EMD/Progress Rail SD70Ace tier 3 1010

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EMD/Progress Rail SD70Ace tier 3 1010
Posted by Michigan on Friday, November 03, 2017 9:02 AM

Dose anyone think that EMD/Progress rail will build a SD70Ace with the Tier 3 1010 motor without all the emissions crap now that Trump has relaxed the emission standard in the country?

Ed

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Posted by Overmod on Friday, November 03, 2017 9:43 AM

Let me respond to your question with a question: does anyone think Progress would go to the time and trouble of DFMing a 1010-based design like that when the Trump administration might not persist past, effectively, 2020?

I, personally, think the ‘sense’ would be to rationalize NO emission standards for locomotives, particularly in light of the present disconnect in classical atmospheric conversion of combustion NO to NO2 ... but since the very first effect of this would likely be to allow legal use of 710 engine architecture, it is little if any help toward introducing the 1010 domestically.

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Posted by Michigan on Friday, November 03, 2017 10:09 AM

I beleve the 1010J 12 cylinder is the future with the isolated prime mover, cab and other improvement. I would be testing this motor without the emissions equipment . do to slow sales of tier 4 units.

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Posted by erikem on Friday, November 03, 2017 10:30 AM

One very questionable assumption with respect to changes in emissions regulations is that the changes will not significantly affect sales. It isn't out of the question that dropping tier 4 regulations for a while and sticking with tier 3 may result in lower emissions as it would be more likely that the pre-tier 3 units would be replaced by tier 3 unts.

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Posted by VOLKER LANDWEHR on Friday, November 03, 2017 11:21 AM

Michigan
Dose anyone think that EMD/Progress rail will build a SD70Ace with the Tier 3 1010 motor without all the emissions crap now that Trump has relaxed the emission standard in the country?

Did I miss something? All I read here in Germany was that the Trump administration considered to relax the greenhouse gas emission standards for new cars.
Regards, Volker

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Posted by Entropy on Friday, November 03, 2017 12:13 PM

Michigan

Dose anyone think that EMD/Progress rail will build a SD70Ace with the Tier 3 1010 motor without all the emissions crap now that Trump has relaxed the emission standard in the country?

Ed

 

 

Emission standards are still Tier 4 for locomotoves. Its just Trump may have stalled CAFE regulation for a few years, which only applies to automotive.

Funny I was recently thinking about this, if the UP Tier 4 credit loco's are any indication, I dont foresee enough demand to create a Tier 3 version of the "T4 ACe", its not as easy as taking the "emissions crap" off as you call it. You would have to certify it to Tier 3, develop tier 3 parts, Progress already has a Tier 3 loco with 710, work was already done.

 

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Posted by Overmod on Friday, November 03, 2017 12:58 PM

Entropy, I had the same evil worry about the government minions requiring essentially ‘de novo’ documentation from a Tier 3 version of an accepted Tier 4 design.  As erikem said, there is overall “benefit” (by government-official standards) if older and lower-tier units are preferentially retired in favor of new tier-3-compliant hp equivalent.  In addition to the adjustment of formal NO target level I mentioned, seems to me there should be legislation that (1) gives at least streamlined and perhaps largely pro forma review and approval to lower-tier versions of designs derived from proven higher-tier units and their test data; and (2) provides some real incentive (not just more annoying sticks and mandates) for railroads to retire ‘worse’ power in return for some calculated replacement basis of Tier 3, not higher, power.  I tremble to mention the ‘permanent prime-mover retirement‘ methods as used in Obama’s original new-car stimulus, but perhaps scrapping older blocks would be enough... 

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Posted by Michigan on Friday, November 03, 2017 1:08 PM

Dose Canada and Austraila have tier 4 regulations ? No.  just beleve that they should be doing some testing like higher milliage , lower emissions with the 1010J over the 710. "just spit balling here". Why so serious! lol

Ed

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Posted by Overmod on Friday, November 03, 2017 1:33 PM

Why just spitball when you can take up all the issues involved with just a bit more ‘spressin?Wink  

Yes, I would expect meaningful improvement in fuel economy for the 1010 family, and I think at least some testing of it ‘overseas’ has been done in detail; meanwhile there ought to be an enormous amount of data from the Chinese on the 265H, much of which should be applicable to the metric-disguised engine...

