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

Monitoring and Laboratory Division (MLD) January 27, 2005Mobile Source Operations Division (MSOD)California Air Resources Board

Small Off-Road Engines/Equipment (SORE) Emission Regulations

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

Outline

• Evaporative Certification Process > 80 cc– Process Flow-chart– Guidance and Clarifications– Templates and Forms

• 2005 & Later SORE Exhaust Standards• Exhaust Certification Guidance

2006 & Later SORE Evaporative Emissions Requirements

Danny Tran

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

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

New SORE Evaporative Requirements(Handheld)

• Apply to small engines < 80 cc• Typical equipment includes string trimmers,

leaf blowers, and chainsaws

New SORE Evaporative Requirements(Small Non-Handheld)

Performance RequirementsSection 2754(a)

Design Requirements Section2754(b)

EffectiveDate

Model Year

Diurnal Standard GramsHC/day

Fuel Hose PermeationGrams ROG/m2/day

2006 None 152007 and

20081.3 N/A

2009 1.0 N/A

• Apply to walk-behind mowers with engines > 80 cc to < 225 cc

New SORE Evaporative Requirements(Small Non-Handheld)

PerformanceRequirements

Section2754(a)

Design Requirements Section 2754(b)

EffectiveDate

Model Year

DiurnalStandard

Grams HC/day

Fuel HosePermeation

GramsROG/m2/day

Fuel TankPermeation

GramsROG/m2/day

Carbon Canister orEquivalent

Butane WorkingCapacity

Grams HC2006 None 15 None None

2007 through2011

1.20 +0.056*tank vol.

(liters)15 2.5 Specified in TP-902

20120.95 +

0.056*tank vol.(liters)

15 1.5 Specified in TP-902

• Apply to equipment other than walk-behind mowers with engines > 80 cc to < 225 cc

New SORE Evaporative Requirements(Large Non-Handheld)

• Apply to large equipment like lawn tractors and generators with engines > 225 cc


Section2754(a)


EffectiveDate

Model Year

DiurnalStandard

Grams HC/day

Fuel HosePermeation

GramsROG/m2/day

Fuel TankPermeation

GramsROG/m2/day

Carbon Canister orEquivalent

Butane WorkingCapacity

Grams HC2006 and

2007None 15 None None

20081.20 +



20131.20 +



New SORE Evaporative Requirements(engines > 225 cc)

Small Production Volume Tank Exemption


Section2754(a)


EffectiveDate

Model Year

DiurnalStandard

Grams HC/day

Fuel HosePermeation

GramsROG/m2/day

Fuel TankPermeation

GramsROG/m2/day

Carbon Canister or EquivalentButane Working Capacity

Grams HC

2010 None 15 None Specified in TP-902

• Total identical tank sales in California of 400 or fewer units per model year

Component Certification

Monitoring & Laboratory Division

LaMar MitchellPat BennettJim Watson


• 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.


• 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

Component Certification(How it works)

Tank is Certified by Component Manf.

Certified Components will be

Listed on theSORE Web Page

Hose is Certified by Component Manf.

Canister is Certified by Component Manf.

Engine/Equipment Manf.References Components

on Certified List

ARB Certifies Engine/Equipment

Using Component EOsin Lieu of Component Data


• 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

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.


• Components Tested– Fuel hose - smallest inside diameter

– Fuel Tank - smallest volume to surface area ratio

– Carbon canister - canister sized for the largest fuel tank


• 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


• 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


• 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

Component Certification Process FlowchartComponent Manf. Tests Component

Component Manf. Submits Letter

with Data to ARB

ARB Reviews LetterFor Completeness

ARB Issues Component EOand Adds Component

to Certified List

ARB Requests Further Info. From Manufacturer

Within 30 Days

ARB Mails EOto Manufacturer

Yes

No

Within 90 days

ARB Approves or Denies Component

EO

Approves EO

Denies EOARB Mails denial letter

to Manufacturer

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


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


• 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

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.)


