Comprehensive Guide to Small Off-Road Engine Evaporative Emissions Regulations

1. Small Off-Road Engines/Equipment (SORE) Emission Regulations Monitoring and Laboratory Division (MLD) January 27, 2005 Mobile Source Operations Division (MSOD) California Air Resources Board

2. Outline • Introduction • 2006 & Later SORE Evaporative Requirements • Evaporative Component Certification/Innovative Products • Evaporative Certification Process < 80 cc • Process Flow-chart • Guidance and Clarification • Templates and Forms

3. Outline • Evaporative Certification Process > 80 cc • Process Flow-chart • Guidance and Clarifications • Templates and Forms • 2005 & Later SORE Exhaust Standards • Exhaust Certification Guidance

4. 2006 & Later SORE Evaporative Emissions Requirements Danny Tran

5. New SORE Evaporative Requirements(Applicability) • Engines < 19 kW • Engines grouped by displacement • < 80 cc, handheld • > 80 cc to < 225 cc, small non-handheld • > 225 cc, large non-handheld • Lawn and garden and small industrial equipment • Two and four-stroke engines

6. New SORE Evaporative Requirements(Applicability) • Regulations do not apply to: • Snowthrowers and ice augers • Engines or equipment that use compression-ignition engines • Engines or equipment powered with CNG, Propane, LPG, LNG • Farm and construction equipment

7. New SORE Evaporative Requirements(Handheld) • Apply to small engines < 80 cc • Typical equipment includes string trimmers, leaf blowers, and chainsaws

8. New SORE Evaporative Requirements(Small Non-Handheld) • Apply to walk-behind mowers with engines > 80 cc to < 225 cc

9. New SORE Evaporative Requirements(Small Non-Handheld) • Apply to equipment other than walk-behind mowers with engines > 80 cc to < 225 cc

10. New SORE Evaporative Requirements(Large Non-Handheld) • Apply to large equipment like lawn tractors and generators with engines > 225 cc

11. New SORE Evaporative Requirements(engines > 225 cc)Small Production Volume Tank Exemption • Total identical tank sales in California of 400 or fewer units per model year

12. Component Certification Monitoring &LaboratoryDivision LaMar Mitchell Pat Bennett Jim Watson

13. Component Certification • What is component certification? • Component certification is the certification of fuel hoses, fuel tanks, and carbon canisters by ARB. • Certification means that the manufacturers have demonstrated that their product meets applicable design requirements.

14. Component Certification • How is component certification useful? • Allows engine and equipment manufacturers to reference a component Executive Order (EO) in a certification application when certifying by design • Multiple OEMs can rely on same component EO • Expedites certification process by eliminating the need to review component compliance data

15. Component Certification(How it works) Hose is Certified by Component Manf. Tank is Certified by Component Manf. Canister is Certified by Component Manf. Certified Components will be Listed on the SORE Web Page Engine/Equipment Manf. References Components on Certified List ARB Certifies Engine/Equipment Using Component EOs in Lieu of Component Data

16. Component Certification • Who is expected to apply for a component EO • Fuel hose manufacturers like Goodyear, Teleflex, Mark IV, and Mold-Ex, Inc. • Fuel tank manufacturers like Kelch Corp., Honeywell Plastics, and Mergon Corp. • Carbon canister manufacturers like MPC, Eaton Corp., Delphi Automotive, and Sentec E&E

17. Component Certification Process • Manufacturer tests a minimum of 5 samples of component using applicable test procedure • Fuel hose - SAE J1737 (allowable test fuels and test temperatures specified in 13 CCR 2754) • Fuel tank - TP-901 • Carbon canister - TP-902 • Alternative test procedures must be approved by ARB in advance.

18. Component Certification Process Components Tested Fuel hose - smallest inside diameter Fuel Tank - smallest volume to surface area ratio Carbon canister - canister sized for the largest fuel tank

19. Component Certification Process • Manufacturer submits letter with test data requesting a component EO to: • California Air Resources Board • Monitoring and Laboratory Division • Attn: Division Chief • P.O. Box 2815 • Sacramento, CA 95812

20. Component Certification Process • Letter, on company letterhead must include: • Emissions data from 5 component samples • Reference to the test procedure used to generate the data • Letter signed by authorized company representative

21. Component Certification Process Letter should also include: General description of material composition Drawing of component Installation and maintenance instructions (if applicable) Limits for proper functioning Sample of untested component or coupon for tanks

22. Component Certification Process Flowchart Component Manf. Tests Component Component Manf. Submits Letter with Data to ARB ARB Reviews Letter For Completeness No ARB Requests Further Info. From Manufacturer Within 30 Days Yes ARB Approves or Denies Component EO ARB Mails denial letter to Manufacturer Denies EO Within 90 days Approves EO ARB Mails EO to Manufacturer ARB Issues Component EO and Adds Component to Certified List

23. Component Certification Process(Fuel Hose Case Study) Example: A manufacturer seeks a component EO for low permeation fuel hoses with internal diameters ranging in size from 1/4 to 3/8 inches

24. Component Certification Process(Fuel Hose Case Study) To obtain a component EO, a manufacturer would: • Generate fuel hose permeation data for the fuel hose with smallest inside diameter within the production range • Test five samples of hose following SAE J1737 • Test must be conducted at 40°C or higher with CERT fuel, Indolene, CE10, or CM15

25. Component Certification Process(Fuel Hose Case Study) • Submit a letter to ARB requesting a component EO which includes: • hose emissions data from five samples • a declaration of how the test data was generated (hose was tested at a constant 40°C with CE10 following SAE J 1737) • a signature by authorized company representative

26. Component Certification Process(Fuel Hose Case Study, continued) • general material description of the hose with CAD drawing • an untested sample hose • location and mounting instructions • any conditions which might affect the hose’s integrity (maximum skin temperature, kinking radius, etc.)

