Owners Manual: Flow Through Filter (FTF) System

PROVENTIA EMISSION CONTROL carb-verified, level 2+ tru Filter RETROFIT Owners Manual: Flow Through Filter (FTF) System Including Installation Guide for SB Model TRUs Proventia Americas, LLC c/o Proventia Group, Tietotie 1, FI-90460 Oulunsalo, Finland Tel. 800 609 4021 www.proventiafilters.com

2 contents OPERATION AND MAINTENANCE REQUIREMENTS Versión en español: www.proventiafilters.com/spanish CONTENTS Operators Information Operation and Maintenance Requirements... 2 Operators Pretrip Check... 3 Periodic Maintenance... 4 CARB Compliance Schedule... 4 Installer and Service Technician information Preinstallation Checks... 5 Installation... 8 Warranty Registration and Installer's Checklist...29 CARB Identification Number (IDN) Registration...29 Cleaning the FTF and Safe Ash-Handling Guidelines...29 Wiring Diagram for Backpressure Controller...30 Troubleshooting...31 Parts List...34 Warranty statements Warranty Statements...34 OPERATION AND MAINTENANCE REQUIREMENTS In order for the Proventia FTF system to meet the CARB Verification requirements, the Transport Refrigeration Unit (TRU) owner must meet these operation and maintenance requirements before installation: 1) TRU owner is responsible for checking engine backpressure level at every Preventive Maintenance Interval (PMI) to determine whether accumulated ash within the FTF needs to be cleaned out. With the TRU running at high speed, check the backpressure on the backpressure indicator gauge. 2) TRU owner is responsible for confirming normal oil consumption rate greater than 50 hours/quart of oil before installation of the Proventia FTF to ensure proper filter operation (a new engine gets about 120 hours/quart of oil). 3) Fuel requirement: Use only Ultra Low Sulfur Diesel (ULSD). In California, both On-road and Off-road diesel is ULSD. In the other 49 states, only On-road diesel is ULSD (In June 2010, Off-road diesel in the other 49 states will become ULSD). Use of higher sulfur diesel will clog FTF.

OPERATION AND MAINTENANCE OPERATORS PRETRIP CHECK 3 4) Mixing lube oil with fuel is not allowed because it will cause excessive ash accumulation in the filter. 5) Engine: This Proventia FTF kit is verified for use on SB model years 1985-2002. 6) Follow TRU engine maintenance schedule. 7) Recommended for maximum filter life, but not required, is to use TRU engine oil compatible with ULSD applications, such as PC-10 low sulfate ash oil. 8) TRU engine injectors must be replaced with new or remanufactured injectors at the time of FTF installation. 9) This Proventia FTF system can impose a backpressure of up to 2.5 psi on the TRU engine at low-speed operation. There is a possible fuel consumption penalty of less than 1% when running with the Proventia FTF. OPERATORS PRETRIP CHECK Inspect backpressure indicator gauge with the TRU operating at high speed. If yellow gauge line is within the red service range of the gauge (see photo at left), the FTF filter should be serviced (see page 32). Photo at right shows the yellow indicator in the green normal range.

4 PERIODIC MAINTENANCE COMPLIANCE SCHEDULE PERIODIC MAINTENANCE At the regular TRU Preventive Maintenance Interval, check the Proventia FTF system: 1) Check to see if TRU is being forced to high-speed operation frequently by the FTF backpressure controller (cycle would be repeating 10 minutes high speed and 5 minutes low speed). If so, this indicates that the filter may have an excessive accumulation of soot or ash. See troubleshooting on page 32. 2) Check to see if the yellow gauge line in the backpressure indicator gauge is within the red service range (shown in picture at left) while the TRU is running in highspeed mode. If so, this indicates that the filter may have an excessive accumulation of soot or ash. See troubleshooting on page 32. 3) If black smoke is visible during steady speed operation, see troubleshooting on page 33. CARB COMPLIANCE SCHEDULE Table shows compliance dates if Proventia FTF is installed. TRU Model Year TRU will be LETRU compliant until Total useful life of TRU 1985 December 31, 2015 30 years 1986 December 31, 2015 29 years 1987 December 31, 2015 28 years 1988 December 31, 2015 27 years 1989 December 31, 2015 26 years 1990 December 31, 2015 25 years 1991 December 31, 2015 24 years 1992 December 31, 2015 23 years 1993 December 31, 2015 22 years 1994 December 31, 2015 21 years 1995 December 31, 2015 20 years 1996 December 31, 2015 19 years 1997 December 31, 2015 18 years 1998 December 31, 2015 17 years 1999 December 31, 2015 16 years 2000 December 31, 2015 15 years 2001 December 31, 2015 14 years 2002 December 31, 2016 14 years

