United States       Air and Radiation      EPA420-R-01-019
           Environmental Protection               April 2001
           Agency                    M6.EVP002
vvEPA     Modeling Hourly Diurnal
           Emissions and Interrupted
           Diurnal Emissions Based
           on Real-Time Diurnal Data
                               > Printed on Recycled Paper

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                                                                          EPA420-R-01-019
                                                                                 April 2001
                                        on

                               M6.EVP.002
                                Larry C. Landman

                         Assessment and Standards Division
                       Office of Transportation and Air Quality
                       U.S. Environmental Protection Agency
                                    NOTICE

    This technical report does not necessarily represent final EPA decisions or positions.
It is intended, to present technical analysis of issues using data which are currently available.
         The purpose in the release of such reports is to facilitate the exchange of
      technical information and to inform the public of technical developments which
        may form the basis for a final EPA decision, position, or regulatory action.

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                             ABSTRACT
     Evaporative emissions due to changes in ambient temperature
are an important source of hydrocarbons.  These full-day diurnal
emissions were described as daily averages in a parallel report
(M6.EVP.001).   This report presents the method used in MOBILE6
for distributing these full-day emissions among the 24 hours of
the day.

     This document reports both on the methodology used to
analyze the data from real-time diurnal  (RTD) tests on 270
vehicles and on the results obtained from those analyses.  The
purpose of the analysis was to develop a model of the hourly
diurnal emissions of the in-use fleet to be used in MOBILE6.

     This report was originally released  (as a draft)  in May
1998,  and then revised (and re-released) in July 1999.  This
current version is the final revision of the July 1999 draft  (of
M6.EVP.002).  This final revision incorporates suggestions and
comments received from stakeholders during the 60-day review
period and from peer reviewers.

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                       TABLE OF CONTENTS
                                                     Page Number
1.0 Introduction   	    1
2.0 Stratifying the Test Fleets    	    3
    2.1  Evaluating Untested Strata    	    4
3.0 Evaporative Emissions Represented by the RTD.  ...    5
4.0 Hourly Diurnal Emissions 	    7
    4.1  Characterizing Hourly Diurnal Emissions.  ...    7
    4.2  Calculating Hourly Diurnal Emissions  	   13
       4.2.1  Carbureted Vehicles    	   13
       4.2.2  Fuel-Injected Vehicles	   18
       4.2.3  Gross Liquid Leakers	   21
       4.2.4  Summarizing All Strata	   25
5.0 Interrupted Diurnal  	   27
    5.1  Example of an Interrupted Diurnal	   27
    5.2  Calculating Emissions of an Interrupted Diurnal  29
6.0 Assumptions Related to Hourly Emissions  	   32
    6.1  Distribution of Hourly Diurnal Emissions  ...   32
    6.2  Assumptions for Interrupted Diurnals  	   33
    6.3  Temperature Ranges 	   33
    6.4  Estimating Vapor Pressure   	   34
    6.5  Duration of Diurnal Soak Period	   35
7.0 Conclusions	   36
                               11

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                     TABLE OF CONTENTS (Continued)
                                                      Page Number
APPENDICES
 A.  Temperature Cycles	  37
 B.  Vapor Pressure	  38
 C.  Modeling 24-Hour Diurnal Emissions   	  41
 D.  Using Linear Regressions to Model
     Ratios of Hourly Diurnal Emissions   	  43
 E.  Hourly RTD Emissions of Gross  Liquid  Leakers. ...  58
 F.  Modeling Hourly Resting Loss Emissions   	  59
 G.  Peer Review Comments from H. T. McAdams	  60
 H.  Peer Review Comments from Harold Haskew  	  85
 I.  Comments from Stakeholders	  97
                                111

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                Modeling Hourly Diurnal  Emissions
                and  Interrupted Diurnal Emissions
                Based on  Real-Time  Diurnal  Data

                   Report  Number  M6.EVP.002

                         Larry C. Landman
            U.S. EPA Assessment and Standards Division


1.0   INTRODUCTION

     In a recently released  final report,*  the Environmental
Protection Agency  (EPA) presented a model  for estimating resting
loss and diurnal emissions over the course  of a full day (i.e.,
24 hours).   (The diurnal emissions  are the  pressure-driven
evaporative HC  emissions resulting  from the daily increase in
temperature, while the resting  loss emissions are the evaporative
HC emissions not related to  pressure  changes.)   These estimates
were based on the results of 24-hour  real-time diurnal (RTD)
tests during which the ambient  temperature  cycles over one of
three similar 24-degree Fahrenheit  ranges.   The three ambient
temperature cycles used in those RTD  tests  are illustrated in
Figure 1-1; however, most of the testing was performed using the
72 to 96 degree cycle.**  In that parallel  report,  EPA developed
a method for estimating resting loss  and diurnal emissions on a
daily basis.  Those  estimates of full-day  diurnal emissions will
be used in MOBILE6.

     However, many vehicles  do  not  experience a full-day diurnal;
they experience a partial-day  (or interrupted)  diurnal.  In a
parallel report, M6.FLT.006  (entitled "Soak Length Activity
Factors for Diurnal  Emissions"), EPA  analyzes data from an
instrumented vehicle study conducted  in Baltimore, Spokane, and
Atlanta to determine what percent of  the fleet is undergoing
either full-day or interrupted  diurnals  at  each hour of the day.

     Therefore, in this report,  EPA developed a method for
estimating both resting loss and diurnal emissions on an hourly
basis.  Using those  hourly estimates,  EPA  calculates (in MOBILE6)
both the emissions from full-day diurnal as well as the emissions
from "interrupted" diurnal  (i.e., diurnals  that are delayed due
to vehicle activity  and do not  start  until  after 6 AM when the
daily temperature rise has already  begun).
   Report  numbered  M6.EVP.001,   "Evaluating  Resting  Loss   and  Diurnal
   Evaporative Emissions Using RTD Tests."

   Many of  RTD  tests were  actually  performed  for periods of more  than  24
   hours.  The results after  the 24-hour point  are analyzed in M6.EVP.003,
   entitled "Evaluating Multiple Day  Diurnal  Evaporative Emissions Using RTD
   Tests."

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                               -2-
     As illustrated in Figure 1-1, these three temperature cycles
are parallel  (i.e., have identical hourly increases/decreases).
The temperature profiles used in all of the RTD tests have the
ambient temperature rising gradually from the daily low
temperature to the daily high temperature nine hours later.  Over
the course of the remaining 15 hours, the temperature slowly
returns to the daily low temperature.  The three hourly
temperature cycles used in this study are given in Appendix A.
The most rapid increase in temperatures occurs during the fourth
hour.  For RTD tests that exceed 24 hours, the cycle is  simply
repeated for the necessary number of hours.   (See Section 6.3 for
estimating the effects of alternate temperature profiles.)

                             Figure 1-1

          Temperature Cycles for Real-Time Diurnal (RTD) Testing
         110
          90° --
          70° --
          50

                                  12

                             Time (hours)
18
24
     In a parallel document  (M6.EVP.001), EPA analyzed  full-day
RTD test results from 270 vehicles.  In  this document,  we analyze
the hourly results from those same tests.  This document reports
both on the methodology used to analyze  the data from those  same
RTD tests and on the results obtained from those analyses.

     The cumulative hydrocarbon  (HC) emissions were measured and
reported hourly.  Subtracting successive cumulative results
produces the hourly emissions.  However, using the hourly
emissions requires associating a clock time with each test hour.
The RTD test is modeled after a proposal by General Motors  (GM).
(GM's proposal is documented in SAE Papers Numbered 891121 and
901110.)  The temperature cycle suggested by GM had its minimum
temperature occurring at 5 AM and its maximum temperature at
2 PM.   For MOBILES,  EPA analyzed 20-year averaged hourly

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                               -3-
temperatures by month from Pittsburgh on high ozone days.  EPA
found that the minimum daily temperature typically occurred
between 6 and 7 AM,  while the maximum daily temperature typically
occurred between 3 to 5 PM.   Obviously,  the local temperature
curve depends on local conditions.  However, for MOBILE6, EPA
will combine the GM and MOBILES time estimates and assign the
daily low temperature to 6 AM,  and the daily high temperature to
at 3 PM.   Applying this approach to the temperature cycles in
Appendix A results in having the time zero correspond with 6 AM.


2.0   STRATIFYING THE  TEST FLEET

     It was necessary to stratify the test fleet for two reasons.
First,  different mechanisms are involved in producing the diurnal
emissions for different groups of vehicles, thus, necessitating
different analytical approaches.  Second, the recruitment of test
vehicles was intentionally biased to allow testing a larger
number of vehicles that most likely had problems with their
evaporative control systems.  The test data used for these hourly
analyses are the same data used in the aforementioned EPA draft
report.  The data were obtained by combining RTD tests performed
on 270 vehicles tested by the Coordinating Research Council  (CRC)
and EPA in separate programs.  The distribution of the fleet is
given in Table 2-1.
                             Table 2-1

                     Distribution of Test Vehicles
Vehicle Type
Pre-80 Carbureted

80-85 Carbureted

80-85 Fuel-injected

86-95 Carbureted

86-95 Fuel-injected

Program
CRC
EPA
CRC
EPA
CRC
EPA
CRC
EPA
CRC
EPA
Cars
38
4
0
13
0
9
0
8
0
67
Trucks
13
2
47
5
3
0
7
0
43
11
     In that parallel report, EPA noted that the resting loss and
diurnal emissions from vehicles classified as "gross liquid
leakers" (i.e., vehicles identified as having substantial leaks
of liquid gasoline, as opposed to simply vapor leaks) are
significantly different from those of the remaining vehicles.
Based on that observation, those two groups were analyzed
separately in both reports.

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                                -4-
     The two  testing parameters in the EPA programs  that were
found  (in M6.EVP.001)  to affect the 24-hour RTD  test results are:
       4  the Reid vapor pressure  (RVP) of the test  fuel and

       4  the temperature cycle.

Similarly, the  two vehicle parameters that were  found to affect
the 24-hour RTD test results are:
       4  the model year range:

            1)  1971 through 1979
            2)  1980 through 1985
            3)  1986 through 1995
       4  the fuel delivery system:

            1)  carbureted (Garb) or
            2)  fuel-injected (FI).

Also,  since many of the EPA vehicles were recruited  based on the
pass/fail results of two screening tests  (i.e.,  canister purge
measured during a four-minute transient test and pressurizing the
fuel system using the tank lines to the canister), each of those
resulting stratum was further divided into the following three
substrata:

       4  vehicles that passed both the purge and pressure tests,

       4  vehicles that failed the purge test, but passed the
          pressure test,  and
       4  vehicles that failed the pressure test (including both
          the vehicles that passed the purge test as well as
          those that failed the purge test).*

This stratification was used in both the analysis of the 24-hour
diurnal emissions and in this current analysis  (see  Section 4.0).


2.1   Evaluating Untested  Strata

     As noted in M6.EVP.001,  no pre-1980 model year,  FI vehicles
were recruited  because of the small numbers of those vehicles in
the in-use fleet (i.e., less than three percent).

     Since the  FI vehicles lack a carburetor bowl, they also lack
the evaporative emissions associated with this component.  This
suggests that the resting loss and diurnal emissions of the pre-
1980 FI vehicles are likely to be no higher than the
   For only one of the  fuel delivery system/model year range groupings (i.e.,
   pre-1980 carbureted vehicles)  were  there sufficient data  to  distinguish
   between the vehicles that  failed both the  purge and pressure tests and
   those  that failed only  the pressure  test.  Therefore,  these two substrata
   were combined into a single  ("fail pressure") stratum.

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                               -5-
corresponding emissions of the pre-1980 carbureted vehicles.  For
MOBILE6, EPA will estimate the RTD emissions of the (untested)
pre-1980 FI vehicles with the corresponding emissions of the pre-
1980 carbureted vehicles.  This should be a reasonable assumption
since any actual differences between the emissions of these
strata should be balanced by the relatively small number of these
FI vehicles in the in-use fleet.


3.0   EVAPORATIVE EMISSIONS REPRESENTED BY THE RTD  TEST

     As described in M6.EVP.001,  the results from the real-time
diurnal (RTD)  tests actually measure the combination  (sum)  of two
types of evaporative emissions:

     1)   "Resting loss" emissions are always present and related
          to the ambient temperature (see Section 7.1 of
          M6.EVP.001).
          That report (M6.EVP.001) estimated the hourly resting
          loss emissions as the mean of the RTD emissions from
          hours 19 through 24  (i.e., midnight through 6 AM) at
          the nominal temperature for the end of hour 24 (6 AM).

