EPA-420-R-74-107 Mobile Source Evaporative Emissions by C. Do'n Paulsell June 1974 Environmental Protection Agency Office of Air and Waste Management Programs Office of Mobile Source Air Pollution Control Emission Control Technology Division Regulations Development and Support Branch Ann Arbor, Michigan ------- Executive Summary of Evaporative Emissions Document The paragraphs below summarize the important points contained in each of the three parts of the attached document on mobile source evaporative emissions. Position Paper: Evaporative emissions have been studied and measured since 1958. Federal regulations became effective in 1971 to reduce evaporative emissions. The Federal canister test procedure which has been used with those regulations indicates that vehicles are emitting about 0.13 grams/mile from fuel evaporative processes. Tests have shown that this procedure does not adequately cover all potential sources and does not accurately measure the true magnitude of all evaporative emissions. An improved procedure (SAE J171) involves placing the vehicle inside an enclosure where all emissions can be measured on a mass basis by monitoring the concentration of hydrocarbons in a known volume. The SAE J171 test procedure indicates that 1972 model vehicles (controlled) are actually emitting about 1.87 grams/mile. If evaporative regulations are notfcchanged prior to implementation of the statutory exhaust emission hydrocarbon standard of 0.41 grams/ mile, evaporative emissions will constitute the dominant hydrocarbon emission. The total hydrocarbon emissions would then exceed the established reductions necessary to meet the air quality standards for oxidant levels. Adoption of the SAE 0171 enclosure procedure will require that necessary changes be made in evaporative control systems to reduce evaporative emissions. However, to simply replace the canister test with the enclosure test would be very costly. Data indicate this implementation plan is unnecessary. By developing selection criteria for evaporative system families, the number of required tests could be reduced to less than 1000 per year, and the enclosure procedure could be implemented in a cost effective manner. A program plan has been outlined to achieve the implementation of the enclosure procedure by December, 1975 (Start of 1977 MY testing). Program Plan: A data base of 202 enclosure tests exists for a vehicle population covering 1957-72 model year vehicles. The program plan provides for supplementing that data with tests that specifically look for the cause of the emissions. A contract will be negotiated to assess evaporative sources and to develop the cost/effectiveness analysis for various evaporative control approaches. Communications will be established with the automobile industry to maximize their lead time for hardware development and to solicit their comments and data on our approach to revised regulations. ------- -2- This program will require the assignment of high priority in order to accomplish the critical deadlines scheduled in FY75. Costs, manpower, and tasks have been itemized and summarized. Technical Appendix: The various specifications used in the enclosure procedure are discussed. Simulation of real world conditions related to time, temperature, fuel volumes, and types of fuel are documented. The four phases of the evaporative process, (diurnal losses, running losses, hot soak losses, and refueling losses) have been discussed. The preferred measurement and recommended calculation procedures are covered. A complete list of references on the subject of mobile source evaporative emissions has been compiled.. ------- TABLE OF CONTENTS A. A Position Paper on Evaporative Emissions Page I. Introduction II. Background on Evaporative Emissions Regulations III. Evaporative Emissions Test Procedures 9 A. Canister Test Procedure B. Enclosure Test Procedure IV. Implementation Alternatives V. Problems of Implementation VI. Conclusions VII. Recommendations 10 14 15 16 16 17-19 VIII. Closure IX. References B. A Program Plan for Evaporative Emissions Regulation Development I. Title 1 II. Responsibility 1 III. Problem Assessment 1 IV. Purpose 1 V. Objectives 1 VI. Approach/Scope of Work 1 VII. Milestones/Accomplishments 1 VIII. Current Status 2 IX. Technical Support 2 X". Coordination and Manpower 2 XI. Program Description and Timetable 2 C. A Technical Appendix on the Measurement of Evaporative Emissions I. Introduction 1 II. Summary Statement and Background 1 III. Diurnal Emissions 2 IV. Running Losses 8 V. Hot Soak Emissions 9 VI. Measurements and Calculations 10 VII. Closure 11 VIII. Charts and Graphs 12-19 IX. References 20-22 ------- A POSITION PAPER ON EVAPORATIVE EMISSIONS I. Introduction: This document summarizes the background and the present state of knowledge regarding evaporative emissions from light duty motor vehicles. It discusses the effectiveness of our present evaporative emissions regulations and explores the revision of those regulations to facilitate more accurate measurement, assessment, and control of evaporative emissions. The purpose of this document is: to present the facts that define the problem, to discuss the test techniques available as regulatory procedures, to weigh the pros and cons of actions which may effect a solution to the problem, and to outline the conclusions and recommenda- tions that will lead to the revision of those regulations. II. Background on Evaporative Emissions Regulations: Section 202(a) of the Clean Air Act requires the Administrator to prescribe regula- tions applicable to motor vehicle emissions which contribute to air pollution and endanger public health or welfare. Hydrocarbons emitted to the atmosphere from motor vehicles have been judged as a pollutant requiring regulation. Hydrocarbons are generated from three processes: gaseous,, products from combustion, engine crankcase blowby, and valors from fuel evaporation. These emissions contribute to the formation of smog. References (4,19,20,23) at the end of this paper discuss this process and the interactions of the components. Basically, the conclusions have been that it is neces- sary to reduce both hydrocarbons and oxides of nitrogen to reduce the oxidant levels produced by the photochemical reactions; furthermore, a reduction in hydrocarbons has been shown more effective than an equal reduction in oxides of nitrogen. This fact underscores.the importance of hydrocarbon regulation. The preceding paragraph illustrates the importance of controlling al1 hydrocarbon emissions, but this document has been written to assess one source of hydrocarbons, evaporative emissions. Studies and measure- ments on evaporative losses have been documented since 1958. One of the first studies (1 ) which deals with carburetor losses v/as prompted by interest in idling performance, fuel economy, and air pollution. Throughout the mid-sixties, many studies were conducted to quantify the magnitude, mechanism, and sources of fuel vapor emissions. At the time of this research vehicles were uncontrolled; fuel tanks had vented caps, carburetors had externally vented float bowls, and some engines had vented crankcases. Basically, the emissions have been differentiated into three categories: diurnal breathing losses, running losses, and hot soak losses. Diurnal breathing, losses are caused by the daily temperature rise and resultant expulsion of vapors from the fuel tank vent. Running losses are similar to the diurnal losses, except that the temperature rise occurs during vehicle operation from engine waste heat flowing over the fuel tank and carburetor. Hot soak losses are caused ------- -2- by boiling in the carburetor bowl after engine shutdown. A comprehen- sive discussion of the mechanisms and parameters related to these emissions has been written as a technical appendix to this paper. Several test techniques for measuring these specific source loca- tions were developed (16) and used to assess the amount, composition, and influencing factors on the fuel evaporative emissions. The tech- nique most widely used was vapor condensation in a cold trap immersed in a slurry of dry ice, alcohol, and acetone to maintain a temperature of -80°F. One AMA (Automobile Manufacturer's Association) program (15) extensively tested 5 vehicles and reported carburetor losses as high as 50 grams/test. Vehicle design was the largest single factor affect- ing carburetor losses. The program also reported tank emissions as high as 125 grams/day, with 69% of the losses occurring during vehicle operation (running loss). Fuel volatility and maximum temperature had the major impact on these tank emissions. After the influence of fuel volatility and temperature had been assessed, a test procedure was developed that standardized the fuel and fuel temperature variations,. Additional data were collected using this procedure and interim standards were proposed by the California Motor Vehicle Pollution Control Board in November, 1966. Their stan- dards v/ere based on an 80% reduction of baseline emissions from un- controlled vehicles. The baseline emissions were consolidated from several references (25,2Ł,21) and v/sre set at average values of 30 grams per day from the diurnal and 10 grams per test from the hot soak. Hence, California standards were 6 grams and 2 grams for the respec- tive diurnal and hot soak tests. One system to control evaporative emissions had been in the develop- ment phase since 1960. It was the forerunner of the present control system and basically incorporated a canister of activated charcoal that was plumbed to the tank and carburetor vents and operated on a controlled adsorption-desorption principle. A report (8 ) on the effectiveness of this system concluded that vehicles controlled by this system achieved 90-100% reduction in emissions. This reduction has been shown dependent on the test procedure used to measure the emissions, The California standards were never finalized as they had been proposed. Three months later, February 4, 1967, the Federal Government (HEW) issued a notice of proposed standards for evaporative emissions (27). The standard proposed, 2 grams per test, was a composite sample representing the total diurnal and hot soak emissions. The test pro- _ cedure in this proposal involved running an exhaust emissions test on a dynamometer, fueling the vehicle with cold fuel, moving the vehicle into a sealable enclosure, and monitoring the hydrocarbon concentration within the enclosure to determine the mass of fuel vapors emitted, This proposal was technically correct and realistically practical because it ------- -3- required no modification of the vehicle and measured the total diurnal and hot soak emissions from aj_]_ sources, Unfortunately, the proposed concept had not been substantiated by quantitative data, was not sup- ported by the automotive industry, and was consequently replaced by an alternate technique. This technique involved trapping the vapors from specific sources by attaching charcoal canisters; this was basi- cally the proposal California had made. A test procedure employing the vapor trapping technique was finalized and published as a federal regulation on June 4, 1968. The evaporative emission standard of 6 grams per test was applicable to 1971 model year vehicles sold nation- wide; the MVPCB of California adopted the procedure and standard to apply to 1970 model year vehicles sold in California. The 1971 HEW certification results showed that 107 of 131 (82%) vehicles tested emitted less than 1.0 gram. Consequently, the standard was lowered to 2 grams per test for 1972 vehicles and evaporative emissions regulations have not changed since. This brief summary on the regulation of evaporative emissions has hopefully provided the reader with the necessary background to place the remainder of this paper in the proper perspective. The enclosure procedure th^t had bŁen proposed in 1967 by HEW was technically correct and had many merits, as mentioned