Here’s part of it, too: the 710 with at least one version of EGR-only came within something like 2/10 of a percent of meeting the nominal Tier 4 final NOx standard, and that was primarily due to emissions under stressful or transient conditions — there are people on list who might PM you specific information on ‘how close’ and where the specific performance-envelope issues were observed.  I don’t recall any ‘hard’ problem other than the artificially low NOx including ordinary particulates that EMD failed to address.

This does not bode well for plans to sell the 1010 overseas anywhere there are emissions standards even a trace lower than North American Tier 4; the 710 and existing approaches would work there.  So the engine needs to have proven better efficiency, reliability and durability, and perhaps lower perceived noise to become ‘better enough’ to be chosen under those circumstances.  Now come the concerns that the single medium-speed approach to large freight locomotives might be obsolescent in some places if the difficulties with the C175 or QSK engine families in that service get worked out...

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Posted by VOLKER LANDWEHR on Friday, November 03, 2017 4:40 PM

Overmod
Entropy, I had the same evil worry about the government minions requiring essentially ‘de novo’ documentation from a Tier 3 version of an accepted Tier 4 design.

If you take a 1010 Tier 4 and use it as Tier 3 there is no problem. But reducing the 1010 to Tier 3 standard means to take some Tier 4 measures off the engine. How do you make sure it reaches Tier 3? I think there has to be a certification.
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Posted by YoHo1975 on Friday, November 03, 2017 8:56 PM
And certification costs money and R&D time. If the standards are relaxed, then EMD could turn right back to the 710 at effectively zero cost and if the standards become something akin to Tier 3.5, then that work has already been done in the guise of UP9900 SD59MX. 1010 would no longer solve a problem. What reason other than Tier 4 is it the future?
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Posted by VOLKER LANDWEHR on Saturday, November 04, 2017 3:53 AM

I think you are right, EMD would go back to the 710. A 80 year old design gets to its limits some day and that has happened with Tier 4 regulation. Using it again would be a bad move as it furthers the advantage of GE. When Tier 4 would return and I think it would, EMD has the 1010 but GE has refined the GEVO in the meantime.
Regards, Volker

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Posted by beaulieu on Saturday, November 04, 2017 6:20 PM

Michigan

Dose Canada and Austraila have tier 4 regulations ? No.  just beleve that they should be doing some testing like higher milliage , lower emissions with the 1010J over the 710. 

Ed 

 

Canada does not have Locomotive emissions regulations like the US. What Canada does have is a binding agreement between CP and CN with the Canadian Government that the two companies will only buy new locomotives that meet the US regulations in effect at the time of their manufacture. So both CP and CN have Tier 3 locomotives, while CN has Tier 4 Credit and Tier 4 locomotives. CP has not bought any all new locomotives since Tier 4 went into effect.

CN did buy 25 Tier 3 ES44AC locomotives after Tier 4 went into effect, and those locomotives are banned from operation in the US. They are kept in a captive pool on the former British Columbia Railway to avoid them accidently wandering into the US. I don't know how that works with the agreement with the Canadian Goverment.

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Posted by YoHo1975 on Saturday, November 04, 2017 11:03 PM

VOLKER LANDWEHR

I think you are right, EMD would go back to the 710. A 80 year old design gets to its limits some day and that has happened with Tier 4 regulation. Using it again would be a bad move as it furthers the advantage of GE. When Tier 4 would return and I think it would, EMD has the 1010 but GE has refined the GEVO in the meantime.
Regards, Volker

 

 

That's a little unfair to the 710 Engine design and I think a little overly Rosey on the GEVO. As has been discussed in here before, the GEVO engine and the T4 GEVO engine are not the same motors. GE would have every incentive to go back to their previous engine too. For the fuel economy if nothing else. And as pointed out, it's not like either the 710 or the T2-T3 GEVO was stagnant. Plenty of Engineering work could be done.

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Posted by VOLKER LANDWEHR on Sunday, November 05, 2017 9:51 AM

YoHo1975
That's a little unfair to the 710 Engine design and I think a little overly Rosey on the GEVO.

Could you explain why it is unfair, please?

EMC once choose the two-stroke design as it promised the lowest weight per horsepower ratio. Later it was developed for higher horsepower and then fuel economy. The 710's underlying design is nevertheless approximately 80 years old.

GE realized that it would be possible to make the FDL Tier 2 compliant but at the cost of fuel economy and not much development potential for further emission stages. So they developed an engine with the focus on emission reduction and fuel efficiency.

I think that tells themain differences.

The Gevo Tier 4 has development potential for stricter standards, the 710 not.

EMD didn't switch to a four-stroke design because it was impossible to get the 710 Tier 4 compliant. It was impractical loosing too much fuel economy.