     2)   "Diurnal" emissions are the pressure-driven emissions
          resulting from the rising temperature in the daily
          temperature cycle (Section 7.2 of M6.EVP.001).

          The 24-hour diurnal emissions were calculated by first
          adjusting the resting loss value for each hour's
          ambient temperature, and then subtracting that
          temperature-adjusted resting loss estimate from the
          full 24-hour RTD test results.

     A special case of each of these two categories consists of
evaporative emissions from vehicles that have significant leaks
of liquid gasoline.  We defined these "gross liquid leakers" as
vehicles with resting loss emissions exceeding two grams per
hour.  As stated in Section 2, these "gross liquid leakers" were
analyzed separately from the other vehicles.  Alternative
definitions of these "gross liquid leakers" are possible;
however, with each such new definition, a new frequency
distribution and mean emission value would have to be determined.

     The following graph (Figure 3-1) is an example of hourly RTD
emissions for vehicles that were not gross liquid leakers.   For
this example,  we averaged the RTD hourly results (in grams) from
69  1986-95 model year,  FI vehicles that had passed both the
pressure and  purge tests.   All were tested over the 72° to 96°
cycle using a 6.8 RVP gasoline.  We then plotted the temperature-
adjusted hourly resting loss and diurnal emissions.

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                               -6-
                            Figure 3-1

     An  Example  of  Hourly RTD Emissions (grams)  versus Time
            0.2  -
            0.0
                           7     10    13     16    19    22

                            Duration (hours)
     This example represents the hourly resting loss and diurnal
emissions of the mean of a single stratum.  Each combination of
the five parameters discussed in Section 2.0 can produce a
different graph.  In the database used for these analyses, there
are:

       4  five combinations of fuel delivery system and model
          year range,
       4  six combinations of temperature cycle and fuel RVP, and
       4  three combinations of results of the purge and pressure
          tests.

Therefore, using the available data, we could construct 86 graphs
for which there are any data (58 are based on the average of no
more than four RTD tests).   EPA chose to consolidate those strata
into the smaller number of groups that were actually used.  The
selection of both the categorical variables  (used to form the
strata) and the analytical variables is discussed in the
following section.

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                               -7-


4.0   HOURLY DIURNAL  EMISSIONS

4.1   Characterizing Hourly Diurnal Emissions by Strata

     In Table 4-1  (on the following page), to normalize the
hourly diurnal emissions  (which can vary substantially), we
divided each hour's diurnal emissions by the full  (i.e., total
24-hour)  diurnal emissions within each of the stratum described
in Section 3.0.  Twenty-four of those strata were  represented by
at least ten tests.  Within each of those 24 strata, we estimated
(by interpolation) the time at which the cumulative hourly
diurnal emissions totaled 25, 50, and 75 percent of the full-
day's diurnal emission.  We also identified the test hour during
which the day's highest (i.e., peak) hourly diurnal emission
occurred.  (These values would correspond to the quartiles and
the mode.  These four clock times permitted us to  distinguish
among strata without having to resort to using all 24 hourly
values.)   No attempt was made  (in Table 4-1) to estimate the
overall mean values.

     A visual inspection of these results in Table 4-1 suggests
that:

    4  These  strata (containing at least 10 tests)  do not yield a
       complete representation of the various technologies (i.e.,
       not all of the combinations of fuel delivery systems and
       model  year ranges are present),  specifically:

       44 The only strata containing fuel-injected vehicles  are
           exclusively composed of  the  1986-95 model year
           vehicles.

       44 The only strata containing the  Pre-1980 or  the  1980-
           85 model year  vehicles are exclusively  composed of
           the carbureted vehicles.

       Thus,  we cannot treat as independent variables both the
       type of fuel delivery system and the model year range.
       Therefore, EPA selected the type of fuel delivery system
       (i.e.,  carbureted versus fuel-injected)  as the stratifying
       variable  (rather than model year range).

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                               -8-
                            Table 4-1

             Distribution  of Hourly Diurnal  Emissions
        Within  Each  Stratum Containing  at Least  10  Tests




Purge / Pressure
Cateqorv
Fail ONLY Purge






Fail Pressure







Passing Both












Temperature
Cycle
60.T0.84

72.T0.96


82.T0.106

60.T0.84

72.T0.96



82.T0.106

60.TO.84

72.TO.96




82.TO.106





MYR
Ranqe
86-95
86-95
80-85
86-95
86-95
86-95
86-95
86-95
86-95
Pre-80
80-85
86-95
86-95
86-95
86-95
86-95
86-95
Pre-80
80-85
86-95
86-95
86-95
86-95
86-95




Fuel
Meterinq
Fl
Fl
GARB
Fl
Fl
Fl
Fl
Fl
Fl
GARB
GARB
Fl
Fl
Fl
Fl
Fl
Fl
GARB
GARB
GARB
Fl
Fl
Fl
Fl





Cnt
12
17
11
19
17
16
12
11
19
33
10
20
19
17
12
16
32
11
38
10
70
31
25
22





RVP
6.8
9.0
6.8
6.8
9.0
6.8
9.0
6.8
9.0
6.8
6.8
6.8
9.0
6.8
9.0
6.8
9.0
6.8
6.8
6.8
6.8
9.0
6.8
9.0
— Hour During Which —
Cumulative Hourly
Reaches Stated Percent
of Full-Day

25%
3.90
4.16
4.24
3.52
4.50
3.99
5.01
4.06
4.08
4.39
4.18
4.31
4.37
4.26
4.57
4.06
5.49
6.32
4.98
5.36
4.62
6.43
4.59
6.73

50%
5.40
5.89
6.50
5.50
6.35
5.74
6.71
5.73
5.60
6.28
6.04
6.04
6.06
5.98
6.29
7.10
7.88
8.46
7.00
7.72
6.73
8.36
6.97
8.06

75%
7.38
7.86
8.83
7.65
8.02
7.70
8.58
7.54
7.15
8.35
8.10
8.09
7.84
7.79
7.90
9.73
10.36
10.85
9.19
10.10
8.98
10.46
9.56
9.72


Max
Diurnal
Occurs
5
6
7
6
7
6
7
7
6
6
6
6
6
7
7
8
8
8
7
9
7
8
7
8
A further visual inspection of these results
suggests that:
[in Table 4-1) also
       The emissions distribution as indicated by these four
       clock times (i.e.,  the number of hours into the tests that
       the maximum hourly diurnal emissions occur as well as the
       number of hours into the tests necessary for the

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                               -9-
       cumulative hourly diurnal emissions to total 25,  50,  and
       75 percent of the full 24-hour diurnal)  appear to be
       affected by both the temperature cycle and the fuel RVP,
       specifically:

        44 The higher temperature cycles usually  (but not
           consistently) correspond with a delay  in  the
           occurrence of the four clock times in  the
           distributions.

        44 For the  strata of vehicles  that passed the pressure
           test  (either  "Fail ONLY Purge" or "Passing Both"), a
           higher fuel RVP corresponds with delaying the
           occurrence of all four clock times in  the
           corresponding distributions.

       In the analyses of full-day diurnals (M6.EVP.001),  EPA
       used the RVP to estimate the vapor pressure (VP)  of the
       fuel at each point in the temperature cycle.  The mean of
       the VP at the highest and lowest daily temperatures
       incorporates aspects of  both the temperature cycle and the
       fuel RVP.   EPA will  use  that (midpoint)  value (in
       kiloPascals)  as one  of the potential variables.   (This
       variable serves to more  effectively distinguish among the
       three temperature cycles in Appendix A.)

   4   There appears to be  differences among the three purge /
       pressure categories,  specifically:

        44 As noted above,  the  four clock times in the
           distributions appear  to be  affected by the fuel RVP
           in the strata that passed the pressure test.
           However, for  the  strata of  vehicles that  failed the
           pressure test, those  times  are fairly  insensitive  to
           differences in fuel RVP.

        44 For the  strata of vehicles  that passed both the purge
           and pressure  tests,  the occurrence of  all four clock
           times in the  corresponding  distributions  are delayed
            (relative to  the  strata of  vehicles that  failed only
           the purge test).

       Based on these observations,  EPA estimated the hourly
       diurnal emissions separately for each of  the three purge /
       pressure categories.

     Therefore, EPA modeled the hourly diurnal emissions  (as
percentages of the full day diurnal):

    4  separately for the category of "gross liquid leakers"   (see
       Section 4.2.3),

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                               -10-
    4  separately for each of the six combinations of fuel
       delivery system (i.e., fuel-injected versus carbureted)
       and purge / pressure category,

    4  using (midpoint)  VP to distinguish among the temperature
       cycles and the fuel RVP (for vehicles that are not "gross
       liquid leakers"),  and

    4  using variables that describe the change in ambient
       temperature (discussed on the following page).

These decisions result in modeling the hourly diurnal emissions
separately within each of the following seven strata:

   1)  carbureted vehicles (not "gross liquid leakers")  that pass
       both the purge and pressure tests,
   2)  carbureted vehicles (not "gross liquid leakers")  that fail
       the pressure test,
   3)  carbureted vehicles (not "gross liquid leakers")  that fail
       only the purge test,
   4)  FI vehicles (not "gross liquid leakers")  that pass both
       the purge and pressure tests,
   5)  FI vehicles (not "gross liquid leakers")  that fail the
       pressure test,
   6)  FI vehicles (not "gross liquid leakers")  that fail only
       the purge test, and
   7)  the vehicles classified as "gross liquid leakers" (see
       Section 4.2.3).


NOTE:  Since  the diurnal emissions are pressure driven,  and  since
      the pressure in the fuel tank  (while  the vehicle  is
      parked)  is  dependent on changes in ambient  temperature,
      the choice  of  "changes in  temperature"  as  the independent
      variable(s)  is  reasonable  from a physical  standpoint.
      This choice  also yields more flexibility in estimating the
      diurnal  emissions.

      If EPA's  intent were simply to predict  the  hourly
      emissions over  temperature cycles limited  to only the
      three  (parallel) cycles in Appendix A,  then "clock time"
      might  be  an  obvious choice for an independent variable.
      However,  since  the  resulting equations  must permit the
      modeling  of  different  temperature cycles including
      interrupted  cycles, the "changes in temperature"  variables
      were used in lieu of a "time" variable.
Those seven strata can be illustrated in the following table.
The numbering of the cells (1 through 7)  within the  table

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                               -11-
coincides with both the numbering in the preceding list as well
as with the numbering of the seven equations in Section 4.2.
Fuel
Delivery
System
Carbureted
Fuel-
Injected
Passing
Both Purge
and
Pressure
(1)
(4)
Failing the
Pressure
Test
(2)
(5)
Failing
ONLY the
Purqe Test
(3)
(6)
Gross
Liquid
Leakers
(7)
     As stated in Section 3.0, the diurnal emissions are the
pressure-driven emissions resulting from the daily increase in
the temperature of both the fuel and the vapor.  Although the
fuel temperature is not a readily available variable, it does
follow the daily cycle of the ambient temperature.  On 80 of the
119 vehicles that EPA tested using the RTD cycles, EPA measured
both the ambient temperature and the fuel tank temperature.  For
hour of each of the three temperature cycles  (illustrated earlier
in Figure 1-1),  we averaged the measured ambient temperatures and
the measured fuel tank temperatures.   These values are plotted
below in Figure 4-1 (ambient temperatures as the solid lines and
fuel tank temperatures as the dotted lines).

