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NJ Diesel Retrofit Law:
Solid Waste Collection Vehicles
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Diesel Retrofit Overview
Directed at reducing diesel emissionsand the health impacts associated withdiesel exhaustComponents of the rules:
Provides for installation of closedcrankcase ventilation systems (school bus)Provide tailpipe retrofits for certain heavyduty diesel enginesReimbursement of purchase andinstallation costs
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Intent of the Diesel Retrofit Law
Reduce 150 tons of diesel particulatematter from the air every year.Target vehicles that have large operationalpresence in neighborhoods and havepotential to directly expose citizens todiesel particulate matter.Prioritizes the reduction of fine particulatematter (PM2.5) in urban communities
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Retrofit Law Components
Compliance burden on vehicle ownerSubmit Inventory / Cost Estimate
March 2008 for Solid Waste CollectionVehicles
State pays for retrofitsState ContractAuthorized installers
Retrofit warranty
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Compliance ToolsGuidance DocumentState Contract - Authorized InstallersElectronic Submittal including webportal in 12/07Workshopswww.Stopthesoot.org websiteListserver messaging systemProgram Staff
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Devices on Contract
Designed to capture solids, liquids, andgaseous emissions and treat before exhaustDesigned to replace mufflerApplication design based on engine/chassismanufacturer for sizing & plumbingParticle Filters, Oxidation Catalysts, Flow-Through FiltersMeet definition of BARTUSEPA or CARB verified
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Authorized Installers
A person/entity who holds a writtenagreement – service, sales, etc… withone or more retrofit manufacturerMust be on State Contract as perregulationsProvide Best Available RetrofitTechnology that has been verified byCalifornia or USEPA to meet standardsreferenced in NJ regulations.
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Authorized Installer Tasks
Needs to confirm the device will workwith target engine/chassiscombinationMust be manufacturer authorized &trainedCan provide turnkey cost estimateWarranty ServiceProduct information and trainingCoordinate Reimbursement with State
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Choosing an Authorized Installer
Listed on the state contractDEP will make available a list ofauthorized installers who are eligible toperform the retrofits
Familiarity/Comfort LevelOne of the installers has performed workon your vehicles previouslyYou use the brand of products beingoffered by an installer on your vehicles
Interviews
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ReimbursementReimbursement direct to Authorized Installer on StateContractCovered cost
BART & ancillary items for turnkeyInstallation
Not coveredConsumable items such as replacement filtersRemedial repairs necessary to retrofit vehicleExisting damage, wear and tear, or modificationsprecluding installation of BART.Non-contract installations unless under approvedgrant.
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Regulated Vehicles
School BusesSolid Waste Collection VehiclesPublic & Private Commercial BusesPublicly Owned On-Road Vehicles
Includes Recycling Trucks
Publicly Owned Off-Road Equipment
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Diesel Retrofits-Regulated Vehicles
Solid Waste Collection Vehicles (SWCV)that meet the following criteria
Publicly ownedor
In a contract with a public entity
Includes Solid Waste Cabs and SolidWaste Transport Units
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Regulated solid waste vehicle means any dieselsolid waste vehicle registered in the State, thatis owned by the State, or any politicalsubdivision thereof, or a county or municipalityor any political subdivision thereof, or that isowned by a person providing solid wasteservices with the vehicle pursuant to a contractwith the State or any political subdivisionthereof, or a county or municipality or anypolitical subdivision thereof.
Diesel Retrofits-Regulated Vehicles
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Vehicle Types and General Designation of Scope:
Vehicle Description Contract Type (Issuer)
Regulated?