When EMD decided to try the 710 for Tier 4 they lacked the money to develop a new engine other as GE. With Caterpillar as new owner that changed that and might have influenced the decision for the 1010.

I haven't found a discussion of the two GEVOs. What I remember, the GEVO Tier 4 has EGR, two instead of one turbocharger (12 cylinder), higher firing pressure, and better computer engine control.
Regards, Volker

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Posted by Entropy on Sunday, November 05, 2017 10:31 AM

YoHo1975
And certification costs money and R&D time. If the standards are relaxed, then EMD could turn right back to the 710 at effectively zero cost and if the standards become something akin to Tier 3.5, then that work has already been done in the guise of UP9900 SD59MX. 1010 would no longer solve a problem. What reason other than Tier 4 is it the future?
 

Completely disregard the thought or idea of emissions standards being changed from Tier 4, its not even worth the discussion. Even with the changes in the EPA, I don't see them putting effort into revising non road Tier 4 standards. Cars and Trucks maybe, they're much large focus of the EPA. If anything I would expect non road Tier 5 to be indefinatly delayed.

If i'm wrong feel free to one day say "I told you so".

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Posted by Entropy on Sunday, November 05, 2017 10:46 AM

Overmod

Entropy, I had the same evil worry about the government minions requiring essentially ‘de novo’ documentation from a Tier 3 version of an accepted Tier 4 design.  As erikem said, there is overall “benefit” (by government-official standards) if older and lower-tier units are preferentially retired in favor of new tier-3-compliant hp equivalent.  In addition to the adjustment of formal NO target level I mentioned, seems to me there should be legislation that (1) gives at least streamlined and perhaps largely pro forma review and approval to lower-tier versions of designs derived from proven higher-tier units and their test data; and (2) provides some real incentive (not just more annoying sticks and mandates) for railroads to retire ‘worse’ power in return for some calculated replacement basis of Tier 3, not higher, power.  I tremble to mention the ‘permanent prime-mover retirement‘ methods as used in Obama’s original new-car stimulus, but perhaps scrapping older blocks would be enough... 

 

Interesting never thought of it that way, retire say -8's and 60's for Tier 3 versions from either manufacture, as a credit unit, I think theres some merit to that idea. I don't see much effort coming from Washington on that. 

One aspect though, the emissions standards for repower, for line haul or transit locomotives 1973+ only option is Tier 4 or overhaul to Tier 0+. Theres large ground between the two. Switch Cycle repower has to be Tier 3 or overhaul Tier 0+, what if you have a 4 axle switcher Tier 0, you want to upgrade, say 8-710 engine, but you can't go Tier 1 repower, either Tier 0+ or Tier 3. I think that needs to be looked at. 

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Posted by YoHo1975 on Sunday, November 05, 2017 10:49 AM

VOLKER LANDWEHR

 

When EMD decided to try the 710 for Tier 4 they lacked the money to develop a new engine other as GE. With Caterpillar as new owner that changed that and might have influenced the decision for the 1010.

EMD developed the engine in the 1990s. the 1010j is a 265H engine. It's a new engine in the same way that the 710 was a new engine and you just told me that that was developed 80 years ago. So by the same logic, the 1010j is the 265H engine. And it was in continuous production for export in the interveneing years AND went through Tier 4 test work in the lab. It may or may not have cost more to develop the 1010 than the 710, but you're misreading the tea leaves I think. EMD was behind GE by a lot. The 265H had a bad reputation in the US so switching to it was going to cost EMD good will it couldn't afford to loose. The 710 had a stellar reputation and tons of units in the field. Given their position, even at equal cost of investment, 710 makes much more sense. 

I haven't found a discussion of the two GEVOs. What I remember, the GEVO Tier 4 has EGR, two instead of one turbocharger (12 cylinder), higher firing pressure, and better computer engine control.
Regards, Volker

 

 

user M636 has stated as much multiple times. 

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Posted by Overmod on Sunday, November 05, 2017 11:26 AM

Entropy
Completely disregard the thought or idea of emissions standards being changed from Tier 4, its not even worth the discussion.

I find I actually disagree ... but in a highly qualified sense.  What I’m pushing for is very slight *revision* of the nominal Tier 4 final NO emission standard — justified, politically, by reference to concomitant Tier 4 reduction of photochemical adjuvants causing NO2 conversion in the atmosphere — by just that tenths-of-a-percent that allows the 710 to be built practically to pass.  Then make sure this level is preserved for as many applicable service classes as possible into Tier 5 and later when they come.

