Advisory Number: YASA2012-001–M Yanmar Marine New

Advisory Number: YASA2012-001–M
THIS ADVISORY APPLIES TO:
DATE:
TO:
SUBJECT:
MODEL(S):
Construction
Industrial
Marine
January 31, 2012
All USA Marine Distributors & Dealers
EPA Non-Compliant Engine Replacement
All 4LHA, 6LY2A, 6CXM and 6LPA-STP2 (Tier 2)
Yanmar Marine New Replacement Engines for EPA Non-Compliant
As you already know, Yanmar Marine discontinued the sale of 4LHA, 6LYA, 6LY2A, and 6CXM
engines in the U.S.A market in 2006 and 2007 calendar year, because these engines were not compliant
to EPA Tier 2 Emission Standards mandated at that time. Today, Yanmar Marine is adding another
engine to the list, because the 6LPA-STP2 (Tier 2) engine does not comply with the upcoming Tier 3
Emission Standards which started 1/1/2012. However, EPA Marine regulations allows Yanmar
Marine to supply new replacement engines to boats/vessels owners once it has been determined that
there is no engine produced and available which is certified to the standards outlined in 40 CFR Part 94
and 40 CFR Part 1042 with the appropriate physical or performance characteristics to repower the
existing marine vessels. Each new replacement engine will be labeled and identified as such according to
the requirements outlined in 40 CFR Part 94.1103(b) (3) (iii) and (iv) and 40 CFR § 1042.615
Replacement Engine Exemption. Additionally, each new replacement engine will be identical in all
material respects to a certified configuration of the same or later model year as the engine being
replaced. Each new replacement engine will be labeled and identified as such according to the
requirements in 40 CFR Part 1068.240(b) (6) (i) and (ii).
This Marine Service Advisory follows the same procedure explained in the Marine Service Advisory
(MSA) 07-020 issued on August 16, 2007.
Repowering With a New Engine
Translating the above into Leman’s English, if a vessel owner is going to replace an existing engine
on an existing vessel with a new engine, then the new engine must comply with EPA Tier 3
standards that are in effect when the repower occurs. EPA provides a replacement exemption
which allows a vessel owner to replace an existing engine with a new uncertified engine or a new
engine certified to an earlier standard if it can be demonstrated that no new engine that is certified
to the emission limits in effect at that time is produced by any manufacturer with the appropriate
physical or performance characteristics needed to repower the vessel. In other words, if a new
certified engine is not available, an engine manufacturer in this case Yanmar Marine may produce a
replacement engine that does not meet all of the requirements of our marine emission-control
program.
YASA2012-001
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January 31, 2012
For instance, if a vessel has twin uncertified engines and it becomes necessary to replace one of them,
the vessel owner can request approval for an engine manufacturer to produce a new uncertified
engine if it can be demonstrated without any doubt that the vessel will not function properly if the
engines are not identically matched. There are other instances where there no other engines
manufactured that can be used.
However, there are certain conditions for this exemption. The replacement engine must meet
standards at least as stringent as those of the original engine. Therefore, for example, if the original
engine is a pre-Tier 1 engine, then the replacement engine need not meet emission limits. If it is a Tier
1 engine, it need not meet the Tier 2 limits if those are the limits in place when the replacement occurs.
Another condition that must be considered, in twin or triple engine applications, is the engine(s) that is
not being replaced must have a substantial amount of expected useful life left. If the engine(s) is at or
near the end of its expected useful life then all engines will need to be replaced with EPA compliant
engines. These conditions will be examined on a case by case basis by Yanmar Sales Department
and Customer Support Department team members when an application is submitted by Yanmar’s
distributors and/or customers.
Also as a condition for the exemption, the engine manufacturer must take possession of the original
engine or make sure it is destroyed. In addition, the replacement engine must be clearly labeled to
show that it does not comply with the standards and that sale or installation of the engine for any
purpose other than as a replacement engine is a violation of federal law and subject to civil penalty.
Through the Technical Amendments Package, the EPA now allows manufacturer determination that no
compliant engine can be used for a replacement engine, provided that certain conditions are met.