PREINSTALLATION CHECKS 5 PREINSTALLATION CHECKS Before installing the Proventia FTF system, the installer must confirm the oil consumption rate of the TRU engine and also replace the injectors. 1) Check the oil consumption rate using the following procedure (or confirm from recent TRU service records that oil consumption rate was at least 50 hours/qt): a. Add oil to the engine to the full mark on the dipstick. b. Record the engine hourmeter reading with engine oil at full: hours c. Run TRU for about 50 hours under normal operation. The TRU can be used on normal routes and deliveries. It is not necessary to remove the TRU from service during this oil consumption rate check. d. Again add oil to the engine to the full mark on the dipstick. e. If the engine used less than a quart (32 ounces) of oil in 50 hours, the oil consumption is okay. Proceed to number 2 (Replace injector assemblies). f. If the engine used more than a quart of oil in 50 hours, service the TRU engine per TRU manufacturer s guidelines to reduce the amount of oil the engine is burning before installing the Proventia FTF system. 2) Replace injector assemblies with new or remanufactured injectors available from www.proventiafilters.com. Remanufactured injectors should be set at 2,800 to 3,000 psi for Yanmar injectors and 2,633 to 2,704 psi for Isuzu injectors.

6 PREINSTALLATION CHECKS injector installation TOOLS: 17mm open-end wrench, 14 or 10mm deep socket wrench, injector removal tool PARTS: Isuzu or Yanmar injectors injectors and gaskets 1) Remove injector line from top of injector. Remove injector hold-down collar. (Isuzu, 14mm socket) 2) Remove injector line from top of injector. Remove injector hold-down collar. (Yanmar, 10mm socket) Yanmar injectors can be difficult to remove, due to corrosion. Running the Yanmar engine for 10 minutes to warm it up will make injector removal much easier. Isuzu injectors should be removed when the engine is cold.

PREINSTALLATION CHECKS 7 3) Loosely thread injector removal tool on top of injector. 4) Install injector removal tool tube, positioning the cutouts in the tube for the injector bleed line. Thread 1/2" nut onto injector removal tool until injector is lifted out of injector socket. If injector is difficult to remove due to rust, add liquid penetrant to loosen. Be careful not to damage metal injector bleed tubes, so that injector cores can be reused and remanufactured.

8 PREINSTALLATION CHECKS INSTALLATION 5) Install new o-ring and copper gasket with Isuzu injector. Put a spot of grease on the copper gasket to hold it in place during installation. Injector pressure spec is 2,633 to 2,704 psi. Torque injector stud nut to 27.5 ft-lb. INSTALLATION 2 hours installation time Installation video is available on the Web at www.proventiafilters.com/owners_manuals.html SAFETY PRECAUTIONS 1) Disconnect positive battery cable from battery to prevent TRU from starting during installation. 2) Do not touch hot exhaust components; make sure TRU exhaust system is at room temperature before installing Proventia FTF system. 3) Use safety glasses and make sure to have a safe work platform when installing the Proventia FTF system. 6) Install new nozzle protector and gasket with Yanmar injector. Injector pressure spec is 2,800 to 3,000 psi. Torque injector stud nuts to 12 ft-lb.

INSTALLATION 9 REMOVE MUFFLER TOOLS: 7/16, 1/2, and 9/16 socket wrenches, 9/16 box-end wrench PARTS: None 1) Remove and save the two bolts that hold the muffler onto the SB frame. Bolts will be reused for installing the FTF in place of the muffler. 2) Access the third mounting bolt, which has a nylock nut, by opening the side access panel.

10 INSTALLATION 3) Remove and save this nut and bolt for reuse. 4) Remove and discard exhaust clamp that connects muffler to upper exhaust tube. A new clamp to be used on the FTF is included in the FTF kit.

