading
in
mind.
C1­
type
engine
loadings
are
not
allowed
for
Marine
engines.

As
an
example
of
engine
speeds
and
loads
seen
during
a
pumping
job
with
one
of
these
engines,
the
BJ
Services
application
can
be
seen
as
typical.
In
filling
the
drilling
core
with
cement,
the
engine
will
be
run
at
a
low
speed
(
800­
1000
rpm)
at
the
start
of
the
fill,
while
the
equipment
is
being
adjusted
and
fine­
tuned
for
the
pour.
Then,
the
operator
will
increase
the
flow
to
a
maximum
(
1800
rpm)
to
fill
the
core
most
of
the
way.
Finally,
near
the
top,
flow
has
to
be
reduced
so
as
not
to
overfill,
so
the
engine
will
be
operated
at
1000­
1400
rpm
until
the
pour
is
completed.

The
characteristic
of
a
liquid
pump
is
that
the
load
used
to
drive
it
is
proportional
to
the
engine
speed
cubed.
In
other
words,
a
plot
of
horsepower
vs.
rpm
would
have
a
y=
x^
3
shape,
which
is
the
same
shape
as
a
propeller
curve.
==================================================================
Summary
of
Cummins
position:
(
See
attached
file:
EPA
request
­
E3
vs.