Publicly-Owned Solid Waste Collection Vehicle None Yes Privately-Owned Solid Waste Collection Vehicle Public Yes Privately-Owned Solid Waste Collection Vehicle Private No Solid Waste Cab and Solid Waste Transport Unit Public Yes Solid Waste Cab and Solid Waste Transport Unit Private No Construction Truck – Solid Waste Public No Construction Truck – Solid Waste Private No
Diesel Retrofits-Regulated Vehicles
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Retrofit Law-General exemptions
2007 & newer model year on-road enginesEngines meeting the 0.01 g/bhp*hr standard
Off-road engines meeting 0.015 g/bhp*hr PMstandard (~2011 to 2014 phase in)
First aid, emergency, ambulance, rescue & fire
Agricultural VehiclesFarm Equipment
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What are the retrofits?Best Available Retrofit Technology (BART)
Attached to exhaust pipe in place of existing muffler3 main types – Diesel Oxidation Catalyst (DOC), FlowThrough Filter (FTF), and Diesel Particulate Filter (DPF)
Minimum exhaust PM (particulate) emissionreductions established by DEP
3 PM reduction levels called BART Levels
USEPA or CARB verified diesel retrofitemission control and reductions (%)
USEPA and CARB restrictions apply on model,year, use, fuel & temperature restrictions
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BART Minimum Control Efficiency
BART Level Minimum Control Efficiency(particulate matter reduction by
weight %)3 85
2 50
1 25
Control Efficiency determined according to verification results from USEPA or CARB
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Steps to Compliance
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Owner identifies Regulated VehiclesDetermine appropriate BART & InstallerSubmit Inventory Form (includes costestimates)DEP review/approve cost estimatesInstallationSubmittals and RecordkeepingOne-Time Compliance Inspections
Basic Program Steps
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Develop InventoryAfter obtaining the inventory/cost estimate formfor each vehicle
Determine desired BART modelInstaller inputIndependent research
Choose installer(s) from the state contractInstallers offer 1-2 BART brandsCan use more than one installer
May be needed for unique applicationsSome exceptions based on vehicle design –space constraints
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Determining BART
Type of vehicle and Engine Model YearSWCV – 1987 & older engines – BART 1SWCV – 1988–2006 engines – BART 2SWCV – 2007 & newer engines – Exempt
Examination and Observations byAuthorized Installer
Exhaust Temperature ProfilesBackpressure MonitoringSizing Concerns
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BART Levels for Solid WasteCollection Vehicles
25%BART 11987 & older
50%BART 21988-2006
Not applicableNot applicable2007 and newer
Minimum controlefficiency
(particulate emissionreduction by
weight)
Minimum BARTLevel
Engine ModelYear
Control Efficiency determined according to verification results from USEPA or CARB
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Cost Estimate Info
Installer provides cost estimate amount foreach vehicleBART Kit at contract discount
Labor hours & rateMobile Install cost– optional
Exemption or Lower BART LevelDocument indicated required BART Level isinfeasible.
Owner puts info into form.Form is electronic only
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What’s on the Form?General Information
Owner/Contact PersonAddress/Location of Vehicle
General Vehicle InformationVehicle Type/Model/YearLicense Plate/Vehicle Identification Numbers
Engine InformationHorsepowerManufacturer/YearEPA Engine Family Number
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What’s on the Form?
BART InformationManufacturer/Make/ModelAuthorized Installer
Cost EstimateBART Cost/ Labor Rate and full estimated costquoted from authorized installer on State ContractEstimated Install Time
Choose Compliance MethodNotice of Intent to ComplyOne of the Fleet Plan Types
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Submittal Process
Owners submit one of four submittaltypes & full diesel inventory
Notice of Intent to Comply (NIC) / Fleet PlanCombined Fleet PlanFleet Averaging PlanCombined Fleet Averaging Plan
DEP has the authority to reject unreasonable cost estimates
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Notice of Intent to Comply
The regulated vehicle will meet theprescribed BART levelIncludes cost estimate per vehicle asprovided by the authorized installerInventories submitted with NICs needto include all of the diesel vehicles inthe fleet
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Fleet PlanWhen prescribed BART level is not feasiblefor at least one vehicleAllows alternate (lower level) BART,repower, rebuild, retirement or exemption
Need reports from multiple Authorized InstallersDEP has to approve “drop down” application forlower BART level
Inventory includes other diesel vehiclesand Notice of Intent to Comply vehiclesAnd cost estimates for all retrofits
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Combined Fleet PlanTwo or more fleets can combine all of theirdiesel vehicles into one submissionTrigger- one vehicle that cannot meet BARTCan be a mixture of NICs or Fleet Plans
All owners involved have Shared Liability
May be beneficial for smaller diesel fleetsFor example a municipality combining withcounty fleet
Includes cost estimate per vehicle asprovided by the authorized installer
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Fleet Averaging PlanOption if fleet has 75+ regulated vehiclesSubmitted when one or more vehicle in afleet cannot meet BART
fleet plan trigger
Allows alternate (lower level) BART, repower,rebuild, or retirements.Can use non-regulated vehicles andequipment as a means of achieving therequired diesel emissions reduction
All vehicles in plan then become regulated vehicles
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Fleet Averaging PlanRequires emissions modelingsubmittals to show same or greaterbenefit and better cost benefitSubmittal includes all diesel vehicles infleetIncludes cost estimate per vehicle asprovided by the authorized installer
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Combined Fleet Averaging Plan
Used to reach minimum 75 vehicle fora fleet averaging plan
All involved will sign the Joint andSeverable Liability Statement
Includes all diesel vehicles in fleet
Include cost estimate per vehicle asprovided by the authorized installer
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Multiple Types of RegulatedVehicles
All diesel vehicles in the fleet have tobe submitted with this inventory
Non-regulated dieselsDiesels that will be regulated later, suchas off-road equipment
Choose “Non-Regulated/Due Later”As a compliance option in the inventory
Early RetrofitsOnly done in special cases as per policy
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Why Collect This Information?
