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									    Evaporative Emission
    Evaporative Emission
     Standards for Boats
     Standards for Boats


                     Mike Samulski
          Office of Transportation and Air Quality

          International Boat Builders’ Exhibition &
                         Conference
              Session 309: Boat Fuel Systems
                      October 7, 2008




1
    Outline

    •   Overview of new program
    •   Evaporative emission types
    •   New Standards
    •   Program details
    •   Small businesses
    •   Certification
    •   Questions

2
    Final Rule

    • On September 4, 2008, EPA Administrator Steve Johnson
      signed, into law, new exhaust and evaporative emission
      standards for spark-ignition marine engines and vessels.

    • These standards apply only to new engines and vessels
      sold for use in the United States.

    • The standards will help reduce
      harmful health effects of ozone
      and carbon monoxide from these
      products.

3
    Final Standards: Overview

    • HC+NOx exhaust emission standards for
      SI marine engines are similar in stringency
      to existing standards in California
    • New CO exhaust emission standards for all
      SI marine engines
    • New Not-to-Exceed provisions
    • New evaporative emission standards

4
    Evaporative Emission Types
                                  Venting emissions
    Refueling/spillage
                                    (diurnal, hot soak, running loss)




                         Permeation
5                          (fuel tank, hoses, other)
    Highway Evap Standards



                Three decades of automotive
                evaporative emission control
                 (full vehicle test/standards)


                              Nonroad equipment are
                                just now becoming
                               subject to evaporative
                                  emission control
6
    Existing Nonroad Standards

    • Component based standards
      – Fuel and tank permeation
      – Component test for diurnal control
      – Design-based certification


    • Existing standards
      – Large SI equipment (2007)
      – Recreational vehicles (2008)
      – Portable gas cans (2009)

7
    New Standards

    SI Marine
    • Portable tanks
      – Tank permeation
      – Self-sealing vent
    • Vessels
      – Hose and tank permeation
      – Diurnal emissions
      – Refueling spillage

    Small SI as well
      – Hose and tank permeation
8     – Running loss
    Marine Evap Standards
           Standard/              Hose         Tank
                                                           Diurnal
           Category            Permeation Permeation
         Standard level        15 g/m2/day 1.5 g/m2/day 0.40 g/gal/day
         Portable tanks           2009a        2011         2010b
             PWC                   2009        2011          2010
          Other tanks              2009a               2012                2011c,d
    a2011 for primer bulbs. Phase-in for under cowl fuel lines, by length, on OB
    engines: 30% 2010, 60% 2011, 90% 2012, 100% 2015.
    b   Design standard.
    cFuel tanks installed in nontrailerable boats (> 26 ft. in length or >8.5 ft. in width)
    may meet a standard of 0.16 g/gal/day over an alternative test cycle.
    dThe standard is effective July 31, 2011. For boats with installed fuel tanks, this
    standard is phased-in 50%/100% over the first two years. As an alternative, small
9   manufacturers may participate in a diurnal allowance program.
     Program Details
                          Hose
                       Permeation

       Certification
                                       Tank
                                    Permeation

          Small
         Business                   Diurnal
        Provisions
                        Refueling
                        Spillage
10
     Fuel Line Permeation

     • Fuel line
       – 15 g/m2/day, 2009
          • Fuel CE10, 23°C
       – Boat and engine hose
          • Phase-in for under cowl fuel line
       – Primer bulbs, 2011

     • Vent and fill lines
       – Standards do not apply unless
         hose will hold standing fuel


11
     • Fuel line manufacturers will certify
     Technical Approaches
     • Straight-run hose
       – Low permeation hose widely available
       – Fluoroelastomer/fluoroplastic barriers
       – SAE J1527 includes specification for 15 g/m2/day hose
     • Molded hose and other rubber components
       – Fluoroelastomer construction
       – Alternative primer bulb products             cover

                              rubber




                              barrier layer
12                                                     reinforcement
     Fuel Tank Permeation

     • 1.5 g/m2/day
       – E10 fuel, 28°C
       – Preconditioning
          • Fuel soak
          • Durability testing

     • Design-based certification
       – Metal tanks
       – Automotive type multi-layer tanks

     • Tank manufacturer will certify
13
     Technical Approaches


          •   Multi-layer constructions
          •   Alternative materials
          •   Barrier treatments
          •   Barrier platelets
          •   Coatings
          •   Nanocomposites

14
     Diurnal Standards
     • Portable fuel tanks                                   33.0

       – Self-sealing valve                                  32.0                            <26 ft




