To all: I do not make many posts, unless I am sure what I post can be read as irrefutable, I do my homework. While researching the specifics of grid interconnection in Ct. I have spoken to CL&P, CT DEP and the EPA. To all those who are concerned about the EPA restrictions; I have 1 question, who of you have actually read the text? I have read the text in full several times and to me the answer is clear. It seems clear that some who would benefit (dealers) are making it seem that all of the sudden the EPA is gunning for “lister types” are you kidding me? Take a step back and think about what the role of the EPA is. Do you really think that they are going to expend resources to stop an 800lb 6 hp diesel engine from clearing a US port? If there is anyone here who is concerned about importing an engine, let me know I will buy it for you. I will charge you my cost plus $200.00 Get me a quote from any manufacturer and I will do the leg work. You do not need a dealer to deal with EPA, you need a dealer to act as a buffer between you and some Indian exporter who will never sell you anything again. You need their clout. I have spoken to a few manufacturers in India, and guess what??? You get what you pay for.
The following is the response fromthe EPA to my e-mail, at bottom/
Scott,
Here are the regulations for stationary engines.
Stationary engine.
The engine must be used for a stationary
purpose and remain at a single
site at a building, structure, facility or
installation for more than 12
consecutive months throughout its lifetime,
or at a seasonal source
during its full annual operating period (see
the definition of “nonroad
engine” in 40 CFR 1068.30, 89.2 or 90.3 ).
Starting January 1, 2004
for spark-ignition engines above 19 kW and
January 1, 2006 for all
compression-ignition engines, the engine
must be labeled (see 40 CFR
1039.20 or 1048.20 ). Penalties: Any person
who circumvents or
attempts to circumvent residence-time
requirements for stationary
engines may be fined up to $32,500 per day
of violation ( 40 CFR
1068.101(b)(3), 89.1106(a)(5), 90.1006(a)(5)
). NOTE: Stationary
engines may be subject to state or local
regulations.
1068.30
iii) The engine otherwise included in paragraph (1)(iii) of this
definition remains or will remain at a location for more than 12… consecutive months or a shorter period of time for an engine located at
a seasonal source. A location is any single site at a building,
structure, facility, or installation. Any engine (or engines) that
replaces an engine at a location and that is intended to perform the
same or similar function as the engine replaced will be included in
calculating the consecutive time period. An engine located at a seasonal
source is an engine that remains at a seasonal source during the full
annual operating period of the seasonal source. A seasonal source is a
stationary source that remains in a single location on a permanent basis
(i.e., at least two years) and that operates at that single location…. My guess is that 95 % of the people who read this post will never bother to read this far into the text. Please prove me wrong…
approximately three months (or more) each year. This paragraph (2)(iii)
does not apply to an engine after the engine is removed from the
location.
§ 1039.20 What requirements from this part apply to excluded
stationary engines?
The provisions of this section apply for engines built on or after
January 1, 2006.
(a) You must add a permanent label or tag to each new engine you produce
or import that is excluded under §1039.1(c) as a stationary engine. To
meet labeling requirements, you must do the following things:
(1) Attach the label or tag in one piece so no one can remove it without
destroying or defacing it.
(2) Secure it to a part of the engine needed for normal operation and
not normally requiring replacement.
(3) Make sure it is durable and readable for the engine's entire life.
(4) Write it in English.
(5) Follow the requirements in §1039.135(g) regarding duplicate labels
if the engine label is obscured in the final installation.
(b) Engine labels or tags required under this section must have the
following information:
(1) Include the heading “EMISSION CONTROL INFORMATION”.
(2) Include your full corporate name and trademark. You may instead
include the full corporate name and trademark of another company you
choose to designate.
(3) State the engine displacement (in liters) and maximum engine power.
(4) State: “THIS ENGINE IS EXCLUDED FROM THE REQUIREMENTS OF 40 CFR PART
1039 AS A “STATIONARY ENGINE.” INSTALLING OR USING THIS ENGINE IN ANY
OTHER APPLICATION MAY BE A VIOLATION OF FEDERAL LAW SUBJECT TO CIVIL
PENALTY.”.