                            Figure  4-1

         Comparison  of Ambient and  Fuel  Tank  Temperatures
                      By  Temperature Cycle
        110
      tn
      3
      +j
      5
      o>
      a.
      a>
         90
         50
                                   12

                              Time (hours)
18
24

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                               -12-
In Figure 4-1, the fuel tank temperatures lagged behind the
corresponding ambient temperatures.  We estimated a lag time for
each of the three cycles by minimizing the sum of the squares of
the temperature differences (ambient temperature less tank
temperature).   Those lag times  (given below)  are the times  (in
minutes) by which the fuel tank temperatures lagged behind the
corresponding ambient temperatures.
              Ambient Temperature Cycle
                  60 to  84° Cycle
                  72 to  96° Cycle
                  82 to 106° Cycle
Lag Time
(minutes)
   44.4
   67.0
  108.4
To validate those estimated lag times, each of the three curves
in Figure 4-1 that represented the fuel tank temperatures  (i.e.,
the dotted lines) were shifted left  (i.e., translated) by the
corresponding time lag.  The result of shifting each of those
three curves is illustrated below in Figure 4-2.
                            Figure 4-2

    Comparison  of  Ambient  and "Shifted"  Fuel  Tank Temperatures
                       By  Temperature Cycle
         50
                                   12

                              Time (hours)
   18
24

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                               -13-
     It is basic thermodynamics that the temperature changes
recorded in the fuel tank will lag behind the temperature changes
in the ambient.  What is important is that the lag time of those
temperature changes  (which in turn produce the pressure changes
driving the diurnal emissions) will vary depending upon the
individual daily temperature cycle.  Therefore, for some
temperature cycles the most significant temperature change would
be the one for the current hour, and for other temperature cycles
the most significant temperature change would be one for an
earlier hour.  Thus, EPA considered the following three variables
(and multiplicative combinations of them to allow for
interactions) in modeling the hourly diurnal emissions:

       4  the change in ambient temperature during that specific
          hour,
       4  the change in ambient temperature during the previous
          hour, and
       4  the total change in temperature from the start of the
          cycle until the start of the previous hour.

Since all three of those temperature terms are actually
differences of temperatures, it was not necessary to convert the
temperature units from Fahrenheit to an absolute temperature
scale.  For the three temperature cycles used, these three
temperature variables are given in Appendix A.


4.2   Calculating Hourly Diurnal Emissions by Strata

     EPA will estimate the mean hourly diurnal emissions by
multiplying the full day's diurnal emissions  (estimated in the
parallel report, M6.EVP.001, and reproduced in Appendix C) by the
hourly percentages predicted in Sections 4.2.1 through 4.2.3 of
this report.


4.2.1  Carbureted Vehicles

     As noted in the discussion associated with Table 4-1, there
is limited data on carbureted vehicles.  The only combination of
temperature cycle and fuel RVP represented by at least 10 tests
was that of the 72 to 96 degree cycle using the 6.8 RVP fuel.
That condition persisted even after eliminating the model year
groupings as a stratifying factor.  EPA, therefore, had the
option of either performing analyses based on a small number of
carbureted vehicles or applying the results of the analyses of
the FI vehicles directly to the carbureted vehicles.  EPA decided
to proceed using the limited test results on carbureted vehicles.
The distribution of the tests is given on the following page in
Table 4-2.

-------
                                  -14-
                               Table 4-2

         Distribution of RTD  Tests of  Carbureted Vehicles
Purge/Pressure
Catea ory
Fail ONLY Purge





Fail Pressure





Passing Both





temperature
60 to 84

72 to 96

82 to 106

60 to 84

72 to 96

82 to 106

60 to 84

72 to 96

82 to 106

RVP
6.8
9.0
6.8
9.0
6.8
9.0
6.8
9.0
6.8
9.0
6.8
9.0
6.8
9.0
6.8
9.0
6.8
9.0
Number of
Tests
4
6
19
6
5
4
4
8
45
8
6
4
4
9
59
9
6
4
      EPA chose  to use  stepwise* linear regressions  to identify
the variables that were  the most  influential in determining the
shape of the graph of  the hourly  diurnal  emissions  when plotted
against the hour (clock  time).   ("Time" itself is not actually
the independent variable in the analysis.   See the  "Note"  on page
10.)   The mean  hourly  diurnal emissions were calculated within
each  of the 18  sub-stratum determined by  the purge  / pressure
   The stepwise regression process first  uses  the  Pearson Product-Moment to
   select the independent variable  that has the highest  correlation with  the
   "Ratio of Hourly Diurnal."  The difference between  the best linear estimate using
   that variable  and  that  "Ratio of Hourly Diurnal"  (i.e., the residuals)  is then
   compared with the  set  of  remaining  variables  to  identify  the variable
   having the next  highest  correlation.  This process  continues  as  long as
   the "prob" values  do not exceed (an arbitrary)  5 percent, thus,  creating a
   sequence of  variables in descending order of statistical correlation.   The
   rank ordering  produced by this process is dependent  upon the independence
   of the variables.   In this instance, there is  some  collinearity among  the
   variables which may reduce the usefulness of this statistical tool.

-------
                                 -15-
category,  the temperature cycle, and fuel RVP.   The emissions
were positive for hours  one through  18,  and were zero for hours
19 through 24.  The  emissions for  each hour were divided by the
full  (i.e.,  total 24-hour)  diurnal emissions to  calculate the
percentage (ratio) of  the total diurnal the percentage for hour
19 always  zero).   Therefore, each  purge/pressure stratum
contained  19 hourly  percentages for  each of six  combinations of
temperature cycles and fuel RVP  (for a total of  114 results).
Within  each purge/pressure stratum,  a stepwise linear regression
of those 114 hourly  diurnal ratios was performed to estimate the
"Ratio of Hourly Diurnal" as a linear function of the temperature
variables  (from page 13)  and multiplicative combinations of them,
as well as,  multiplicative combinations of them  with the VP term
(calculated as the midpoint of the VP at the highest and lowest
temperatures of the  day  in kiloPascals).   The stepwise regression
process produced the following three equations that predict the
ratios  of  hourly diurnal emissions from carbureted vehicles:
For Carbureted Vehicles Passing Both Purge and Pressure Tests:                     (1)

    Ratio of Hourly Diurnal      =   0.007032

                    + 0.000023 * [ ( Midpoint VP ) *
                          ( Change in Ambient During Previous Hr)
                          ( Change in Ambient Prior to Previous Hr) ]

                    + 0.003586 * ( Change Prior to Previous Hr)

                    - 0.001111 * ( Sqr of Change During Previous Hr)


For Carbureted Vehicles Failing the Pressure Test:                               (2)

    Ratio of Hourly Diurnal      =   0.010549

                    + 0.001138 * [ ( Change During Previous Hr) *
                          ( Change in Ambient Prior to Previous Hr) ]

                    + 0.001758 * ( Change Prior to Previous Hr)

                    + 0.001765 * ( Sqr of Change During Current Hr)

-------
                                -16-
For Carbureted Vehicles Failing ONLY the Purge Test:                            (3)

    Ratio of Hourly Diurnal      =   0.006724

                   + 0.000023 * [ ( Midpoint VP ) *
                         ( Change in Ambient During Previous Hr)
                         ( Change in Ambient Prior to Previous Hr) ]

                   + 0.003966 * ( Change Prior to Previous Hr)

                   - 0.001122 * ( Sqr of Change During Previous Hr)

                   + 0.000019 * [ ( Midpoint VP ) *
                         ( Sqr of Change During Current Hr) ]

                   - 0.000018* [( Midpoint VP)*
                         ( Change Prior to Previous Hr) ]
More details  can be found in Appendix  D  which contains the
regression  tables and graphs comparing the actual and predicted
hourly ratios.   The solid lines in each  of the graphs in Appendix
D are not regression lines.  If the predicted values exactly
matched the actual values, then the points of predicted versus
actual pairs  would exactly lie on those  lines (i.e., unity
lines).

     EPA will use equations (1) through (3) to predict  the  ratios
of hourly diurnal emissions of the carbureted vehicles that were
not gross liquid leakers.  EPA will then multiply those
percentages by  the full  (24-hour) diurnals estimated by using  the
corresponding equations in Appendix C  to obtain the hourly
emissions  (in grams of HC).

NOTE:  In Appendix  D,  each "point" in the data  is  actually the
      average (mean)  of all  of hourly diurnal  emissions  from all
      of the  tests  within that stratum using  the  same fuel RVP
      and temperature cycle.   This averaging permitted us to
      eliminate  the vehicle-to-vehicle test variability;  however,
      this also  exaggerates  (i.e.,  reduced the usefulness of)  the
      "R-squared"  statistic.   Thus,  that statistic  is a  measure
      of the  amount of the variability in  the  mean  (not  the
      variability  in the individual test data) that is accounted
      for by  the  resulting regression equation.

     The preceding three equations for carbureted vehicles are
actually written in a mixture of algebra and  English.  By
adopting the  following standard notation,  these equations can  be
rewritten in  a  concise algebraic form.

-------
                                 -17-
Let:
            VP  = midpoint vapor pressure
            N   = index (subscript)  indicating current hour
            DN  = temperature change during current  hour
            DN-I = temperature change during previous hour
            DS  = total temperature  change prior  to  previous hour

Using  this notation,  the previous equations become:


For Carbureted Vehicles Passing Both Purge and Pressure Tests:                     (1)

    Ratio of Hourly Diurnal      =   0.007032

                           +   0.000023  * VP *  DN-I  *  Ds
                           +   0.003586  * Ds
                           -   0.001111  * DN-I * DN-I
For Carbureted Vehicles Failing the Pressure Test:                               (2)

    Ratio of Hourly Diurnal      =  0.010549

                           +   0.001138 * DN-I  *  Ds
                           +   0.001758 *  Ds
                           +   0.001765 *  DN * DN


For Carbureted Vehicles Failing ONLY the Purge Test:                             (3)

    Ratio of Hourly Diurnal      =   0.006724

                           +   0.000023 *  VP * DN-1 * Ds
                           +   0.003966 *  Ds
                           -   0.001122 *  DN-1 *  DN-1
                           +   0.000019 *  VP * DN  *  DN
                           -   0.000018 *  VP * Ds
     For each combination of temperature cycle  and fuel RVP,  the
19 fractions (in each  of the preceding three stratum)  total
exactly  1.0.  However,  the fractions  produced by  the three
regression equations do not necessarily sum to  1.0.   Therefore,
to normalize these  fractions in MOBILE6, the fractions for hours
1 through 18 are summed and divided  into the individual results.
The fractions for hours 19 through 24 are set to  zero (on the
assumption that the vehicles are producing only resting loss
emissions for those six hours).  This produces  (for each of the
seven  strata) a distribution of hourly fractions  that total
exactly  1.0.

-------
                               -18-
4.2.2  Strata of Fl Vehicles

     The distribution of the tests of fuel-injected vehicles is
given below in Table 4-3.  This table is similar to the previous
table on the distribution of the tests of carbureted vehicles
(Table 4-2).
                            Table 4-3
             Distribution of  RTD Tests  of FI  Vehicles
Purge/Pressure
Category
Fail ONLY Purge





Fail Pressure





Passing Both





temperature
60 to 84

72 to 96

82 to 106

60 to 84

72 to 96

82 to 106

60 to 84

72 to 96

82 to 106

RVP
6.8
9.0
6.8
9.0
6.8
9.0
6.8
9.0
6.8
9.0
6.8
9.0
6.8
9.0
6.8
9.0
6.8
9.0
Number of
Tests
15
21
21
21
18
16
13
21
23
21
18
14
17
33
73
33
26
22
     For the strata of fuel-injected vehicles, the analytical
approach was similar to that used for the carbureted vehicles.
That is, the mean hourly diurnal emissions were calculated within
each of the 18 sub-stratum determined by the purge/pressure
category,  the temperature cycle, and fuel RVP.  The emissions
were positive for hours one through 18, and were zero for hours
19 through 24.  The percent of the total diurnal emissions
represented by each hour was calculated for hours one through 19
(with the percentage for hour 19 always zero).  Therefore, each
purge/pressure stratum contained 19 hourly percentages for each
of six combinations of temperature cycles and fuel RVP (for a
total of 114 results).