                                      Fuel Temp, Degrees C
                                                             31.0                            26 ft +
                                                             30.0

     • Installed tanks                                       29.0
                                                             28.0
       – Trailerable boats (<26 ft)                          27.0
          • 0.40 g/gal/day                                   26.0
          • 25.6-32.2°C                                      25.0

       – Nontrailerable boats                                       0   4   8    12
                                                                                Hours
                                                                                        16    20       24


          • 0.16 g/gal/day
          • 27.6-30.2°C

     • Tank manufacturer will certify
15
     Technical Approaches
     • Design-based certification
       – Seal tank (up to 1.0 psi)
          • Can use pressure mitigation (e.g. bladder)
       – Passive-purge carbon canister
          • Prevent fuel from entering canister
          • Carbon and canister
            specifications




16                      canister in boat
     Refueling
     • Fuel nozzle standards
       – Marinas must use standard nozzles whenever they
         replace existing nozzles or install new ones
       – Same to those already used for motor vehicle pumps
          • Standardized dimensions
          • Automatic shut-off


     • System integration
       – Fuel systems should be designed to allow flow to
         nozzle for automatic shut-off
       – Will help with carbon canister installation designs and
         reduce spillage
17
     System Integration
     • Industry consensus standards
       – SAE J1527 addresses hose permeation
       – ABYC H24 potential vehicle for specifying best
         practices for fuel system designs
       – NMMA certification
     • Canister installation standards
       – Industry is developing canister installation practices
         in context of EPA & USCG standards
       – ABYC is assessing fuel/air separators and fuel
         system designs for spillage control


18
     Potential Canister Installation

                                            Vent line
              Vapor space
          (for fuel expansion)
                                 Valve or
                                  orifice



      Fill neck                                 Canister
                            Fuel tank


19
     Small Businesses
     • Small Business Regulatory Enforcement
       Fairness Act
       – Convened SBREFA Panels in 2001 and 2006
       – Representatives from engine, boat, tank, and hose
         manufacturers
     • Rule includes all recommendations from panel
       report
       –   Appropriate lead time
       –   Broad definition of emission family
       –   Compliance progress review for fuel tanks
       –   Engineering design-based certification for tanks
       –   Fuel tank credit program
20
       –   Hardship provisions
     Certification Procedures

        The ABCs of getting a Certificate
        of Conformity with EPA emission
                 regulations…


21
     Certification Procedures

     • The basics:
       – If your product is subject to EPA emissions standards,
         you must obtain a Certificate of Conformity before you
         introduce it into US Commerce.
          • Must demonstrate compliance with the applicable regulation.
       – Certificates are issued by the Compliance and
         Innovative Solutions Division (CISD), Office of
         Transportation and Air Quality.
          • CISD’s Heavy-Duty and Nonroad Engines Group processes
            the Applications for Certification for Marine SI
       – You must certify every model year or production
         period
22
     How do I certify?

     •    To obtain a Certificate of Conformity:
         1. Read the regulations!
            •   SD/I & components: 40 CFR Parts 1045, 1060, 1065 and 1068
            •   OB/PWC: add 40 CFR Part 91
            •   http://epa.gov/otaq/marinesi.htm
         2. Request an EPA Manufacturer Code:
            •   http://epa.gov/otaq/verify/mfr-code.htm
            •   Contact: Mr. Pete Petersen, 734.214.4204;
                petersen.pete@epa.gov
         3. Determine:
            •   Engine Families/Permeation Families
            •   The type of Certificate you need:
                –   Exhaust, Evaporative (fuel lines, fuel tanks), or both
23
     How do I certify?
     4.       Gather your data

     5.       Pay your fee:
          •     Per Application                                     Calendar Year*

          •     Information:                       Type of
                http://epa.gov/otaq/fees.htm      Certificate         2008      2009       Use Form

          •     Pay electronically at:         Exhaust                $694      $562        3520-29
                https://www.pay.gov/                                                    "Miscellaneous
          •     Contact:                       Evaporative               $241             Payments"

                •   Mr. Bill Vanden Broek          *The amount of the fee depends on the calendar
                                                   year in which the application is submitted, not the
                •   734.214.4468                   engine’s model year. Pay a fee for each
                •   vandenbroek.willem@epa.g       application.
                    ov


24
     How do I certify?
     5.       Complete an Application for
              Certification
          –         Per engine or permeation family
          –         Download application template:
                    epa.gov/otaq/certdat2.htm
          –         Software required: FileMaker
                    Pro (versions 7.0 to 9.0)
                –       www.filemaker.com             Additional
          –         Questions on completing/          Information
                    submitting the application:
                •       Exhaust: Mike Marko,
                        202.343.9536;
                        marko.michael@epa.gov
                •       Evaporative: Nick Flores:
                        202.343.2800;                          Application for marine
                                                               SI components is not
                        flores.nick@epa.gov
                                                               on the website yet.
          –         Carry over, running changes,               Look for it here in the
                    carry across                               near future.
          –         Mark CBI
          –         Comments section
25
     How do I certify?

