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Evaporative Emission Standards for Boats. Evaporative Emission Standards for Boats. Mike Samulski Office of Transportation and Air Quality International Boat Builders’ Exhibition & Conference Session 309: Boat Fuel Systems October 7, 2008. Overview of new program
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Evaporative EmissionStandards for Boats Evaporative Emission Standards for Boats Mike Samulski Office of Transportation and Air Quality International Boat Builders’ Exhibition & Conference Session 309: Boat Fuel Systems October 7, 2008
Overview of new program Evaporative emission types New Standards Program details Small businesses Certification Questions Outline
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.
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
Evaporative Emission Types Venting emissions (diurnal, hot soak, running loss) Refueling/spillage Permeation (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
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) Existing Nonroad Standards
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 • Running loss
Marine Evap Standards 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. c Fuel 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. d The 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 manufacturers may participate in a diurnal allowance program.
Program Details Hose Permeation Certification Tank Permeation Small Business Provisions Diurnal Refueling Spillage
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 • 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 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
Multi-layer constructions Alternative materials Barrier treatments Barrier platelets Coatings Nanocomposites Technical Approaches
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 • Tank manufacturer will certify
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 Technical Approaches 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
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
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 Hardship provisions Small Businesses
Certification Procedures The ABCs of getting a Certificate of Conformity with EPA emission regulations…
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 Certification Procedures
To obtain a Certificate of Conformity: 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 Request an EPA Manufacturer Code: http://epa.gov/otaq/verify/mfr-code.htm Contact: Mr. Pete Petersen, 734.214.4204; petersen.pete@epa.gov Determine: Engine Families/Permeation Families The type of Certificate you need: Exhaust, Evaporative (fuel lines, fuel tanks), or both How do I certify?
How do I certify? 4. Gather your data • Pay your fee: • Per Application • Information: http://epa.gov/otaq/fees.htm • Pay electronically at: https://www.pay.gov/ • Contact: • Mr. Bill Vanden Broek • 734.214.4468 • vandenbroek.willem@epa.gov *The amount of the fee depends on the calendar year in which the application is submitted, not the engine’s model year. Pay a fee for each application.
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 • Questions on completing/ submitting the application: • Exhaust: Mike Marko, 202.343.9536; marko.michael@epa.gov • Evaporative: Nick Flores: 202.343.2800; flores.nick@epa.gov • Carry over, running changes, carry across • Mark CBI • Comments section Additional Information Application for marine SI components is not on the website yet. Look for it here in the near future.
Engine Family Names 12-character string Must follow EPA’s family naming convention MY 2009 = 9; 2010 = A Marine SI (Exhaust) Evaporative (for MY 2009 only) How do I certify? 9XYZPTANKAB1 Industry Sector Code for Fuel Tanks Model Year 9XYZM1.72AB1 EPA Mfr Code Sequence Characters (Unique Identifier) Industry Sector Code for Fuel Lines Model Year EPA Mfr Code Sequence Characters 9XYZPLINEAB1 Engine Displacement (in Liters or Cubic Inches) Industry Sector Code for Marine SI Engines
How do I certify? Example of Engine (Exhaust) Certification Template. Does not include SD/I yet.
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.
How do I certify? This template will be used for both Marine SI and Small SI components.
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 How do I certify?
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 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 EPA Review
Heavy-Duty and Nonroad Engines Group Regular Mail: US EPA 1200 Pennsylvania Avenue, NW Mail Code 6403J Washington, DC 20460 Courier Address: US EPA 1310 L Street, NW, Mail Code 6405J Washington, DC 20005 Fax: 202.343.2804 To submit: AB&T: abt_engine@epa.gov PLT (OB/PWC): plt@epa.gov Cert data available @: www.epa.gov/otaq/certdata.htm Imports Line: 734.214.4100 Email-imports@epa.gov Exemptions: David Hurlin 734.214.4098 CBI: Robert Doyle, 202.343.9258 Doyle.robert@epa.gov Other useful information
Questions http://www.epa.gov/otaq/marinesi.htm For general program questions: Mike Samulski, Samulski.Michael@epa.gov For questions regarding certification: Nydia Reyes-Morales, Reyes-Morales.Nydia@epa.gov