First, the manufacturer must determine that no certified engine is available (see attachment ‘B’),
either from its own product lineup or that of the manufacturer of the original engine (if different). In
cases where a vessel owner simply wants to replace an engine (a non-catastrophic failure) with a
new version of the same engine as part of a vessel overhaul for example, it will still be necessary to
obtain Administrator (EPA) approval before the replacement. Second, the engine manufacturer must
document the reasons why an engine of a newer tier is not usable, and this report must be made
available to the EPA upon request. Finally, no other significant modifications to the vessel can be
made as part of the process of replacing the engine, or for a period of 6 months thereafter.
Repowering With a (Yanmar Remanufactured) Engine (not available at this time)
In the near future if a vessel owner replaces an existing engine with a (Yanmar remanufactured)
engine, the replacement engine that goes through a remanufacturing process must be certified to the
model year that it was produced. Any rebuild to an engine (or work that is not remanufacturing) still
requires the engine to maintain its certification standard of the model year it was originally
produced to.
Disposal of the Replaced Engine
The current regulations require the engine manufacturer to take possession of the engine that is
replaced or have a process in place to verify the engine was destroyed in the field. At this time,
Yanmar America chooses to have the cores destroyed with proof of destructions sent to
Yanmar.
YASA2012-001
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January 31, 2012
Ordering New Replacement Engines
At time of ordering non-EPA engines, Yanmar America Cooperation Sales and Customer Support
Department will gather all information on engine being replaced. ‘Export’ and ‘NSE’ from the
distributor on each engine ordered. (See order form attached)
Replacement Inquiry and Disposal of the Replacement Engine
Before engines are replaced, Yanmar America Cooperation will require information for each engine
using the report form (‘A’) attached. After information is reviewed and authorized by the Customer
Support Department Yanmar will require the following items listed in the report: 1) New engine
information 2) Disposal engine information 3) Engine model name plate 4) Picture of the drilled
cylinder block. An agreement will then be made with Yanmar America Cooperation and the distributor.
If you have any questions regarding this advisory please contact Yanmar America Manager of Customer
Support at (770) 877- 9894.
YASA2012-001
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January 31, 2012
New Marine Replacement Engine Order Form
The new replacement engine must be the same emissions certification or later model year as the engine
being replaced.
- The new replacement engine can only be installed into the marine vessel that contains the
original engine being replaced.
- Modifications to any engine emission control system including but not limited to the: air
system, fuel system and electronic controls is strictly prohibited.
- The new replacement engine must be maintained and operated according to the Yanmar
approved Operation Manual provided with each unit.
Fill in all information requested on this form:
Distributor Name:
__________________________________________________________________
1.
2.
Distributor Representative Name
Print: ___________________________________________________________________
Signature: ________________________________________________________________
3.
If for stock order, (Yes) or (No) : ____________________
4.
P.O. Number from distributor : ____________________
5.
Model Name and Unit number
Model number : ____________________ Unit number : ____________________
6.
Purpose (Please select among them)
6-1 Replacement
6-2 NSE
6-3 Export
7. Vessel
Owner’s Name:
_____________________________________________________________________
Vessel Manufacturer and HIN:
__________________________________________________________________
8.
Engine model and Serial Number(s):
_____________________________________________________________________
9.
YASA2012-001
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January 31, 2012
In-Service Date:
_____________________________________________________________________
10.
Failure Date and Detail Description:
__________________________________________________________________________
__________________________________________________________________________
___________________________________________
11.
12.
Total Running Hours on Failed Engine(s):
________________________________________________________________
13. Reason
for Request of EPA Non-Compliant Engine as Replacement Engine:
_____________________________________________________________________________
_____________________________________________________________________________
_____________________________________________________________________________
______
Attach photos of failed engine(s) along with specific remarks/notes: Please use attachment
form below.
14.
Received and accepted at Yanmar by:
____________________________________________________
Date: _______________________________________________
THE INFORMATION IN THIS DOCUMENT IS CONFIDENTIAL AND PROTECTED BY COPYRIGHT AND IS THE PROPERTY OF
YANMAR AMERICA CORPORATION.
This document is provided for the sole and exclusive use of the original recipient as prescribed by Yanmar America Corp and may not
be distributed or copied, digitally or otherwise, without the prior written consent of Yanmar America Corp.
