Proposed Evaporative Emission Standards for Boats

1. Proposed Evaporative Emission Standards for Boats Proposed Evaporative 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

2. Evaporative emission types Overview of proposed standards Rulemaking process Program details Questions Outline

3. Evaporative Emission Types Venting emissions (diurnal, hot soak, running loss) Refueling/spillage Permeation (fuel tank, hoses, other)

4. Evap Standards Three decades of automotive evaporative emission control (full vehicle test/standards) Nonroad equipment are just now becoming subject to evaporative emission control

5. 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) New Nonroad Standards

6. 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 • Diffusion

7. Refueling Spillage:requested comment on potential for industry consensus standards (ABYC) Marine Evap: NPRM Overview aDesign standard – self-sealing vent bFuel tanks installed in nontrailerable boats (≥ 26 ft. in length) may meet a standard of 0.16 g/gal/day over an alternative test cycle

8. gather information meet with stakeholders SBREFA Rulemaking Process • publish “Final Rulemaking” Implement FRM (2008) YOU ARE HERE • publish “Notice of Proposed Rulemaking” • lead time • certification Public Comment (closed Aug 3) NPRM (5/18/07) • public hearing • written comment period • address comments Pre- Proposal

9. 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 Hardship provisions Small Businesses

10. Program Details Diurnal Refueling Spillage Hose Permeation Tank Permeation

11. 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 • Tank manufacturer would certify

12. Diurnal: sealed tank with pressure relief

13. 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

14. 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

15. Straight-run hose Low permeation hose widely available Fluoroelastomer/fluoroplastic barriers Molded hose and other rubber components Fluroelastomer construction Hose: Low Permeation Materials cover rubber SAE J1527 Includes specification For 15 g/m2/day hose barrier layer reinforcement

16. 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

17. 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 Tank Permeation: barrier treatment HC HC

18. Tank Permeation:barrier treatment HDPE Blow-Molded Fuel Tanks [g/m2/day] Crosslink PE Roto-Molded Fuel Tanks [g/m2/day]

19. Tank Permeation:barrier platelets HDPE/EVOH Blow-Molded Fuel Tanks [E10] HC Nanocomposite Fiberglass [E10]

20. Tank Permeation:continuous barrier Thermoformed HDPE/EVOH Fuel Tanks [g/m2/day] 29°C, E10 adhesive HDPE EVOH HDPE adhesive HDPE/IXEF Blow-molded Test Bottles [g/m2/day] 29°C, E10 XLPE IXEF

21. Tank Permeation:continuous barrier Roto-Molded PE/PA11 Fuel Tanks [g/m2/day] 29°C, E10 XLPE PA 11 Roto-Molded PE/CBT “Single-Shot” Fuel Tanks Manufacturer testing on 5 gallon tanks showed permeation results well below proposed standards XLPE CBT

22. Epoxy coatings applied to XLPE tanks Adhesion treatment (light fluorination) Tank Permeation: barrier coating * Inspection showed uneven application of the coating which likely affected permeation results

23. Tank Permeation:alternative materials Alternative Material Fuel Tanks [g/m2/day] 29°C, E10 Vandar Celcon

24. 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

25. 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

26. Questions http://www.epa.gov/otaq/marinesi.htm Mike Samulski samulski.michael@epa.gov