Information is needed toDetermine correct BARTPrevent fraudPre-populate Compliance FormVerify BART and Authorized Installer,satisfy procurement processDetermine funds availability
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DEP review
Reasonable cost based on statecontract ratesFleet plan and Exemption andrequests – technical soundness.Evaluate Fleet averaging plansOutcome is approval, partial approval
Rejected portions must resubmit
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Notification
If costs are reasonable--> LetterApproval for purchase and installation
If costs are unreasonable--> LetterThe DEP will work with owner to identifymutually acceptable BARTIf no agreement can be reached, thenDEP will issue final determination:
Identify alternative BARTOr provide an exemption
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Cost Estimate Approval
Letter of approval sent to ownerLetter must be presented to installerNo installations shall be performeduntil the DEP confirms that funds areset aside (approval letter)
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Install Timeframes
DEP provides owner with a Notification toretrofit
Install timeframes based on fleet size< 75 regulated vehicles - install requiredwithin 120 days of notification75 - 150 regulated vehicles - install requiredwithin 180 days of notification> 150 regulated vehicles - install requiredwithin 270 days of notification
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Installation
Letter from DEP noticing to begininstallation
Has location for downloading compliance form
Use authorized installer on cost estimateOwner coordinates with installerDEP does not coordinate installations
Compliance form must be submitted to DEPw/in 5 days of installation with ownersignoff – VERY IMPORTANT
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Compliance Form
Pre-populated with inventory infoKey tracking document for state contractingprocess and program monitoring
Documents from owner that the vehicle has beenretrofittedMVC signoff at next regularly scheduledinspectionSteps required in Diesel Retrofit Statute
Keep on vehicle at all timesCopy at central office location and DEP
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Compliance FormCompliance form
Owner signs after installcopy to DEP, original with vehicleForm due to DEP 5 days after retrofitinstallation is complete (Owner signature)
Installation verified at next MVC inspectionInspector signs compliance form
Owner sends copy of signed form to DEPForm due 30 days after inspection
Must have Inspector signature
Original stays with vehicle
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Annual Submittals
Required by Diesel Retrofit LawA supplement or modification is dueannually
Anniversary date based on NIC or Fleet Plan
Update of NIC or Fleet PlanAdditions, subtractions to the fleetChanges in compliance methods
Similar form to the inventoryCan be completed on-line
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Reimbursement
Direct reimbursement to installer – statecontract
No out of pocket costs to vehicle/fleet ownerPublic fleet - may self-install if “authorizedinstaller”
Labor costs reimbursed by grantHardware purchased from state contract
Ineligible = Fuel, maintenance, & repairs
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Particulate ControlTechnology
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Tailpipe technologies
3 main categories: DOC (dieseloxidation catalyst), FTF (flow throughfilter), DPF (diesel particulate filter)Mostly muffler replacements + ancillary
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Diesel Oxidation Catalyst (DOC)
BART Level 1 DevicesHave a PM reduction capability of 25%
Uses a catalytically induced reaction thatconverts PM, CO and Hydrocarbons to CO2and H2O (usually platinum catalyst)Does not use a filterOften used in combination with otherdevices to achieve a higher PM reduction
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Flow Through Filter (FTF)
BART Level 2 DevicesHave a PM reduction capability of 50%
Exhaust flows through a filter medium(wire mesh) that has flow channelswhich create a turbulent conditionFilter medium typically treated with acatalystPM that is not treated flows out withexhaust
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FTF- Cutaway
