United States Air and Radiation EPA420-F-99-036
Environmental Protection September 1999
Agency
Office of Mobile Sources
&EPA Technical
Highlights
Requirements for Railroads
Regarding Locomotive Exhaust
Emission Standards
In 1998, the U.S. Environmental Protection Agency (EPA) promulgated
final exhaust emission standards for oxides of nitrogen (NOx),
hydrocarbons (HC), carbon monoxide (CO), particulate matter (PM)
and smoke for newly manufactured and remanufactured locomotives
and locomotive engines. The requirements for compliance with these
emission standards are described in 40 CFR Part 92. These provisions
apply to manufacturers, remanufacturers, and owners and operators of
locomotives and locomotive engines manufactured on or after January
1, 1973. The three most significant requirements for railroads relate to:
1) remanufacture of locomotives, 2) maintenance of locomotives, and
3) testing of locomotives.
Remanufacture of Locomotives
The regulations require that post-1972 locomotives be covered by an
EPA Certificate of Conformity when they are remanufactured. (See
Applicability of Locomotive Emission Standards, EPA420-F-99-037, for
more information about which locomotives are covered by these regula-
tions.) The certificate certifies that the locomotive was remanufactured in
a specific manner so that it complies with EPA's emission standards.
Each certificate covers a group of similar locomotives that is referred to
as an "engine family." A railroad may apply directly to EPA to obtain a
certificate, or may rely on a supplier or remanufacturer that has obtained
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a certificate. The company that obtains the
certificate is referred to as the certificate
holder, and is responsible for ensuring that
the locomotive complies with EPA's emis-
sion standards.
Readers should note that EPA defines the
term remanufacture broadly when deter-
mining the applicability of these standards.
It does not require that the entire engine be
reconditioned to be considered
remanufactured, it only requires that all
power assemblies be
removed and replaced
or requalified. EPA
makes an exception for
maintenance practices
that replace power
assemblies intermit-
tently during ongoing
maintenance rather
than during a single
overhaul. However,
this exception only
applies where the
power assemblies are
replaced so infre-
quently that it takes
more than five years to '>•;•.?'
replace all of them. If
they are replaced more
frequently than this, the locomotive must
be covered by a certificate of conformity.
EPA regulations require that railroads
perform emission-related maintenance on
all regulated locomotives. This requirement
is described in 40 CFR 92.1004. Emission-
related maintenance is specified by the
certificate holder and approved by EPA at
the time of certification. The certificate
holder is required to provide the emission-
related maintenance instructions to the
railroads. Emission-related maintenance
generally includes regular replacement of
fuel injectors and air filters, as well as the
use of fuels and lubricants meeting the
specifications of the certificate holder. In
most cases, it will also include frequent
inspection of other emission-related com-
ponents to ensure that they are functioning
properly. This section of the regulations
also prohibits any maintenance that would
reasonably be expected to adversely affect
the emission performance of the locomo-
tive.
Railroads have the flexibility to use mainte-
nance practices other than those specified
by the certificate holder, but only where the
alternate maintenance is equivalent to the
specified maintenance in terms of main-
taining emission performance. Railroads
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intending to deviate significantly from the
specified maintenance should notify EPA
to ensure that the alternate maintenance
will meet the requirements of 40 CFR
92.1004.
Railroads are required to maintain records
of all emission-related maintenance and
any other maintenance that might reason-
ably be expected to affect the emission
performance of the locomotive. These
records must be kept for eight years from
the time that the maintenance is performed.
Railroads have flexibility in determining
how these records should be maintained,
and may contact EPA to ensure that their
record keeping procedures comply with the
requirements of 40 CFR 92.1004.
40 CFR 92.1003. Under this second pro-
gram, which begins January 1, 2005, each
Class I freight railroad is required to test
0.15 percent of its locomotive fleet each
year using the specified EPA test procedure
(40 CFR Part 92 Subpart B). This railroad
testing program focuses on the locomotives
in the fleet that have exceeded their useful
life values. (Useful life is the period speci-
fied in a certificate during which the
locomotive is designed to comply with the
standards; it is generally equivalent to
750,000 miles or more.) Railroads may
request approval from EPA to use other test
programs that accomplish
the same objective of providing informa-
tion about the emissions of high-mileage
locomotives.
Locomotive Testing
EPA has established two testing programs
to monitor the in-use emissions of locomo-
tives. The first program is run by the
certificate holders and is not discussed
here. The second program is run by the
Class I freight railroads and is described in
For information
Additional documents on locomotive
exhaust emission standards are available
electronically from the EPA Internet server
at:
http://www.epa.gov/oms/locomotv.htm
For further information on compliance with
these regulations, please contact the loco-
motive certification contact at:
U.S. Environmental Protection Agency
Office of Mobile Sources (6403 J)
401 M Street SW
Washington, DC 20460
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