Then establish fast-track cert for ’newer’-Tier-compliant designs adapted for lower-Tier compliance - in the specific case of the 1010J at Tier 3, little more than submission of a pro forma request accompanied by verifiable (perhaps peer-reviewed) load cycle testing.  This would be the framework for design in setting up an incentive program to replace older power.  The Democratic Party approach, requiring fully ‘Tier 4 or the highway’ for anything new, but permitting rebuilds only if there is no improvement, has had just the predictable results that rational expectations would expect.

Perhaps the great pity is that railroads could ‘secretly’ modify engines for lower emissions, but not advertise it or even admit it to the FRA ... when no good deed goes unpunished, it’s a sign something needs to be fixed as opposed to having a fix put in.

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Posted by VOLKER LANDWEHR on Sunday, November 05, 2017 11:53 AM

YoHo1975
EMD developed the engine in the 1990s. the 1010j is a 265H engine.

YoHo1975
EMD developed the engine in the 1990s. the 1010j is a 265H engine.

The 1010J has the same bore and stroke but according to Railway Gazette International December 2015 "Tier 4 locomotive take to the tracks" EMD engineers deny that it is a retread of the 265H: https://web.archive.org/web/20160616053215/http://media.getransportation.com/sites/default/files/RGI-Dec-00-15-p28-31.pdf

I think it was posted before but the old link is broken. I think EMD has learned from the 265H as GE hs from the HDL. So you are right both date back to the mid 1990s.

The same article states: EMD successfully got the 710 engine up to Tier 4 requirements. But while the tests were successful, the resulting design was too heavy, too cumbersome and not cost competitive enough to be marketable. In particular, the fuel economy was worse than for Tier 3.
and:
Two years after the start of testing with the 710 engine, EMD’s new parent Caterpillar decided to rethink the quest for a Tier 4 engine.

Regards, Volker

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Posted by VOLKER LANDWEHR on Sunday, November 05, 2017 12:20 PM

Overmod
I find I actually disagree ... but in a highly qualified sense. What I’m pushing for is very slight *revision* of the nominal Tier 4 final NO emission standard — justified, politically, by reference to concomitant Tier 4 reduction of photochemical adjuvants causing NO2 conversion in the atmosphere — by just that tenths-of-a-percent that allows the 710 to be built practically to pass.

When you look at my previous post, the 710 could have been made Tier 4 compliant but EMD deemed it impractical.

Even if the Tier 4 regulations would be changed to let the 710 pass I think it wouldn't hold in court. For me that would look like preferential treatment of on competitor.

Giving incentives for rebuilds to lower standards than Tier 4 (which is required now) would be OK I think.
Regards, Volker

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Posted by Saturnalia on Sunday, November 05, 2017 12:54 PM

Why build a new Tier 3 unit when the SD70ACe (Tier 3) unit is as easy to make as pulling out the old blueprints and filing some new part orders? 

There's been some discussion about another round of "cash for clunkers" which might also apply to trucking, shipping, and railroads, potentially in the next few years. That would in theory get the railroads to retire a lot of their Dash8 types in favor of new Tier 4 or maybe, depending on the law, Tier 3 units. It's just political theory right now, but there's been some noise about encoraging the older non-emission-controlled stuff out of service without penalizing those who remain attached to them. Incentive to ditch, not penalty to keep. 

We shall see...but at this point, there's not much use in going back. Tier 4 has proven to eat slightly more fuel and be slightly less reliable, but no so terrible as to make them worse than the older units they're replacing - such as the Dash8s. Tier 3 appeared to be, with today's tech, the best "bang for your buck" in terms of fuel consumption and emissions, but the government will never actually care. 

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Posted by YoHo1975 on Sunday, November 05, 2017 6:35 PM
They don't even need to pull out the blueprints, they're still building them right now. You think those credit units were sitting in a warehouse?
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Posted by YoHo1975 on Sunday, November 05, 2017 6:45 PM

Overmod

 

 
Entropy
Completely disregard the thought or idea of emissions standards being changed from Tier 4, its not even worth the discussion.

 

I find I actually disagree ... but in a highly qualified sense.  What I’m pushing for is very slight *revision* of the nominal Tier 4 final NO emission standard — justified, politically, by reference to concomitant Tier 4 reduction of photochemical adjuvants causing NO2 conversion in the atmosphere — by just that tenths-of-a-percent that allows the 710 to be built practically to pass.  Then make sure this level is preserved for as many applicable service classes as possible into Tier 5 and later when they come.