-------
                                   -19-
      Within  each of  the three purge/pressure stratum,  a stepwise
linear regression of those  114 hourly diurnal ratios was
performed to estimate the  "Ratio of Hourly Diurnal"  as a  linear function
of the temperature variables  (from  page 13)  and multiplicative
combinations of them,  as well as, multiplicative  combinations of
them  with the VP term (calculated as the midpoint  of the VP at
the highest  and lowest temperatures of the day in  kiloPascals).
The stepwise regression process produced the following three
equations that predict the  ratios of hourly  diurnal  emissions
from  fuel-inj ected vehicles:
For  Fuel-injected Vehicles Passing Both Purge and Pressure Tests:                     (4)
     Ratio of Hourly Diurnal      =   0.008001
                     + 0.001961 * ( Change Prior to Previous Hr)
                     + 0.000535 * [ ( Change During Previous Hr) *
                           ( Change in Ambient Prior to Previous Hr) ]
                     -  0.000060 *[( Midpoint VP )*
                           ( Sqr of Change During Previous Hr) ]
                     + 0.005964 * ( Change During Current Hr)
                     + 0.000056 * [ ( Midpoint VP ) *
                           ( Change in Ambient Prior to Previous Hr) ]
For  Fuel-injected Vehicles Failing the Pressure Test:                                (5)
     Ratio of Hourly Diurnal       =   0.006515
                     + 0.001194 * [ ( Change During Previous Hr) *
                           ( Change in Ambient Prior to Previous Hr) ]
                     + 0.001963 * ( Change Prior to Previous Hr)
                     + 0.001329 * ( Sqr of Change During Current Hr)
                     + 0.000574 * ( Sqr of Change During Previous Hr)

-------
                                   -20-
For  Fuel-injected Vehicles Failing ONLY the Purge Test:                              (6)

     Ratio of Hourly Diurnal       =   0.007882
                     + 0.000855 * [ ( Change During Previous Hr) *
                           ( Change in Ambient Prior to Previous Hr) ]
                     + 0.000084 * [ ( Midpoint VP ) *
                           ( Change in Ambient Prior to Previous Hr) ]
                     + 0.006960 * ( Sqr of Change During Current Hr)
                     - 0.000160 * [ ( Midpoint VP ) *
                           ( Sqr of Change During Current Hr) ]
                     - 0.001172 * ( Change Prior to  Previous Hr)
                     + 0.000118* [( Midpoint VP)*
                           ( Change in Ambient During Current Hr) ]
                     + 0.000825 * ( Sqr of Change During Previous Hr)


More details can be  found in Appendix D which contains the
regression  tables  and graphs comparing  the actual  and predicted
hourly ratios.  Again,  the solid  lines  in each of  the graphs  in
Appendix D  depict  the case in which the predicted  values exactly
matched the actual values.  EPA will use equations (4)  through  (6)
to predict  the ratios of  hourly diurnal emissions  of  the fuel-
injected vehicles  that  were not gross liquid  leakers.

      By adopting the same standard notation  (as in Section
4.2.1), the preceding equations can also be  rewritten in the
following concise  algebraic form:


For  Fuel-injected Vehicles Passing Both Purge and Pressure Tests:                     (4)

     Ratio of Hourly Diurnal       =   0.008001

                            + 0.001961 * Ds
                            + 0.000535 * DN-1 * Ds
                            - 0.000060 * VP * DN-I * DN-I
                            + 0.005964 * DM
                            + 0.000056 * VP * Ds

For  Fuel-injected Vehicles Failing the Pressure Test:                                (5)

     Ratio of Hourly Diurnal       =   0.006515

                            + 0.001194* DN-I * Ds
                            + 0.001963* Ds
                            + 0.001329* DM* DN
                            + 0.000574 * DM.-I * DM.-I

-------
                               -21-
For Fuel-injected Vehicles Failing ONLY the Purge Test:                          (6)

    Ratio of Hourly Diurnal      =  0.007882

                         + 0.000855 * DN-I * Ds
                         + 0.000084 * VP * Ds
                         + 0.006960 * DN * DN
                         - 0.000160* VP* DN* DN
                         - 0.001172* Ds
                         + 0.000118* VP* DN
                         + 0.000825 * DN-1 * DN-1


     As with the equations for the carbureted strata, these three
equations are also normalized (for full-day diurnals) by dividing
each of the predicted hourly  fractions by the sum of predicted
fractions for hours one  through 18.  The fractions for hours 19
through 24 are again set  to zero.

     In the observations  following Table 4-1, it was noted that
the shape of the hourly  distribution curve (i.e., the ratios not
the actual magnitude) for FI  vehicles  that failed the pressure
test seemed to be insensitive to changes in the fuel RVP.  The
regression in Appendix D  confirms  that observation.  The
regression table indicates that more than 95 percent of the
variability in the hourly diurnal  emissions can be explained
using only the variables  involving changes in the temperature.
(A similar condition holds true for carbureted vehicles that
failed the pressure test.)  Therefore,  while changing the RVP of
the fuel will affect the  magnitude of  the full-day's diurnal
emission, it does not affect  how those emissions are distributed
over the day for the vehicles that fail the pressure test.


4.2.3  "Gross  Liquid  Leaker" Vehicles

     In the parallel report (M6.EVP.001),  vehicles classified as
"gross liquid leakers" were analyzed separately from the other
vehicles for the following two reasons:
       4  the large differences in both resting loss and diurnal
          emissions, as  well  as,

       4  the mechanisms  that produce  those high emissions.

For these vehicles, the  primary source of the evaporative
emissions is the leakage  of liquid (as opposed to gaseous) fuel.
Therefore, we would expect the diurnal emissions from these
vehicles to be less sensitive to changes in ambient temperature
than the diurnal emissions from vehicles that do not have
significant leaks of liquid gasoline.

-------
                               -22-
     The analyses in Sections 4.2.1 and 4.2.2 were repeated for
the vehicles identified as being gross liquid leakers.  The
hourly RTD results for those test vehicles are given in Appendix
E.  Several of these vehicles exhibited unusually high emissions
during the first one or two hours of the test (relative to their
emissions for the next few hours).   One possible explanation is
that during the first two hours of the RTD test, the analyzer was
measuring gasoline vapors that resulted from liquid leaks that
occurred prior to the start of the test.  These additional
evaporative emissions (if they existed as hypothesized) would
have resulted in a higher RTD result than this vehicle would
actually have produced in a 24 hour period.  In the last column
of Appendix E, we attempt to compensate (as explained in the
footnote in Appendix E)  for what appears to be simply an artifact
of the test procedure.  The modified RTD evaporative emissions
were then converted to diurnals by assuming that the hourly
resting loss for these vehicles is completely independent of
ambient temperature, subtracting that amount (8.52 grams per hour
which is the average RTD emissions of hours 19 through 24) from
each hour's modified RTD emissions, and then dividing by the
total diurnal to yield the hourly percentages below in Table 4-4.
                            Table 4-4

             Distribution  of  Hourly  Diurnal  Emissions
                     of Gross Liquid Leakers
         (Hourly  Emissions as Percent of  24-Hour Diurnal)
Hour
1
2
3
4
5
6
7
8
9
10
11
12
Time of Dav
6- 7 AM
7- 8 AM
8- 9 AM
9 -10 AM
10-11 AM
11 AM -Noon
Noon - 1 PM
1 -2PM
2- 3PM
3- 4PM
4- 5PM
5- 6PM
Emissions
1 .82%
3.64%
7.27%
8.63%
9.19%
9.80%
9.64%
9.61%
7.95%
7.50%
5.89%
5.09%
Hour
13
14
15
16
17
18
19
20
21
22
23
24
Time of Dav
6-7 PM
7-8 PM
8-9 PM
9-10PM
10-11 PM
11 PM- Midnight
Midnight- 1 AM
1 -2AM
2-3 AM
3 -4 AM
4-5 AM
5 -6 AM
Emissions
4.53%
2.99%
1 .95%
1 .73%
1 .48%
1 .28%
0%
0%
0%
0%
0%
0%
     A stepwise linear regression of those hourly diurnal ratios
(for hours 1 through 19)  was performed to estimate the "Ratio of
Hourly Diurnal"  as  a  linear function of  the  temperature  variables
(from page 13)  and multiplicative combinations of them, as well
as, multiplicative combinations of them with the VP term
(calculated as the midpoint of the VP at the highest and lowest
temperatures of the day in kiloPascals).  The stepwise regression
process produced the following equation that predicts the ratios

-------
                                -23-
of hourly  diurnal emissions  from vehicles with  gross liquid
leaks:

For "Gross Liquid Leaker" Vehicles:                                         (7)

    Ratio of Hourly Diurnal      =   0.021349
                    + 0.010137 * ( Change During Previous Hr)
                    + 0.002065 * ( Change Prior to Previous Hr)


     Just  as  the six equations  for carbureted and fuel-injected
vehicles  (sections 4.2.1 and  4.2.2)  were rewritten in concise
algebraic  forms,  so too can  this equation:

For "Gross Liquid Leaker" Vehicles:                                         (7)

    Ratio of Hourly Diurnal      =   0.021349

                           +  0.010137 * DN-I
                           +  0.002065 * Ds


More details  can be found in  Appendix D which contains the
regression table and graph comparing the actual  and predicted
hourly  ratios.   A second graph  comparing the actual and predicted
hourly  ratios appears in Figure 4-3  in which equation (7) is
plotted as a  solid line and  the data from Table  4-4 as a bar
chart.  Based on those two graphs depicting close matches between
the predicted and actual ratios of hourly diurnal emissions, EPA
will use equation (7) to predict  the  ratios of the  hourly diurnal
emissions  of  the gross liquid leakers.

-------
                                -24-
                             Figure  4-3

             Distribution of Hourly Diurnal Emissions
                    from  "Gross Liquid Leakers"
          12%
           8%
           4% -
           0%
                                7       10

                               Duration (hours)
13
16
     In  the  earlier report  (from Section 10.2  of M6.EVP.001),  it
was determined that the mean 24-hour diurnal emissions from
"gross liquid leakers"  (for  any of the three temperature cycles
in Appendix  A and independent of the fuel RVP)  was 104.36 grams.
Multiplying  the hourly ratios in equation (7) by  that  value
produces  equation (7a)  that predicts  the mean hourly diurnal
emissions (in grams of HC) for vehicles that are gross liquid
leakers.
For "Gross Liquid Leaker" Vehicles:

    Hourly Diurnal Emissions (grams of HC) =

                    + 2.22798

                        + 1.057897 * ( Change During Previous Hr)

                        + 0.215503 * ( Change Prior to Previous Hr)
                  (7a)

-------
                               -25-
     In that earlier report, we predicted  the  full  24-hour
diurnal emissions from vehicles that  were  not  gross liquid
leakers for all temperature cycles  in which the hourly changes in
temperatures are proportional  to  the  cycles in Appendix A.
Unfortunately, the corresponding  data on the "gross liquid
leakers" were limited  (i.e., practically all of the tests were
performed using the same temperature  cycle), and we did not make
similar predictions for the gross liquid leakers.   However, if we
apply equation (7a)  to  each hour of any temperature cycle  (with
the hourly changes in temperatures  proportional to  the cycles in
Appendix A) and then add these hourly predictions together, we
obtain equation (7b):

 Total 24-Hour Diurnal Emissions (grams)                                   (7b)

                              = 40.5533 + ( 2.658611 * Diurnal_Temperature_Range )


Where the Diurnal_Temperature_Range  is  the difference  of  the  daily  high
temperature minus the daily low temperature.

     Note, equation (7b) predicts a 24-hour total diurnal  emission
of 40.48 grams for a day during which the  temperatures do not
change.  This is not reasonable since diurnal  emissions result
from the daily rise in ambient temperatures.   Therefore,  EPA will
set the 24-hour diurnal equal  to  zero for  a diurnal temperature
range of zero degrees Fahrenheit.   For diurnal temperature ranges
between zero and ten degrees Fahrenheit, EPA will calculate the
24-hour diurnal for gross  liquid  leakers as increasing linearly
from zero to 67.21 grams  (i.e., the value  predicted by the
equation for a diurnal temperature  range of 10 degrees).

     Of the seven regression analyses performed (and displayed in
Appendix D),  the simplest  equation  (in terms both of number of
variables and complexity of the variables)  is  the equation that
predicts the hourly diurnal emissions of gross liquid leaking
vehicles.  This most likely results from the simplicity of the
primary mechanism that produces the emissions  for the vehicles in
this stratum  (i.e., a significant leakage  of liquid fuel).


4.2.4  Summarizing All Strata

     Examining the seven stepwise regression analyses in Appendix
D (one for each of the stratum identified  on page 10),  we note
that not every possible variable  described on  page  13  (along with
their multiplicative combinations)  were found  to be statistically
significant in one or more of  those analyses;  only  11 variables
and products of variables  were found  to be statistically
significant:

    4  Delta  (change)  in previous hour's temperature,
    4  Delta  (change)  in current  hour's temperature,

-------
                               -26-
    4  Total change in temperature prior to the previous hour
       (i.e.,  temperature at the start of the previous hour minus
       the daily low temperature),
    4  Square of the delta in previous hour's temperature,
    4  Square of the delta in current hour's temperature,
    4  Product of the delta in previous hour's temperature  times
       the total (change in temperature)  prior to the previous
       hour,
    4  Product of the "midpoint vapor pressure value" (VP)  times
       the delta in current hour's temperature,
    4  Product of the VP times the total change prior to the
       previous hour,
    4  Product of the VP times the square of the delta in
       previous hour's temperature,
    4  Product of the VP times the square of the delta in current
       hour's temperature,  and
    4  Product of the VP times the delta in previous hour's
       temperature times the total prior to the previous hour.

