Monitoring and Laboratory Division (MLD) January 27, 2005 Mobile 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) Apply to walk-behind mowers with engines > 80 cc to < 225 cc

New SORE Evaporative Requirements (Small Non-Handheld) 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

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

Component Certification Monitoring & Laboratory Division LaMar Mitchell Pat Bennett Jim Watson

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.

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

Component Certification (How it works) Tank is Certified by Component Manf. Certified Components will be Listed on the SORE 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 EOs in Lieu of Component Data

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

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.

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

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

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

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

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

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

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

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.)

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

Component Certification Process (Fuel Hose Case Study) –Verifying that all data points are below the design criteria of 15 grams/meter 2 /day –Drafting a component EO for the hoses –Mailing the component EO to the manufacturer –Adding the component EO to Sore Web Page

Component Certification Questions?

Component Certification Contacts LaMar Mitchell Jim Watson SORE Web Page

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

Typical Off-Road Certification Process Flowchart Manufacturer Submit Letter of Intent Manufacturer Submit 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 Mails EO to Manufacturer ARB Notifies Manufacturer Yes No Yes No

Evaporative Certification Guidance Keith Macias

Evaporative Emissions Certification Guidance General Information Obtain a manufacturer code from the U.S. EPA, through the following Website: –

Evaporative Emissions Certification Guidance General Information Manufacturer contact persons –Designate 1 or 2 authorized representatives ARB contact person –ARB will assign a primary certification contact person for certification assistance

Evaporative Emissions Certification Guidance General 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

Evaporative Emissions Certification 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 [ CP 901 (Certification Procedures) [ TP 901 (Test Procedure) [ 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 Options Permeation 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 Options Exemption May certify by meeting the exemption requirements of –submit a letter of conformance –submit certification application less emission test data

Certification Options Innovative 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) –LaMar Mitchell(916) –Fax(916) Certification contact--MSOD –Kumar Muthukumar(626) Certification submittal--MSOD Mobile Source Operations Division Off-Road Certification/Audit Section Air Resources Board 9480 Telstar Avenue, Suite 4 El Monte, California Attn. Division Chief

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

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 Manufacturer Submit 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 Mails EO to Manufacturer 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, MY –225cc and above: 8.0 g/kW-hr, 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

Exhaust Emission Standards for Spark- Ignition Engines (grams per kilowatt-hour)

(2) The Executive Officer may allow gaseous-fueled (I.e., propane, natural gas) engine families, that satisfy the requirements of the regulations, to certify to either the hydrocarbon plus oxides of nitrogen or hydrocarbon emission standard, as applicable, on the basis of the non-methane hydrocarbon (NMHC) portion of the total hydrocarbon emissions. (4)Applicable to all two-stroke engines. (6) Engines used exclusively to power products which are used exclusively in wintertime, such as snowthrowers and ice augers, at the option of the engine manufacturer, need not certify to or comply with standards regulating emissions of HC+NOx or NMHC+NOx, as applicable. If the manufacturer exercises the option to certify to standards regulating such emissions, such engines must meet such standards. If the engine is to be used in any equipment or vehicle other than an exclusively wintertime product such as a snowthrower or ice auger, it must be certified to the applicable standard regulating emissions of HC+NOx or NMHC+NOx as applicable.

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)