before. A few days after that proposal was made, one company of the automotive industry built an enclosure and conducted extensive tests to study the potential problem areas and to assess the value of the proposal. Two published reports (5, 6 ) on these evaluations concluded that the technique was accurate, simple, and repeatable, and represented "a superior technique and versatile tool" for evaporative emissions measurements. Subsequent tests by HEW engineers and various other organizations substantiated those initial results and lead to refinements which were published by the Society of Automotive Engineers (12) in a formal recommended test procedure. This procedure, SAE J171 a, has the same specifications as the presently used canister procedure except that the enclosure-FID setup replaced the gravimetric determination as the measurement method. During the last three years of certification testing, the official results shown in Table A were obtained from the canister evaporative emissions test. ------- -4- Table A 1971-1974 Certification Results Grams/Test No. % Tests % Tests Max. Avg. MY Tests < 0.1gm < 1.Oqm Value Value Std. 71 72 73 74 131 370 351 399 32% 45 56 45 82% 91 94 98 3.65 1.90 1.90 1.90 .545 .307 .251 .258 6 2 2 2 Note: 60% of tests < .1 gm were actually 0.0 gms. The emissions shown in Table A seem to indicate that the evaporative control systems are very effective. However, for this analysis, all the data gathered should be considered. The data collected during the 1974 model year program was readily accessible. Actually, there were a total of 114*1 evaporative emissions tests performed in that program. Durability vehicles accounted for the 399 published results but the emission data vehicles tested totaled 742, There were 20 failures in the emission data population. These failures occurred on .12 vehicles. Most failures were caused by test procedure errors; the vehicles passed subsequent retests. Three.of the vehicles required hardware changes to pass. There were no failures on any dura- bility vehicles and the deterioration factors for evaporative emissions were less than .2 (additive D.F.) for 93% of the vehicle families. Another observation can be made concerning the tests listed as 0.0 emissions. Roughly 60% of those values less than 0.1 grams were actually 0.0. Investigation disclosed that values listed as 0.0 were almost always negative canister weight changes. This aspect of the canister procedure is the most indicative evidence of the canister technique's questionable validity. As a followup to the certification process, the mobile source program conducts surveillance testing to assess the net effect of the regulatory process. Vehicles are procured from private owners and emissions tests are performed to quantify the emission levels generated from production vehicles that have been maintained by the consumer. ------- -5- The surveillance program in 1972 measured evaporative emissions from both controlled and uncontrolled vehicles. The questionable results which had been obtained from the canister procedure prompted the sur- veillance personnel to consider using the enclosure technique which was more simply applied to both controlled and uncontrolled vehicles, The enclosure technique accounts for emissions from areas that are diffi- cult to "trap", i.e. gaskets and throttle shafts, whereas the canister procedure requires many connections and lengthy preparation for uncon- trolled vehicles. Consequently, in order to provide a simple and common basis for comparison of data, the surveillance program adopted the enclosure procedure, SAE J171. The measurements made in Los Angeles encompassed a distribution of 136 California vehicles from model years 1957 to 1971. In addition, twenty-two (22) 1971 model vehicles were tested in Denver to assess the effect of high altitude. The next year, the surveillance program concentrated on 1972 model vehicles only, test- ing twenty-two (22) each at Los Angeles and Denver. The results of all these tests are summarized in Table B. Table B Surveillance Results - Encjosure Procedure —- — / " L.A. Data (qms) Denver Data (qms) Weighted Values** Model No. Year. Tests Diurnal Hot Soak Diurnal Hot Soak qms/nile '57-' 69 102 26.08 14.67 - 2,72 '70 13 17.75 10.70 - 1.95 '71 21 14.87 10.89 - 1,88 '71 22 - - 47.2* 34.8* 6.02* '72 22 12.40 11.80 - 1.87 '72 22 - - 17.4 14.2 2.40 Note: *Winter grade fuel (11.7 RVP) used on all tests, L.A. Data up to 1971 used all types of fuel (7.8 - 12.0 RVP). **Emission = Diurnal + 4.7(Hot Soak)/35 miles/day. Before the comparison of Table A and Table B is made, a few qualifying remarks are necessary. The first contrast one observes in Table B is the disparity between the 1971 and 1972 Denver values. This large difference has been explained by the fact that the 1971 vehicles were tested using commercial winter grade fuel of high volatility (Reid Vapor Pressure (RVP) = 11.7 psi), and the 1972 vehicles used the standard test fuel of summer grade volatility, (RVP = 8.8 psi). Several reports (1,2,3,7,9,11) have quanti- fied that the emissions from fuel having an RVP of 11.7 will be double to triple those from fuel with an RVP of 8.8. This correction factor will ------- -6- tend to faring the Denver results for the two model years (both controlled vehicles) into closer agreement. The same situation occurred during the tests in Los Angeles, but the effect on the overall average is less pro- nounced because a wide variety of vehicles was tested at random times with both types of fuel. However, the standard test fuei was used during the Los Angeles tests on 1972 model vehicles and a valid comparison to the Denver data can be made. The consistent difference in this comparison can be attributed to the effect on the evaporative process of the lower barometric pressure at Denver (24.5"Hg) as compared to that at L.A. {30. A comparison ef the values for the diurnal and fiat soak emissions from controlled ar.ci uncontrolled vehicles does not 'indicate