EPA Grants Relief for Diesel Engine Fire Trucks and Ambulances

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May 2012

The U.S. Environmental Protection Agency's (EPA) 2001 Final Rule on Control of Air Pollution from New Motor Vehicles: Heavy-Duty Engine and Vehicle Standards and Highway Diesel Fuel Sulfur Control Requirements mandated stricter requirements for diesel emissions to improve air quality in the United States. To meet the EPA emission standards, diesel apparatus produced after January 1, 2007, have modified engine designs and exhaust systems that have an after-treatment device (ATD) in place of the muffler and modified exhaust systems and tailpipes downstream from the ATD. This in-line regeneration system was designed to recycle and burn off pre-exhaust particulate. However, the current generation diesels must meet the 2010 EPA regulations, which require significant reduction - about 90 percent of oxides of nitrogen - which is accomplished through further catalysts and oxidation chambers, or regeneration of diesel particulate filters.

Under the 2010 regulations, the diesel engines were to be designed to maximize the use of passive regeneration. Such passive regeneration takes a minimum of 20 minutes driving at highway speeds. Even the most frequently used fire apparatus have duty and response cycles that are considered light, and because the trucks spend considerable time idling at fire and other emergencies, the conditions needed for passive regeneration are not likely. Therefore, these new trucks require frequent stationary regeneration, which typically needs to be completed at about 20 hours of run time. This requires the truck to be taken out of service for 20 to 40 minutes and placed outside since tailpipe exhaust temperatures have been reported as high as 1,200° Fahrenheit. Additionally, an idling diesel engine produces a tremendous amount of particulate matter, which in turn requires the ATD to regenerate more often than other diesel engine/ATD applications. While not designed to happen, once regeneration is needed, the diesel particulate filter light comes on, and the vehicle may shut down and only operate in one-minute increments. This shutdown has been reported to the IAFF by a number of affiliates. Some jurisdictions have also reported disabled auto-shutdown features.

Concerns regarding fire apparatus with ATDs caused the Florida Professional Firefighters, Hollywood, FL, Local 1375, Miami, FL, Local 587 and Boca Raton, FL, Local 1560 to submit Resolution 45 to the IAFF 2010 Convention in San Diego, California. The resolution required the IAFF to petition the EPA to have all fire apparatus exempt from this standard.

Finally, after much lobbying by the IAFF and other fire service organizations, the EPA has granted relief to fire and EMS departments. The EPA is proposing revisions that would allow manufacturers to request, and EPA to approve, modifications to emissions control systems on new and in-use emergency vehicles, including fire apparatus and ambulances, so they can be operated as intended, without reduced performance during emergency situations. For new engine or vehicle certifications, these improved controls or settings would generally be approved as auxiliary emission control devices (AECDs). For in-use engines and vehicles, the EPA is proposing to allow engine and vehicle manufacturers to submit requests for EPA approval of Emergency Vehicle Field Modifications.

The EPA is publishing the provisions for dedicated emergency vehicles in a Direct Final Rule. This means that the EPA is accepting comment on all parts of the rule, but emergency vehicle provisions that do not receive adverse comment will become final 60 days from publication in the Federal Register. The EPA will withdraw the parts of the Direct Final Rule that receive adverse comments, and respond to all comments as part of a final rule.

IAFF affiliates should work with their emergency vehicle suppliers and distributors to determine how their manufacturers plan to implement the changes necessary to make their vehicles safe and effective for fire service use.

Diesel exhaust particulates are classified as "reasonably anticipated to be a human carcinogen," meaning there is no allowable threshold exposure and diesel exhaust must be controlled to the lowest feasible level. Further, it has been well established that diesel fume exposures lead to respiratory and cardiovascular diseases. Therefore, diesel exhaust capturing systems will be required to reduce the health effect to fire fighters. Neither of the 2007 or 2010 EPA regulations eliminated the need for these systems and, of course, with the new EPA proposal these systems will still be required.

However, it may be necessary for departments using these systems to purchase an adapter for the EPA 2007/10-compliant apparatus to attach to the diesel exhaust capture devices. Contact your manufacture for a list of adapters that connect to their systems. Do not alter the exhaust pipe to attach to the diesel exhaust control device. Altering the exhaust pipe could negatively affect vehicle performance and could also negate vehicle warranty. Further, do not allow emergency vehicles to run through its regeneration cycle while attached to the diesel exhaust capture device. The extremely high temperatures of the regeneration process could destroy the diesel exhaust control device and potentially cause a fire.

Republished with permission of the International Association of Fire Fighters. View original article here.



Author:IAFF