Office of Transportation EPA420-B-04-002
and Air Quality January 2004
Guidance for Quantifying and
Using Long Duration Switch
Yard Locomotive Idling
Emission Reductions in State
Implementation Plans
> Printed on Recycled Paper
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EPA420-B-04-002
January 2004
for
in
Transportation and Regional Programs Division
Office of Transportation and Air Quality
and
Air Quality Strategies and Standards Division
Office of Air Quality Planning and Standards
U.S. Environmental Protection Agency
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TABLE OF CONTENTS
Page
Section A: Background Information
1. What is the purpose of this guidance? 1
2. How does this guidance relate to existing Clean Air Act requirements? 1
3. What are switch yard locomotive idling emissions? 2
4. What is an idle reduction technology? 2
5. What are the benefits from using technologies to reduce SYL idling emissions? .... 2
Section B: Basic Criteria Requirements for Long Duration Switch Yard Locomotive Idling
Emissions Reductions
6. What are the basic criteria requirements for using emission reductions in SIPs? .... 1
7. What should you consider when implementing an idle reduction control measure? . . 4
Section C: Specific Considerations for Using Long Duration Switch Yard Locomotive Idling
Emission Reductions
8. Are SYL idling emissions part of the state's emission inventory? 6
9. How can the estimated emission reductions be used for SIP purposes? 6
Section D: Quantifying Long Duration Switch Yard Locomotive Idling Emission Reductions
10. How do you quantify emission reductions from the use of an idle reduction
technology? 7
11. How do you quantify emission reductions for other criteria air pollutants or
precursors? 11
Section E: Monitoring and Penalties
12. What monitoring and record keeping should occur to document long
duration SYL idling emission reductions? V2
13. What kind of validation and reconciliation should occur for emission
reductions in SIPs approved under the Voluntary Measures Policy? 12
14. What types of penalties can be assessed for not complying with CAA
requirements? 12
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Section F: The SIP Process for Using Long Duration SYL Idling Emission Reductions
15. What must a state submit to EPA to meet the requirements for
incorporating a source specific control measure in a SIP? 13
Section G: Contact Information
16. Who should you contact for additional information? 13
Appendix A: Definitions 15
Appendix B: NOX and PM Emission Factors for Long Duration Switch Yard Locomotives . . 16
Appendix C: Quantification Summary j/7
Appendix D: Example Quantification 18
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LIST OF ABBREVIATIONS
AC Air Conditioning
APU Auxiliary Power Unit
CAA Clean Air Act
g/bhp-hr Grams per brake horsepower hour
g/kW-hr Grams per kilowatt hour
g/hr Gram per hour
hp Horsepower
hr Hour
Ibs Pounds
NOX Nitrogen Oxides
PM Paniculate Matter (2.5 and 10)
RPM Revolutions per minute
RFP Reasonable Further Progress
ROP Rate of Progress
SIP State Implementation Plan
SYL Switch Yard Locomotive
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Guidance for Quantifying and Crediting Locomotive Idling Emission Reductions
(Note: As used in this document, the terms "we", "us" and "our" refer to EPA. The terms "you"
and "your" refer to a state air pollution control agency.)
Section A: Background Information
1. What is the purpose of this guidance?
The purpose of this document is to provide you with guidance on quantifying emission
reductions from technologies which reduce long duration switch yard locomotive (SYL) idling
emissions. You may wish to use the emission reductions resulting from implementing an idling
reduction technology for meeting emission reduction requirements such as an RFP/ROP,
attainment or maintenance SIP. Guidance on using these emission reductions for New Source
Review offset purposes is addressed in a separate document.
2. How does this guidance relate to existing Clean Air Act requirements?
This document provides guidance to state air pollution control agencies and the general
public on how control measures to reduce truck idling emissions may be used to meet SIP
requirements. SIP requirements can be found in Sections 110(a)(2) and 172(c) of the CAA. This
document does not substitute for those provisions, nor is it a regulation itself. Unless otherwise
indicated, it does not impose binding, enforceable requirements on any party. Further, it does not
assure that EPA may approve all instances of its application, and thus the guidance may not apply
to a particular situation based upon the circumstances. The EPA and state decision makers retain
the discretion to adopt approaches on a case-by-case basis that differ from this guidance where
appropriate. Any decisions by EPA regarding a particular SIP demonstration will only be made
based on the statute and applicable regulations, and will only be made following notice and
opportunity for public review and comment. Therefore, interested parties are free to raise
questions and objections about the appropriateness of the application of this guidance to a
particular situation; EPA will, and states should, consider whether or not the recommendations in
this guidance are appropriate in that situation. This guidance is a living document and may be
revised periodically without public notice. The EPA welcomes public comments on this
document at any time and will consider those comments in any future revisions of this guidance
document.