a significant improvement. Diurnal emission control shows the highest reduction (.547^1, but the hot soak control techniques; produced a much snailer reduction (27SJ. It is reiterated here tftat trie c&rractiOT? factor will lower the uncontrolled vehicle emissions, a change which demonstrates even lower reductions than those indicated. The very perplexing aspect of the diurnal data has been the magnitude of the emission from a supposedly closed system. Diurnal tests have been coid^ctsd on leak-tight coTtrolJsd vehicles at tfie PISAPC laboratory usirp the enclosure technique. The results confirmed that a control system can limit diurnal emissions to less than \ gram/"test. Ore must conclude that a leak exists in the control system-, speculation as to the sources would point to the canister, lines, tank fittings, or tank cap. Investigation of tfifs latter speculation disclosed that 1Q-20S of the pressure "leak tests performed during the 1974 certification program failed because of leaking caps. Generally, the manufacturers were allowed to replace the cap arid the evaporative test proceeded. The surveillance program did net require a leak test because the purpose of the test was to measure "as received1' emissions. However, testing experience indicates a cap leak would be the likely cause of these high diurnal emissions. The data indicate that hardvjare improvements are needed in this area. The control of hot soak losses relies primarily on plumbing the c&rburetor bowl snd air cleaner to the control canister. In most sys- tems the internal carburetor vents continue to fill the air cleaner witfi vapors, and the diffusion-expulsion process follows the path of least resistance, the air cleaner inlet. Tn the canister test procedure, these vapors must make thejr my through small tubing before they can be ad- sorbed in the charcoal canister. The data indicate this is not happening. A test was reported (5 ) that investigated this problem inside an . enclosure. TEie author concluded that the air cleener merely stores the vapors during a canister test when its inlet is plugged. However, sub- sequent removal of the plug produced a sudden increase in the enclosure tydrocarbon concentration. This is an example of how the trod ifications required by the canister procedure actually fnfn'6it tfte emfssfc/i of hydrocarbons. ------- -7- The comparison of values from Table A and Table B indicates that the canister test procedure does not accurately assess evaporative emissions. There are several reasons to conclude that the enclosure procedure more accurately assesses the true magnitude.. During the surveillance program, replicate tests were performed on 14 of the 188 vehicles tested. After considering the variations caused by the fuel volatility problems cited earlier, the repeatability of the enclosure procedure is on the order of + 1 OX"for all replicates. Simi- lar repetitive testing using the canister procedure has produced stan- dard deviations as high as 200% of the mean for a group of tests. Another reason to accept the enclosure values is that the enclosure can be calibrated. Calibration tests are typically repeatable within +2% for all tests. Enclosure background emissions (if any exist) can be measured and subtracted to yield net vehicle emissions. Finally, the enclosure measures all vehicle emissions without modification to the control system. The discussion to this point has attempted to present the background and to illustrate the quantitative data^available for evaluation. If the most valid block of data, the L.A. and Denver tests on 1972 vehicles, is representative of true emissions, the impact of evaporative emissions on air quality can be estimated. The weighting factors that have been used for exhaust emissions will be applied to evaporative emissions. The model assumes that a vehicle experiences 4,7 starts per day and accumulates 35 miles in average daily operation. In the analysis of total evaporative emissions, the assumption of one diurnal and 4.7 hot soaks per day is made. When the average values from the 1972 vehicles are used in the model for total emissions, the final value is: (Diurnal qms/test x test/day)+(Hot soak gms/test x tests/day) gms/mile Miles/day ~ Evap. gms/mi le = .02-4 x 1 -3 x 4-7) 35 65.5 gms/day 35 rSSSw™ - 1.87 gms/mile Emissions 3 ' These 1972 vehicles, by similar analysis using the 2 gram standard test results, were certified at evaporative emission levels less than 0.13 gms/mile. To place this evaporative emission in perspective, the- tailpipe tmissions have also been considered. ------- -8- The certification HC standard in California for 1972 vehicles was 3.2 grams/mile as opposed to the national standard of 3.4 grams/mile. The surveillance data that was measured on 35-1972 vehicles showed an average HC emission of 4.07 grams/mile. One additional source of HC vapor should be discussed to complete this analysis of total emissions. Two reports (10,24) have been written on the fuel vapors emitted during fueling operations. For the purpose of this analysis, the rates of 5.0 gms/gal. and 13.4 miles/gal. will be used as the average values for fuel transfer emissions and fuel consumption. These values translate to approximately 0.4 grams/mile. If the emission discussed represent the total mobile source contri- bution to HC pollution, the following table shows the relative contribu- tion of each specific source for in-use 1972 vehicles. Table C Total HC Emissions From 1972 Vehicles Exhaust /qms/mile 4.07 64.2% Evaporative 1.87 29.5% Refueling .40 6.3% Total HC 6.34 100.0% This conservative analysis has shown that the- minimum impact on HC emissions due to evaporative losses is presently about 30% from vehicles with evaporative control. The analysis can be developed one step further to show the impact of evaporative emissions relative to 1975 model year vehicles. Evaporative emissions or refueling losses are not expected to change for 1975 or 1976 vehicles because the evaporative and fueling