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

1
Small Off-Road Engines/Equipment (SORE) Emission
Regulations
Monitoring and Laboratory Division (MLD)
January 27, 2005 Mobile Source
Operations Division (MSOD) California Air
Resources Board
2
Outline

• Introduction
• 2006 Later SORE Evaporative Requirements
• Evaporative Component Certification/Innovative
  Products
• Evaporative Certification Process lt 80 cc
• Process Flow-chart
• Guidance and Clarification
• Templates and Forms

3
Outline

• Evaporative Certification Process gt 80 cc
• Process Flow-chart
• Guidance and Clarifications
• Templates and Forms
• 2005 Later SORE Exhaust Standards
• Exhaust Certification Guidance

4
2006 Later SORE Evaporative Emissions
Requirements

• Danny Tran

5
New SORE Evaporative Requirements(Applicability)

• Engines lt 19 kW
• Engines grouped by displacement
• lt 80 cc, handheld
• gt 80 cc to lt 225 cc, small non-handheld
• gt 225 cc, large non-handheld
• Lawn and garden and small industrial equipment
• Two and four-stroke engines

6
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

7
New SORE Evaporative Requirements(Handheld)

• Apply to small engines lt 80 cc
• Typical equipment includes string trimmers, leaf
  blowers, and chainsaws

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New SORE Evaporative Requirements(Small
Non-Handheld)

• Apply to walk-behind mowers with engines gt 80
  cc to lt 225 cc

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New SORE Evaporative Requirements(Small
Non-Handheld)

• Apply to equipment other than walk-behind mowers
  with engines gt 80 cc to lt 225 cc

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New SORE Evaporative Requirements(Large
Non-Handheld)

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

11
New SORE Evaporative Requirements(engines gt 225
cc)Small Production Volume Tank Exemption

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

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Component Certification

• Monitoring Laboratory Division
• LaMar Mitchell
• Pat Bennett
• Jim Watson

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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.

14
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

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Component Certification(How it works)
Tank is Certified by Component Manf.
Hose is Certified by Component Manf.
Canister is Certified by Component Manf.
Certified Components will be Listed on the SORE
Web Page
Engine/Equipment Manf. References Components on
Certified List
ARB Certifies Engine/Equipment Using Component
EOs in Lieu of Component Data
16
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 EE

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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.

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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

19
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

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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

21
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

22
Component Certification Process Flowchart
Component Manf. Tests Component
Component Manf. Submits Letter with Data to ARB
ARB Reviews Letter For Completeness
No
ARB Requests Further Info. From Manufacturer
Within 30 Days
Yes
ARB Approves or Denies Component EO
Denies EO
ARB Mails denial letter to Manufacturer
Within 90 days
Approves EO
ARB Issues Component EO and Adds Component to
Certified List
ARB Mails EO to Manufacturer
23
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

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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 40C or higher with
  CERT fuel, Indolene, CE10, or CM15

25
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 40C with CE10
  following SAE J 1737)
• a signature by authorized company representative

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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 hoses
  integrity (maximum skin temperature, kinking
  radius, etc.)

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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

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Component Certification Process(Fuel Hose Case
Study)

• 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

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Component Certification

• Questions?

30
Component CertificationContacts

• LaMar Mitchell 916-445-9371
• lmitchel_at_arb.ca.gov
• Jim Watson 916-327-1282
• jwatson_at_arb.ca.gov
• SORE Web Page
• http//www.arb.ca.gov/msprog/offroad/sore/sore.htm

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Evaporative Certification Process Flow-chart (lt
80cc)

• Alan Chow

32
Typical Off-Road Certification Process Flowchart
Manufacturer Submit Letter of Intent
Manufacturer Submit Complete Application
ARB Reviews Application For Completeness
No
ARB Requests Further Info. From Manufacturer
Up to 30 Days
Yes
ARB Evaluates Application
No
ARB Notifies Manufacturer
Up to 90 Days
Yes
ARB Issues Executive Order
ARB Mails EO to Manufacturer
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Evaporative Certification Guidance

• Keith Macias

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Evaporative EmissionsCertification
GuidanceGeneral Information

• Obtain a manufacturer code from the U.S. EPA,
  through the following Website
• www.epa.gov/OMSWWW/cfeis.htm

35
Evaporative EmissionsCertification
GuidanceGeneral Information

• Manufacturer contact persons
• Designate 1 or 2 authorized representatives
• ARB contact person
• ARB will assign a primary certification contact
  person for certification assistance