Readers of this document are cautioned not to regard statements recommending the use of
certain procedures as either precluding other procedures or information or providing guarantees
that using these procedures will result in actions that are fully approvable. As noted above, EPA
cannot assure that actions based upon this guidance will be fully approvable in all instances, and
all final actions may only be taken following notice and opportunity for public comment.
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3. What are switch yard locomotive idling emissions?
SYL engines are designed or used solely for the purpose of propelling railroad cars a
short distance within a confined area. They usually idle their engines when not in use, and they
idle for a variety of reasons, such as maintaining engine operating temperature during cold
weather to avoid engine freezing (most locomotive engines do not have anti-freeze). Other
reasons for idling include immediate engine availability, preventing start-up engine damage,
maintaining air brake pressure, and in some cases, company policy or habit.
4. What is an idle reduction technology?
An idle reduction technology consists of the use of an alternative energy source in lieu of
using the main SYL engine or a device designed to reduce long duration idling. Some of these
technologies are mobile and attach onto the SYL (mobile auxiliary power units (APUs)), and
provide heat or electrical power.
Another technology involves electrifying SYL parking spaces (stationary locomotive
parking electrification) and modifying the SYL. In general, this involves installing electric
powered heating systems on SYL which connect to the electrical grid and provide energy to
operate on-board equipment.
This guidance addresses emission reductions generated from both mobile and stationary
technologies. EPA maintains a list of commercially available idle reduction technologies on its
web site at the following address: http://www.epa.gov/otaq/retrofit/idlingtech.htm. This list is
for informational purposes only, is not an endorsement or verification of any specific idle
reduction technology, and is not intended as a complete list of all available idle reduction
technologies.
5. What are the benefits from using technologies to reduce SYL idling emissions?
The primary purpose of this guidance is to quantify emission reductions in criteria air
pollutants and their precursors. This guidance specifically addresses emission reductions of NOX
and PM2 5 and PM^.1 In addition, there are other important benefits associated with reductions in
long duration SYL idling emissions including:
Reductions in the emissions of toxic air pollutants such as formaldehyde, and trace
metals such as nickel.
Reductions in emissions of carbon dioxide.
Reductions in fuel consumption, decreased maintenance costs, and longer engine life
which results in cost savings to the locomotive owner.
1 Based on data collected, almost all diesel PM is submicron in size. Therefore, we
believe it is reasonable to use the same idling emission factor for both PM2 5 and PM10.
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Reductions in noise levels.
Decreased dependency on oil imports.
Local communities near switch yards, some of which are comprised of low income and
minority populations, may benefit from the reduced pollution and noise levels as will SYL
operators and switch yard staff.
Section B: Basic Criteria Requirements for Long Duration Switch Yard Locomotive Idling
Emissions Reductions
6. What are the basic criteria requirements for using emission reductions in SIPs?
In order to be approved as a measure which provides additional emission reductions in a
SIP, a control measure reducing long duration SYL idling emissions cannot interfere with other
requirements of the CAA, and would need to be consistent with SIP attainment, maintenance, or
RFP/ROP requirements. Specifically, the control measure must provide emission reductions that
meet the criteria requirements described below. These requirements are found in the CAA
section 110 provisions concerning SIPs.
(A) Quantifiable - The emission reductions from a control measure to reduce long duration SYL
idling emissions are quantifiable if they can be reliably and replicably measured. Emission
reductions must be calculated for the time period for which the reductions will be used. Section
D of this document provides you with a method for quantifying emission reductions. You can
also submit your own quantification protocol which we will review and make a decision as to the
appropriateness of its use on a case-by-case basis.
(B) Surplus - Emission reductions are generally surplus and can be used as long as they are not
otherwise relied on to meet other applicable air quality attainment and maintenance requirements.
In the event that the measure to reduce long duration SYL idling emissions are relied on by you
to meet such air quality related program requirements, they are no longer surplus and are not
appropriate to be used for additional credit. In addition, to be considered surplus the emissions
from long duration SYL idling must be a part of the SIP's emissions inventory.
(C) Federally Enforceable - Depending on how the emission reductions are to be used, control
measures to reduce long duration SYL idling emissions must be enforceable through either: (1) a
SIP or SIP revision; or (2) a permit issued under a SIP approved permitting program Where the
emission reductions are part of a rule, regulation, or permit they are considered federally
enforceable if they meet all of the following requirements:
They are independently verifiable.
Violations are defined, as appropriate.
You and EPA have the ability to enforce the measure if violations occur.
Those liable for violations can be identified.
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Citizens have access to all the emissions-related information obtained from the
responsible party.
Citizens can file suits against the responsible party for violations.
Violations are practicably enforceable in accordance with EPA guidance on
practicable enforceability.
A complete schedule to implement and enforce the measure has been adopted by the
implementing agency or agencies.