control systems will be essentially the same as those used in 1972. Assuming the 1972 (in-use/cert. std.) factor (4.07/3.2 = 1.27) will be the same in 1975 and 1976, the in-use tailpipe emissions from 1975 and 1976 vehicles can be estimated and compared as shown in Table D. Table D Predicted HC Emissions From 1975/76 Vehicles HC Standard 1975 (1. gms/mile 5 gms'/mile) 1976 (.41 gms/mile) gms/mile Exhaust 1.91 45.7% .52 18.5% Evaporative 1.87 44.7% 1.87 67.0% Refueling .40 9.5% .40 14.4% Total HC 4.18 100.0% 2.79 100.0% ------- -9- This analysis illustrates that evaporative emissions will represent the primary source of hydrocarbons from mobile sources if the present regulatory procedures and standards remain unchanged. The cause of this problem is simply the inability of the evaporative emissions test procedure to measure the true total emissions from the test vehicle. The presence of this weakness has caused an erroneous assessment of the true magnitude of the emissions and has resulted in few improvements in control technology. The two effects are interdependent. One may be tempted to jump at the obvious solution to this problem, which is to change the test procedure. While this is certainly an im- portant aspect of the solution, it alone will not automatically result in the control of emissions. III. Evaporative Emissions Test Procedures: The two principle techniques which have been used for measuring evaporative emissions, the canister and enclosure procedures, have been discussed in general terms previously in this paper. This section will discuss the advantages, limitations, costs, and problems associated with each procedure. A. Canister Evaporative Test Procedure Advantages: 1. Test equipment is simple and relatively low in cost. 2. Required test area is small and test setup is flexible. Limitations: 1. Inability to measure all losses. 2. Poor repeatability of test data. 3. Use of tubing and connectors may actually inhibit real emissions. 4. Low percent of total emissions collected. 5. Time consuming and tedious procedure to perform. Costs: 1. Lengthy preparation phase results in high manpower costs. (Preconditioning study indicates preparation could be shortened) ------- -10- Problems: 1. High void test rate caused by numerous and complex steps. 2. Accurate calibration of test procedure is not possible. B. Enclosure Evaporative Test Procedure Advantages: 1. Accurate measurement of all emission sources. 2. Minimum vehicle modifications and preparation. 3. Good repeatability (+10%) on replicate tests. 4. Precise calibration and verification of equipment is possible. 5. Familiar instrumentation and calculation routines. Limitations: 1. Area required to house ar^ enclosure is large. Costs: 1. Initial investment costs are very high (est. $25K per enclosure) Problems: 1. Vehicle background (tires, seals, paint, undercoat, etc.) emissions from new cars are high. Emissions decrease to low levels after 90 days of ageing. 2. Abnomal high ambient temperatures during hot soak tests must be avoided. Other questions related to simulation of realistic environmental parameters have been addressed in a technical appendix to this report. IV. Implementation Alternatives: Previous position papers and program plans on the subject of evaporative measurement by the enclosure pro- cedure have taken the basic position that the enclosure technique re- places the canister in a test applied to each vehicle subject to certi- fication. The cost benefit relationship, as well as the physical space requirements of such an implementation plan cannot be justified in light of the data available on evaporative emissions. ------- -11- As discussed earlier, evaporative emissions occur from two primary sources, the fuel tank and the carburetor. The test procedure specifies the measurement of separate diurnal and hot soak losses. This differen- tiation is an important requirement because of the weighting factors which must be applied to translate test values to a grams per mile basis. Pro- cedures that combine the diurnal and hot soak tests to reduce test time surrender a necessary part of the data. A reduction of test time should be attainable without sacrifice of important data. An alternative method to reduce the manpower and test time required to obtain the necessary data is to reduce the number of vehicles required for testing. This proposal is more than an alterna- tive; it is a technique that is justified by the character of the emis- sions and the data meas.ured on many systems. For example, the factors that govern the diurnal emission are tank vapor volume, fuel volatility, and maximum fuel liquid temperature. These parameters have been regressed against diurnal emissions (11) which produced a correlation coefficient of 0.93. Similarly, carburetor hot soak losses are primarily dependent on fuel distillation characteristics (% @ 160°F), carburetor maximum fuel temperature, and carburetor bowl liquid volume. Hot soak emissions have been regressed against these three variables with a correlation coefficient of 0.89. These characteristics can be applied to vehicle evaporative control system configurations to determine the appropriate vehicle selection criteria and sampling plan. This method of vehicle selection would predictably reduce the number of vehicles to be tested for evaporative emissions. It is then possible to assess the capability of all control system configurations without testing every vehicle and without expenditures for numerous en- closures and instruments. This implementation plan is justified by the data, and has a very low cost: benefit ratio. In 1973, the Mobile Source Laboratory tested approximately 399 durabi- lity vehicles which represented 114 engine families and 35 manufacturers. In addition 742 emission data vehicles were tested. If sample selection criteria had been applied to fuel tank configurations and carburetor sizes, the number of evaporative emissions tests would have been reduced. For example, if a