david.
e.
brann@
gm.
com
Transmission
Date:
03/
29/
2005
06:
19:
02
PM
To:
David.
Ducharme@
Trans.
ge.
com
cc:"
Kelly,
Brian
E
(
GE
Trans)"
<
Brian.
Kelly@
Trans.
ge.
com>,
cweaver@
railpower.
com,
"
Rumpf,
John
(
GE
Trans,
Legal)"
<
john.
rumpf@
ae.
ge.
com>,
kkokrda@
enginemanufacturers.
org,
"
Baran,
Len
(
GE
Trans)"
<
Len.
Baran@
Trans.
ge.
com>,
mrush@
aar.
org,
"
Lawson,
Pete
J
(
GE
Trans)"
<
pete.
lawson@
Trans.
ge.
com>,
rftimmons@
aslrra.
org,
sfritz@
swri.
org,
Alan
Stout/
AA/
USEPA/
US@
EPA
Subject:
RE:
GE
comments
to
proposed
changes
to
40
CFR
Part
92
with
attachment
Dave,

Continuing
the
dialog:

With
regard
to
the
language
requiring
a
description
of
any
limits
imposed
by
the
certificate
holder
for
remanufactured
locomotives
(
Section
92.203(
d)(
1)(
ii)(
D)),
as
I
interpret
that
was
added
by
EPA
in
response
to
comments
made
by
EMA
with
regard
to
the
certificate
holder's
liability
for
locomotives
remanufactured
under
the
5­
year
cumulative
provision
of
the
rule
In
discussion
at
our
8
February
EMA­
EPA
meeting,
Chuck
Moulis
said
that
certificate
holders
were
free
to
place
whatever
restrictions
that
they
felt
necessary
of
the
application
of
their
kits.
That
being
the
case,
and
so
long
as
GETS
is
doing
something
of
that
sort
already,
I'd
be
just
as
happy
to
leave
that
language
out.

The
two­
label
requirement
doesn't
really
answer
the
railroad
practice
of
moving
engines
from
locomotive
to
locomotive.
The
labels
are
supposed
to
match;
engine
families
should
be
the
same.
So,
for
instance,
moving
an
engine
from
a
wrecked
locomotive
of
a
2004
family
to
a
unit
of
a
2003
family
with
a
catastrophically
failed
engine
results
in
a
mismatch,
even
if
the
2004
family
is
a
carryover
from
the
2003
family.
Having
two
labels
thus
actually
hampers
the
transplanting
of
locomotive
engines.
This
problem
could
be
avoided
by
having
only
one
label,
whether
on
the
engine
or
the
locomotive.