If a SIP revision is approved under EPA's Voluntary Measures Policy, the state is
responsible for assuring that the reductions credited in the SIP occur. The state would need to
make an enforceable SIP commitment to monitor, assess and report on the emission reductions
resulting from the voluntary measure and to remedy any shortfalls from forecasted emission
reductions in a timely manner. Further, the total of all voluntary measures (including the idle
emission reduction measures) may not exceed 3% of the total reductions needed to meet any
requirements for RFP/ROP, attainment or maintenance as described under the policy. In the
circumstance where the actual emission reductions achieved are more than the amount estimated
in the SIP, you may take credit for the additional emission reductions provided it does not exceed
the 3% cap on voluntary measures and meets the other provisions of the Voluntary Measures
Policy. If you wish to have a SIP revision approved under the Voluntary Measures Policy consult
that policy for further information.2
(D) Permanent - The emission reduction must be permanent throughout the term that the
emission reduction is used.
(E) Adequately Supported - The state must demonstrate that it has adequate funding, personnel,
and other resources to implement the control measure on schedule.
7. What should you consider when implementing an idle reduction control measure?
(A) Use a commercially available idle reduction technology to provide SYL needs (such as
engine and oil heat), and/or reduce idling during the operator's long duration rest or wait period,
in lieu of idling the main locomotive engine;
(B) Use an idle reduction technology that is equipped with a non-resettable meter, data logger, or
computerized data acquisition system capable of measuring total hours it operated;
(C) Comply with all necessary monitoring, recordkeeping, reporting, validation, and
reconciliation requirements as described in Section E of this guidance.
(D) In the case of mobile idle reduction technologies:
2 For a description of this policy consult the following web site:
http://www.epa.gov/otaq/transp/traqvolm.htm.
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(1) Ensure the SYL engine is located in a nonattainment or maintenance area for the
pollutant or precursor for which emission reductions are generated;
(2) If any SYL leaves the nonattainment or maintenance area, the responsible party should
notify you of this occurrence so the emission reductions are adjusted appropriately to
reflect this change;3 and
(3) Prior to quantifying emission reductions, determine the historic idling activity for
each SYL that will be generating emission reductions.4 This information should include
sufficient documentation, such as data from an event recorder to determine the following
information:
(a) The historic number of hours the SYL idled per day for an average summer
weekday for the past year (if pursuing NOX emission reductions in an ozone
nonattainment/maintenance area); or
(b) The historic number of hours the SYL idled per day for an average annual
weekday for the past year (if pursuing PM or NOX emission reductions in a PM
nonattainment or maintenance area).5
(3) Prior to generating emission reductions, you should collect the following information
for the mobile idle reduction technology only: the manufacturer and manufacture date of
the idle reduction technology, its engine model, and average daily horsepower load for the
time period for which you will be generating emission reductions.
(E) In the case of stationary idle reduction technologies:
(1) Ensure the technology is located in a nonattainment or maintenance area for the
pollutant or precursor for which emission reductions are generated; and
3 If any SYL leaves due to routinely scheduled maintenance and will return to the same
rail yard (or another rail yard within the same nonattainment or maintenance area), the
responsible party should not have to notify you. In this case, the data meter or logger should
account for the reduced operating time of the idle reduction technology.
4 The historic idling activity should be used to estimate the idling emission reductions to
be achieved from the use of an idle reduction technology. This estimate should be compared
with the actual emission reductions achieved after the monitoring period, as discussed in Section
E.
5 If dealing with large numbers of SYLs, you can use fleet idling averages to determine
the historic long duration idling activity as demonstrated by existing event recorder data on a
representative sample of SYLs that operate in the nonattainment or maintenance area.
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(2) Prior to quantifying emission reductions, determine the historic idling activity for
each SYL location that will be generating emission reductions. This information should
include sufficient documentation, such as survey or direct observation methods to
determine the following information:
(a) Number of SYLs operating at the location throughout the year;
(b) Of the number in (a) above, the percentage of those SYLs which idle for a
long duration (defined as 15 consecutive minutes or more at idle); and
(c)(l) Of the SYLs in (b) above, the historic number of hours the SYLs idled per
day for an average summer weekday for the past year (if pursuing NOX emission
reductions in an ozone nonattainment/maintenance area); or
(c)(2) Of the SYLs in (b) above, the historic number of hours the SYLs idled per
day for an average annual weekday for the past year (if pursuing PM or NOX
emission reductions in a PM nonattainment or maintenance area).6
Section C: Specific Considerations for Using Long Duration Switch Yard Locomotive
Idling Emission Reductions
8. Are SYL idling emissions part of the state's emission inventory?
You must demonstrate that the emissions from the SYLs (from which the emission
reductions will take place) are accurately included in the SIP emissions inventory. In addition,
the crediting of the emission reductions must also be consistent with the assumptions in the
emission inventory upon which the attainment or maintenance demonstration is based. If they
are not already in the SIP inventory, no credit can be given for idling emission reductions unless
the SIP inventory baseline is reassessed to include such emissions at its current level.