After receiving the request, ARB processes the certification application by:

– Logging the date of receipt

– Reviewing the application for completeness

– Notifying applicant


– 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


Questions?

Component CertificationContacts

LaMar Mitchell 916-445-9371

[email protected]

Jim Watson 916-327-1282

[email protected]

SORE Web Page

http://www.arb.ca.gov/msprog/offroad/sore/sore.htm

Evaporative Certification Process Flow-chart (< 80cc)

Alan Chow

Typical Off-Road Certification Process Flowchart

Manufacturer Submit Letter of

Intent

ManufacturerSubmit Complete

Application

ARB Reviews Application For Completeness

ARB Evaluates Application

ARB Issues Executive Order

ARB Requests Further Info. From Manufacturer Up to 30 Days

Up to 90 Days


ARB Notifies Manufacturer

Yes

No

Yes

No

Evaporative Certification Guidance

Keith Macias

Evaporative EmissionsCertification GuidanceGeneral Information

• Obtain a manufacturer code from the U.S. EPA, through the following Website:

– www.epa.gov/OMSWWW/cfeis.htm


• Manufacturer contact persons– Designate 1 or 2 authorized representatives

• ARB contact person– ARB will assign a primary certification contact

person for certification assistance


• 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

Evaporative EmissionsCertification Guidance for Engines

Less Than or Equal to 80 cc

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]

Applicability

• The evaporative standards apply to gasoline fueled 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

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)

Certification OptionsExemption

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

Certification OptionsInnovative Product

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

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

Certification Application Submittal

• Letter of Intent• Cover letter• Application

– Certification Summary– Supplementary Information– Field Data Sheet

• Permeation emissions certification label• Permeation emissions warranty statement

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)

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.

Additional Contacts• Test procedures/Innovative technology certification--MLD

– James Watson (916) 327-1282 [email protected]– LaMar Mitchell (916) 445-9371 [email protected]– Fax (916) 322-2444

• Certification contact--MSOD– Kumar Muthukumar (626) 575-7040 [email protected]

• 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

Evaporative Certification Templates and Forms (< 80cc)

Dr. Paul Adnani

SMALL OFF-ROAD EQUIPMENT FUEL TANK CERTIFICATION (APPLICABLE TO ENGINES/EQUIPMENT 80 cc)

Certification Summary Sheet

Date Created: Date Modified:

1. Model Year: 3. Application Type: 2 a. Manufacturer: 4. Exhaust/Evaporative Family Name: 2 b. Contact Person: 5. Executive Order: 2 c. Production Plant Location: 6. Confidential Information a) Projected California sales(units): __________ b) Projected 50-State Sales (units): _________ c) Introduction into commerce date: _________ 7. Exemptions a) Is this an exempt fuel tank under section 2766(a) ? Yes* No b) If exempt, specify the tank type: Metal tank Coextruded multilayer tank Structurally integrated nylon fuel tank Innovative Product Executive Order #: ___________ * For exempt tanks, permeation data is not required to be submitted in the certification application (Go to #15). 8. Test Information a) New Testing? _____ e) If carry over/carry across, from evaporative family:______________ b) Test Engine or Equipment Model: __________ f) Test Equipment ID: ___________ c) Test Fuel: _____________ d) Test Procedure: _____________ g) Alternate Test Procedure approval number: __________

9. Special Test Equipment

Official Fuel Tank Permeation Test Results**

10. Test No.

11. Type

(Certification (CTG) or

Confirmatory (RTG))

12. Test

Completion Date

13. Certification Test Result (gr/m2/day)

14. Fuel Tank

Permeation Standard (gr/m2/day)

** Permeation rates must be reported to two significant digits. 15. Remarks: 16. Equipment Type:

___ Walk-Behind Lawnmower ___ Generator Set ___ Ice Auger ___ Riding Mower ___ Snowblower ___ Commercial Turf ___ Tractor ___ Non-Backpack Blower ___ Edger ___ Compressor ___ Backpack Blower ___ Brushcutter ___ Pump ___ Line Trimmer ___ Chainsaw ___ Hedge Trimmer ___ Pressure Washer ___ Leaf Blower/Vacuum ___ Stump Beater ___Tiller ___ Other_____________________

Processed By: Date Processed Reviewed By: Date Reviewed:

Supplementary Information

MODEL SUMMARY (Use an asterisk (*) to identify “worst-case” engine or equipment model used for certification testing.)