Installation 11 REMOVE UPPER EXHAUST TUBE TOOLS: 1/2 and 9/16 socket wrenches PARTS: None 5) Remove muffler. 1) Remove and discard exhaust clamp that connects the lower flexible exhaust tube to the upper exhaust tube. A new clamp to be used on the FTF is included in the kit.

12 INSTALLATION 2) Slide lower flexible exhaust tube out from upper exhaust tube. 3) Remove and save bolt holding upper exhaust tube to the SB frame.

Installation 13 4) Remove and discard the upper exhaust tube. INSTALL THE FTF TOOLS: 1/2 and 9/16 socket wrenches, 9/16 box-end wrench PARTS: FTF, R48 exhaust clamp 1) Put FTF on top of the SB unit, aligning the mounting bracket holes with the holes on the SB frame. Install one bolt through the FTF bracket and into top of SB frame.

14 INSTALLATION 2) Lower mounting bolts have nylock nuts, which are accessible by opening the side access panel. Install and tighten these bolts/nuts. 3) Install the new R48 exhaust clamp connecting the filter to the upper exhaust tube. Do not tighten yet. R48 UPPER R45 LOWER

Installation 15 4) Install exhaust outlet elbow with an R48 clamp. INSTALL NEW UPPER EXHAUST TUBE TOOLS: 1/2 and 9/16 socket wrenches PARTS: Upper exhaust tube, insulation sleeve for upper exhaust tube, R45 exhaust clamp 1) Slide insulation sleeve over upper exhaust tube. Slit in insulation sleeve should align with upper exhaust tube mounting bracket.

16 INSTALLATION 2) Install upper exhaust tube and mounting bolt. An alternate method is to loosely assemble upper exhaust tube onto FTF with R48 clamp and lower this assembly down into the TRU from above. After FTF is bolted down into position, tighten R48 clamp and upper exhaust tube mounting bolt. 3) Install the new R45 exhaust clamp connecting the upper exhaust tube to the flexible exhaust tube. 4) Slide flexible exhaust tube into the upper exhaust tube 1.5 to 2 inches. Tighten both upper and lower exhaust clamps. R48 UPPER R45 LOWER

Installation 17 For installation on Isuzu di2.2 engines with spiral wound exhaust tubing: 2) Relace the existing spiral wound tube with this assembly. 1) Relace the existing spiral wound tube with this assembly. Use Permatex Muffler & Tailpipe Sealer at joints.

18 INSTALLATION INSTALL BACKPRESSURE CONTROLLER TOOLS: Cordless drill with 3/8 nut driver, pliers, 7/16 and 1/2 open-end wrenches PARTS: Backpressure fitting, backpressure tube, controller assembly, P-clamp, self-tapping screws (5) 1) Install backpressure fitting into upper exhaust tube and tighten with 7/16" wrench. 2) Install backpressure tube into backpressure fitting and tighten compression nut with 1/2" wrench.

Installation 19 3) Install backpressure controller using 3/8" nut driver and four self-tapping screws. Controller should be mounted as high as possible on the SB bulkhead. 4) Connect silicone hose from controller to backpressure tube. Hose should have slight downward slope from controller to tube. Install hose clamp on end of hose.

20 INSTALLATION 5) Install P-clamp using self-tapping screw to protect hose from possible contact with fan belt. INSTALL INSULATION TOOLS: 13mm socket or box-end wrench PARTS: M8 x 1.25 x 20 metric bolts (3), 2 fender washers (3), insulation blanket with grommets, snap insulation 1) Wrap insulation blanket around flexible exhaust tube and upper exhaust tube. Snap insulation blanket shut.

Installation 21 2) Remove three bolts holding engine exhaust manifold heat shield onto back of engine. Discard metal heat shield and old bolts. 3) Install exhaust manifold insulation blanket using three new M8 x 1.25 x 20 metric bolts and 2 fender washers. There are five grommet holes in the blanket. These three holes are used on Isuzu engines:

22 INSTALLATION 4) These three holes are used on Yanmar engines: 5) Steel tie bands can be used as an alternative on Isuzu se2.2 engines.

Installation 23 6) Steel tie bands can be used as an alternative on Isuzu se2.2 engines. WIRING THE BACKPRESSURE CONTROLLER TOOLS: 3/8 nut driver, 12mm open-end wrench PARTS: Tie wraps WARNING: Disconnect positive battery cable from battery to prevent TRU from starting during installation. 1) Connect backpressure controller wire #2 to the battery cable stud on starter solenoid.

