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This presentation discusses the planning, validation, performance, and field liability aspects of EPA-compliant fuel systems for boats. It covers key topics such as diurnal paths, refueling, venting, engine compatibility, compliance with EPA and ABYC regulations, and system components. The examples and pitfalls to avoid are highlighted to ensure thorough validation and performance testing. The audience is informed about ownership of liability, compliance responsibilities, and common pitfalls in fuel system components. The importance of considering future regulations, consulting with manufacturers, and early plant installation verification is emphasized for successful implementation. Stay informed and prepared for EPA audits, compliance, and potential civil penalties.
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EPA Compliant Fuel Systems IBEX Oct 18, 2011 Sean Whelan P.E. 1
Agenda • I have chosen a Diurnal path, now what? • Validation and Testing • Common Pitfalls to Avoid 2
Planning Overview • Diurnal • Refueling • Venting • Engine Compatibility • Validation • Performance • Field Liability • EPA compliance • ABYC Compliance • Validation • Performance Fuel System System Component • 3rd party • Internal Partner 3
Validation • Performance • Field Liability • EPA compliance • ABYC Compliance System Boat is a system Fuel is a sub-system DVPR Validation Plan FMEA Failure Modes 4
Validation • Performance • Field Liability • EPA compliance • ABYC Compliance System Example Validation Plans 5
Validation • Performance • Field Liability • EPA compliance • ABYC Compliance System Example Validation Plans DV 6
Validation • Performance • Field Liability • EPA compliance • ABYC Compliance System Example Validation Plans PV 7
Validation • Performance • Field Liability • EPA compliance • ABYC Compliance System How well does it perform? High RVP fuels? Hot Days? With Jerry Cans? At Marinas? With engine? Etc… 8
Validation • Performance • Field Liability • EPA compliance • ABYC Compliance System Who Owns Liability Who is responsible for -over pressurization -Un-fillable -diurnal performance -Customer Satisfaction -leaks -USCG violation -Engine compatibility -Etc… Beware finger pointing 9
Validation • Performance • Field Liability • EPA compliance • ABYC Compliance System Who Owns EPA & ABYC Compliance Who is responsible for -diurnal performance -EPA filing -EPA Audit -Certificate of Conformance -Record retention -Exemption tracking -ABYC H24 compliance -NMMA inspection -Weathertight/ Watertight -3psi pressure test Beware finger pointing EPA Civil Penalty $32,500 per vessel (40CFR1068.101(a)(1)) 10
Validation • Performance Component Components- Carbon Canister, Deckfill, Fuel Tank, Valves, Pressure Release Valve etc. DVPR Validation Plan FMEA Failure Modes 11 11
Validation • Performance Component Example Validation Plans
Validation • Performance Component How well does component perform?
Validation • Performance Component How well does component perform?
Common Pitfalls to Avoid • Do not assume water will act like gasoline. • Make sure all needs are met, not just one. • If boat refuels well at 70°F, do not assume it fills well at 90°F. • Don’t assume that an initial demonstration means that system will work after years on the water. • Verify plant installation early in process. • Consult with engine manufacturer and measure pressure drop at engine. • Plan for future CARB regulations now. • Do not underestimate the task of implementation.
Thank you Questions? 16