27. Component Certification Process(Fuel Hose Case Study) After receiving the request, ARB processes the certification application by: • Logging the date of receipt • Reviewing the application for completeness • Notifying applicant

28. Component Certification Process(Fuel Hose Case Study) • Verifying that all data points are below the design criteria of 15 grams/meter2/day • Drafting a component EO for the hoses • Mailing the component EO to the manufacturer • Adding the component EO to Sore Web Page

29. Component Certification Questions?

30. Component CertificationContacts LaMar Mitchell 916-445-9371 lmitchel@arb.ca.gov Jim Watson 916-327-1282 jwatson@arb.ca.gov SORE Web Page http://www.arb.ca.gov/msprog/offroad/sore/sore.htm

31. Evaporative Certification Process Flow-chart (< 80cc) Alan Chow

32. Typical Off-Road Certification Process Flowchart Manufacturer Submit Letter of Intent Manufacturer Submit Complete Application ARB Reviews Application For Completeness No ARB Requests Further Info. From Manufacturer Up to 30 Days Yes ARB Evaluates Application No ARB Notifies Manufacturer Up to 90 Days Yes ARB Issues Executive Order ARB Mails EO to Manufacturer

33. Evaporative Certification Guidance Keith Macias

34. Evaporative EmissionsCertification GuidanceGeneral Information • Obtain a manufacturer code from the U.S. EPA, through the following Website: • www.epa.gov/OMSWWW/cfeis.htm

35. Evaporative EmissionsCertification GuidanceGeneral Information • Manufacturer contact persons • Designate 1 or 2 authorized representatives • ARB contact person • ARB will assign a primary certification contact person for certification assistance

36. Evaporative EmissionsCertification GuidanceGeneral Information • Executive Order must be obtained prior to sale • The following items may be submitted prior to the certification application for ARB approval: • Evaporative emission control warranty statement • Evaporative emission equipment label • Alternative test procedures

37. Evaporative EmissionsCertification Guidance for EnginesLess Than or Equal to 80 cc

38. Regulations and Guidance • Title 13, CCR, Sections 2750 to 2773 • The engine exhaust family is the evaporative family [www.arb.ca.gov/msprog/offroad/sore/sore.htm] • CP 901 (Certification Procedures) [www.arb.ca.gov/regact/sore03/cp901.pdf] • TP 901 (Test Procedure) [www.arb.ca.gov/regact/sore03/tp901.pdf] • Certification guidelines (guidance and examples)[weblink to be posted]

39. Applicability • The evaporative standards apply togasolinefueled small spark-ignited engines. • Implementation date: 2007 Model Year • Only the fuel tank is required to meet permeation standards • These standards do not apply to CI engines or engines powered by the following fuels: • CNG • Propane • LPG • LNG

40. Certification OptionsPermeation Emission Standards • Data from fuel tank permeation that exhibits the highest evaporative emissions. • Typically, the worst case tank is the one with the least tank volume to internal surface area ratio. • May certify to cleaner emissions standard (Blue Sky)

41. Certification OptionsExemption • May certify by meeting the exemption requirements of 2766. • submit a letter of conformance • submit certification application less emission test data

42. Certification OptionsInnovative Product • Must apply to MLD. • Upon approval, MLD will provide an EO number. • Submit application with EO number.

43. Data Carryover and Carryacross • May Carryover emission data from the previous model year • Same material process • No changes to emission control system • May Carryacross emission data from one evaporative family to another • Must be representative of new family • Subject to ARB Approval

44. Certification Application Submittal • Letter of Intent • Cover letter • Application • Certification Summary • Supplementary Information • Field Data Sheet • Permeation emissions certification label • Permeation emissions warranty statement

45. Certification Application Samples • Samples provided in guidelines in Attachments 2A through 2E: • 2A (completed certification application) • 2B (cover letter) • 2C (Application template) • 2D (samples of engine or equipment labels) • 2E (samples of emission control warranty statements)

46. ARB Review Process • Is certification application complete? • Is the fuel tank representative of worst case configuration/model? • Is the fuel tank exempt? • letter of conformance and application • Innovative Product Executive Order number in application • Do test results indicate marginal compliance? • (within 5 % of standard -- may request confirmatory test) • Any additional information or clarification needed? • Create EO and submit for final review and signature.

47. Additional Contacts • Test procedures/Innovative technology certification--MLD • James Watson (916) 327-1282 jwatson@arb.ca.gov • LaMar Mitchell (916) 445-9371 lmitchel@arb.ca.gov • Fax (916) 322-2444 • Certification contact--MSOD • Kumar Muthukumar (626) 575-7040 cmuthuku@arb.ca.gov • Certification submittal--MSOD • Mobile Source Operations Division • Off-Road Certification/Audit Section • Air Resources Board • 9480 Telstar Avenue, Suite 4 • El Monte, California 91731-2988 • Attn. Division Chief

48. Evaporative Certification Templates and Forms (< 80cc) Dr. Paul Adnani