24 INSTALLATION 2) Connect #7D controller wire to the 7D terminal on speed solenoid. 3) Connect CH controller wire to CH terminal on speed solenoid. 4) Install diode assembly on 7D terminal of speed solenoid. 5) Remove Thermo King 7D wire from speed solenoid and cut off ring terminal. 6) Remove 1/4" of insulation from end of Thermo King 7D wire, insert wire into connector on diode assembly, and crimp connector onto Thermo King 7D wire. 7) Apply heat to heat shrink tubing to seal onto 7D wire. Diode assembly Proventia controller wires Thermo King harness wires CH and 7D

Installation 25 8) Use tie wraps to gather and route the backpressure controller wire harness. 9) WARNING: When routing the controller wire harness, make sure it does not touch any fuel lines.

26 INSTALLATION INSTALL LABELS TOOLS: Rag and degreaser PARTS: CARB VDECS label, ULSD fuel label 1) Remove CARB VDECS label, which is tie-wrapped in a plastic bag to the FTF. 2) Clean and degrease the engine surface before installing the label. Install label so it is visible to a CARB inspector when opening the TRU service doors.

Installation 27 3) Install the ULSD fuel label next to filler cap on TRU fuel tank. Clean and degrease the surface before installing the label. HOW BACKPRESSURE CONTROLLER WORKS The backpressure controller measures when there is too much soot accumulated inside the FTF during low-speed TRU operation. When the controller measures 2.5 psi backpressure, it will force the TRU to run in high speed by energizing the speed solenoid for 10 minutes by putting +12V at the 7D solenoid terminal. Operating at high speed will regenerate and reduce the soot accumulated inside the FTF. After 10 minutes at high speed, the controller will return the TRU to low-speed operation. After 5 minutes at lowspeed operation, if the controller again detects a 2.5 psi backpressure, it will energize the high-speed solenoid for another 10 minutes. The controller will repeat this sequence until the soot is sufficiently reduced inside the FTF. No operator intervention is required for controller to function properly.

28 INSTALLATION CHECK PROPER OPERATION OF BACKPRESSURE CONTROLLER AFTER COMPLETING INSTALLATION TOOLS: Pliers, pressurizer 1) To test if controller is functioning correctly, temporarily remove silicone hose from the backpressure tube and connect hose to the pressurizer. 2) Reconnect positive battery cable. Start TRU and run in low speed. Squeeze pressurizer until yellow indicator line is in middle of green range on gauge. This will cause controller to shift TRU into high speed. If controller doesn t respond, see troubleshooting section on page 31. Remove pressurizer and reconnect silicone hose.

WARRANTY & CARB REGISTRATION CLEANING, ASH HANDLING 29 WARRANTY REGISTRATION and Installer s checklist After installation of the Proventia FTF system, register at www.proventiafilters.com/warranty.html and provide the following info to FTF distributor who will keep it for 4 years: TRU owner s name: TRU owner s contact phone number: TRU owner s e-mail Installer s name: Installer s contact phone number: Installer s e-mail Installation date: TRU hourmeter reading on installation date: hours TRU model name: (SBIII, Super II, Sentry): TRU unit serial number: TRU unit model year: TRU engine model: (Isuzu se2.2, Isuzu di2.2, Yanmar TK482, Yanmar TK486, etc.): TRU engine serial number: Proventia FTF serial number: Oil consumption: ounces/50 hours Injectors replaced at : hourmeter reading Installer initial that oil rate was measured and injectors were replaced CARB Identification Number (IDN) REGISTRATION After installing the Proventia FTF system, the TRU owner may apply for CARB IDN at: www.arb.ca.gov/diesel/tru/application.htm CLEANING THE FTF AND SAFE ASH-HANDLING GUIDELINES If there is excessive ash accumulation within the FTF (see page 32), the FTF will need to be cleaned. Clean the FTF by removing it from the TRU and blowing compressed air into the FTF outlet (seal around air hose), in the direction opposite of the exhaust flow. However, ash that would be blown out of the FTF inlet must be collected using a vacuum with a HEPA filter that collects the particulates for hazardous waste disposal. Call 800-609-4021 for recommendations of companies capable of removing ash from the FTF. Individuals who own, operate, or maintain diesel engines equipped with diesel particulate filters must manage hazardous ash waste generated by these devices. Follow ash-handling guidelines as prescribed by CARB at: www.arb.ca.gov/diesel/tru/documents/ashguide.pdf