manufacturer uses the same fuel tank system with several different carburetors, it is not necessary to perform a diurnal tank test for each carburetor hot soak test. The emission value could be assigned to each evaporative configuration on the basis of fuel tank and carburetor combinations. It has been estimated that a testing scheme based on selection criteria would result in approximately 50 fuel tank families and 150 carburetor families. If each selected system is tested three times, i.e. 5000, 25,000 and 50,000 miles, the test load would be reduced from an estimated 4500 tests to 600 for upcoming model years. ------- -12- The discussion above is contrary to the established certification process. However, evaporative emissions are generated from physical mechanisms that are hardware oriented rather than chemical reactions as in the case of exhaust emissions. Furthermore, control systems are prone to deteriorate with time rather than with the mileage ac- cumulated in the accelerated durability testing. For these reasons, it does not appear to be necessary to test each durability vehicle at 5 mileage points. In general, the evaporative emissions test should be separated from the exhaust emissions test to allow more flexibility in the testing sequence. However, when a hot soak test is required on a vehicle, the hot soak test should obviously follow a phase of hot vehicle operation. The diurnal test could be conducted as an in- dependent test. Tests ( 22 ) have been conducted that showed that the inclusion or exclusion of the diurnal test prior to the exhaust emissions test has no detectable effect on the exhaust emissions. Similarly, vehicle operating temperatures are generally at stable conditions during hot operation, and the hot soak temperature profile tends to achieve the same maximum temperature regardless of the previous operation. Hot soak testing obviously (toes not influence the exhaust test phase. The evaporative emission that has not been specifically measured heretofore is the "running loss" emission. At present, the assumption is made that the only possible source for a running loss would be at the tank cap or recognized vents. In most cases, no canister measure- ment is made at the tank cap because the caps are considered leak tight and void of emissions. The fallacy of this assumption is that, running losses could occur from many unrecognized sources. A scheme has been developed at the MSAPC laboratory to measure the total running losses by essentially operating the dynamometer and vehicle inside an enclosure. A flow through the enclosure is maintained and sampled during the exhaust emissions test. In practice, this has been achieved by sampling the inlet and outlet of the test cell air handling system. Exhaust emissions were measured by the normal CVS.while the air handler acted as a running loss CVS. This concept is a CVS within a CVS which measures and differentiates all vehicle hydrocarbon emissions. A description of this concept and some data collected using it have been presented in the technical appendix. This method of measuring running losses has been discussed here as a potential part of the implementation plan because it is compatible with the enclosure principle, CVS concept, and vehicle sample selection plan". This total concept could be implemented by constructing one enclosure that incorporated all the phases of a total emissions test. One such enclosure would have the capability of handling about 2 total emissions tests/day or about 40 vehicles per month; this capacity will not accommodate the number of tests that might be required under the sample selection criteria. ------- -13- However, if running losses are not measured this way, one enclosure could handle 120 diurnal and hot soak tests per month if performed independently. A fourth evaporative emission, refueling losses, can also be measured by the enclosure technique. Although this is presently unregulated, the effectiveness of a standard fueling connector which might be adopted to eliminate refueling losses could be assessed by this method. Again, the flexibility of the enclosure method has been illustrated. Most of this discussion has been about an implementation) plan that is based on vehicle sample selection criteria and testing with the en- closure - hydorcarbon analyzer combination. Several alternative plans have been previously proposed and are listed below with a brief dis- cussion of their limitations and problems. A. SAE Procedure applied to all vehicles. 1) Description: Replace the federal canister procedure with the enclosure technique and apply the test to every vehicle tested under the present vehicle selection plan. 2) Problems: The cosl;, space*- and time involved to perform the test sequence on each vehicle are not justified by the data. It would be technically and politically unpopular to propose such a plan, and very costly to execute such a scheme. B. SAE modified procedure applied to all vehicles. 1) Description: The diurnal and hot soak phases have been combined to shorten test time. 2) Problems: Separate emission data are lost and weighting factors cannot be properly applied. Diagnostic aspect is also sacrificed. Same problems of (a) apply here also. Cost: benefit ratio is still high. Safety regulations may not permit the fueling operations required. C. MSAPC/ECTD procedure. 1) Description: A procedure that employed radiant heat lamps instead of the electric blanket pads for the diurnal test, which was also combined with the hot soak. 2) Problems: The critical temperature profile, fuel tank liquid temperature, was' not attained by this method. Ve- hicle color requirements (all black) were too restrictive. Enclosure ambient temperatures would be too high, separate emission data would be sacrificed, and energy consumption per test would be very high. ------- -14- These alternatives were proposed to improve, simplify, and shorten the test. Unfortunately, each had an associated aspect that rendered the proposal less beneficial and more costly than the one recommended in this paper. That proposal has been summarized again for review. D. MSAPC evaporative emission procedure. 