Air National Guard Air Quality SME DAF, Air National Guard Readiness Center (ANGRC), MA
Abstract Description: Aircraft Arresting System (AAS) engines are utilized across several ANG installations. There are typically two different types, Wisconsin V465D and Duetz D 2011 L04I. While A4ICS preforms the mandatory 10-year overhaul of the units, due to their manufacturer age, the Wisconsin V465D engines are not equipped with a non-resettable hour meter, nor does A4ICS install the meter during overhaul. As a result, the regulatory compliance burden falls onto the Environmental Manager (EM) at the installation. Recent communication with EPA has verified that the Wisconsin V465D engines must follow 40 CFR Part 60 Subpart ZZZZ requirements, including the engine operating with a non-resettable hour meter.
Internal combustion engines are significantly regulated by the EPA under 40 CFR Part 60 Subparts ZZZZ, IIII, and JJJJ. The Wisconsin V465D engines utilize gasoline for operation and therefore are required to follow Subpart ZZZZ. In 2019 the EPA issued a Notice of Violation to an ANG installation for the Wisconsin V465D engine operating with a non-resettable hour meter. More recently, the EPA has inquired at several installations the verification of the use of a non-resettable hour meter for the affected engines.
Currently, 17 ANG installations operate a total of 72 Wisconsin V465D engines without a non-resettable hour meter. A significant portion of these units were manufactured in the 1980’s and are still in-use today.
Based on available data from the Air Program Information System (APIMS), most engines have or will be due for the 10-year overhaul by A4ICS. The overhaul process does not include the installation of a non-resettable runtime meter. However, A4ICS staff has confirmed that the install of a non-resettable hour meter does not meet the definition of a modification and can be completed at the installation by shop personnel. Furthermore, A4VN and A4CIS should coordinate a method for installations to procure the non-resettable hour meters for install.