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### Stout, Alan

From: Stout, Alan Sent: Monday, August 04, 2014 3:16 PM To: Dan Ostrosky; John McKnight Subject: RE: 1060 rewrite EPA

Dan and John, The proposed approach would allow manufacturers to use SAE J2996 for those under-cowl fuel lines with ID < 5.0 mm. The new SAE procedure was intended to apply fo r Small SI fuel lines, but the physics apply equall y to all narrowdiameter fuel lines (that was mostly geared toward eliminating air bubbles that would interfere with p ermeation rates during testing). If there are some marine fuel lin es that are not subject to USCG requirements, then it becomes clear that we should keep the language unchanged to allow SAE J2996 for both land-based and marine products. Since this is an optional procedure, it should be no problem for us to allow that even though USCG requirements may make it an unavailable option for some applications. We could add a note in §1060.515 to warn against USCG viola tions if there is agreement that this is necessary or appropriate.

Alan

From: Dan Ostrosky [mailto:dan_ostrosky@yamaha-motor.com ]
Sent: Monday, August 04, 2014 2:55 PM
To: Stout, Alan; John McKnight Subject: RE: 1060 rewrite EPA

Thanks for the clarifications Alan!!
We do use small diameter fuel line under the cowls of both Carbureted and FI systems. These lines do n ot need to be USCG A1 approved. My understanding of your explanat ion below is with your new addition of J2996 is th at if we test small diameter fuel line for our SORE engines we ca n use same cert for OB on engine h ose where appropriate and would be acceptable to EPA?

Best regards,
Dan O

From: Stout, Alan [ mailto:stout.alan@epa.gov ] Sent: Monday, August 04, 2014 11:20 AM To: John McKnight Cc: Dan Ostrosky Subject: RE: 1060 rewrite EPA

John and Dan, See my responses interspersed below.

Alan

From: John McKnight [ mailto:jmcknight@nmma.org ]
Sent: Monday, August 04, 2014 9:54 AM
To: Stout, Alan2 Cc: Dan Ostrosky Subject: FW: 1060 rewrite EPA

Alan:

Please take a look at Dan’s comments. NMMA is fine with 1060.525. Keep the testing using fuel temperat ure not ambient air temperature. The question on 1060.515(c ) we are not sure why this was changed and what th e effect will be. A little background would help.

1060.515 (d) (e) are referencing J2996. Why? Can we have a copy of that standard. Marine always uses J 1527 and its
referenced in ABYC H24 not sure if this new standar d is harmonized both with J1527 and reviewed by the USCG. We have to put J1527 on our hoses as per USCG.  We can’t share a copy of the new SAE standard for copyright reasons. You could get a copy from SAE, or give me a call to get a better idea of what it includes.

From: Dan Ostrosky [ mailto:dan_ostrosky@yamaha-motor.com ] Sent: Wednesday, July 30, 2014 2:20 PM To: John McKnight; bhilke@parker.com Cc: Lindsey Myers Subject: 1060 rewrite EPA

Good morning John, I have the following comments on the proposed chang es/corrections to 40CFR 1060 which are few.

1060.515.( c) added 2 daily (14 total) measurement s omission. Why is there that much variation in the testing? Also they have added an averaging format. Was it always averaging or highest reading? Will a mfg have to retest or allowed to use existin g data remove up to 2 data points per day and avera ge the rest?  Our original regs said to use the highest value; w e want to align with CARB’s requirement to comply w ith the standard based on average values. The allowance to omit two days of testing is simply to allow for a weekend off for test labs. By moving to average values, it is no l onger necessary to get a reading every day. Omitti ng data points is allowed, but not required, so it has no impact on v alidity of data from earlier model years. Changing from highest value to average value would also not affect validity of carryover data. Test results are still valid and t here will be no need to
resubmit the file with a different bottom-line numb er. The cert folks will look for an average value inste ad of the highest value in the data-entry fields for Verify, but it’s quite clear that we won’t reject the application i f someone puts in the wrong one of those two numbers. Bottom line—no nee d to worry.

1060.515 (d) EPA has added a new permeation test J2 996 of hoses with I.D.’s 5mm or smaller. Does this standard need to be included into H24 or seek USCG approval since the conventional test stan dard has and still is J1527? Perhaps this is directed at small SI engines. If so, it should be s tipulated within the document.  The new (optional) reference to SAE J2996 is geare d toward handheld Small SI equipment. I wouldn’t e xpect marine engines to have such skinny fuel lines. If there a re skinny marine fuel lines, we wouldn’t mind if ma nufacturers use those for demonstrating compliance with evap standa rds. If there is a strong interest in disallowing the us e of SAE J2996 for marine fuel lines, we could do that. I would p refer not to create differentiated requirements whe re we don’t have a technical basis for doing that, but I can understan d that we may want to carve this out as a Small SI item to avoid any confusion about CG and ABYC requirements.

1060.515 (e) EPA has added a comment about small se ctions and proper reservoir sizing for hose permeat ion testing. J1527 does have minimum sample hose length and rese rvoir capacity. I have not read J2996 as of yet to determine what it contains, Perhaps John you can get a copy from E PA and circulate to be sure it has parallel require ments to that in
J15273  The only real change to (e) is to take out the ref erence to alternative test arrangements for narrow- diameter fuel lines since we are addressing that directly in (d). If we allow people to use SAE J2996 only for land -based applications, we might need to keep this in place for marine syst ems. That may not be necessary.

1060.525 It appears that the EPA has maintained fuel temp over air temp on Marine Fuel tanks for diurnal testing but maintained ambient air temps for Permeation. My understanding was this was not a true real world representation that canister mfgs. wanted ambient air. Since ARB will likely adopt the EPA testing but at a lower le vel, this seems to be something we should change no w as ARB may still not allow “design base“ certification without test data support.  We continue to believe that fuel temperature is th e proper basis for testing marine fuel tanks for di urnal emissions.

Best regards,
Dan