Then establish fast-track cert for ’newer’-Tier-compliant designs adapted for lower-Tier compliance - in the specific case of the 1010J at Tier 3, little more than submission of a pro forma request accompanied by verifiable (perhaps peer-reviewed) load cycle testing.  This would be the framework for design in setting up an incentive program to replace older power.  The Democratic Party approach, requiring fully ‘Tier 4 or the highway’ for anything new, but permitting rebuilds only if there is no improvement, has had just the predictable results that rational expectations would expect.

Perhaps the great pity is that railroads could ‘secretly’ modify engines for lower emissions, but not advertise it or even admit it to the FRA ... when no good deed goes unpunished, it’s a sign something needs to be fixed as opposed to having a fix put in.

 

I agree with this.

The carrots and sticks of the policy are a little misaligned. 

 

One of the biggest (traditional) problems in politics regardless of which party is that there is often little incentive or desire to revisit or tweak a law that is functioning sub-optimally...often, because the other side profits by simply crying failure and sometimes, because politics isn't about science at the end of the day.

And lastly, sometimes the sociological best choice is not the political best choice.

So in this case, the practical on the ground understanding that the EPA created a situation where Locomotives emissions across the fleet are not as good as they could have been given different carrots and sticks are extremely difficult if not impossible to address. 

 

Volker, I think you're missing the point. Adjusting the rules MAY have helped EMD in the short term, but in theory it would have lead to more new loco sales overall.

Also, please recall, the issues that make Tier 4 impractical on the 710 are on the order of thenths of a percent.

An SD70ACe that is 90% of Tier 4 has acceptable Fuel economy and cost. They built a few test ones. It's getting it all the way to Tier 4 that doesn't quite work.

 

Also, Is the GEVO the HDL? Is the 710 the 645 the 567 the Winton 201? Is the new T4 Gevo the T2 Gevo?

Is there an objective measure you can point me to so I know what the minimum changes required are? Also, if the 265H is an unloved engine (and it was) and the 1010J is a next generation of that engine, what do you think EMD would be telling Railway Gazette about that engine? 

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Posted by Entropy on Sunday, November 05, 2017 8:55 PM

YoHo1975

 

 
VOLKER LANDWEHR

 

When EMD decided to try the 710 for Tier 4 they lacked the money to develop a new engine other as GE. With Caterpillar as new owner that changed that and might have influenced the decision for the 1010.

 

 

EMD developed the engine in the 1990s. the 1010j is a 265H engine. It's a new engine in the same way that the 710 was a new engine and you just told me that that was developed 80 years ago. So by the same logic, the 1010j is the 265H engine. And it was in continuous production for export in the interveneing years AND went through Tier 4 test work in the lab. It may or may not have cost more to develop the 1010 than the 710, but you're misreading the tea leaves I think. EMD was behind GE by a lot. The 265H had a bad reputation in the US so switching to it was going to cost EMD good will it couldn't afford to loose. The 710 had a stellar reputation and tons of units in the field. Given their position, even at equal cost of investment, 710 makes much more sense. 

 

 

I haven't found a discussion of the two GEVOs. What I remember, the GEVO Tier 4 has EGR, two instead of one turbocharger (12 cylinder), higher firing pressure, and better computer engine control.
Regards, Volker

 

 

 

 

user M636 has stated as much multiple times. 

 

The H engine started in 1984, then was 854H 854 ci per cylinder, when it came time for practical use the application became 6000hp increased the bore size to 265mm and 1010ci per cylinder.

I wouldnt call a 710 engine "80 years old", perhaps the architecture is but not the actual 710 crankcase ,turbocharger design, electrical unit injector design etc etc. Which btw are still being manufactured for anyone interested.

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Posted by VOLKER LANDWEHR on Monday, November 06, 2017 4:41 AM

YoHo1975
Volker, I think you're missing the point. Adjusting the rules MAY have helped EMD in the short term, but in theory it would have lead to more new loco sales overall. Also, please recall, the issues that make Tier 4 impractical on the 710 are on the order of thenths of a percent. An SD70ACe that is 90% of Tier 4 has acceptable Fuel economy and cost. They built a few test ones. It's getting it all the way to Tier 4 that doesn't quite work.

I don't think so. EMD admitted that they would have been able to get the 710 Tier 4 compliant but deemed it impractical for the reasons mentioned in the above linked article.