     • Engine Family Names
         – 12-character string
                                                          Evaporative
         – Must follow EPA’s family
           naming convention                                          (for MY 2009 only)
         – MY 2009 = 9; 2010 = A

                                                                 9XYZPTANKAB1
         Marine SI (Exhaust)
                                                                            Industry Sector
                                                         Model              Code for Fuel Tanks
                                                                  EPA Mfr                          Sequence Characters
             9XYZM1.72AB1                                Year
                                                                   Code
                                                                            Industry Sector Code
                                                                                                    (Unique Identifier)

                                                                            for Fuel Lines
     Model    EPA Mfr
     Year                                   Sequence
               Code
                            Engine
                                            Characters
                                                                 9XYZPLINEAB1
       Industry Sector      Displacement
       Code for Marine SI   (in Liters or
       Engines              Cubic Inches)
26
     How do I certify?




     Example of Engine (Exhaust) Certification Template. Does
     not include SD/I yet.
27
     How do I certify?



                                                          Not applicable for Marine
                                                          SI fuel lines. Use measured
                                                          emission levels for
                                                          certification.




      This template will be used for both Marine SI and
      Small SI components.

28
     How do I certify?




                         This template will be used for both Marine SI
                         and Small SI components.

29
     How do I certify?

     5. Submit your application
       – Complete application = template + signed Statement
         of Compliance
       – To submit:
          • Email complete application to: Application-SI_Cert@epa.gov
              – Subject line: MSI-Company name-# of submissions & Process
                Code
                  » Example: “MSI-BuyMyBoat-3 new submissions”
              – One industry and process code per e-mail
          • May submit by mail
       – Allow at least 60 days from the time EPA receives a
         complete application for processing

30
     EPA Review
     • Mike Marko or Nick Flores receive the
       applications and check them for completeness
       – Contact them if you have questions about the
         templates or need to know where your cert is
     • If you have a question about Marine SI
       regulations, contact: Nydia Yanira Reyes
       – reyes-morales.nydia@epa.gov (e-mail preferred)
       – 202.343.9264
     • Send special requests to:
       – Ms. Khesha Jennings, Manager, Heavy-Duty and
         Nonroad Engines Group
          • jennings.khesha@epa.gov


31
     EPA Review
     • Please keep in mind that once you certify, you
       must comply with all parts of the regulation(s)
       that apply to your product, such as:
       –   Labeling Requirements
       –   Average, Banking and Trading (AB&T)
       –   Production-line Testing (PLT)
       –   In-use Testing
       –   Warranties
       –   Defect Reports & Recalls
       –   Owner’s Manual requirements
       –   Selective Enforcement Audits
       –   Recordkeeping, etc

32
     Other useful information
        Heavy-Duty and Nonroad
             Engines Group

     Regular Mail:                     •   To submit:
        US EPA                              – AB&T: abt_engine@epa.gov
        1200 Pennsylvania Avenue, NW
                                            – PLT (OB/PWC): plt@epa.gov
        Mail Code 6403J
                                       •   Cert data available @:
        Washington, DC 20460
                                           www.epa.gov/otaq/certdata.htm
                                       •   Imports Line: 734.214.4100
     Courier Address:
       US EPA                               – Email-imports@epa.gov
       1310 L Street, NW,              •   Exemptions: David Hurlin
       Mail Code 6405J                      – 734.214.4098
       Washington, DC 20005            •   CBI: Robert Doyle, 202.343.9258
                                            – Doyle.robert@epa.gov
     Fax: 202.343.2804
33
     Questions
                 http://www.epa.gov/otaq/marinesi.htm




      For general program questions:
             Mike Samulski, Samulski.Michael@epa.gov

      For questions regarding certification:
34           Nydia Reyes-Morales, Reyes-Morales.Nydia@epa.gov

								
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