On further examination of Appendix D, we note that some of those
variables are statistically significant in most of the strata:

    4  The total change in temperature prior to the previous
       hour, possibly combined with its product (i.e.,
       interaction)  with the midpoint VP,  is statistically
       significant in all seven strata.
    4  The product of the delta in previous hour's temperature
       times the total change in temperature prior to the
       previous hour,  possibly combined with its product with the
       midpoint VP,  is statistically significant in the six
       strata that do not include gross liquid leakers.
    4  The square of the delta in the previous hour's
       temperature,  possibly combined with its product with the
       midpoint VP,  is statistically significant in the five
       strata that do not include either gross liquid leakers or
       carbureted vehicles that failed the pressure test.
    4  The square of the delta in the current hour's temperature,
       possibly combined with its product with the midpoint VP,
       is statistically significant in the four strata of
       vehicles that failed either the pressure or the purge test
       but which are not gross liquid leakers.

This "universality" of the variable "total change in temperature
prior to the previous hour" will be the basis for a critical
assumption in estimating interrupted diurnals (in Section 5.2).

-------
                               -27-
5.0   INTERRUPTED DIURNAL

     Many vehicles do not actually experience a full  (i.e., 24-
hour)  diurnal.  That is, their soak is interrupted by a trip of
some duration.  This results in what this report refers to as an
"interrupted diurnal."  The following example illustrates such an
interrupted diurnal.


5.1   Example of  an  Interrupted Diurnal

     For the purpose of this example, we will use the type of
vehicle and conditions in Figure 3-1 (i.e., a 1986-95 model year
FI vehicle that passes both the purge and pressure tests, uses a
6.8 RVP fuel, and experiences a daily temperature profile of the
standard 72° to 96° F cycle from Appendix A).  For those
conditions, we will assume the following vehicle activity:

     1.   The vehicle soaks overnight and into the early morning.

     2.   Shortly after 9 AM (corresponding to the fourth hour of
          the RTD test), the vehicle is driven for 30 minutes.
          The vehicle reaches its destination and is parked by
          10 AM.   (That is, the entire drive takes place during
          the fourth hour of the RTD test.)

     3.   The vehicle remains parked until the following morning.

The resting loss emissions would continue throughout the entire
24-hour period of this example.  However, the other types of
evaporative emissions would occur for only limited periods.

     1.   The first segment of this example (from 6 AM through 9
          AM) corresponds to the first three hours of the RTD
          test.   Therefore, the diurnal emissions are represented
          by the first three hours in Figure 3-1.

     2.   The evaporative emissions associated with the morning
          drive are the "running loss" emissions and the
          continuing resting loss emissions.  Thus, the running
          loss emissions replace the diurnal emissions for the
          fourth hour (from 9 AM through 10 AM).   We will
          allocate the entire hour interval (rather than
          fractional intervals) to running loss emissions even if
          the actual drive is much shorter than one hour.  (Since
          running loss emissions are calculated as a function of
          distance, rather than of time, this approach will not
          change the total running loss emissions.  Also, since
          MOBILE6 will not report emissions for intervals smaller
          than one hour, this approach will not change the
          calculated emissions.)  The data used for the driving
           (running) activity and the data use for the soak
           (parked)  activity are both based on the same data set
          and are,  therefore,  consistent.

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                             -28-
  3.    While  the  vehicle was being driven,  the  temperature in
       its fuel tank rose by about 20 degrees Fahrenheit*.
       After  the  vehicle stops and until  this elevated fuel
       temperature  drops to become equal  to the ambient air
       temperature,  the vehicle will be experiencing what is
       referred to  as "hot soak" emissions.

       In MOBILES (and MOBILE4.1), EPA determined the time
       required to  stabilize the temperatures was two hours.
       Therefore, the hot soak emissions  replace the diurnal
       emissions  for the fifth and sixth  hours  (from 10 AM
       through noon).  For calculation purposes,  in MOBILE the
       entire hot soak emissions will be  credited to the first
       hour  (see  reports M6.EVP.004 and M6.FLT.004).  Thus, in
       this example,  from 11 AM to noon,  only resting losses
       will be calculated.

  4.    At noon, we  assume the fuel temperature  has cooled to
       the ambient  temperature of 93.1° F (from the
       temperature  profile).  The hourly  diurnal emission will
       resume but in the modified form of an "interrupted
       diurnal" due to the effects of the drive on canister
       loading and  fuel temperature.  To  modify the hourly
       diurnal emissions, we will make the following
       assumptions:

         4 The pressure that is driving the  interrupted
           diurnal  emissions (starting at  noon)  results from
           the fuel  being heated to above  the temperature
           which  occurred at the end of the  hot  soak (in this
           example,  93.1° F) .   Therefore,   had the ambient
           temperature not risen above 93.1° F,  there would
           have been no further diurnal emissions for the
           remainder of that day,  only resting  loss emissions.

         4 This suggests that the interrupted diurnal
           emissions  will end once the ambient  temperature
           returns  to  its starting point  (i.e.,  93.1° F in
           this example).

         4 From the  temperature profile,   the ambient
           temperature will  return to 93.1   at  5:25 PM.  We
           will assume that  after 6 PM,  there are only resting
           loss emissions.
In SAE Paper Number 931991  (referenced in Appendix B),  the authors discuss
the increase in tank  temperatures as  a function of trip duration when the
trips are longer than 5 minutes.  Table 4 of that report illustrates this
point.  A 15 minute trip would be associated (on average) with an increase
in tank  temperature of  about  12  to  13 degrees Fahrenheit.   A 30  minute
trip would be associated with  an increase in tank temperature of about  20
degrees  Fahrenheit,  while  a  one hour trip would  be  associated with  an
increase in tank temperature of about 30 degrees Fahrenheit.

-------
                               -29-
              Therefore,  we need to modify the estimated hourly
              diurnal emissions so that the modified values are
              zero after 6 PM (i.e.,  from test hour 13 through
              24).  In the following section (Section 5.2), EPA
              presents a method of modifying the hourly diurnal
              emissions following such an interruption to the
              soak period.


5.2   Calculating Emissions  of an Interrupted Diurnal

     Based on the discussions in the preceding sections, EPA will
make the following four key assumptions in estimating interrupted
diurnals:

    4  The ambient temperature at the beginning of the
       interrupted diurnal (i.e., the end of the hot soak)  will
       be  used as the starting temperature for that interrupted
       diurnal.
    4  In  Section 4.2.4,  we commented on the "universality" of
       the variable "total change in temperature prior to the
       previous  hour."  In those analyses of diurnals that were
       not interrupted, that variable was calculated by
       subtracting the daily low temperature (i.e., the starting
       temperature of the full day's diurnal)  from the
       temperature at the start of the previous hour.  For
       interrupted diurnals,  EPA will replace the "daily low
       temperature" in that subtraction with that new starting
       temperature.
    4  The estimate of hourly diurnal emissions from that
       interrupted diurnal will be modified so that they cease
       once the  ambient temperature drops below that new starting
       temperature.
    4  In  reality, when a soak period is interrupted by operating
       a vehicle, that operation may have the effect of purging
       (at least partially)  the vehicle's canister (see GM's SAE
       paper number 891121,  entitled "Measured Performance under
       Interrupted Diurnal Conditions").   That (partial) purge of
       the canister (if it occurs)  has the potential to improve
       the ability of the vehicle's evaporative control system to
       reduce subsequent diurnal emissions.  Due to the lack of
       data on this phenomenon,  EPA has assume that any such
       improvement will be minimal and can be ignored.

     In the preceding paragraphs, we analyzed one theoretical
situation in which the diurnal emissions  (following the morning
drive)  resumed at noon when the ambient temperature reached
93.1°F and, then, continued until the temperatures declined to
that 93.1°F  (at 5:25 PM).  Using the 72° to 96° F temperature
cycle given in Appendix A, we can repeat those calculations for

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                                 -30-
interrupted diurnals that begin at each  hour of the  day.
results  appear in  Table 5-1  (below).
Those
     While the starting temperatures  (the  second column in Table
5-1) would vary with the daily temperature cycle, the time at
which  each (interrupted) diurnal ends would be unchanged for any
of the three temperature cycles in Appendix A or for  any cycle
based  on those three.   Table  5-1,  therefore,  provides the time
intervals during which diurnal emissions could occur  following  an
interruption to the soak period.


                                Table 5-1

                Starting and Ending Times and Temperatures
                         For Interrupted Diurnals
                     For the 72° to 96° Fahrenheit Cycle
Diurnal B
Time
Midnight thru 6 AM*
7:00 AM
8:00 AM
9:00 AM
10:00 AM
1 1 :00 AM
Noon
1:00 PM
2:00 PM
3 PM thru Midnight
egins
Temperature
72.0°
72.5°
75.5°
80.3°
85.2°
89.4°
93.1°
95.1°
95.8°
N/A***
Time
Diurnal
Ends
Midnight**
Midnight**
Midnight**
10:18PM
8:06PM
6:44PM
5:25PM
4:17PM
3:24PM
N/A***
     Therefore, EPA modified  the predicted hourly emissions of
full day's diurnals (from equations (1) through (7))  using the
following four-step process:
    In Section 4.2.1,  it  was noted that diurnal emissions are zero  for hours
    19 through 24  (i.e., midnight  through  6AM) .   Thus,  any diurnal  that
    begins  between  midnight and  6AM  effectively begins at  6AM,  and  that
    diurnal is actually a full  24-hour diurnal.

    In the  previous footnote,  it  was  noted  that diurnal emissions are  zero
    after midnight.   Thus,  even if the ambient temperature  has not returned
    to the  temperature  at which the (interrupted)  diurnal began,  the diurnal
    effectively ends by the following midnight.

    Any interrupted diurnal  that  begins while the ambient  temperatures  are
    declining  (i.e., 3 PM or  later) does not exist  (has zero  emissions).

-------
                               -31-
     1.)   In each of the seven regression equations  (in Sections
          4.2.1 through 4.2.3), the variable "Change Prior to Previous Hr"
          appears.  For an interrupted diurnal, that variable is
          calculated by subtracting the temperature at the start
          of the interrupted diurnal from the temperature at the
          beginning of the previous hour.  This step will produce
          an estimate of the percent of the full day's diurnal
          occurring each hour of the interrupted diurnal.

     2.)   Those hourly percentages would then be modified so that
          any negative estimates would be changed to zero, and
          any estimates for hours beyond the "Time Diurnal Ends"
          column in Table 5-1 would be replaced by zero.

     3.)   The total 24-hour diurnal emissions are then predicted
          using the regression equations from Appendix C.

     4.)   Finally, the hourly  (interrupted) diurnal emissions are
          estimated by multiplying the predicted full 24-hour
          diurnal emissions by the individual hourly percentages.

     To illustrate the use of this four-step process, we return
to the example in Section 5.1.

    4  Both Table 5-1 and the discussion at the end of Section
       5.1 indicate that the interrupted diurnal emissions would
       begin at noon and continue until 6 PM.   For each of those
       six hours,  we can use Appendix A to construct a table of
       hourly temperatures and changes in temperatures.   (We will
       assume that the changes in temperature prior to noon are
       zero.)   Those temperature values are given in Table 5-2 on
       the following page.

    4  Using the changes in temperature in Table 5-2 we use
       equation (4)  (to estimate hourly emissions from FI
       vehicles that pass both the pressure and purge tests)  to
       calculate the estimated percentages of the full 24-hour
       diurnal emissions that occur each hour of this interrupted
       diurnal.  Those hourly fractions are given (as
       percentages)  in the seventh column of Table 5-2.

    4  For the purpose of that example,  we assumed a 1986-95
       model year,  FI vehicle that passed both the purge and
       pressure tests,  that used a 6.8 RVP fuel, and where the
       daily temperature profile was the standard 72° to 96° F
       cycle from Appendix A.  The equation in Appendix C
       predicts the full 24-hour diurnal in this case would be
       2.55 grams (per day).

