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					       Proposed Evaporative
       Proposed Evaporative
    Emission Standards for Boats
    Emission Standards for Boats


                         Mike Samulski
              Office of Transportation and Air Quality
              International Boat Builders’ Exhibition &
                             Conference
                  Session 310: Boat Fuel Systems
                          October 11, 2007




1
    Outline

    •   Evaporative emission types
    •   Overview of proposed standards
    •   Rulemaking process
    •   Program details
    •   Questions




2
    Evaporative Emission Types
                                   Venting emissions
     Refueling/spillage
                                     (diurnal, hot soak, running loss)




                          Permeation
3                           (fuel tank, hoses, other)
    Evap Standards



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


                             Nonroad equipment are
                               just now becoming
                              subject to evaporative
                                 emission control
4
    New 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)




5
    Proposed 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
      – Running loss
6     – Diffusion
    Marine Evap: NPRM Overview

           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         2009        2011         2009a
             PWC                2009        2011          2009
          Other tanks           2009        2012         2010b
     a Design standard – self-sealing vent
     b Fuel tanks installed in nontrailerable boats (≥ 26 ft. in length) may meet

       a standard of 0.16 g/gal/day over an alternative test cycle


     Refueling Spillage: requested comment on potential for
       industry consensus standards (ABYC)
7
    Rulemaking Process
                        • publish “Final
                          Rulemaking”
                                            FRM
                                                          Implement
                                           (2008)
                          YOU ARE
     • publish “Notice of   HERE                          • lead time
       Proposed Rulemaking”
                                                          • certification

             NPRM                 Public
            (5/18/07)           Comment
                              (closed Aug 3)    • public hearing
                                                • written comment period
                   • gather information         • address comments
        Pre-
                   • meet with stakeholders
      Proposal
8
                   • SBREFA
    Small Businesses
    • Small Business Regulatory Enforcement
      Fairness Act
      – Convened SBREFA Panels in 2001 and 2006
      – Representatives from engine, boat, tank, and hose
        manufacturers
    • Proposal 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
9
      –   Hardship provisions
     Program Details

                    Diurnal




       Refueling                   Hose
       Spillage                 Permeation



                      Tank
                   Permeation
10
     Proposed Diurnal Standards
     • Portable fuel tanks
       – Self-sealing valve
     • Installed tanks
       – Trailerable boats (<26 ft)
          • 0.40 g/gal/day
          • 25.6-32.2°C
       – Nontrailerable boats
          • 0.16 g/gal/day
          • 27.6-30.2°C
       – Design-based certification
          • Seal tank up to 1.0 psi, or
          • Passive-purge carbon canister
11   • Tank manufacturer would certify
     Diurnal: sealed tank with pressure relief




12
     Diurnal: passive carbon canister
                       72-96°F




           Temp.      Reduction
           72-96 F      64%
           78-90 F      68%
           81.6-86.4 F 71%




                                  canister in boat
13
     Proposed Hose Standards

     • Fuel line
       – 15 g/m2/day
          • Fuel CE10, 23°C
       – Boat and engine hose
          • Requested comment on more time
            for under cowl hose on outboards
       – Primer bulbs
     • Vent and fill hose
       – Standards do not apply unless
         hose will hold standing fuel
     • Fuel line manufacturer
       would certify
14
     Hose: Low Permeation Materials

     • Straight-run hose
        – Low permeation hose widely available
        – Fluoroelastomer/fluoroplastic barriers
     • Molded hose and other rubber components
        – Fluroelastomer construction
                                                   cover

                              rubber
          SAE J1527
     Includes specification
     For 15 g/m2/day hose
                              barrier layer
15                                                  reinforcement
     Proposed Tank Standards

     • 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 would certify

16
     Tank Permeation: barrier treatment

     • Fluorination
       – Expose tank surfaces to fluorine gas
       – Larger F molecules replace smaller H
         molecules on surface
     • Sulfonation
       – Expose tank surfaces to sulfur trioxide
       – Larger sulfonic acid groups form on surface
              HC                     HC