9. How can the estimated emission reductions be used for SIP purposes?
For your SIP RFP/ROP, attainment or maintenance strategy, you should use the emission
reductions which are, or expected to be, generated from the idling reduction technology by
applying the following criteria:
(A) Based on the historic idling hours as determined in question 7(D)(3) and 7(E)(2)
above, the estimated and actual emission reductions per day from the idle reduction
project should be a percentage of the historic idling hours per day. In the circumstance
where the estimated or actual hours idled exceeds the historic idling hours, you should
6 If dealing with large numbers of SYLs, you can use fleet idling averages to determine
the historic idling activity.
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provide an explanation as to the reason for the difference if you decide to seek credit for
the additional amount (that is, the actual amount). We will evaluate the reason for the
difference and make a decision as to the quantity of the emission reduction available on a
case-by-case basis.7
(B) Where required, emission reductions must account for seasonality. For example, if
your SIP only credits those reductions which take place during the summer ozone season,
then only reductions in idling emissions which take place during that season may be
credited.
(C) The total emission reductions from all controls on long duration SYL idling for each
criteria pollutant or precursor is not to exceed the amount in the state's air emissions
inventory for SYL emissions in the year or years the emission reductions are relied upon.
Section D: Quantifying Long Duration Switch Yard Locomotive Idling Emission
Reductions
The following steps describe how to estimate the emission reductions from a proposed
idle reduction project. In addition, these same steps can be used to determine the actual emission
reductions achieved from the project. Step 1 establishes the historic idling activity from which
you will estimate an emission reduction. Steps 2 and 3 describe how to estimate the SYL
emissions that are reduced when using an idle control technology. Step 4 describes how to
estimate the emissions associated with the idle reduction technology (this step is usually not
necessary if using a stationary idle reduction technology). Steps 5 and 6 describe how to estimate
the net reduction in emissions for the entire project. Finally, Steps 7 and 8 describe how to
determine how much of the net reduction is creditable in a SIP. Appendix C provides a summary
of Steps 1-6. Appendix D provides a quantification example for a mobile technology.
10. How do you quantify emission reductions from the use of an idle reduction technology?
Step 1: Determine the historic idling activity of the SYLs involved in the project.
For each SYL using a mobile idle reduction technology, determine the historic idling
hours as described in question 7(D)(3). Likewise, for each SYL space which will have a
stationary idle reduction technology installed, determine the historic idling hours as described in
question 7(E)(2).8
7 For both mobile and stationary idle reduction technologies, determining the historic
idling hours forms the basis for estimating the potential emission reductions. Differences
between the historic idling hours and estimated or actual idling hours may occur due to, for
example, warmer or colder temperatures than the historic time period.
8 If dealing with large numbers of SYLs, you can use fleet idling averages to determine
the historic long duration idling activity as demonstrated by existing event recorder data on a
representative sample of SYLs that operate in the nonattainment or maintenance area.
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Step 2: Select the emission factor for the criteria air pollutant or precursor.
In Appendix B, we provide emission factors for NOX and PM. These emission factors
represent average emissions from a long duration idling SYL. For NOX emissions, the emission
factor is 800 g/hr (2 stroke engine) or 620 g/hr (4 stroke engine). For PM emissions, the
emission factor is 26 g/hr (2 stroke engine) or 32 g/hr (4 stroke engine). Consult Appendix B for
a full explanation of the basis for the emission factors. In the future, we may update the emission
factors or include other criteria air pollutants or precursors.
Step 3: Multiply the emission factor in Step 2 by the number of hours per day the idle reduction
technology is estimated to be used.
Estimate the average number of hours per day of idling emissions to be eliminated by the
use of the idle reduction technology. The estimated hours should be a percentage of the historic
idling activity as determined in Step 1. In the case of mobile technologies, estimate the number
of hours that the technology will reduce long duration idling for each SYL while in the
nonattainment/maintenance area. For stationary technologies, estimate the number of hours that
the technology will reduce long duration idling for each parking space. When determining the
actual emission reductions from an existing project, using a mobile or stationary technology, use
the actual hours the technology was used.
When estimating the number of reduced hours of idling per day you need to consider the
particular pollutant or precursor and how the idling may vary by season or annually (for example,
average summer weekday or average annual weekday) as described in question 7(D)(3) and
7(E)(2).
Thus, to determine the emissions (g/day) from an individual SYL prior to the use of an
idle reduction technology use the following equation:
BASE *
Where,
Emission Per Day = EFBASE
EFBASE = SYL baseline emission factor (NOX or PM in g/hr) (See Appendix B)
ALjRT = Estimated hours of use of idle reduction technology (hr/day)
Step 4(a): Determine emission factor for the mobile idle reduction technology.