    4  Multiplying the predicted full 24-hour diurnal (2.55
       grams)  emissions by the six hourly percentages then
       produces the estimated hourly emissions  (in grams)  which

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                               -32-
       appear as the eighth column of Table 5-2.  (The negative
       value for the second hour is then rounded up to zero.)
                            Table 5-2

         Example of Calculating Hourly Diurnal Emissions
                   From an Interrupted Diurnal

Time
Of Day
Noon - 1PM
1PM -2PM
2PM - 3PM
3PM -4PM
4PM - 5PM
5PM -6PM
Initial
Temp
(°F)
93.1
95.1
95.8
96.0
95.5
94.1
Final
Temp
(°F)
95.1
95.8
96.0
95.5
94.1
91.7
Change in
Previous
HrTemp
0
2.0
0.7
0.2
-0.5
-1.4
Change in
Current
Hr Temp
2.0
0.7
0.2
-0.5
-1.4
-2.4
Change
Prior to
Previous
0
0.0
2.0
2.7
2.9
2.4
Hourly
Diurnal
(pet)
0.80%
-0.06%
1.16%
1 .35%
1 .23%
0.66%
Hourly
Diurnal
(grams)
0.020
0.000
0.030
0.034
0.031
0.017
     EPA believes that while this approach is not perfect  (as
evidenced by the prediction of negative emissions during the
second hour that needed to be rounded up to zero),  it does
provide a reasonable estimate of hourly diurnal emissions during
an interrupted diurnal; therefore, EPA uses this method in
MOBILE6.

     For MOBILE6 to actually use estimates of interrupted diurnal
emissions, it is obvious that for each hour of the day  (or for at
least the 18 hours between 6 AM and midnight) we must know the
percent of the fleet that has been soaking for "n" hours (n = 1,
2, 3, .  .  .  ,  72).   The analysis that yields this distribution of
fleet activity can be found in report number M6.FLT.006 (entitled
"Soak Length Activity Factors for Diurnal Emissions").


6.0   ASSUMPTIONS RELATED TO HOURLY EMISSIONS

     Several basic assumptions related to estimating hourly
emissions were made in this analysis due to the lack of test
data.


6.1   Distribution of Hourly Diurnal Emissions

     In Section 4,  the key assumption is that once the hourly
diurnal emissions are divided by the full 24-hour diurnal
emissions, the distribution (within each of the seven strata
identified on page 10) of those fractions is a function of the
temperature change variables and the midpoint VP.
     As a direct result of that assumption, the hourly diurnal
emissions (in grams) can be predicted by simply multiplying the

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                               -33-
estimated full 24-hour diurnal emissions  (from Appendix C) by the
fractions calculated in Section 4.2.  EPA will use those products
as estimates of the diurnal emission from each individual hour.


6.2   Assumptions  for Interrupted  Diurnals

     The discussion of interrupted diurnals  (in Sections 5.1 and
5.2)  requires a number of assumptions.  Four of these assumptions
are stated at the beginning of Section 5.2.

     The fifth assumption deals with estimating how much time
must elapse following the driving cycle for the diurnal to
resume.  It is an accepted fact that interrupting the diurnal
with a trip will result in a temporary increase in fuel tank
temperature.  The time required after the trip for the fuel
temperature to return to  (i.e., achieve equilibrium with) the
ambient temperature depends on many factors  (e.g., duration of
the trip, fuel delivery system, fuel tank design, fuel tank
materials,  air flow, etc.).  However, EPA will continue the
approach used since MOBILE4.1 of assuming that exactly two hours
is necessary to stabilize the temperatures.   (Also, this approach
of rounding off the vehicle activity periods to whole hours is
also consistent with the vehicle activity data that will be used
in MOBILE6.)


6.3   Temperature Ranges

     All of the tests used in this analysis were performed using
one of the three temperature cycles in Appendix A.  Thus, all of
the resting loss data were measured at only three temperatures
(i.e., 60,  72, and 82 °F).  In Appendix F, we present regression
equations  (developed in M6.EVP.001) to estimate hourly resting
loss emissions at any temperature.  We will limit that
potentially infinite temperature range as we did in the previous
version of MOBILE,  specifically:

 1)  We will assume, for vehicles other than gross liquid
     leakers, there are no resting loss emissions when the
     temperatures are below or equal to 40°F.  (This assumption
     was used consistently for all evaporative emissions in
     MOBILES.)

     For temperatures between 40°F and 50°F, EPA will interpolate
     between an hourly resting loss of zero and the value
     predicted in Appendix F for 50°F.

 2)  We will assume, for vehicles other than gross liquid
     leakers, that when the ambient temperatures are above 105°F
     that the resting loss emissions are the same as those
     calculated at 105°F.

-------
                               -34-
Since vehicles classified as gross liquid leakers were not
handled separately in MOBILES, we will now make a new assumption
concerning the resting loss emissions of those vehicles as
relates to temperatures.  Specifically:

 3)  For the vehicles classified as gross liquid leakers, we will
     assume the resting loss emissions are completely independent
     of temperature,  averaging 9.16 grams per hour, (from report
     number M6.EVP.009, entitled "Evaporative Emissions of Gross
     Liquid Leakers in MOBILE6").

     In a similar fashion, the equations developed in this report
to estimate hourly diurnal emissions theoretically could also be
applied to any temperature cycle.   EPA will limit those functions
by making the following assumptions:

 1)  Regardless of the increase in ambient temperatures, there
     are no diurnal emissions until the temperature exceeds 40°F.
     (This assumption was used consistently for all evaporative
     emissions in MOBILES.)

     For a temperature cycle in which the daily low temperature
     is below 40°F, EPA will calculate the diurnal emissions for
     that day as an interrupted diurnal that begins when the
     ambient temperature reaches 40 °F.

 2)  The 24-hour diurnal emissions will be zero for any
     temperature cycle in which the difference between the daily
     high and low temperatures (i.e., the "diurnal temperature
     range")  is no more than zero degrees Fahrenheit.   For
     temperature cycles in which the diurnal temperature range is
     between zero and ten degrees Fahrenheit, the 24-hour diurnal
     emissions will be the linear interpolation of the predicted
     value for the ten-degree cycle and zero.


6.4   Estimating  Vapor Pressure

     EPA will use the RVP of the fuel and the Clausius-Clapeyron
relationship to calculate the vapor pressure of the fuel at each
ambient temperature (see Figure B-l).  This approach is the
equivalent of attempting to draw a straight line based on only a
single point since RVP is the vapor pressure calculated at a
single temperature (100° F).  Since two different fuels could
have the same vapor pressure at a single temperature,  it is
possible for two fuels to have the same RVP but different
relationships between the vapor pressure and the temperature.
However, the two vapor pressure curves would yield similar
results near the point where they coincide (i.e., at 100° F) .
Thus, at temperatures where ozone exceedences are likely to
occur,  this assumption  (i.e., using Appendix B to estimate vapor
pressure) should produce reasonable estimates of diurnal
emissions.

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                               -35-
6.5   Duration of  Diurnal Soak Period

     The analyses in this report were based on diurnals of 24
hours or less in length.  In the real-world, vehicles could soak
for longer periods of time.  Estimating diurnal emissions when
the soak period is a multiple of 24 hours are analyzed in report
M6.EVP.003.  For the purpose of this analysis, a full 24-hour
diurnal takes place between 6 AM and 6 AM  of the  following day
(with hourly diurnal emissions of zero between midnight and
6 AM).   If a diurnal period extends beyond 6 AM,  then the
emissions during the hours beyond 6 AM will be calculated using
equations (1) through (7)  (in Sections  4.2.1  through  4.2.3).

     EPA's approach of classifying a diurnal that follows a
diurnal of less than 24 hours is based on EPA's hypothesis of why
a single-day diurnal is different from a multiple-day diurnal.
EPA believes that as the time progresses  (during a multiple day
diurnal), the vehicle's evaporative canister becomes more heavily
loaded  (with possible back purge occurring during the night
hours).  Therefore, if the first day's interrupted diurnal is
almost equivalent to a full 24-hour diurnal, EPA will treat the
subsequent days as if the first day's diurnal were a complete
(i.e.,  a full-day) diurnal.

     To determine the meaning of an interrupted diurnal being
"almost equivalent" to a full 24-hour diurnal, we applied the
equations (1) through (6)  to various  combinations of  fuel RVP,
temperature cycle, and starting time of an interrupted diurnal.
This analysis determined that:

        4 Interrupted diurnals that began at 10 AM (i.e.,  the
          start of the fourth hour of the RTD test) exhibited
          only about one-third of the emissions of the full 24-
          hour diurnal.
        4 Interrupted diurnals that began at 9 AM (i.e.,  the
          start of the third hour of the RTD test)  exhibited only
          about one-half of the emissions of the full 24-hour
          diurnal.
        4 Interrupted diurnals that began no later than 8 AM
           (i.e., at least by the start of the second hour of the
          RTD test) exhibited at least 80 percent of the
          emissions of the full 24-hour diurnal.

Based on these observations,  if a vehicle's first day's
incomplete  (i.e., interrupted) diurnal begins no later than 8 AM,
EPA will treat the subsequent days as if the first day's diurnal
were a complete diurnal.  Otherwise, we treat the subsequent day
as the first day of the diurnal.

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                               -36-
7.0   CONCLUSIONS

     The conclusions (and assumptions) that EPA drew from this
analysis and then incorporated into MOBILE6 are:

 1)   For the purpose of analyzing characteristics of hourly
     diurnal emissions, the in-use fleet can be divided into the
     following seven strata:

      4    the vehicles classified as  "gross liquid leakers,"
      4    carbureted vehicles  (not  "gross liquid leakers") that
           pass both the purge and pressure tests,
      4    carbureted vehicles  (not  "gross liquid leakers") that
           fail the pressure test,
      4    carbureted vehicles  (not  "gross liquid leakers") that
           fail only the purge test,
      4    FI vehicles  (not "gross liquid leakers") that pass
           both the purge and pressure tests,
      4    FI vehicles  (not "gross liquid leakers") that fail
           the pressure test, and
      4    FI vehicles  (not "gross liquid leakers") that fail
           only the purge test.
     The full-day's diurnal emissions (for each of the preceding
     seven strata)  can be distributed over 18 hours (from 6AM
     through midnight) using equations (1) through (7)  (in  Sections
     4.2.1 through 4.2.3) .
     For emissions produced over an interrupted diurnal (in which
     "key-off" occurs after 4AM),  those same equations can be
     used with the substitution of the "new starting temperature"
     (i.e., two hours after engine shut-off) in place of "daily
     low temperature."

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                               -37-
                           Appendix A

                     Temperature Cycles (°F)
Hour
0
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
Temperatures Cycling Between
60-84T 72-96°F* | 82-1 06°F
60.0 72.0 ! 82.0
60.5 72.5 ! 82.5
63.5 75.5 | 85.5
68.3 80.3 ! 90.3
73.2 85.2 | 95.2
77.4 89.4 ! 99.4
81.1 93.1 | 103.1
83.1 95.1 ! 105.1
83.8 95.8 | 105.8
84.0 96.0 ! 106.0
83.5 95.5 | 105.5
82.1 94.1 ! 104.1
79.7 91.7 | 101.7
76.6 88.6 ! 98.6
73.5 85.5 | 95.5
70.8 82.8 ! 92.8
68.9 80.9 | 90.9
67.0 79.0 ! 89.0
65.2 77.2 | 87.2
63.8 75.8 ! 85.8
62.7 74.7 | 84.7
61.9 73.9 ! 83.9
61.3 73.3 | 83.3
60.6 72.6 ! 82.6
60.0 72.0 | 82.0
Change in
Previous Hr
Terno (°F)
—
0.0
0.5
3.0
4.8
4.9
4.2
3.7
2.0
0.7
0.2
-0.5
-1.4
-2.4
-3.1
-3.1
-2.7
-1.9
-1.9
-1.8
-1.4
-1.1
-0.8
-0.6
-0.7
Change in
Current Hr
Terno (°F)
—
0.5
3.0
4.8
4.9
4.2
3.7
2.0
0.7
0.2
-0.5
-1.4
-2.4
-3.1
-3.1
-2.7
-1.9
-1.9
-1.8
-1.4
-1.1
-0.8
-0.6
-0.7
-0.6
Change
Prior to
Previous Hr
—
0.0
0.5
3.5
8.3
13.2
17.4
21.1
23.1
23.8
24.0
23.5
22.1
19.7
16.6
13.5
10.8
8.9
7.0
5.2
3.8
2.7
1.9
1.3
0.6
  *  The temperature versus  time  values  for  the  72-to-96  cycle  are
    reproduced from Table  1 of Appendix II  of 40CFR86.


These three temperature cycles  are parallel (i.e.,  identical
hourly increases/decreases).  The temperatures  peak at hour nine.
The most rapid increase in temperatures occurs  during the fourth
hour (i.e., a 4.9° F rise).
For cycles in excess of 24 hours,  the pattern is repeated.