17
     Tank Permeation: barrier treatment

                    HDPE Blow-Molded Fuel Tanks [g/m2/day]
              Treatment       Tank 1       Tank 2             Tank 3       Average
               Baseline        11.5           11.4             11.2         11.4
             Sulfonation        2.5            2.7             2.2           2.5
             % reduction       78%            76%             80%           78%
             Fluorination       0.6            0.6             0.2           0.5
             % reduction       95%            95%             98%           96%

                Crosslink PE Roto-Molded Fuel Tanks [g/m2/day]
              Treatment     Tank 1     Tank 2        Tank 3      Tank 4      Avg.
              Baseline       7.5        8.5            --             --      8.0
             Sulfonation     7.3        7.8            7.2        7.7         7.5
             % reduction     9%         2%            10%         4%          6%
             Fluorination     5.7       5.0            6.2         4.6        5.4
18           % reduction     29%       37%            23%         42%        33%
     Tank Permeation: barrier platelets
        HDPE/EVOH Blow-Molded Fuel Tanks [E10]
                              Permeation
                % Barrier
                              [g/m2/day]
                   2%               3.0                  HC
                   4%               1.9
                   4%               2.0
                   6%               1.4
                   6%               1.4




                        Nanocomposite Fiberglass [E10]
                            Tank Size      Permeation
                            [gallons]      [g/m2/day]
                               14             1.0

19
     Tank Permeation: continuous barrier

                Thermoformed HDPE/EVOH
               Fuel Tanks [g/m2/day] 29°C, E10
                 Soak Period   Tank 1    Tank 2
                                                                 adhesive
                  27 weeks      0.15      0.05     HDPE
                  35 weeks      0.07      0.09                    EVOH
                  44 weeks      0.11      0.04     HDPE
                                                                 adhesive
                  Average       0.11      0.06

                  HDPE/IXEF Blow-molded
               Test Bottles [g/m2/day] 29°C, E10
                     Bottle    Permeation
                       1           0.3
                                                      XLPE
                       2           0.7
                       3           0.4                    IXEF
20
     Tank Permeation: continuous barrier

                      Roto-Molded PE/PA11
                 Fuel Tanks [g/m2/day] 29°C, E10
                            Outer    Permeation
                   Tank
                            Shell                   XLPE
                    1       MDPE         0.7
                                                    PA 11
                    2       XLPE         0.8



                          Roto-Molded PE/CBT
                        “Single-Shot” Fuel Tanks
                        Manufacturer testing on 5
                           gallon tanks showed      XLPE
                         permeation results well    CBT
                        below proposed standards
21
     Tank Permeation: barrier coating

     • Epoxy coatings applied to XLPE tanks
     • Adhesion treatment (light fluorination)
                                            Soak Period       Permeation
                            Coating
                                               E10             g/m2/day
                                                                   7.5
                             None             29 weeks
                                                                   8.5
                           Inside                                  0.6
                        Thermocured           15 weeks            0.02
                                                                   1.0
                          Outside                                  1.9
                        Thermocured*          15 weeks             3.3
                                                                   3.3
                           Outside           additional            0.4
                           UV cured           6 weeks
                        * Inspection showed uneven application of the coating
22                      which likely affected permeation results
     Tank Permeation:          alternative materials

                      Alternative Material
                Fuel Tanks [g/m2/day] 29°C, E10
                         Material              Permeation
         Tank
                                            g/m2/day, 29°C, E10
          V1      thermoplastic polyester           5.6
          C10                                       0.8
                    impact toughened
          C11                                       0.5
                    acetal copolymer*
          C13                                       0.6




                   Vandar                         Celcon
23
     Refueling

     • Spillage control
       – Design filler neck for nozzle with automatic shut off, or
       – Filler neck orientation to cause fuel flow-back into tank
     • Approaches
       – Redesign of fuel system
       – Automatic fuel shut-off before overflow
       – Fuel/air separator in vent line




24
     System Integration
     • Industry consensus standards
       – SAE J1527 addresses hose permeation
       – ABYC H24 potential vehicle for spillage control
     • Working with NMMA/ABYC/USCG
       – Industry is developing canister installation
         specifications in context of EPA & USCG standards
       – ABYC is assessing fuel/air separators and fuel
         system designs for spillage control
       – NMMA certification



25
     Questions
           http://www.epa.gov/otaq/marinesi.htm




                     Mike Samulski
26              samulski.michael@epa.gov

				
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