In the case of stationary locomotive parking electrification project, for the purpose of this
guidance, it may be presumed that all emissions from power plants (including any increase in
demand resulting from a stationary project) will be accounted for in projections of, or limits on,
overall power plant emissions in the SIP's emission inventory. Therefore, related stationary
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project emissions at power plants should not be considered when quantifying the emission
reductions associated with a stationary project.9
If a stationary project does not rely on energy from the electrical grid, but instead is using
an alternative source of electricity (for example, a portable generator), then you should provide
data that demonstrates the emissions associated with that energy source. The data should comply
with EPA regulations regarding the measurement of emissions from that energy source. If no
regulations exist, provide all emissions data available to you for the energy source. We will
review this information and determine its appropriateness for use on a case-by-case basis.
You will now determine the emission factor associated with the mobile idle reduction
technology used. If the mobile idle reduction technology is an EPA certified diesel fueled non-
road engine, as is the case with many APUs, use the emission factor provided for that engine
family by the manufacturer as part of its certification application under 40 CFR Part 89. This
factor is in g/kW-hr or g/bhp-hr and is publicly available (in Step 4(b) you will convert this factor
to g/hr so the terms are consistent with Step 3). You should know the engine manufacturer's
name, year of manufacture, and 12-character EPA engine family number. This information is
available on the engine label. You can obtain the emission data by contacting EPA's Office of
Transportation and Air Quality (Certification and Compliance Division) or consulting the
certification data at http://www.epa.gov/otaq/certdata.htm (search under "Non-Road
Compression Ignition Engine" and "Engine Family General Information" using the engine's
manufacture date).
Step 4(b): When using a mobile idle reduction technology, multiply emission factor from 4 (a) by
the average daily horsepower load of the mobile idle reduction technology. Skip this step for a
stationary idle reduction technology.
Since the mobile idle reduction technology emission factor is usually in g/bhp-hr, you
should convert this emission factor to g/hr by multiplying by the average daily horsepower load.
This step involves determining the average daily horsepower load which refers to the power use
of the technology. This power use will differ during different times of the year depending on
power needs (AC or heat). For mobile auxiliary power units, the average daily horsepower load
ranges from 5-10 hp. You should contact the idle reduction technology manufacturer (not the
engine manufacturer) to determine the average daily horsepower load within this range for the
time period considered. If the technology emission factor is in kW, you should convert this to
horsepower by multiplying the kW by 1.34. Multiplying the emission factor by the daily
horsepower load gives a gram per hour emission factor for the engine.
9 To the extent that there may be a concern that the power plant emission increases
resulting from a stationary project are not otherwise reflected in the state's overall consideration
of power plant emissions, then the power plant increases in the nonattainment/maintenance area
from a stationary project, where quantifiable, should be considered when quantifying the amount
of emission reductions.
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Step 4(c): When using a mobile idle reduction technology, multiply the g/hr factor by the
number of operating hours (per day) it is estimated to be used. Skip this step for a stationary
idle reduction technology.
Thus, to determine the emissions (g/hr) for the idle reduction technology you should
follow the following equation:
Idle Reduction Technology Emission = EF^ * HP * ALjRT
Where,
EFIRT= Idle reduction technology emission factor (NOX or PM in g/bhp-hr)
HP = Average daily HP load
ALjRT = Estimated hours of use of idle reduction technology (hr/day)
Step 5: Determine the net emission reduction for the mobile technology. Skip this step for a
stationary idle reduction technology.
To determine the net emission reduction, subtract the emissions associated with the idle
reduction technology as determined in Step 4 from the SYL emissions as determined in Step 3.
The equation is as follows:
NER = (EFBASE * AL^) - (EF^ * HP *
Where,
NER = Net emission reductions in grams per day
EFBASE = Baseline emission factor (NOX or PM in g/hr)
ALjRT = Estimated hours of use of the idle reduction technology (hr/day)
EFIRT= Idle reduction technology emission factor (NOX or PM in g/bhp-hr)
HP = Average daily HP load
ALjRT = Estimated hours of use of the idle reduction technology (hr/day)
Net average daily emission reductions can be converted from grams to pounds by
dividing by 454. If necessary for estimating annual reductions of NOX or PM, average daily
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emissions reduced can be converted to annual emissions reduced by multiplying by the number
of days in the year it is assumed the technology will be used.
Step 6: Sum all emission reductions for the project.
For a stationary project, the sum would include the emission reductions from the use of
all the electrified parking spaces. For mobile technologies, the sum would include the emission
reductions from all the participating SYLs.
Step 7: Make sure net average daily emissions reduced from the idling reduction project do not
exceed the historic idling activity of the SYLs involved in the project as determined in Step 1.
The daily emission reductions per day from the idle reduction project should be a
percentage of the historic idling hours per day. In the circumstance where the actual hours idled
exceeds the historic idling hours, you should provide an explanation as to the reason for the
difference if you seek credit for the additional reduction. We will evaluate the reason for the
difference and make a decision as to the quantity of the emission reduction available on a case-
by-case basis. Where verified, the additional emission reduction may be credited.