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Diesel Particulate Filter (DPF)BART Level 3 Devices
Have a PM reduction capability of > 85%Uses a filter to “trap” PM particles in theexhaustTwo styles of filters
PassiveUses a catalyst to reduce PM ignitiontemperature and PM is incinerated usingexhaust heat
ActiveUses an external source of heat to incineratethe PM trapped in the filter
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DPF Flow
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DPF - Disassembled
FilterElement
End Flanges
Seals -Clamps
Seals-Clamps
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BART Examples
DOCs and DPFs
Flow Through Filter
DOC
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Retrofit Device Label
SerialNumber
FamilyName
ManufacturerInformation
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Particulate Retrofit Resources
CARB – California Air Resources Boardwww.arb.ca.gov/diesel/verdev/verdev.htm
USEPA - National Clean Diesel Campaignhttp://www.epa.gov/otaq/retrofit/verif-list.htm
Retrofit manufacturers' websites:Caterpillar, Donaldson, Engelhard, HUSS,Engine Control Systems, CumminsFiltration (Fleetgard), Johnson Mattheyetc.
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Warranty, Maintenance,On-Road Requirements
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BART Warranty & InstallationRequirements
Retrofit Device ManufacturerWarranty for retrofit and engine damageMust repair any damage to vehicle causedby normal use of retrofit
Authorized InstallerWarranty for installationMust repair any damage to vehicle causedby the installation
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BART Warranty & InstallationRequirements
Vehicle OwnerMust be installed by a manufacturer’sauthorized installer to be eligible forreimbursement (Statutory requirement)Vehicle has to be in good working orderMust maintain BART retrofit device inaccordance with manufacturerspecifications
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Retrofit Device Warranties
Two years, unlimitedmileage
>250 HP; GVWR >33,000 pounds; typicallydriven >100,000 miles per year;<300,000 miles on odometer at time ofinstallation
Five years or 150,000miles>250 HP; GVWR >33,000 pounds
Five years or 100,000miles
170-250 HP; GVWR ≥19,500 pounds and≤33,000 pounds
Five years or 60,000miles70-170 HP; GVWR < 19,500 pounds
MinimumWarranty
PeriodEngine Size & Gross vehicle Rating
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Maintenance
Owners are responsible forRetrofit Maintenance
Varies by retrofit typeincludes visual inspection, ash removal
General conditionProper operationRepair damage
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On-Road Standards
N.J.A.C. 7:27-14.3- Emissions controldevices shall not be:
DisconnectedDetachedDeactivated or in any way be renderedinoperable or less effective
Except for the purposes of diagnostics,maintenance, repair or replacementEnforceable
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Diesel RiskReduction Program
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Submittal Dates (anticipated)Inventory, NICs, Fleet plans, Averaging Plans
Solid Waste Vehicles March 6, 2008
NJ Transit 9/08
Private Commercial Bus 3/09*
Other gov’t vehicles/Equipment 9/11
School Bus Tailpipe ??/??*Or after NJ Transit submittal, whichever is later
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Ultra Low Sulfur Diesel
Must use with 2007 on-road engines &most BART applicationsEPA mandates on refineries mean ULSDwidely available since mid-October 2006ULSD Issues
Meets ASTM D975Lubricity sameNo fuel penalty- energy content is samePump labeling requirements for ULSF & standard2D
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ResponsibilityOwners
Select correct BART for your fleetFill-out, submit and maintain formsAnnual supplementsMaintain BART
DEPWork with owners and installers to solveproblemsMaintain website for dataStore documentationGuidance to regulated communityEnsure compliance
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Support Information
Website athttp://www.stopthesoot.org
Program InfoGuidance DocumentsContactsPortal for document submittals/updatesView state retrofit contractsList Server
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CONTACTS
Diesel Risk Reduction Program(609) 292-7953
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How to complete aBART submittal
