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

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

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 Marine Evap: NPRM Overview Refueling Spillage: requested comment on potential for industry consensus standards (ABYC) Standard/ Category Hose Permeation Tank Permeation Diurnal Standard level15 g/m 2 /day1.5 g/m 2 /day0.40 g/gal/day Portable tanks a PWC Other tanks b 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

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

9 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 –Hardship provisions

10 Program Details Hose Permeation Diurnal Refueling Spillage Tank Permeation

11 Proposed Diurnal Standards Portable fuel tanks –Self-sealing valve Installed tanks –Trailerable boats (<26 ft) 0.40 g/gal/day °C –Nontrailerable boats 0.16 g/gal/day °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 Temp.Reduction F 64% F 68% F 71% canister in boat 72-96°F

14 Proposed Hose Standards Fuel line –15 g/m 2 /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 Hose: Low Permeation Materials Straight-run hose –Low permeation hose widely available –Fluoroelastomer/fluoroplastic barriers Molded hose and other rubber components –Fluroelastomer construction rubber barrier layer reinforcement cover SAE J1527 Includes specification For 15 g/m 2 /day hose

16 Proposed Tank Standards 1.5 g/m 2 /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 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

18 Tank Permeation: barrier treatment Treatment Tank 1Tank 2Tank 3Average Baseline Sulfonation % reduction % % % % Fluorination % reduction % % % % TreatmentTank 1Tank 2Tank 3Tank 4Avg. Baseline Sulfonation % reduction 7.3 9% 7.8 2% % 7.7 4% 7.5 6% Fluorination % reduction % % % % % HDPE Blow-Molded Fuel Tanks [g/m 2 /day] Crosslink PE Roto-Molded Fuel Tanks [g/m 2 /day]

19 Tank Permeation: barrier platelets % Barrier Permeation [g/m 2 /day] 2% 4% 6% HC HDPE/EVOH Blow-Molded Fuel Tanks [E10] Nanocomposite Fiberglass [E10] Tank Size [gallons] Permeation [g/m 2 /day] 141.0

20 Tank Permeation: continuous barrier Soak Period Tank 1Tank 2 27 weeks weeks weeks Average HDPE adhesive EVOH adhesive IXEF XLPE Thermoformed HDPE/EVOH Fuel Tanks [g/m 2 /day] 29°C, E10 HDPE/IXEF Blow-molded Test Bottles [g/m 2 /day] 29°C, E10 Bottle Permeation

21 Tank Permeation: continuous barrier PA 11 XLPE Tank Outer Shell Permeation 1MDPE0.7 2XLPE0.8 Roto-Molded PE/PA11 Fuel Tanks [g/m 2 /day] 29°C, E10 CBT XLPE Roto-Molded PE/CBT “Single-Shot” Fuel Tanks Manufacturer testing on 5 gallon tanks showed permeation results well below proposed standards

22 Tank Permeation: barrier coating Epoxy coatings applied to XLPE tanks Adhesion treatment (light fluorination) Coating Soak Period E10 Permeation g/m 2 /day None29 weeks Inside Thermocured 15 weeks Outside Thermocured* 15 weeks Outside UV cured additional 6 weeks 0.4 * Inspection showed uneven application of the coating which likely affected permeation results

23 Tank Permeation: alternative materials Tank MaterialPermeation g/m 2 /day, 29°C, E10 V1thermoplastic polyester5.6 C10 C11 C13 impact toughened acetal copolymer* VandarCelcon Alternative Material Fuel Tanks [g/m 2 /day] 29°C, E10

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 Mike Samulski