30 WIRING DIAGRAM FOR Backpressure ControlleR

TROUBLESHOOTING 31 TROUBLESHOOTING PROBLEM CAUSE SOLUTION TRU does not shift to high-speed mode when backpressure is 2.5 psi at lowspeed mode. Leak in backpressure fitting, backpressure tube, or silicone hose Faulty backpressure switch inside controller box #2 Wire is disconnected from starter solenoid terminal #7D Wire is disconnected from speed solenoid CH Wire is disconnected from speed solenoid Faulty timer module inside controller box Check for and repair leaks in the backpressure fitting, tube, or hose. Check if switch contacts close when pressure is greater than 2.5 psi. If not, replace switch. Terminal C on timer module should always be +12V. If not, check 5 amp in-line fuse on controller harness. Also, check for continuity of #2 wire from starter solenoid terminal up to C terminal on timer module. Put +12V on terminal #1 on timer module. 7D wire on speed solenoid should go to +12V for 10 minutes. If not, check for continuity of 7D wire from speed solenoid terminal up to NO terminal on timer module. Check if terminal #2 on timer module is grounded. If not, check for continuity of CH wire from speed solenoid terminal up to #2 terminal on timer module. Put +12V on terminal #1 on timer module. NO terminal on timer should go to +12V for 10 minutes. If not, replace timer module.

32 TROUBLESHOOTING PROBLEM CAUSE SOLUTION TRU repeatedly shifts to high speed for 10 minutes, then low speed for 5 minutes. Backpressure indicator gauge is in the red service range. Faulty Backpressure switch inside controller box Soot or ash accumulation inside of FTF Check if backpressure switch contacts are open when TRU is not running. If not, replace switch. If switch is okay, proceed to next section. Check if yellow gauge line in backpressure indicator gauge is within red service range during high-speed operation (see picture on page 3). If so, this is an indication that the FTF may have an excessive accumulation of soot or ash. The soot can be regenerated (cleaned out of the FTF) by running at high speed for 10 minutes and then shutting TRU off manually for 5 minutes. Repeat this cycle 5 times, then check backpressure indicator gauge reading again. If the yellow gauge line in backpressure indicator gauge continues to be within the red service range, this is an indication that the FTF may have an excessive accumulation of ash. Follow the filter cleaning and ash guidelines on page 29.

TROUBLESHOOTING 33 PROBLEM CAUSE SOLUTION Black smoke is visible from exhaust during steady speed operation Poor combustion Visible smoke is normal when TRU shifts from low- to highspeed operation or high- to low-speed operation. If black smoke is visible during steady speed operation, injectors need to be serviced or replaced. To service the TRU engine injectors, follow the TRU engine manufacturer guidelines: a. Check the injector spray pattern on a nozzle test stand. The injector spray pattern should have four good sprays with no dripping. b. Check the opening pressure of the nozzles: i. Yanmar injectors should be 2,800 to 3,000 psi. Isuzu injectors should be 2,633 to 2,704 psi. ii. Adjust nozzle opening pressure with shims as needed to meet the specification.

34 PARTS LIST WARRANTY STATEMENTS PARTS LIST Replacement parts available at www.proventiafilters.com. PART# DESCRIPTION F00688 FLOW THROUGH FILTER, FTF FOR SB T001 INSULATION WITH SNAPS T002 INSULATION BLANKET, EXHAUST MANIFOLD T003 INSULATION SLEEVE, EXHAUST PIPE UPPER T004 BACK PRESSURE INDICATOR GAUGE T005 UPPER EXHAUST TUBE T006 FTF CONTROLLER ASSEMBLY (includes T014 & T015) T007 EXHAUST CLAMP SET, R48 & R45 T008 HOSE, 0.17 ID X 14 T009 TEE FITTING, BRASS T010 SPRING CLAMP FOR SILICONE HOSE T011 BACKPRESSURE TUBE T012 BACKPRESSURE FITTING T013 ULSD DIESEL FUEL LABEL T014 BACKPRESSURE SWITCH T015 TIMER MODULE T017 PRESSURIZER TO50 DIODE ASSEMBLY WARRANTY STATEMENTS YOUR WARRANTY RIGHTS AND OBLIGATIONS Proventia Americas, LLC will warrant the Proventia FTF for the Transport Refrigeration Unit (TRU) for which it is sold or leased to be free from defects in design, materials, workmanship, or operation of the Proventia FTF that cause the Proventia FTF to fail to conform to the emission control performance level the Proventia FTF was verified to, or to the other requirements of the California Code of Regulations Title 13CCR sections 2700-2706 and 2710 for the period of 4 years, or 2,600 hours, whichever occurs first, provided there has been no abuse, neglect, or improper maintenance of the TRU, TRU engine, or Proventia FTF system, as specified in the owner s manuals. Where a warrantable condition exists, this warranty also covers the TRU engine from damage caused by the Proventia FTF system, subject to the same exclusions for abuse, neglect, or improper maintenance of the TRU or TRU engine. Please review the owners manuals for other warranty information. The Proventia FTF system may include a core part (e.g. particulate filter) as well as hoses, connectors,