Lowering standards when compliant locomotives are already in production is not a good idea. OK EMD could fall back to the 710 but GE would have to stay with the GEVO-T4. That is what I called preferential treatment of a single competitor.

Even to reach 90% Tier 4 the EMD 710 would have needed at least EGR and a perhaps paticulate matter filters I think. According to the article EMD had testet the 710 for 3 g NOx from the off-road rule. When EPA came out with the final rule of 1.3 g they had to use more EGR and DPF. So they used EGR for the 3.0 g.

YoHo1975
Also, Is the GEVO the HDL? Is the 710 the 645 the 567 the Winton 201? Is the new T4 Gevo the T2 Gevo?

YoHo1975
Also, Is the GEVO the HDL? Is the 710 the 645 the 567 the Winton 201? Is the new T4 Gevo the T2 Gevo?

According to GE the Gevo is not the HDL but they used as a basis. Same for the 1010J and the 265H, EMD denies that the 1010 is a retread. The EMD engines you listed are different engines with same basic design fom the 1930s.

I think the Gevo-T4 is mostly like the Gevo-T2 with the changes I described in a former post.

The only objective test results I know of are UP 9900 a Tier 2 locomotive with added EGR, DOC, DPF that reached 3.387 g/bhp-hr instead of 1.3 for Tier 4:
https://www.arb.ca.gov/railyard/docs/final_report_emd_tier_4_pm_aftertreatment_upgrade_83112_final_v1.pdf
Regards, Volker

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Posted by M636C on Monday, November 06, 2017 6:57 AM

I think the Gevo-T4 is mostly like the Gevo-T2 with the changes I described in a former post.

The GEVO-T4 shares the same bore and stroke with earlier GEVO engines, but is an entirely different engine. The crankshaft is longer with larger bearing surfaces and as a result the crankcase is significantly longer so these major components are no longer interchangeable. There have been changes to the power assemblies, but I don't know if these are still interchangeable. The tier 4 GEVO engine weighs 8000 lbs more than the tier 3 engine. I think this information was in "Railway Age" about the time EMD announced the 1010 series and both new engines were being discussed.

Caterpillar are currently marketing the 710 as the E23 for marine use. It is available with aftertreatment to meet Tier 4 requirements. The aftertreatment is part of an integrated package with the aftertreatment equipment mounted above the auxiliary rack at the free end of the engine.

Both 12 and 16 cylinder versions are available. Since most recent passenger locomotives use aftertreatment, there would seem to be no reason not to use the Tier 4 710 in passenger locomotives.

Peter

 

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Posted by Shadow the Cats owner on Monday, November 06, 2017 7:24 AM

You run into size restrictions on a locomotive.  Beyond a certain size your getting to heavy on your axles and also long for the shops.  Everything you add to an engine adds weight and is something that needs to come off for repair and maintance at times.  Also at sea they have a huge advantage over locomotives when it comes to cooling capacity they are not restricted to the amount of water they can carry on board they have the entire waterway they are in to use to cool their onboard heat exchangers instead.  If you can eliminate the need to carry 30 tons of water around for cooling and their radiators and use the ocean to cool the engine instead your golden.

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Posted by Overmod on Monday, November 06, 2017 12:37 PM

The aftertreatment Peter describes packages relatively neatly in existing locomotives (I believe he can even provide pictures or diagrams that show this).  The system that was difficult to package was the 'all EGR' system for Tier 4 final on 710s that would not involve the use of DEF or other consumables -- that was the thing that was 'so close, yet so far' in meeting the standard.  I don't recall there was ever much difficulty, or much doubt, in getting the 710 successfully through Tier 4 final NOx cycle testing, if catalytic and DEF were used.

My argument about 'walking back' the NO standard despite its "helping a competitor" is largely based in the (to me, thoroughly equitable) notion that setting the arbitrary number just a smidge past what EMD happened to be able to do is the original "inequity" -- I think the dollar amount of this 'unfairness' is quite easily calculated over the last several years! -- and all we're discussing is relieving the existing unfairness.  Were the NO numbers scientifically chosen, or if there were indication that the lessening of photochemical adjuvants was not also considered when deciding on draconian reductions in NO combustion emissions, I might think closer to H. Landwehr's argument, but my research did not indicate that level of competence.

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Posted by Entropy on Monday, November 06, 2017 1:26 PM

GE Tier 4 engine is nothing close to previous tier levels design, has common rail injection, so fuel system and cylinder head is 100% new design. 

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