Regards,

Dave
"
Ducharme,
David
J
\(
GE
Trans\)"
<
David.
Ducharme@
Tr
ans.
ge.
com>
To:
<
david.
e.
brann@
gm.
com>
cc:
"
Kelly,
Brian
E
\(
GE
Trans\)"
<
Brian.
Kelly@
Trans.
ge.
com>,
<
cweaver@
railpower.
com>,
"
Rumpf,
John
\(
GE
Trans,
Legal\)"
<
john.
rumpf@
ae.
ge.
com>,
<
kkokrda@
enginemanufacturers.
org>,
"
Baran,
Len
\(
GE
Trans\)"
<
Len.
Baran@
Trans.
ge.
com>,
<
mrush@
aar.
org>,
"
Lawson,
Pete
J
\(
GE
Trans\)"
<
pete.
lawson@
Trans.
ge.
com>,
<
rftimmons@
aslrra.
org>,
<
sfritz@
swri.
org>,
<
Stout.
Alan@
epamail.
epa.
gov>
Subject:
RE:
GE
comments
to
proposed
changes
to
40
CFR
Part
92
with
attachment
03/
28/
2005
06:
37
AM
Dave,
thanks
for
the
clarification.
I
agree
with
the
position
you
articulated
below
but
am
concerned
on
the
limits
wording
that
the
EPA
chosen
as
it
may
have
the
opposite
effect
from
your
intent
and
force
the
OEMs
to
establish
inspection
limits
in
cases
where
it
may
not
be
practical
or
even
possible
in
a
manner
that
would
ensure
compliance
throughout
the
useful
life.
GE
already
controls
acceptable
overhual
criteria
by
identifying
what
components
must
be
replaced
or
overhauled
at
the
time
of
a
remanufacture.
If
overhaulers
decide
to
reuse
some
components
without
overhaul
or
refurbishment
as
called
for
in
our
emissions
overhaul
instructions
I
believe
that
the
risk
is
assumed
by
the
overhaulers.
I
would
be
happy
to
confer
with
EMA/
EMD
and
the
EPA
to
arrive
at
mutually
acceptable
wording
if
you
still
believe
that
the
current
rule
wording
is
too
interpretive.
I
fully
agree
that
the
need
for
separate
labels
is
questionable
at
best.
My
guess
is
that
the
EPA
is
concerned
about
the
railroads
practice
of
switching
engines
from
loco
to
loco
especially
when
canabalizing
parts
from
wrecks
and
wants
to
make
sure
that
each
engine
retains
it's
emissions
pedigree.
Given
that
all
post
1972
engines
must
be
upgraded
anyways
and
the
physical
differences
that
have
been
implemented
between
Tier
0,
1,
and
2
engines
it
is
highly
unlikely
that
an
engine
will
loose
it's
pedigree
however
when
the
origninal
rule
was
written
EPA
had
no
way
of
knowing
how
the
different
tier
engines
might
be
implemented.
Again
if
EMA/
EMD
would
like
to
discuss
alternate
wording
or
elimination
of
a
separate
engine
label
further
with
the
EPA
GE
would
be
happy
to
participate.

Best
Regards
Dave
Ducharme
­­­­­
Original
Message­­­­­
From:
david.
e.
brann@
gm.
com
[
mailto:
david.
e.
brann@
gm.
com]
Sent:
Thursday,
March
24,
2005
5:
15
PM
To:
Ducharme,
David
J
(
GE
Trans)
Cc:
Kelly,
Brian
E
(
GE
Trans);
cweaver@
railpower.
com;
Rumpf,
John
(
GE
Trans,
Legal);
kkokrda@
enginemanufacturers.
org;
Baran,
Len
(
GE
Trans);
mrush@
aar.
org;
Lawson,
Pete
J
(
GE
Trans);
rftimmons@
aslrra.
org;
sfritz@
swri.
org;
Stout.
Alan@
epamail.
epa.
gov
Subject:
Re:
GE
comments
to
proposed
changes
to
40
CFR
Part
92
with
attachment
Dave,

A
couple
of
comments
on
your
comments.
Some
of
the
things
that
you
have
commented
on
are
the
result
of
comments
made
by
EMA
(
mostly
at
EMD's
instigation)
to
EPA
on
the
proposed
technical
amendments
package.
I
feel
that
I
should
tell
you
how
some
of
them
came
about.

15.
92.203
­
Application
for
Certification.
I
believe
that
the
added
language
in
subparagraph
(
d)(
ii)(
D)
is
EPA's
response
to
our
noting
that
the
provision
requiring
changing
all
of
the
power
assemblies
over
five
years
to
trigger
the
requirement
for
a
remanufacture
system
to
be
applied
exposed
system
manufacturers
to
a
higher
liability
for
emissions
performance
than
application
of
a
system
at
a
single­
event
overhaul
did.
In
fact,
the
holder
of
a
remanufacture
system
certificate
could
be
responsible
for
the
emissions
of
a
locomotive
with
some
power
assemblies
one
useful
life
plus
five
years
old.
At
the
meeting
we
had
with
EPA
on
February
8,
Chuck
Moulis
said
that
manufacturers
could
place
whatever
restrictions
they
wanted
on
the
application
of
their
kits
to
locomotives.
I
look
at
the
wording
that
EPA
has
inserted
as
a
clarification
of
that,
and
a
requirement
to
list
what
restrictions
are
imposed,
if
any.