Step 8: Make sure the net average daily emission reductions from all idling reduction projects
do not exceed the total long duration idle emissions accounted for in the SIP's regional inventory
analysis.
The net average daily emission reductions for all existing and new long duration SYL
idling reduction projects in a nonattainment or maintenance area should be summed to determine
the total reductions from all programs for a given year. The total reductions claimed for all
programs is not to exceed the emission estimate for SYLs for any criteria air pollutant or
precursor used in the applicable SIP inventory for the calendar year in question. See Section C
for detailed discussion.
11. How do you quantify emission reductions for other criteria air pollutants or precursors?
To quantify emission reductions for other criteria air pollutants or precursors (such as
hydrocarbon emissions), you can follow the same steps outlined in this section, substituting an
EPA approved idling emission factor for that pollutant or precursor. Once we have identified an
idling emissions factor for use, similar to those listed or referenced in this document, it may
subsequently be used in the same manner without additional review by us. If no idling emission
factor has been identified, you can submit data supporting an idling emission factor and we will
review this data on a case-by-case basis and make a decision as to the appropriateness of its use.
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Section E: Monitoring and Penalties
12. What monitoring and record keeping should occur to document long duration SYL idling
emission reductions?
(A) For each SYL or stationary location generating emission reductions, the responsible
party (for example, railroad company) should monitor and record the following
information for each time period for which an emission reduction is generated (or other
information capable of demonstrating the emission reductions to our satisfaction):
(1) For mobile and stationary technologies, the number of hours the idle
reduction technology operated while the main SYL engine did not idle, recorded
by a non-resettable meter, data logger, or computerized data acquisition system
capable of recording total hours operated on each SYL.
(2) For mobile technologies only, demonstrate that the SYLs are located in a
nonattainment or maintenance area for the pollutant or precursor for which
emission reductions determined in (1) above occurred in the nonattainment or
maintenance area.
(B) All information to be monitored and recorded in accordance with this guidance for
existing SIP requirements should be maintained by the responsible party for a period of
no less than five years.
13. What kind of validation and reconciliation should occur for emission reductions in SIPs
approved under the Voluntary Measures Policy?
The SIP submission for a voluntary measure should contain a description of the
evaluation procedures and time frame(s) in which the evaluation of SIP reductions will take
place. Once the voluntary control measure is in place emission reductions should be evaluated
by you as required to validate the actual emission reductions. You should submit the results of
your evaluation to EPA in accordance with the schedule contained in the SIP. If the review
indicates that the actual emission reductions are not consistent with the estimated emission
reductions, then the amount of credit should be adjusted appropriately and applicable remedial
measures should be taken under the Voluntary Measures Policy. See the EPA's Voluntary
Measures Policy for further information regarding validation and reconciliation requirements for
such measures.
14. What types of penalties can be assessed for not complying with CAA requirements?
Use of this guidance does not relieve the responsible party of any obligation to comply
with all otherwise applicable CAA requirements, including those pertaining to the crediting of
emission reductions for your SIP, such as emission reductions for your attainment or
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maintenance strategy. Violations of CAA requirements are subject to administrative, civil,
and/or criminal enforcement under Section 113 of the CAA, as well as to citizen suits under
Section 304 of the CAA. The full range of penalty and injunctive relief options would be
available to the federal or state government (or citizens) bringing the enforcement action.
Section F: The SIP Process for Using Long Duration SYL Idling Emission Reductions
15. What must a state submit to EPA to meet the requirements for incorporating a source
specific control measure in a SIP?
The state must submit to EPA a written document which:
(A) Identifies and describes the idle reduction project and its implementation schedule to
reduce long duration SYL idling emissions within a specific time period;
(B) Contains a quantification methodology to estimate the emission reductions from the
idle reduction project. You can follow the quantification methodology provided in
Section D of this document or you can submit your own. If you submit your own
quantification methodology for quantifying the emission reductions, you must provide all
relevant technical support documentation, including the information and quantification
uncertainties used to calculate emission reductions. You must rely on the most recent
information available at the time the SIP is developed;
(C) Contains federally enforceable requirements for the responsible party (for example,
railroad company) to monitor and record the appropriate information;
(D) Under the Voluntary Measures Policy only, enforceably commits to evaluate and
report the resulting emission reductions of the measure as applicable;
(E) Enforceably commits to remedy any SIP emission shortfall in a timely manner if the
measure does not achieve estimated emission reductions; and
(F) Meets all other requirements for SIP revisions under sections 110 and 172 of the
CAA.