19. Sales Codes

(Check all appropriate)

17.

Worst Case

18.

Engine or Equipment

Model Calif. Only

49-State

50-State

20.

Fuel Tank Vol.

(liters)

21.

Fuel Tank Internal

Surf. Area (m2)

22. Fuel Tank Material: ___________________________________________________________ 23. Fuel Tank Treatment Type: _____________________________________________________ 24. Fuel Tank Unique Properties: ___________________________________________________ 25. LABELING: Permeation emission label format approved? No____ Yes ___ If yes, reference approval:___________

Sample label attached? No____ Yes (put label in #28)____ 26. WARRANTY: Fuel Tank emission warranty approved? No___ (Provide full warranty statement in #29) Yes ___ (Reference approval: _______________ ) 27. Have any changes been made since the last approval? No____ Yes ____ If yes, provide an explanation

of the changes: ___________________________________________________________________________________ ___________________________________________________________________________________ ___________________________________________________________________________________ ___________________________________________________________________________________ ___________________________________________________________________________________

28. PERMEATION EMISSION LABEL INFORMATION

29. FUEL TANK EMISSION WARRANTY STATEMENT

Field Data Sheet (Trip Blank Correction)

30. Tank Manufacturer:

31. Tank I.D: 32. Tested By: 33. Water Bath Test (pass/fail): 34. Tank Internal Surface Area (meter2): Full Tank Data

35. Start Date

36. Start Time

37. End Date

38. End Time

39. Initial Weight Wif (grams)

40. Final Weight Wff (grams)

41. Difference Df (grams)

42. Weight Loss Wl (grams)

Wl = (Wif – Df), Df = (Wff + De), De = (Wie – Wfe)

Empty Tank Data 43.

Start Date

44. Start Time

45. End Date

46. End Time

47. Initial Weight Wie (grams)

48. Final Weight Wfe (grams)

49. Difference De (grams)

50.

%RH

51. Baro. Pres.

52. ADDITIONAL INFORMATION AND COMMENTS (for tanks soaked less than 140 days, submit fuel tank soak data, Figure 1 of TP-901 (Test Procedure for Determining Permeation Emission from Small Off-Road Engines and Equipment Fuel Tanks) and the calculated correlation coefficient. This applies to tanks that are soaked at non-elevated temperature (30 °C 10 °C) for less than 140 days and tanks with a nominal wall thickness of greater than 0.2” (5 mm) that are soaked at an elevated temperature (40 °C 2 °C) for less than 140 days):

Evaporative Certification Templates and Forms (< 80cc)

Questions?

Evaporative Certification Process Flow-chart (> 80cc)

Alan Chow

Typical Off-Road Certification Process Flowchart

Manufacturer Submit Letter of

Intent

ManufacturerSubmit Complete

Application

ARB Reviews Application For Completeness

ARB Evaluates Application

ARB Issues Executive Order

ARB Requests Further Info. From Manufacturer Up to 30 Days

Up to 90 Days


ARB Notifies Manufacturer

Yes

No

Yes

No

Evaporative Certification Guidance(> 80cc)

Joseph Jegede

Outline

• Engine and Equipment Categories• Evaporative System Certification

– Design-Based Certification– Performance-Based Certification

Engine and Equipment Categories

• Walk-Behind Mowers (WBMs) > 80 cc - < 225 cc

• Other Engines/Equipment > 80 cc - < 225 cc

• All Engines/Equipment > 225 cc

Evaporative System Certification

• Engines or equipment must be certified under one of the following options:

– Design-Based Option, 13 CCR 2754 (b)

- Compliance demonstrated by using components that meet specified design requirements

- Likely option for equipment manufacturers that purchase engines without fuel tanks

– Performance-Based Option , 13 CCR 2754 (a)

- Durability required prior to diurnal test

- Compliance demonstrated through diurnal test

- Likely option for engine manufacturers that sell engines with complete evaporative systems

• Optional Performance Standards

• Engines/Equipment Fuel Cap Performance standards

Design-Based Certification

• What is design-based certification?