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                               -38-
                            Appendix B

                          Vapor Pressure
Using the Glausius-Clapeyron Relationship

     The Clausius-Clapeyron relationship assumes that the
logarithm of the vapor pressure  is  a  linear function of the
reciprocal  (absolute) temperature.  This relationship is a
reasonable estimate of vapor pressure (VP)  over the moderate
temperature ranges* (i.e., 60° to 106°F)  that  are being
considered for adjusting  the diurnal  emissions.

     In an earlier EPA work assignment,  test fuels having RVPs
similar to those used in  EPA's RTD  work  assignments were tested,
and their vapor pressures  (in kilo  Pascals)  at three different
temperatures were measured.  The results of those measurements
are given below in the following table:
Nominal
RVP
7.0
9.0
Measured
RVP
7.1
8.7
Vapor Pressure (kPa)
75° F
30.7
38.2
100°F**
49.3
60.1
130°F
80.3
96.5
     ** The VPs at 100° F are  the  fuel  RVPs (in kilo Pascals).

Plotting these six vapor pressures (using a logarithm scale for
the vapor pressure) yields  the graph  (Figure B-l)  on the
following page.

     For each of those two  RVP fuels, the Clausius-Clapeyron
relationship estimates that, for temperature in degrees Kelvin,
the vapor pressure  (VP) in  kPa will be:

         Ln(VP) = A +  (B /  Absolute Temperature),  where:
                   RVP
                   8.7
                   7.1
   C.  Lindhjem  and D.  Korotney, "Running Loss Emissions from Gasoline-Fueled
   Motor Vehicles",  SAE Paper 931991,  1993.

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                               -39-
                            Figure B-l

             Comparison of Vapor Pressure (in kPa) to
                Reciprocal of Absolute Temperature
         100
          10
             4-
          0.0030
  4-
0.0031       0.0032

 Reciprocal of Temp (1/°K)
0.0033
0.0034
     Since MOBILE6 will estimate diurnal  emissions  by using the
vapor pressure of the typical  (local)  fuel  at  two temperatures
(the daily low and high temperatures), we need to create a
similar VP curve for any local  fuel.   Since that  curve is a
straight line  (in log-space), all we  need is the  vapor pressure
of the local fuel measured at two different temperatures.  (That
is, two points determine a straight line.)   Unfortunately,  ALL we
usually have available is the Reid vapor  pressure (RVP)  which is
the VP at 100 degrees Fahrenheit.  To obtain a second point (to
determine the VP curve), EPA will use the preceding graph (Figure
B-l).   In that graph the two lines are not  parallel,  they
intersect at a point.   (That point of intersection  has meaning
only in a mathematical context.  In an engineering  context,  both
the temperature  (825.8 °F) and  VP  (12,679 kPA)  at the point of
intersection are so high as to  be meaningless.  This point could
correspond to the "point at infinity" in  perspective drawings.)

     Combining the reported VP  of the fuel  at  100 degrees
Fahrenheit (i.e., RVP) with this artificial VP value at 825.8
degrees Fahrenheit, we obtain the linear  equation:

          Ln(VP)  = A + ( B / Absolute Temperature),  where:
               B = -3565.2707   +   ( 70.5114 *  RVP )
             and
               A = Ln( 6.89286  * RVP  ) -  (  B / 310.9 )

-------
                               -40-
     Despite the artificial nature of that second point, this
equation accurately predicts the vapor pressure  (in kPa) of the
two test fuels  (in Figure B-l)  as well as producing reasonable
estimates for the range of fuels and temperatures that are
modeled in MOBILE6.  Therefore, EPA will use this equation to
estimate the values of VP  (that are used as an intermediate step
in MOBILE6)  to predict the hourly and full-day diurnal emissions.

-------
                                  -41-
                              Appendix C
                    Modeling 24-Hour Diurnal Emissions
             As Functions of Vapor Pressure  (kPa) and RVP (psi)
                      (Reproduced from M6.EVP.001)
In each of the following 18 strata, 24-hour diurnal emissions are modeled using
four constants:
                      A ,B, C, D.  Where,
      24-Hour Diurnal (grams) =
                  = A
                  + B * RVP (in psi)
                  + C * [(Mean VP) * (Change in VP)]
                  + D * [(Mean VP) * (Change in VP)]2 /1,000
For each of the 9 strata, the four constants used to model diurnal emissions are
given below in the following table. Within each cell of this table, the four
constants are listed vertically (i.e., with "A" at the top and "D" at the bottom).

Fuel Delivery
Carbureted










Model Year
Range
1972-79*



1980-1985



1986-1995**



Fail Pressure
Test
-0.29374
-0.62160
0.039905
0
-1.22213
-0.62160
0.039905
0
18.97709
-1.81237
0
0.017098

Fail Only Purge
Test
21.94883
-2.23907
0
0.02990
16.69934
-2.23907
0
0.02990
13.90647
-2.14898
0.021368
0
Pass Both
Purge and
Pressure
21.13354
-2.42617
0
0.024053
15.50536
-2.42617
0
0.024053
8.37118
-0.767027
0
0.005934
    *  The B,  C, and  D values  are based  on 1980-85  carbureted
       vehicles.
   '*   The B,  C, and  D values  are based  on 1986-95  FI vehicles.

-------
                                -42-
                       Appendix C (Continued)

                   Modeling 24-Hour Diurnal Emissions
            As Functions of Vapor Pressure (kPa) and RVP (psi)

                     (Reproduced from M6.EVP.001)

In each of the following 18 strata, 24-hour diurnal emissions are modeled using
four constants:

                     A ,B, C, D.   Where,
     24-Hour Diurnal (grams) =
                  =  A
                  +  B * RVP (in psi)
                  +  C * [(Mean VP) * (Change in VP)]
                  +  D * [(Mean VP) * (Change in VP)]2 /1,000

Fuel Delivery
Fuel-
Injected









Model Year
Range
1972-79*



1980-1985



1986-1995



Fail Pressure
Test
-0.29374
-0.62160
0.039905
0
7.11253
-1.25128
0.036373
0
14.19286
-1.81237
0
0.017098

Fail Only Purge
Test
21.94883
-2.23907
0
0.02990
7.48130
-0.701002
0
0.010466
9.93656
-2.14898
0.021368
0
Pass Both
Purge and
Pressure
21.13354
-2.42617
0
0.024053
5.62111
-0.701002
0
0.010466
5.85926
-0.767027
0
0.005934
       The three untested strata of Pre-1980  FI vehicles were
       represented using  the Pre-1980 model year carbureted
       vehicles  (which were themselves based  on the 1980-85 model
       year carbureted vehicles).

-------
                               -43-
                            Appendix D

     Using Linear Regressions to Model Ratios of Hourly Diurnal Emissions
For each of the seven strata identified in Section 4.1  (pages 10
and 11), this appendix presents a two-page format that  includes:

    4  the table of statistics produced by the regression
       described in Section 4.2,

    4  a scatter plot comparing the averaged  (actual) hourly
       fractions with the corresponding values generated using
       the regression (note that the solid lines are not
       regression lines,  they are "unity lines" indicating where
       perfect correlation would exist),

    4  a combination bar and line chart comparing the actual
       (averaged)  hourly fractions with the predicted values for
       the single temperature cycle / RVP  combination at which
       most of the vehicles in the stratum were tested  (i.e., the
       72 to 96 degree cycle using fuel with an RVP of  6.8 psi),
       and

    4  a combination bar and line chart comparing the actual
       (averaged)  hourly fractions with the predicted values for
       a typical summer cycle (i.e., the 82 to 106 degree cycle
       using fuel with an RVP of 6.8 psi).

Note that for the seventh stratum  (i.e.,  vehicles with  gross
liquid leaks of gasoline), all three temperature cycles (in
Appendix A) and all fuel RVPs were assumed to produce the same
diurnal emissions.  Therefore, only a  single combination bar and
line chart graph is given.

-------
                           -44-
                   AppendJX D (continued)

Regression of Ratio of Mean Hourly Diurnal Emission Fractions
 Carbureted Vehicles Passing Both Purge and Pressure Tests
Dependent variable is
No Selector
R squared = 91 .6%
s= 0.0146 with 114
Source
Regression
Residual
Variable
Constant
VP * Previous *
Total Prior to
Previous
Total Prior to
Previous
Sqr_Delta Previous


Ratio
of Hourly Diurnal
R squared (adjusted) = 91 .4%
-4 = 110 degrees of freedom
Sum of Squares
0.257692
0.023597
Coefficient
0.007032
0.000023
0.003586
-0.001111
Df
3
110
s.e. of Coeff
0.0033
0.0000
0.0002
0.0002
Mean Square
0.085897
0.000215
t-ratio
2.15
23.1
20.7
-5.01
F-ratio
400
prob
0.0336
< 0.0001
< 0.0001
< 0.0001
        Plotting Predicted versus Actual Hourly Ratios
£U70

5
O.
C
3
>> 10% -
—
o
I
3
O








<6
o  »
> o
•
•
•
«
* * S
0


•



I










              0%               10%               20%

                     Predicted Hourly Diurnal (pet)

-------
                                   -45-
                            Appendix D (continued)




Sample Comparison of Averaged Hourly Diurnal Emission Fractions v. Predicted

       For Carbureted Vehicles Passing  Both Purge and Pressure Tests




          Over 72-96 Degree Temperature Cycle - Using 6.8 RVP Fuel
                20%
                                                 Averaged Hourly


                                                 MOBILES
                 0%
                                              11   13   15   17
                                    Duration (hours)
         Over 82-106 Degree Temperature Cycle - Using 6.8 RVP Fuel
                20%
 .2
(/) Q

I >

liiS
ra
             ^  10%
           .   0)

           Q  O)
              "
           X  0)

             Q.
                                                ] Averaged Hourly


                                                •MOBILES
                                    7    9    11   13   15   17



                                    Duration (hours)

-------
                           -46-
                    Appendix D (continued)
Regression of Ratio of Mean Hourly Diurnal Emission Fractions
        Carbureted Vehicles Failing the Pressure Test
Dependent variable is
No Selector
R squared = 95.1%
s= 0.0119 with 114
Source
Regression
Residual
Variable
Constant
Previous * Total
Prior to Previous
Total Prior to
Previous
Sqr_Delta Current


Ratio
of Hourly Diurnal
R squared (adjusted) = 95.0%
-4 = 110 degrees of freedom
Sum of Squares
0.300208
0.015505
Coefficient
0.010549
0.001138
0.001758
0.001765
df
3
110
s.e. of Coeff
0.0029
0.0000
0.0001
0.0002
Mean Square
0.100069
0.000141
t-ratio
3.60
37.4
11.8
10.4
F-ratio
710
prob
0.0005
< 0.0001
< 0.0001
< 0.0001
        Plotting Predicted versus Actual Hourly Ratios
£U70 '
O
_Q.
CO
3
>» 10% -
o
CO
o
<
0% '-
0














ix

ro
«
o>
•
t* y^
o

*



I
1
?
l_^^^







% 10% 20
                     Predicted Hourly Diurnal (pet)

-------
                                   -47-
                            Appendix D (continued)

Sample Comparison of Averaged Hourly Diurnal Emission Fractions v. Predicted
              For Carbureted Vehicles Failing the Pressure Test

          Over 72-96 Degree Temperature Cycle - Using 6.8 RVP Fuel
                20%
                                                 Averaged Hourly
                                                 MOBILES
                                    7    9    11   13   15   17
                                    Duration (hours)
         Over 82-106 Degree Temperature Cycle - Using 6.8 RVP Fuel
                20%
                                                 Averaged Hourly
                                                 MOBILES
                 0%
                                    7    9    11   13
                                    Duration (hours)
15
17

-------
                           -48-
                    Appendix D (continued)



Regression of Ratio of Mean Hourly Diurnal Emission Fractions

       Carbureted Vehicles Failing ONLY the Purge Test
Dependent variable is
No Selector
R squared = 93.5%
s= 0.0124 with 114
Source
Regression
Residual
Variable
Constant
VP * Previous *
Total Prior to
Previous
Total Prior to
Previous
Sqr_Delta Previous
VP * Sqr_Delta
Current
VP * Tot Prior to
Previous


R squared (adjusted)


= 93.1%
Ratio


of Hourly Diurnal


- 6 = 108 degrees of freedom
Sum of Squares
0.236796
0.01659
Coefficient
0.006724
0.000023