101 International Pkwy. Adairsville, GA 30103 U.S.A.
Telephone 770-877-9894 FAX 770-877-9009
http://www.yanmar.com
YASA2012-001
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January 31, 2012
A
Original Engine Disposition Form - Destruction
submittance date : ___________________
Distributor name. : _________________
Dist representative name : ___________________
1. Original engine information (Being replaced engine)
print name
Model name : ________________________
Claim No. : _____________
( if you have )
Serial No. : __________________________
2. The replacement engine information
Model name : ________________________
Serial No. : __________________________
3. Reason for need non-EPA replacement engine
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
4 The new replacement engine shipment date from distributor :______________________
5 Application information (replacement engine installation information)
Vessel Model name : ________________________
Vessel Serial No. : __________________________
6. Visual evidence (image file) of destruction of the original being replaced
(1) The disposition date of the original engine being replaced :_______________
(2) The condition of the cylinder block
(after making a hole)
(3) Engine Name Plate
Dist representative signature : ___________________
B
Replacement engine list
Replacement model
Engine model
Regulation
EPA
RCD
IMO
Tier 1 (EPA, GL)
Tier 2 (GL)
6LY2-STE
STE was discontinued and can not be built. Output difference is only 5% up(rpm
6LY2A-STE
is same). Alternative model does not exist except for STP, including
competitors' model. All model meets IMO Tier1and STP meets IMO Tier2.
6LY2A-STP
X
X
X
X
X
Stage 1
6LP-DTE
6LPA-DTE
6LPA-DTP
6CXM-GTE
X
X
X
X
X
X
Stage 1
Stage 1
6CXM-GTE2
X
Stage 1
Tier 1 (EPA)
X
4LHA-DTP
X
Stage 1
X
4LHA-STP
X
Stage 1
Tier 1 (EPA, GL)
Tier 2 (GL)
6LYA-STP
6LY2A-STP
X
X
Stage 1
Stage 1
4LHA-STP
X
Stage 1
6CXBM-GT (S)
X
X
Remark
(1) X: Not applicable
(2) NK is not included in IMO.
Regulation
6LY-STE
STE was discontinued and can not be built. Output difference is only 5% up(rpm
6LYA-STE
is same). Alternative model does not exist except for STP, including
competitors' model. All model meets IMO Tier1and STP meets IMO Tier2.
6LYA-STP
Stage 1
Stage 1
Engine model
Tier 1 (EPA, GL)
Tier 2 (GL)
X
Tier 2
Selection reason of Replacement engine
IMO
X
X
X
X
X
X
Tier 1 (EPA, GL)
Tier 1(EPA, GL)
Tier 1(EPA, GL)
Tier 2 (GL)
Tier 1 (EPA, GL)
X
Tier 1 (EPA, GL)
Tier 1 (EPA, GL)
Tier 2 (EPA, GL)
Tier 1 (EPA)
Tier 1 (EPA, GL)
Tier 1 (EPA, GL)
Tier 2 (GL)
Tier 1 (EPA)
Tier 1 (GL)
Tier 1 (EPA, GL)
Tier 2 (GL)
Tier 1 (EPA)
X
Tier 1 (EPA)
Tier 1 (EPA)
4LHA-HTP
6LPA-STP2
being replaced engine model
Tier 1 (EPA, GL)
Tier 2 (EPA, GL)
EPA
X
X
X
X
X
X
X
X
RCD
X
X
Stage 1
X
X
Stage 1
X
X
X
Stage 1
6LP-STE
6LPA-STE
6LPA-STP
X
X
X
X
X
Stage 1
6LPA-STP2
Tier 2
Stage 1
X
X
X
X
X
Stage 1
4LH-HTE
4LHA-HTE
4LHA-HTP
4LH-DTE
4LHA-DTE
4LHA-DTP
4LH-STE
STE was discontinued and can not be built. Output difference is only 5% up(rpm
4LHA-STE
is same). Alternative model does not exist except for STP, including
competitors' model. All model meets IMO Tier1and STP meets IMO Tier2.
4LHA-STP
HTE was discontinued and can not be built. Output difference is only 5% up(rpm
is same). Alternative model does not exist except for HTP, including
competitors' model.
DTE was discontinued and can not be built. Output difference is only 5% up(rpm
is same). Alternative model does not exist except for DTP, including
competitors' model.
STE and STP were discontinued and can not be built.
Alternative model does not exist except for STP2, including competitors' model.
Tier 1 (EPA, GL)
Tier 2 (GL)
Alternative model does not exist except for 4LHA-STP, including competitors'
model.
Output is almost same.
Tier 2 (GL)
GTE and GTE2 were discontinued and can not be built.
Output difference is within 10%.