Section G: Contact Information
16. Who should you contact for additional information?
State agencies, the regulated community and members of the public with questions
concerning a case-specific application of this guidance should contact the EPA Regional Office
with responsibility for air quality planning in the area where the switch yard is located. A contact
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list of your EPA Regional Office is available at the following web address:
http://www.epa.gov/epahome/locate2.htm
For general questions regarding the quantification of SYL idling emissions reductions,
please contact Paul Bubbosh of EPA's Office of Transportation and Air Quality at (202) 343-
9322 or David Solomon of EPA's Office of Air Quality Planning and Standards at (919)541-
5375.
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Appendix A
DEFINITIONS
For the purposes of this guidance only, the following definitions apply:
(A) ACTUAL IDLING EMISSION REDUCTIONS means the emission reductions
achieved from an idle reduction project.
(B) ESTIMATED IDLING EMISSION REDUCTIONS means the projected emission
reductions from an idle reduction project which is based on a percentage of the historic
idling activity.
(C) GLOBAL POSITIONING SYSTEM means a satellite-based radio navigation
receiver capable of providing the time, the date, and position of the switch yard
locomotive.
(D) HISTORIC IDLING ACTIVITY means the demonstrated past long duration idling
of a switch yard locomotive, or past long duration idling from switch yard locomotives at
a particular location, in the nonattainment or maintenance area.
(E) IDLE REDUCTION TECHNOLOGY means a commercially available technology or
device that provides cab comfort or engine needs, or otherwise reduces the need for long-
duration switch yard locomotive idling.
(F) LOCOMOTIVE SWITCHER means a locomotive designed or used solely for
the primary purpose of propelling railroad cars a short distance.
(G) LONG DURATION IDLING means the operation of a switch yard locomotive's
propulsion engine for a period greater than 15 consecutive minutes at a time at which the
main drive engine is not engaged in gear.
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Appendix B
NOX and PM Emission Factors for Long Duration Switch Yard Locomotives
Two Stroke Locomotive Engines
NOxg/hr
800
PMg/hr
26
Four Stroke Locomotive Engines
NOxg/hr
620
PMg/hr
32
Emission factors listed above are derived from various sources.10 In some cases, multiple
trials or replicate measurements were reported for the idle mode for individual locomotives.
Before deriving the final means, all replicates for individual locomotives were averaged to give a
single mean for each locomotive, to give each locomotive equal weight in the resulting emission
rate.
Throughout, measurements obtained for locomotives on "special settings" were not
included. Special settings included retarded timing and continuous throttle.
Measurements of particulate matter from Hare & Springer (1972) were not included in
the calculation of the PM emission rate. The apparatus used for paniculate measurement in that
study was experimental, and the resulting measurements are not considered reliable.
10 Fritz, S.G., J.C. Hedrick, V.O. Markworth, M.B. Treuhaft, and J.F. Wakenell. Diesel
Fuel Specification and Locomotive Improvement Program: Tenth Research Phase Final Report.
AAR Report No. R-771. Engine and Vehicle Research Division, Southwest Research Institute.
San Antonio, TX. December, 1989; Fritz, S.G., V.O. Markworth and R.L. Mason. Locomotive
Exhaust Emission Field Tests: Phase 1, EMD SD40-2 and GE C40-8 Locomotives. Final Report,
AAR Report No. R-877, Association of American Railroads, Research and Test Department,
Washington, DC; SwRI Project No. 03-4171, Southwest Research Institute, San Antonio, TX.
October, 1994; Fritz, S.G. Emission Measurements for Locomotives: Final Report. SwRI 5374-
024. Southwest Research Institute, San Antonio, TX. August, 1995; Hare, C.T., and KJ.
Springer. Exhaust Emissions from Uncontrolled Vehicles and Related Equipment Using Internal
Combustion Engines: Final Report, Parti, Locomotive Diesel Engines and Marine
Counterparts. Contract No. EHS 70-108. Southwest Research Institute, Antonio, TX. October
1972.
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Appendix C
Quantification Summary
The purpose of this quantification summary is to provide a concise formula to calculate
the net emission reduction for long duration switch yard locomotive (SYL) idling. This summary
is intended to be consistent with the more detailed step-by-step process in Section D.
(ErBASE (ALIRT/ CrG/LBS)) - (J±rIRT rir (ALIRT/
Where,
NER = Net emission reduction
EFBASE = SYL baseline emission factor (NOX or PM in g/hr)
ALIRT = Estimated hours of use of the idle reduction technology (hr/day)
CFG/LBS = Conversion factor for grams to pounds which is 454
EFIRT = Idle reduction technology emission factor (NOX or PM in g/bhp-hr)
HP = Average daily horsepower load (ranges from 5-10 hp depending on the
technology; consult the technology manufacturer)
ALIRT = Estimated hours of use of the idle reduction technology (hr/day)
There are three essential parts to this formula. First, you determine the emissions from
the SYL by selecting the emission factor for the pollutant or precursor for reduction, multiply this
factor by the number of hours you estimate the technology will reduce long duration idling
emissions. This number is divided by the conversion factor to derive a grams per hour number.
