First Name | Bryn |
---|---|
Last Name | Burke |
Email Address | bryn@vertical-constructors.com |
Affiliation | |
Subject | Comments to Verification Procedures Regulation (verdev2012). |
Comment | August 20, 2012 Clerk of the Board, Air Resources Board 1001 I Street, Sacramento, California 95814 Subject: Comments to Verification Procedures Regulation (verdev2012). Dear ARB: As you are aware, the combined requirements of the On-Road Rule and Off-Road Rule will soon require that all mobile cranes operating in normal service throughout California be retrofitted with verified diesel emission control systems (VDECS) in the very near future. As the deadlines approach, and the state’s crane owners begin to undertake VDECSs retrofits, several serious safety and feasibility issues have surfaced. We have brought these issues to the attention of the Mobile Source Control Division, and are pleased to report that they have been very responsive to these issues and are in the process of exploring them first hand. Therefore, we wish to use the current rulemaking to provide an update of the current issues we believe to remain with regard to VDECS installations on mobile cranes. • Cranes do little lifting and a lot of holding, idling, and sitting. We have provided staff with documentation from engine manufactures that shows in our application the cranes and trucks never get hot enough to meet minimum temperature requirements. We have likewise made several cranes available for exhaust temperature mapping to illustrate this point. • In addition to engine exhaust temperature, there is the issue of safety regarding the active VDECS. If there is a load on the hook, OSHA regulations require that the engine remain on for safety reasons. The exhaust temperature of a passive VDECS cannot be maintained in idle, and that a shutdown (including an automatic shutdown) required by an active VDECS is not feasible. • The crane body itself, i.e., the structural build, is engineered and in “ANSI & ASME Code Compliance” as a lifting machine, not a driving vehicle. As discussed, the total weight and the “Center of Gravity” is what makes the crane, a crane. To our knowledge and from our experience thus far, we have yet been able to get a manufacture to approve and/or certify a repower or retrofit, as is required by California and federal OSHA regulations. • The crane owners believe that the manufacturers’ reluctance to approve VDECS retrofits is directly related to the weight of the engine and where they put the engine in the crane. Different models of cranes, even if they are from the same manufacturer, make each engine in a different configuration, compacting and lightening it as much as possible. Adding weight will require the manufactures to confirm and re-certify their load charts. For cranes that have been working for years and/or are no longer manufactured, no crane manufacturer is willing to do this. If we change anything on the crane that is not a factory supplied or approved aftermarket parts with a part number, that alters the structural integrity of the crane, it voids all charts and certifications and therefore no longer meets ANSI standards and we will be operating outside of OSHA regulations. The crane will not pass certification and we have no protection against any failure. • The crane owners note that the verifying Executive Orders for passive VDECS are being issued with the following standard condition: “The engine must not be in an auxiliary power unit for on-road trucks, transport refrigeration unit, gantry crane, stationary application, marine vessel, or locomotive” [Emphasis Added]. We believe that the same feasibility issues applicable to gantry cranes also apply to mobile cranes (and to an even greater degree). Likewise we believe that due to the difference in lift patterns and lift duration, the same feasibility issues preclude the installation of active systems on mobile cranes.” Again, we appreciate your time in noting the unique challenges that face our industry and would like to thank staff for their willingness to explore these issues further. Kind regards, Bryn Burke on behalf of the Mobile Crane Operators Group |
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Date and Time Comment Was Submitted | 2012-08-20 09:15:12 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.