– Design-based certification is where engine or equipment manufacturers use certified fuel hoses, fuel tanks, and carbon canisters, that meet specific design requirements and have received component EOs, in evaporative emission control systems.

– Alternatively, a manufacturer may test its own components using applicable test procedures and generate test data showing compliance with applicable design requirements. Worst case components must be tested.

Design-Based Certification

• How is design-based certification useful?

– Allows manufacturers to show compliance without testing the complete evaporative system in a Sealed Housing for Evaporative Determination Enclosure (SHED)

– Manufacturer certifying by design-based will most likely use pre-certified components that have been issued component EO by ARB to avoid actual component testing and providing test data

Design-Based Certification Process

• Application must include:– Component EO numbers in lieu of component test

data, or– Provide hose and tank permeation and canister

working capacity data– Running loss determination– Engineering description of evaporative control system– Worst Case Determination– Sample engine or equipment label– Emission Control Warranty Statements

Worst Case Determination

• Design-Based

– Fuel hose - smallest inside diameter– Fuel Tank - smallest volume to surface area ratio– Carbon canister - canister sized for the largest fuel

tank

Performance-Based Certification

• What is performance-based certification?

– Performance-based certification is where compliance with the evaporative requirements are demonstrated by diurnal testing of engines or equipment with complete evaporative emission systems in a SHED.

– The test procedures for diurnal testing can be found in TP-902.

Performance-Based Certification

• How is performance-based certification useful?

– “Gold Standard” for demonstrating compliance.

– A SHED test can detect high emitting evaporative system components and connectors that may go undetected in a design-based certification.

– Manufacturers can take advantage of averaging and banking provisions within the regulations to optimize production.

Performance-Based Certification(Durability)

• Durability test must actuate control valves, cables, linkages, where applicable for a minimum of 5000 cycles

• Pressure/Vacuum test must be performed• Slosh Test must be performed• Carbon Canister thermal and vibration

exposure must be performed

Optional Performance Standards(Blue Sky Label)

• Optional Evaporative Emission Standard– Manufacturer certifying to an optional performance

standard would be allowed to affix a Blue Sky Label on their equipment

- In 2007 and later, for > 80 cc to < 225 cc, diurnal emissions shall not exceed 0.5 grams THC/day.

- In 2008 and later, for > 225 cc, diurnal emissions shall not exceed 1.0 grams THC/day.

Performance-Based Certification Process

• Application must include:– Cover Letter/Statement of Compliance– Diurnal emissions data– Running loss determination– Engineering description of evaporative control

system– Worst Case Evaporative Emission Control System

Determination– Certification Averaging and Banking Worksheet, if

applicable– Sample engine or equipment label– Emission warranty

Worst Case Determination

• Performance-Based

– Estimate evaporative emissions (vented and permeation) from system components

– Worst case is system with the evaporative emissions closest to its applicable standard for all models within the family

Fuel Cap Performance Standard

• For > 80 cc to < 225 cc (2007 and Later)• For > 225 cc (2008 and Later)• Requirements:

– Fuel cap must be permanently tethered to the tank, equipment, or engine

– Fuel cap must provide a vapor seal– Fuel cap must be designed to provide physical

and/or audible feedback to the user that a fuel tank vapor seal is established.