The second part is to determine the emissions associated with the idle reduction technology (this
step typically does not apply to stationary idle reduction technologies). This requires determining
the emissions associated with the technology, multiplying this by the horsepower to derive a
grams per hour number, multiplying this number by the number of hours the technology will
operate, and then dividing this number by the conversion factor. The final part is simply
subtracting the emissions from the second part (idle reduction technology emissions) by the first
part (switch yard locomotive's baseline emissions) to arrive at the net emission reduction.
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Appendix D
Example Quantification
This example is for the purpose of illustrating the quantification steps only, and it does
not address the additional considerations to credit the reductions generated. In this example we
will quantify the NOX long duration idling emission reductions from a two stroke locomotive
engine using a mobile idle reduction technology. In the nonattainment area, 10 SYLs will use
this technology 8 hours per day.
For the idle reduction technology, we will use an auxiliary power unit (APU). The APU
allows an idling SYL to be shut down by heating and circulating the coolant and oil, charging the
batteries and powering the cab heaters It is important to note that not all idling can be
eliminated. In certain circumstances, such as when the wait from active use to active use is not
long, the operator may decide to keep the SYL engine idling.
Per the steps outlined in this guidance document, the NOX emission reduction associated
with the use of the APU is calculated as follows:
Step 1: Determine the historic idling activity of the SYL involved in the project.
You should follow the discussion provided in question 7(D)(3) in this guidance to derive
the historic number of hours the SYL idled for an average summer weekday in the nonattainment
or maintenance area. In this example, we determined a SYL's long duration idling occurred an
average of 10 hours per day.
Step 2: Select the emission factor for the criteria air pollutant or precursor.
We are evaluating NOX emission reductions for a two stroke SYL so the emission factor
is 800 grams per hour.
Step 3: Multiply the emission factor in Step 2 by the number of hours per day the idle reduction
technology is estimated to be used.
We estimated that the APU will reduce 8 of the 10 hours of long duration idling.
Therefore, the average daily emissions reduced is 800 grams/hr * 8 hours/day = 6,400 grams/day.
Step 4(a): Determine emission factor for the mobile idle reduction technology.
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In this example, the APU uses a 2003 Lister Fetter engine (EPA engine family
2L5XL1.86LWS )n which was certified under 40 CFR Part 89. By examining the certification
data for this engine family, we find the certified NOX emission level is 6.69 g/kW-hr.12
Step 4(b): When using a mobile idle reduction technology, multiply emission factor from 4 (a) by
the average daily horsepower load of the mobile idle reduction technology.
Since the emission factor is in kW, we begin by converting this to hp (6.69 g/kW-hr *
1.34 =8.9 g/bhp-hr). According to an APU manufacturer, the average daily hp load for this
engine during typical summer weekdays is 8 hp. So the grams per hour emission rate of the
auxiliary power unit is 8.9 g/bhp-hr * 8 hp = 71 g/hr.
Step 4(c): When using a mobile idle reduction technology, multiply the g/hr factor by the
number of operating hours (per day) it is estimated to be used.
As a result, the total average daily emissions of the APUs are 71 grams/hr * 8 hours/day =
568 grams/day.
Step 5: Determine the net emission reduction.
The estimated net emissions reductions from this program are 6,400 grams/day - 568
grams/day =5832 grams/day or 12.8 Ibs/day.
Step 6: Sum all emission reductions for the project.
In this example, we estimate that all SYLs will operate in a similar manner. In practice,
each SYL could have its own idling emission reductions. We add the total amount of idling for
all 10 participating SYLs in the project, which is 10 * 5832 = 58,320 grams/day or 128 Ibs/day.
Step 7: Make sure the net average daily emission reductions from the idling reduction project
do not exceed the historic idling activity of the SYLs involved in the project as determined in Step
1.
This step involves taking your estimate of idling activity (or the actual emission reduced)
and reconciling this estimate (or actual number) with your historic idling hours from Step 1
11 For purposes of this example we have selected a specific engine model to better
illustrate the APU's emissions. The use of this engine model does not confer any endorsement of
this company or its products.
12 In some circumstances, the NOX emission factor is reported as a combined NOX + HC
emission factor. You will need to contact the engine manufacturer to determine the NOX only
value.
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(following question 7(D)(3)). If the estimate (or actual number) exceeds the historic idling
hours, you will need to explain this increase if you seek credit for the estimated (or actual)
amount. In this example, the estimate does not exceed the historic idling activity.
Step 8: Make sure the net average daily emission reductions from all idling reduction projects
do not exceed the total long duration idle emissions accounted for in the regional inventory used
in the SIP.
In this example, you will need to assess the total SYL NOX emissions projected in the
inventory for the year or years the emission reductions are to be relied upon, and ensure that the
estimated emission reductions do not exceed this amount. If the emission reductions do not
exceed this amount, full credit for the project can be taken assuming all other requirements are
met.
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