WARRANTY STATEMENTS 35 a backpressure monitor, and other emission-related assemblies. Where a warrantable condition exists, Proventia will repair or replace the FTF system at no cost to you including diagnosis, parts, and labor. WARRANTY COVERAGE For a TRU engine used in a TRU, the warranty period is 4 years or 2,600 hours of operation, whichever occurs first. If any emissions-related part of the Proventia FTF system is defective in design, materials, workmanship, or operation of the Proventia FTF system thus causing the Proventia FTF system to fail to conform to the emission control performance level it was verified to, or to the requirements in the California Code of Regulations Title 13CCR sections 2700-2706 and 2710, within the warranty period, as defined above, Proventia Americas, LLC will repair or replace the Proventia FTF system, including parts and labor. In addition, Proventia Americas, LLC will replace or repair the TRU engine components to the condition they were in prior to the failure, including parts and labor, for damage to the TRU engine proximately caused by the Proventia FTF system. This also includes those relevant diagnostic expenses in the case in which a warranty claim is valid. Proventia Americas, LLC may, at its option, instead pay the fair market value of the TRU engine prior to the time the failure occurs. OWNER S WARRANTY RESPONSIBILITY As the TRU and Proventia FTF system owner, you are responsible for performing the required maintenance described in the TRU and Proventia FTF owners manuals. Proventia Americas, LLC recommends that you retain all maintenance records and receipts for maintenance expenses for your TRU and Proventia FTF system. If you do not keep your receipts or fail to perform all scheduled maintenance, Proventia Americas, LLC may have grounds to deny warranty coverage. You are responsible for presenting your TRU and Proventia FTF system to a Proventia Americas, LLC dealer as soon as a problem is detected. The warranty repair or replacement should be completed in a reasonable amount of time, not to exceed 30 days. If a replacement is needed, this may be extended to 90 days, should a replacement not be available, but must be performed as soon as a replacement becomes available.

36 WARRANTY STATEMENTS If you have questions regarding your warranty rights and responsibilities, contact Proventia Americas, LLC at 800-609-4021 or the California Air Resources Board at Stationary Source Division - TRU, 1001 I Street, Sacramento, CA 95814, (888) 878-2826, or e-mail: tru@arb.ca.gov The installer will furnish the Proventia FTF owner with a copy of the following statement: YOUR WARRANTY RIGHTS AND OBLIGATIONS (Installer s name) (Installer s phone number) will warrant that the installation of the Proventia FTF system is free from defects in workmanship or materials which cause the Proventia FTF to fail to conform to the emission control performance level it was verified to or to the requirements in the California Code of Regulations Title 13CCR sections 2700-2706. The warranty period and the extent of the warranty coverage provided by the installer will be the same as the warranty provided by Proventia Americas, LLC, and the same exclusions apply. OWNER S WARRANTY RESPONSIBILITY As the TRU owner and Proventia FTF system owner, you are responsible for presenting your TRU and Proventia FTF system to the installer as soon as a problem with the installation is detected. If you have questions regarding your warranty rights and responsibilities, you should contact the Installer of the Proventia FTF system or the California Air Resources Board at Stationary Source Division - TRU, 1001 I Street, Sacramento, CA 95814, (888) 878-2826, or e- mail: tru@arb.ca.gov 5/11/09