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EPA Compliant Fuel Systems IBEX Oct 18, 2011 Sean Whelan P.E.

EPA Compliant Fuel Systems IBEX Oct 18, 2011 Sean Whelan P.E. 1. Agenda. I have chosen a Diurnal path, now what? Validation and Testing Common Pitfalls to Avoid. 2. Planning Overview. Diurnal Refueling Venting Engine Compatibility. Validation Performance Field Liability

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EPA Compliant Fuel Systems IBEX Oct 18, 2011 Sean Whelan P.E.

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  1. EPA Compliant Fuel Systems IBEX Oct 18, 2011 Sean Whelan P.E. 1

  2. Agenda • I have chosen a Diurnal path, now what? • Validation and Testing • Common Pitfalls to Avoid 2

  3. Planning Overview • Diurnal • Refueling • Venting • Engine Compatibility • Validation • Performance • Field Liability • EPA compliance • ABYC Compliance • Validation • Performance Fuel System System Component • 3rd party • Internal Partner 3

  4. Validation • Performance • Field Liability • EPA compliance • ABYC Compliance System Boat is a system Fuel is a sub-system DVPR Validation Plan FMEA Failure Modes 4

  5. Validation • Performance • Field Liability • EPA compliance • ABYC Compliance System Example Validation Plans 5

  6. Validation • Performance • Field Liability • EPA compliance • ABYC Compliance System Example Validation Plans DV 6

  7. Validation • Performance • Field Liability • EPA compliance • ABYC Compliance System Example Validation Plans PV 7

  8. Validation • Performance • Field Liability • EPA compliance • ABYC Compliance System How well does it perform? High RVP fuels? Hot Days? With Jerry Cans? At Marinas? With engine? Etc… 8

  9. Validation • Performance • Field Liability • EPA compliance • ABYC Compliance System Who Owns Liability Who is responsible for -over pressurization -Un-fillable -diurnal performance -Customer Satisfaction -leaks -USCG violation -Engine compatibility -Etc… Beware finger pointing 9

  10. Validation • Performance • Field Liability • EPA compliance • ABYC Compliance System Who Owns EPA & ABYC Compliance Who is responsible for -diurnal performance -EPA filing -EPA Audit -Certificate of Conformance -Record retention -Exemption tracking -ABYC H24 compliance -NMMA inspection -Weathertight/ Watertight -3psi pressure test Beware finger pointing EPA Civil Penalty $32,500 per vessel (40CFR1068.101(a)(1)) 10

  11. Validation • Performance Component Components- Carbon Canister, Deckfill, Fuel Tank, Valves, Pressure Release Valve etc. DVPR Validation Plan FMEA Failure Modes 11 11

  12. Validation • Performance Component Example Validation Plans

  13. Validation • Performance Component How well does component perform?

  14. Validation • Performance Component How well does component perform?

  15. Common Pitfalls to Avoid • Do not assume water will act like gasoline. • Make sure all needs are met, not just one. • If boat refuels well at 70°F, do not assume it fills well at 90°F. • Don’t assume that an initial demonstration means that system will work after years on the water. • Verify plant installation early in process. • Consult with engine manufacturer and measure pressure drop at engine. • Plan for future CARB regulations now. • Do not underestimate the task of implementation.

  16. Thank you Questions? 16

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