
 From:
"Ueno Christine, R3L MTU Detroit Diesel Inc." <Christine.Ueno@mtu-online.com>
 To:
<kopinski.donald@epa.gov>
 Date:
09/16/2010 05:31 PM
 Subject:
1033.625(a)(1)



First, Don, are you still the contact person for locomotive regulations? If not, can you please pass this to the correct person. While this issue is not yet a cert issue for us, it may become an issue for our locomotive chassis partner so we are trying to resolve it before it does become an issue.
 
It looks like 40 CFR Part 1033.150(e) allows engine manufactures to build nonroad engines built to 89 to 1039 , while 1033.625(a)(2) allows locomotive manufactures to build locomotives with engines to standards that are numerically lower than the 1033.  However, the nonroad CO limit in part 1039 is not numerically lower than the CO limit in Part 1033. Therefore, it would be impossible to use this provision as there is no standard that is numerically lower than the Part 1033 CO limit. This may not be an issue for engine suppliers that certify to the provisions of 1033.150(e), since the locomotives are exempt from Part 92 and 1033. But, this becomes a real issue for loco builders who want certify nonroad engines to loco standards in their loco certification.  According to the NPRM preamble, this is the long term solution but it may never be a viable solution.
 
40 CFR Part 1039 CO standard 3.5 g/kW-hr
40 CFR Part 1033 CO standard 2.4 g/bhp-hr (switch) or 3.2 g/kW-hr
 
Was this intentional? I do not believe that EPA meant to constrict loco certifiers this way. This may have simply been an oversight. What do you think?
 
If you have any questions, please let me know. 
------------------------------------------------------------------- 
Christine Ueno 
Manager, Regulatory Compliance 
MTU Detroit Diesel, Inc. 
13400 Outer Drive, West 
Detroit, MI 48239 
Office: +1(313)592 5427 
Mobile: +1(313)401 3681 
Fax: +1(313)592 7616 
Email: Christine.Ueno@mtu-online.com 
Web: www.mtu-online.com 
  
a Tognum Group Company