20.
92.212
­
Labeling.
The
changes
that
EPA
has
proposed
are
in
response
to
our
comments
that
the
wording
of
the
present
engine
and
locomotive
labels
is
so
similar
as
to
cause
confusion
in
application
of
remanufacture
system
labels
in
the
field.
I
don't
believe
that
EPA
has
any
intent
of
asking
us
to
campaign
the
field
to
replace
all
of
the
labels
that
have
been
applied
since
2000.
Also
in
my
opinion,
the
changes
that
EPA
has
made
do
not
go
far
enough,
in
that
there
is
considerable
confusion
on
railroads
on
the
meaning
of
the
word
"
engine."
When
we
say
"
engine,"
we
mean
an
HDL
or
a
710;
when
railroaders
say
"
engine,"
they
as
often
as
not
mean
what
is
to
us
and
EPA
a
"
locomotive."
So
wording
added
to
the
label
saying
"
Apply
this
label
to
the
engine,"
as
indirectly
suggested
by
EPA,
is
ambiguous
on
the
railroads.
I'd
really
prefer
to
see
the
wording
of
the
labels
be
made
identical,
if
there
must
be
two;
in
the
best
of
all
possible
worlds
(
that
dwelt
in
by
the
truck
and
non­
road
engine
manufacturers)
there
would
be
only
one.

Regards,

Dave
"
Ducharme,
David
J
(
GE
Trans)"
<
David.
Ducharme@
Trans.
ge.
com>
Transmission
Date:
03/
23/
2005
09:
53:
35
AM
To:
Alan
Stout/
AA/
USEPA/
US@
EPA,
cweaver@
railpower.
com,
david.
e.
brann@
gm.
com,
mrush@
aar.
org,
rftimmons@
aslrra.
org,
sfritz@
swri.
org,
kkokrda@
enginemanufacturers.
org
cc:"
Lawson,
Pete
J
(
GE
Trans)"
<
pete.
lawson@
Trans.
ge.
com>,
"
Rumpf,
John
(
GE
Trans,
Legal)"
<
john.
rumpf@
ae.
ge.
com>,
"
Baran,
Len
(
GE
Trans)"
<
Len.
Baran@
Trans.
ge.
com>,
"
Kelly,
Brian
E
(
GE
Trans)"
<
Brian.
Kelly@
Trans.
ge.
com>
Subject:
GE
comments
to
proposed
changes
to
40
CRFR
Part
92
with
attachment
Alan,
attached
are
GE
comments
to
the
EPA
proposed
changes
to
Part
92.
If
you
have
any
questions
or
would
like
to
discuss
our
comments
further
please
call
me
at
814­
875­
2084.
Thank
you
Dave
Ducharme
­­­­­
Original
Message­­­­­
From:
Stout.
Alan@
epamail.
epa.
gov
[
mailto:
Stout.
Alan@
epamail.
epa.
gov]
Sent:
Wednesday,
March
02,
2005
4:
46
PM
To:
cweaver@
railpower.
com;
david.
e.
brann@
gm.
com;
Ducharme,
David
J
(
GE
Trans);
mrush@
aar.
org;
rftimmons@
aslrra.
org;
sfritz@
swri.
org;
kkokrda@
enginemanufacturers.
org
Subject:

Attached
is
updated
draft
regulatory
language
for
the
technical
amendments
to
40
CFR
part
92.
We
intend
to
adopt
these
changes
as
part
of
our
final
rule
later
this
year.
This
advance
draft
is
intended
to
give
opportunity
to
review
these
technical
changes
to
make
sure
everything
lines
up.
Let
us
know
if
anything
needs
further
attention.

The
file
includes
redline
information
showing
what
has
changed
since
the
proposal.
Alan
Stout
U.
S.
EPA
Office
of
Transportation
and
Air
Quality
2000
Traverwood
Dr.
Ann
Arbor,
MI
48105
734­
214­
4805
734­
214­
4816
(
fax)
stout.
alan@
epa.
gov
www.
epa.
gov/
otaq/
locomotv.
htm