1039.1(c)
(c) The definition of nonroad engine in 40 CFR 1068.30 excludes certain
engines used in stationary applications. These engines are not required
to comply with this part, except for the requirements in §1039.20. In
addition, the prohibitions in 40 CFR 1068.101 restrict the use of
stationary engines for nonstationary purposes.
§ 1048.20 What requirements from this part apply to my excluded
engines?
(a) Engine manufacturers producing an engine excluded under §1048.5(d)
must add a permanent label or tag identifying each engine. This applies
equally to importers. To meet labeling requirements, you must do the
following things:
(1) Attach the label or tag in one piece so no one can remove it without
destroying or defacing it.
(2) Make sure it is durable and readable for the engine's entire life.
(3) Secure it to a part of the engine needed for normal operation and
not normally requiring replacement.
(4) Write it in block letters in English.
(5) Instruct equipment manufacturers that they must place a duplicate
label as described in 40 CFR 1068.105 if they obscure the engine's
label.
(b) Engine labels or tags required under this section must have the
following information:
(1) Include the heading “Emission Control Information”.
(2) Include your full corporate name and trademark.
(3) State the engine displacement (in liters) and maximum brake power.
(4) State: “THIS ENGINE IS EXCLUDED FROM THE REQUIREMENTS OF 40 CFR PART
1048 AS A “STATIONARY ENGINE.” INSTALLING OR USING THIS ENGINE IN ANY
OTHER APPLICATION MAY BE A VIOLATION OF FEDERAL LAW SUBJECT TO CIVIL
PENALTY.”.
1048.5(d)
(d) As defined in §1048.801, stationary engines are not required to
comply with this part (because they are not nonroad engines), except
that you must meet the requirements in §1048.20. In addition, the
prohibitions in 40 CFR 1068.101 restrict the use of stationary engines
for non-stationary purposes.
Penalties:
1068.101(b)(3)
(b) The following prohibitions apply to everyone with respect to the
engines to which this part applies:
(3) Stationary engines. For an engine that is excluded from any
requirements of this chapter because it is a stationary engine, you may
not move it or install it in any mobile equipment, except as allowed by
the provisions of this chapter. You may not circumvent or attempt to
circumvent the residence-time requirements of paragraph (2)(iii) of the
nonroad engine definition in §1068.30. We may assess a civil penalty up
to $31,500 for each day you are in violation.
89.1006(a)(5)
(a) Violations. A violation of the requirements of this subpart is a
violation of the applicable provisions of the Act, including sections
213(d) and 203, and is subject to the penalty provisions thereunder.
(5) A person who violates §89.1003(a)(2) or (a)(5) is subject to a
civil penalty of not more than $25,000 per day of violation.
.1006(a)(5)
(a) Violations. A violation of the requirements of this subpart is a
violation of the applicable provisions of the Act and is subject to the
penalty provisions thereunder.
(5) A person who violates §90.1003(a)(2) or (a)(6) is subject to a civil
penalty of not more than $25,000 per day of violation.
(See attached file: Regulations for Stationary and Mobile Engines.pdf)
David C. Hurlin ________________________
EPA Imports Line
Compliance & Innovative Strategies Division
Light Duty Vehicle Programs
Imports Group
Managed by EG&G Technical Services
Phone: (734) 214-4100
Fax: (734) 214-4676
2000 Traverwood Drive
Ann Arbor, MI 48105
Hello
I would like to get the opinion of the EPA regarding the legality of
importing the following diesel engine. The engine in question is a
"lister type" slow speed diesel consisting of either 1 or 2 cylinders
ranging from 6 -25 hp.
Link:
http://www.poweranand.com/diesel_engine.htmThese engines weigh anywhere from 750-1500 lbs, they are intended for
stationary use only. The main use is for electricity production.
As I understand current regulations this type engine should be allowed
under the following circumstance: Stationary use box # 20 on the
following form:
Link:
http://www.epa.gov/otaq/imports/forms/3520-21.pdfI have been told that any engine produced after April 1 2006 will not be
allowed to use the above exception. Is that correct?
Please let me know
Scott