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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 for Small SI fuel lines, but the physics apply equally to all narrowdiameter fuel lines (that was mostly geared toward eliminating air bubbles that would interfere with permeation rates 

during testing). If there are some marine fuel lines 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 violations 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 not need to be 

USCG A1 approved. My understanding of your explanation below is with your new addition of J2996 is that if we test 

small diameter fuel line for our SORE engines we can use same cert for OB on engine hose 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, Alan 
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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 temperature not 

ambient air temperature. The question on 1060.515(c) we are not sure why this was changed and what the 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 J1527 and its 

referenced in ABYC H24 not sure if this new standard 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 changes/corrections to 40CFR 1060 which are few. 

1060.515.( c) added 2 daily (14 total) measurements 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 existing data remove up to 2 data points per day and average the rest? 

 Our original regs said to use the highest value; we want to align with CARB’s requirement to comply with 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 longer necessary to get a reading every day. Omitting data points is 

allowed, but not required, so it has no impact on validity 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 there will be no need to 

resubmit the file with a different bottom-line number. The cert folks will look for an average value instead of the highest 

value in the data-entry fields for Verify, but it’s quite clear that we won’t reject the application if someone puts in the 

wrong one of those two numbers. Bottom line—no need to worry. 

 

1060.515 (d) EPA has added a new permeation test J2996 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 standard has and still is J1527? Perhaps this is 

directed at small SI engines. If so, it should be stipulated within the document. 

 The new (optional) reference to SAE J2996 is geared toward handheld Small SI equipment. I wouldn’t expect marine 

engines to have such skinny fuel lines. If there are skinny marine fuel lines, we wouldn’t mind if manufacturers use 

those for demonstrating compliance with evap standards. If there is a strong interest in disallowing the use of SAE J2996 

for marine fuel lines, we could do that. I would prefer not to create differentiated requirements where we don’t have a 

technical basis for doing that, but I can understand 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 sections and proper reservoir sizing for hose permeation testing. 

J1527 does have minimum sample hose length and reservoir capacity. I have not read J2996 as of yet to determine what 

it contains, Perhaps John you can get a copy from EPA and circulate to be sure it has parallel requirements to that in 

J1527 
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 The only real change to (e) is to take out the reference 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 systems. 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 level, this seems to be something we should change now as ARB may still 

not allow “design base“ certification without test data support. 

 We continue to believe that fuel temperature is the proper basis for testing marine fuel tanks for diurnal emissions.

Best regards, 

Dan