1) Vehicle sample selection criteria are used to define evaporative diurnal and hot soak families and to reduce the number of vehicles and tests required for certifica- tion of evaporative control systems. 2) SAE J171 procedure used for testing. 3) Independent diurnal and hot soak tests are performed on selected vehicles; each vehicle may not get both tests. 4) Calculations are performed to yield weighted emission rates (g/mi) for each system defined. V. Problems of Implementation: 'The proposal that has been made is not competely without problems. Lead time, control technology, vehicle sample selection criteria, and evaporative emission standards are all problems which must be addressed prior to a final implementation. The lead time problem affects both MSAPC and industry laboratories. MSAPC has two enclosure that are operational, but a formal data col- lection and analysis program is required prior to conducting large numbers of tests. These problems can be resolved in the anticipated lead time. The industry has tv:o lead time problems. Some automotive laboratories will require construction of enclosures, and all companies will require lead time to develop the appropriate evaporative emission control hardware. Communications should be established with the in- dustry to inform them of our intentions so as to maximize their lead time. The proposed program plan, Part II of this document, estimates that 1977 MY vehicles could be tested by the enclosure procedure. These tests might begin as early as December, 1975. As mentioned, the control technology represents the biggest problem to the industry. The evaporative emissions standards that would be set weigh heavily on the control technology changes that would be required. As the program plan outlines, the potential for control by various tech- nques and devices will be determined. The cost of extensive changes will be weighed against their impact on overall air quality. This is an area^ where additional information and data are needed. The program plan provides for obtaining this information by a control technology assessment contract. The final problem associated with adopting a new procedure is to determine the appropriate standard of compliance. The data indicate that the average evaporative emissions as measured by the enclosure are much higher than the 2 gram/test (.13 g/mi) standard presently in effect. The existing data base from enclosure tests can be combined with data ------- -15- generated during the control technology assessment, development, and demonstration programs to provide a concise determination of the ap- propriate standard and timetable for compliance. The control systems now in use appear to have an emission rate somewhere betv/een 1.5-2.0 g/mi as calculated form the weighted en- closure emission values and average daily mileage. Had the evaporative standards been established using the enclosure procedure and weighted calculations, the 1975 standard would have been 0.27 g/mi. Assuming the diurnal emission can be reduced to zero, the allowable one hour hot soak emission translates to a value of 2.0 grams per test. There have been some hot soak enclosure results obtained at the 2.0 gram per test level, but the overall vehicle population average of 11.0 grams per test illustrates the amount of reduction still required. It is unlikely that this reduction can be achieved in one year, al- though the fact that the problem is a single component, hardware oriented phenomenon makes its solution much simpler than the multi- component, chemical reactions associated with vehicle exhaust emis- sions. The design work being done to meet impact/fuel spillage safety regulations may improve evaporative emissions. Other questions related to simulation of realistic environmental parameters have been addressed in a technical appendix to this report. VI. Conclusions; A. The canister test procedure is so limited in its accuracy and integrity that its continued use has little value towards con- tinued improvement in air quality. B. The enclosure test procedure as specified in SAE J171 will accurately and repeatedly measure true total evaporative emis- sions. The parameters of the procedure represent a realistic simulation of the critical environmental conditions. Its use will correctly assess the performance of control techniques and their impact on air quality. C. Data indicate that evaporative emissions control can be assessed on a vehicle sample selected by use of characteristic criteria. This is an evaporative family approach which is similar to the engine family scheme used for exhaust emissions. This type of regulatory program would be highly cost effective. D. Evaporative emissions will become the dominant hydrocarbon emis- sion by 1976 under present control techniques and will result in reductions that are lower than those needed to meet ambient air quality requirements. Actions to regulate evaporative emissions are required by the Clean Air Act. ------- -16- E. The problems of changing the procedure and standard can be solved. Some automotive companies will require a larger effort to im- plement the change and to develop the control techniques. F. A program plan can be executed to provide a regulatory program and evaporative emissions standard by September, 1975. A milestone chart has been included at the end of this paper to show the tasks required. VII. Recommendations: A. The use of the canister procedure should be minimized as soon as possible for the following reasons: 1) High costs are incurred that produce no benefits. 2) Evaporative control technology has not changed; therefore, evaporative emission values should remain the same. From the data shown in Table A, the probability of a vehicle failing the evaporative standard is very low. 3) Tests ( 22 ) have shown that the vehicle preparation and diurnal test have no detectable effect on exahust emissions and could therefore be deleted or separated. 