Evaporative Certification Templates and Forms (> 80cc)

Ha Le

2005 & Later SORE Exhaust Standards

Michael Pham

2005 And Later Handheld Exhaust Emission Standards

Tier 3

• Align with most stringent U.S. EPA HC+NOx standard for engines < 50 cc– 50 g/kW-hr– 30% reduction from current standard– California exhaust emission standards for

displacement between 50 to 80 cc HC+NOx: 72 g/kW-hr CO: 536 g/kW-hr PM(*): 2 g/kW-hr * Applicable to all two-stroke engines

2007 And 2008 Non-Handheld Exhaust Emission Standards

Tier 3

• Exhaust Emission Standards:– >80 - <225cc: 10.0 g/kW-hr, 2007+ MY– 225cc and above: 8.0 g/kW-hr, 2008+ MY

• Standards based on the use of a catalytic converter

“Blue Sky” Engine Standards

• Voluntary

• HC+NOx levels 50% of Tier 3 standard

• Provides opportunity for clean label and

incentives

• Includes zero-emission engine eligibility

Additional Changes to Exhaust Regulations

• Alignment with U.S. EPA– < 25 hp vs. < 19 kW– 1000 hour durability option– Test procedures

• Handheld limit raised to 80cc

Additional Changes to Exhaust Regulations

• Warranty Defects Reporting– Voluntary/Ordered Recall– Included in Exhaust and Evaporative Program

• Additional text to clarify use of engine cooling during testing

MYDisplacement

(cc)Durability

Periods (hours) HC + NOx

(2), (6)CO PM

< 50 50/125/300 50 536 2.0 (4)

50-80, inclusive 50/125/300 72 536 2.0 (4)

> 80 to < 225 125/250/500 16.1 549> 80 to < 225 N/A 16.1 467

> 225 125/250/500 12.1 549>80 to < 225 125/250/500 16.1 549

> 225 125/250/500 12.1 549> 80 to < 225 125/250/500 10.0 549

> 225 125/250/500 12.1 549> 80 to < 225 125/250/500 10.0 549

> 225 125/250/500/1000 8.0 549

2005and later

2008 and later

2007

2006

2005

Exhaust Emission Standards for Spark-Ignition Engines

(grams per kilowatt-hour)

2005 & Later SORE Exhaust Guidance and Clarifications

Geeta Osborn

Confirmatory Testing

• Regulations provide authority to request Confirmatory Testing (CT)

• If a manufacturer submits only one certification test result, then CT is required if:– Certification level is >85% of the standard– CT result must be below the standard

• Example, if the standard is 16.1, then:– 16.1 x 0.85 = 13.7– CT done for certification levels above 13.7

Confirmatory Testing

• CT may be performed voluntarily by manufacturer without prior ARB notification

• All tests must be reported in the certification application

Auxiliary Engine Cooling Systems

• Applicability - all 2005 & later SORE EFs• All current applications received must include

the AECS questionnaire (available on ARB webpage)

• Evaluation of AECS is based on comparison to in-use operating conditions

• Manufacturers are encouraged to submit the AECS questionnaire prior to certification

Engine Family Name Carryover

• EF name must be updated on the emission label every year with the 2007 MY

• Verifying if products are legal for sale is difficult– Verification is delayed when serial number must be

located on the engine and provided to mfr for MY identification

– ARB relies on accuracy and availability of mfr records

• New Evaporative requirements– non-compliant engines that are missing evap. labels

and require evap. controls will not be readily identifiable

Tamper Resistance Method Review

• TRMs prevent consumers from making unauthorized in-use changes to manufacturer-certified calibrations

• Previously approved TRMs will be periodically reevaluated to assure their continued effectiveness

Tamper Resistance Method Review

• Evaluation criteria includes but is not limited to:– need for special tools for access and/or adjustment– cannot be tampered with using common tools– physical ease of access to the adjustable parameter– attempts to adjust parameter ineffective or result in

unsatisfactory engine operation– physical device that controls the adjustable parameter

is restricted from movement beyond engine’s design range (e.g. limiter caps)

Documents

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