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Evaporative EmissionsCertification
GuidanceGeneral 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

37
Evaporative EmissionsCertification Guidance for
EnginesLess Than or Equal to 80 cc
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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/rega
  ct/sore03/tp901.pdf
• Certification guidelines (guidance and examples)
  weblink to be posted

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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

40
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)

41
Certification OptionsExemption

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

42
Certification OptionsInnovative Product

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

43
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

44
Certification Application Submittal

• Letter of Intent
• Cover letter
• Application
• Certification Summary
• Supplementary Information
• Field Data Sheet
• Permeation emissions certification label
• Permeation emissions warranty statement

45
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)

46
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.

47
Additional Contacts

• Test procedures/Innovative technology
  certification--MLD
• James Watson [phone] jwatson_at_arb.ca.gov
• LaMar Mitchell [phone] lmitchel_at_arb.ca.gov
  
• Fax [phone]
• Certification contact--MSOD
• Kumar Muthukumar [phone] cmuthuku_at_arb.ca.go
  v
• 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

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Evaporative Certification Templates and Forms (lt
80cc)

• Dr. Paul Adnani

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Evaporative Certification Templates and Forms (lt
80cc)

• Questions?

58
Evaporative Certification Process Flow-chart (gt
80cc)

• Alan Chow

59
Typical Off-Road Certification Process Flowchart
Manufacturer Submit Letter of Intent
Manufacturer Submit Complete Application
ARB Reviews Application For Completeness
No
ARB Requests Further Info. From Manufacturer
Up to 30 Days
Yes
ARB Evaluates Application
No
ARB Notifies Manufacturer
Up to 90 Days
Yes
ARB Issues Executive Order
ARB Mails EO to Manufacturer
60
Evaporative Certification Guidance(gt 80cc)

• Joseph Jegede

61
Outline

• Engine and Equipment Categories
• Evaporative System Certification
• Design-Based Certification
• Performance-Based Certification

62
Engine and Equipment Categories

• Walk-Behind Mowers (WBMs) gt 80 cc - lt 225 cc
• Other Engines/Equipment gt 80 cc - lt 225 cc
• All Engines/Equipment gt 225 cc

63
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

64
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.

65
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

66
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

67
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

68
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.

69
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.

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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

71
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 gt 80 cc to lt 225 cc,
  diurnal emissions shall not exceed 0.5 grams
  THC/day.
• In 2008 and later, for gt 225 cc, diurnal
  emissions shall not exceed 1.0 grams THC/day.

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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

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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

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Fuel Cap Performance Standard

• For gt 80 cc to lt 225 cc (2007 and Later)
• For gt 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.

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Evaporative Certification Templates and Forms (gt
80cc)

• Ha Le

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2005 Later SORE Exhaust Standards

• Michael Pham

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2005 And Later Handheld Exhaust Emission
StandardsTier 3

• Align with most stringent U.S. EPA HCNOx
  standard for engines lt 50 cc
• 50 g/kW-hr
• 30 reduction from current standard
• California exhaust emission standards for
  displacement between 50 to 80 cc
• HCNOx 72 g/kW-hr
• CO 536 g/kW-hr
• PM() 2 g/kW-hr
• Applicable to all two-stroke engines

78
2007 And 2008 Non-Handheld Exhaust Emission
StandardsTier 3

• Exhaust Emission Standards
• gt80 - lt225cc 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

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Blue Sky Engine Standards

• Voluntary
• HCNOx levels 50 of Tier 3 standard
• Provides opportunity for clean label and
  incentives
• Includes zero-emission engine eligibility

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Additional Changes to Exhaust Regulations

• Alignment with U.S. EPA
• lt 25 hp vs. lt 19 kW
• 1000 hour durability option
• Test procedures
• Handheld limit raised to 80cc

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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

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Exhaust Emission Standards for Spark-Ignition
Engines (grams per kilowatt-hour)
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• (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 HCNOx
  or NMHCNOx, 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 HCNOx or NMHCNOx as applicable.

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2005 Later SORE Exhaust Guidance and
Clarifications

• Geeta Osborn

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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 gt85 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

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Confirmatory Testing

• CT may be performed voluntarily by manufacturer
  without prior ARB notification
• All tests must be reported in the certification
  application

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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

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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

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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

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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
  engines design range (e.g. limiter caps)