4) Test time could be reduced to facilitate highway fuel economy measurements and enclosure testing for evaporative emissions. B. The enclosure procedure should be adopted as the official test procedure for measuring evaporative emissions. Communications with the automobile industry should be established as soon as possible to express the intended changes in evaporative regulation, to maximize lead time, and to solicit their comments on our program. C. The program plan to achieve the development and implementation of an appropriate standard should be approved and given high priority. The revised regulation could possibly be implemented by December, 1975 if high priorities are assigned. VIII. Closure: This document has attempted to reveal the problems associated with mobile source evaporative emissions. These environ- mental, technical, and political problems pose a challenge to the OMSAPC which requires action. In the consideration of alternative actions, "no action" is not a responsible alternative. ------- IX. References for Evaporative Losses SAE Vehicle Emissions - Part I Vol. 6, 1955-1962 1. Wentworth, J. T., "Carburetor Evaporation Losses", SAE Transactions 1955. SAE Vehicle Emissions - Part II Vol. 12, 1963-1966 2. Muller, H. L., Kay, R. E., and Wagner, T. 0., "Determining the Amount and Composition of Evaporative Losses from Automotive Fuel Systems". SAE Transactions, Vol. 75, 1967. 3. Ebersole, G. D., and McReynolds, L. A., "An Evaluation of Automobile Total Hydrocarbon Emissions", SAE Transactions, Vol. 75, 1967. 4. Caplan, J. D., "Smog Chemistry Points and the Way to Rational Vehicle Emissions Controls". SAE Transactions, Vol. 74, 1966. SAE Vehicle Emissions - Part III, Vol. 14, 1967-1970 5. Martens, S. W., and Thurstor), K. W.* "Measurement of Total Vehicle Evaporative Emissions" SAE Transactions 680125, 1968, p. 191. 6. Martens, S. W., "Evaporative Emissions Measurements with the Shed - A-Second Progress Report" SAE Transactions 690502, 1969, p. 202. 7. Wade, D. T., "Factors Influencing Vehicle Evaporative Emissions", SAE Transactions, 670126, 1967, p. 743. 8. Wade, Clarke, Gerrard, Skarstrom, Vardi, "An Adsorption-Regeneration Approach to the Problem of Evaporative Control", SAE Preprint, 670126 1967, p. 756. 9. Koehl, W. J. Jr., "Mathematical Models for Prediction of Fuel Tank and Carburetor Evaporative Emissions", SAE Preprint, 690506, May, 1969. 10. Nelson, E. E., "HC Control for Los Angeles by Reducing Gasoline Volatility", SAE Transactions, 690087, 1969, p. 775. 11. Jackson, M. W., and Everett, R. L., "Effect of Fuel Composition on Amount and Reactivity of Evaporative Emissions", SAE Transactions, 690088, 1969, p. 802. 12. Society of Automotive Engineers, SAE J171a, "Measurement of Fuel Evaporative Emissions Using the Enclosure Technique", July , 1972. 13. Deeter, W. F., et. al. "An Approach for Controlling Vehicle Emissions SAE Preprint 680400, (1968). ------- -18- 14. Deeter, W. F., and Jewell, R. G., "Factors Affecting Carburetor Vapor Losses". 15. Automobile Manufacturer's Association, AT-1A Engineering Notes 6/6, "Fuel Systems Evaporation Losses", September, 1961. 16. Coordinating Research Council, CRC Report No. 400, "1966 CRC Motor Vehicle Evaporation Loss Measurement Technique Evaluation", January, 1967. 17. U. S. Dept. of Commerce, NOAA, "Climatography of the United States No. 84, Daily Normals 1941-70", September, 1973. 18. National Academy of Sciences, "Semiannual Report to EPA by CMVE of NAS", January 1, 1972. 19. National Academy of Sciences, "A Critique of the 1975-76 Federal Automobile Emissions Standards for Hydrocarbons and Oxides of Nitrogen", Prepared for EPA, May 22, 1973. 20. Korth, M. W., Rose, A. H., and Stahman, R. C., "Effect of Hydrocarbon to Oxides of Nitrogen Ratios'on Irradiated Auto Exhaust", APCA Annual Meeting, June, 1963, PHS Document. 21. Rose, A. H. Jr., "Summary Report of Vehicular Emissions and Their Control", PHS Report, Unpublished, 1966. 22. Kruse, R. E., "Evaluation of the Effect of Evaporative Emission Testing Upon Exhaust Emission Test Results", January, 1974. EPA Memo to M. W. Korth. 23. Patterson, D. J., and Henein, N. A., "Emissions from Combustion Engines and Their Control", (Ann Arbor: Science Publishers, Inc., 1972) Chapter 6, p. 181. 24. Society of Automotive Engineers, SAE J1045, "Instrumentation and Techniques for Vehicle Refueling Emissions Measurement", August, 1973. 25. Letter from D. A. Jensen to Technical Advisory Group on Evaporative Emissions, October 18, 1965. 26. Letter from M. L. Brubacker to the Evaporative Emissions Advisory Group, January 10, 1966. 27. Federal Register, Volume 32, Number 24, Part 85, "Control of Air Pollution from New Motor Vehicles and New MOtor Vehicle Engines", February 4, 1967, p. 2448. ------- -19- 28. Federal Register, Volume 33, Number 108, Part II, "Standards for Exhaust Emissions, Fuel Evaporative Emissions and Smoke Emissions, Applicable to 1970 and Later Vehicles and Engines". June 4, 1968, p. 8304. 29. Federal Register, Volume 35, Number 136, July 15, 1970. 30. Federal Register, Volume 36, Number 70, "Certification Test Results for 1971 Model Year", April 10, 1971. 31. Federal Register, Volume 37, Number 114, "Certification Test Results for 1972 Model Year", June 13, 1972. 32. Federal Register, Volume 38, Number 84, "Certification Rest Results for 1973 Model Year", May 2, 1973. 33. Federal Register, Volume 38, Number 212, "Certification Test Results for 1972 Model Year", November 5, 1973. 34. Miscellaneous reports on file in EPA Procedures Development File on Evaporative Emissions. MSAPC, Ann Arbor, Michigan, 1973 35. Coordinating Research Council, CRC-Scott Project No. 2602, CAPE-5-68, "Time-Temperature Histories of Specified Fuel Systems". Vol. 1, October, 1969. 36. Coordinating Research Council, CRC-SDC, CAPE-10, "Summary Report on Vehicle Driving Patterns", January 1971. ------- |