0.003966

-0.001122
0.000019

-0.000018

df
5
108
s.e. of Coeff
0.0030
0.0000


0.0004

0.0003
0.0000

0.0000

Mean Square
0.047359
0.000154
t-ratio
2.23
27.1


10.1

-4.05
3.14

-2.24

F-ratio
308

prob
0.0276
< 0.0001


< 0.0001

< 0.0001
0.0022

0.0272

        Plotting Predicted versus Actual Hourly Ratios


           20%
        o
        Q.
        CO
        o


        "co

        o
           10%
            0%
F^
               0%               10%              20%


                     Predicted Hourly Diurnal (pet)

-------
                                   -49-
                            Appendix D (continued)

Sample Comparison of Averaged Hourly Diurnal Emission Fractions v. Predicted
             For Carbureted Vehicles Failing ONLY the Purge Test

          Over 72-96 Degree Temperature Cycle - Using 6.8 RVP Fuel
                20%
           
-------
                           -50-
                    Appendix D  (continued)

Regression of Ratio of Mean Hourly Diurnal Emission Fractions
     Fl Vehicles Passing Both Purge and Pressure Tests
Dependent variable is
No Selector
R squared = 85.2%
s= 0.0188 with 114
Source
Regression
Residual
Variable
Constant
Total Prior to
Previous
Previous * Total
Prior to Previous
VP * Sqr_Delta
Previous
Delta Current
VP * Tot Prior to
Previous


R squared (adjusted)


= 84.5%
Ratio


of Hourly Diurnal


- 6 = 108 degrees of freedom
Sum of Squares
0.220626
0.03832
Coefficient
0.008001
0.001961

0.000535

-0.000060

0.005964
0.000056

df
5
108
s.e. of Coeff
0.0046
0.0006

0.0000

0.0000

0.0015
0.0000

Mean Square
0.044125
0.000355
t-ratio
1.75
3.33

5.61

-8.75

4.11
4.47

F-ratio
124

prob
0.0834
0.0012

^0.0001

^0.0001

^0.0001
^0.0001

        Plotting Predicted versus Actual Hourly Ratios
L\}/o -
O
^Q.
15
_3
>> 10% -
0
X
CO
3
O
0% i
0



o
**•



<
o
^r 4*
s v
o
•
LJlpl^
v


I





Yo 1 0% 20
                                                    7o

                     Predicted Hourly Diurnal  (pet)

-------
                                  -51-
                           Appendix D (continued)



Sample Comparison of Averaged Hourly Diurnal Emission Fractions v. Predicted

           For Fl Vehicles Passing Both Purge and Pressure Tests
         Over 72-96 Degree Temperature Cycle - Using 6.8 RVP Fuel
                20%
                                                Averaged Hourly

                                                MOBILES
                                   7    9    11   13


                                   Duration (hours)
                   15    17
         Over 82-106 Degree Temperature Cycle - Using 6.8 RVP Fuel
                20%
.2 ^  15%


-------
                          -52-
                   Appendix D (continued)
Regression of Ratio of Mean Hourly Diurnal Emission Fractions
            Fl Vehicles Failing the Pressure Test
Dependent variable is
No Selector
R squared = 95.9%
s= 0.0118 with 114
Source
Regression
Residual
Variable
Constant
Previous * Total
Prior to Previous
Total Prior to
Previous
Sqr_Delta Current
Sqr_Delta Previous


R squared (adjusted)


= 95.7%
Ratio


of Hourly Diurnal


- 5 = 109 degrees of freedom
Sum of Squares
0.350423
0.015068
Coefficient
0.006515
0.001194

0.001963

0.001329
0.000574
df
4
109
s.e. of Coeff
0.0029
0.0000

0.0002

0.0003
0.0003
Mean Square
0.087606
0.000138
t-ratio
2.25
33.9

12.9

5.04
2.03
F-ratio
634

prob
0.0267
< 0.0001

< 0.0001

< 0.0001
0.0449
        Plotting Predicted versus Actual Hourly Ratios
        >
       ^Z
        o

       15

       H
       <
10%
           0%
    \£

                                         *
0%
                    10%
                                               20%
                    Predicted Hourly Diurnal (pet)

-------
                                    -53-
                            Appendix D (continued)




Sample Comparison of Averaged Hourly Diurnal Emission Fractions v. Predicted

                   For Fl Vehicles Failing the Pressure Test
          Over 72-96 Degree Temperature Cycle - Using 6.8 RVP Fuel
                 20%
                                                 Averaged Hourly


                                                 MOBILES
                 0%
                                    7    9    11    13



                                    Duration (hours)
                                             15    17
         Over 82-106 Degree Temperature Cycle - Using 6.8 RVP Fuel
                 20%
 .2
(/) Q

I >

™s
ra
             ^  10%
           .   0)

           Q  O)
              "
           X  0)

              Q.
                                                 Averaged Hourly


                                                 MOBILES
                                    7    9    11    13



                                    Duration (hours)
                                             15    17

-------
                    -54-
            Appendix D  (continued)

   Fl Vehicles Failing ONLY the Purge Test
Dependent variable is
No Selector
R squared = 95.6%
s= 0.0120 with 114
Source
Regression
Residual
Variable
Constant
Previous * Total
Prior to Previous
VP * Tot Prior to
Previous
Sqr_Delta Current
VP * Sqr_Delta
Current
Total Prior to
Previous
VP * Delta Current
Sqr_Delta Previous


R squared (adjusted)


= 95.3%
Ratio


of Hourly Diurnal


- 8 = 106 degrees of freedom
Sum of Squares
0.329042
0.015255
Coefficient
0.007882
0.000855

0.000084

0.006960
-0.000160

-0.001172

0.000118
0.000825
df
7
106
s.e. of Coeff
0.0030
0.0001

0.0000

0.0007
0.0000

0.0004

0.0000
0.0004
Mean Square
0.047006
0.000144
t-ratio
2.66
7.87

8.82

10.7
-10.0

-2.88

2.98
2.06
F-ratio
327

prob
0.0090
< 0.0001

< 0.0001

< 0.0001
< 0.0001

0.0048

0.0036
0.0419
Plotting Predicted versus Actual Hourly Ratios
t>
a.
c
3
a
o
ra







10% -



<
0% *










^









-------
                                   -55-
                            Appendix D (continued)

Sample Comparison of Averaged Hourly Diurnal Emission Fractions v. Predicted
                 For Fl Vehicles Failing ONLY the Purge Test
          Over 72-96 Degree Temperature Cycle - Using 6.8 RVP Fuel
                20%
                                                 Averaged Hourly

                                                 MOBILES
                         7     9    11   13   15

                         Duration (hours)
                                                            17
         Over 82-106 Degree Temperature Cycle - Using 6.8 RVP Fuel
                20%
.2 3  15%

                10%
              0)
           Q  O)
           =  §   5%

           X  o>
             Q.
                                   rT
                                      Nl
                                          \
                                                lAveraged Hourly

                                                •MOBILES
                     1    3    5    7    9   11   13   15   17

                                    Duration (hours)

-------
                           -56-
                    Appendix D  (continued)

Regression of Ratio of Mean Hourly Diurnal Emission Fractions
               "Gross Liquid Leaker" Vehicles
Dependent variable is
No Selector
R squared = 96.2%
s= 0.0070 with 19-
Source
Regression
Residual
Variable
Constant
Delta Previous
Total Prior to
Previous

R squared (adjusted) = 95.7%
3 = 16 degrees of freedom
Sum of Squares df
0.019576 2
0.000783 16
Coefficient s.e. of Coeff
0.021349 0.0032
0.010137 0.0006
0.002065 0.0002
Ratio

Mean Square
0.009788
0.000049
t-ratio
6.67
16.90
10.30
of Hourly Diurnal

F-ratio
200
Prob
< 0.0001
< 0.0001
< 0.0001
        Plotting Predicted versus Actual Hourly Ratios
1 £70
O
_Q.
C
3
>, 6% -
o
X
3
O
0% -,
0(
















4
>






>







^




Yo 6% 1 2%
                    Predicted Hourly Diurnal (pet)

-------
                                 -57-
                          Appendix D (continued)

Comparison of Averaged Hourly Diurnal Emission Fractions versus Predicted
                   For "Gross Liquid Leaker" Vehicles

                      (Reproduction of Figure 4-3)
         20%
                                                Averaged Hourly
                                                MOBILES
                                 7     9    11    13
                                 Duration (hours)
15
17

-------
                            -58-
                         Appendix E

        Hourly Real-Time Diurnal (RTD) Emissions (in grams)
                 From Six Gross Liquid Leakers

Hour
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

5002
4.56
4.71
6.12
7.93
9.55
11.29
9.41
9.78
7.14
6.06
5.35
4.18
3.66
3.08
2.89
2.83
2.97
2.76
2.91
2.82
3.01
3.06
3.01
2.96

5082
2.23
2.41
3.18
4.00
4.63
5.14
5.39
5.11
4.73
4.36
4.30
4.10
3.51
2.76
2.55
2.23
2.22
2.20
2.18
2.09
2.06
2.09
1.97
2.13

9049
11.88
8.79
10.24
11.74
11.62
11.19
10.99
9.74
9.04
8.02
7.42
6.91
6.91
6.25
5.63
5.78
5.09
4.91
4.93
4.89
4.70
5.02
4.78
4.88

9054
10.99
11.24
9.78
13.05
14.28
14.69
14.00
16.08
15.05
14.06
14.85
15.53
14.93
15.03
14.60
13.93
16.37
14.65
11.54
11.30
11.12
9.89
10.36
9.28

9087
27.67
28.50
24.65
25.98
25.06
24.61
25.70
25.22
24.21
23.36
20.95
19.67
18.50
17.58
16.57
16.31
13.59
15.29
13.86
13.46
13.69
13.62
13.04
17.05

9111
55.95
46.77
44.26
44.32
45.49
47.67
48.07
47.46
42.41
43.84
36.43
33.72
32.96
25.79
21.55
21.24
20.46
19.64
17.60
16.85
16.52
15.89
15.82
16.40

Mean
18.88
17.07
16.37
17.84
18.44
19.10
18.93
18.90
17.10
16.62
14.88
14.02
13.41
11.75
10.63
10.39
10.12
9.91
8.84
8.57
8.52
8.26
8.16
8.78

Modified*
10.48
12.45
16.37
17.84
18.44
19.10
18.93
18.90
17.10
16.62
14.88
14.02
13.41
11.75
10.63
10.39
10.12
9.91
8.84
8.57
8.52
8.26
8.16
8.78
*  Mean  emissions   for  the  first  two  hours  have  been
   "MODIFIED"   (see  Section  4.2.3)  to  fit  the following
   assumed pattern:

    4  The diurnal  emissions  (i.e.,  RTD minus the hourly
       resting loss of 8.52 grams) during the first hour
       were assumed to be one-half  the diurnal emissions
       during the second hour.

    4  The diurnal  emissions during  the second hour were
       assumed  to   be  one-half  the  diurnal  emissions
       during the third hour.

-------
                                -59-
                              Appendix F

                 Modeling Hourly Resting Loss Emissions
                    As Functions of Temperature (°F)

 In each of the following 12 strata, resting loss emissions (in grams per hour) are
 modeled using a pair of numbers (A and B), where:

 Hourly Resting Loss (grams) = A + ( B *  Temperature in °F )

                     B = 0.002812 (for ALL strata) and

                    "A" is given in the following table:
Fuel Delivery
Carbureted


Fuel -Injected


Model Year_
Ranqe
Pre-1980
1980-1985
1986-1995
Pre-1980*
1980-1985
1986-1995
Pass Pressure _
Test
0.05530
-0.05957
-0.07551
0.05530
-0.09867
-0.14067
Fail Pressure _
Test
0.07454
-0.02163
0.05044
0.07454
0.02565
-0.10924
    *  The  untested   stratum  (Pre-1980   FI   vehicles)  was
       represented using the Pre-1980  model year carbureted
       vehicles.    (See  report  M6.EVP.001  for  additional
       details.)

These  equations can then be  applied (in each  stratum)  to each of
the hourly  temperatures in Appendix A to obtain  the  resting loss
emissions released in a 24 hour  period.  If we use an alternate
temperature profile in which the hourly change in temperature is
proportional to the cycles in Appendix A, we  find that:

             24-Hour Resting Loss (grams) = (24*A) + (B*C)

Where  A  and B are given above,  and where

          C  =  0.002632 + (24 * Low Temperature)
                + (11.3535 * Diurnal_Temperature_Range)
Where the  Diurnal_Temperature_Range is the  difference of the daily high
temperature  minus the daily  low temperature.

-------
                               -60-
                           Appendix G

         Response to Peer Review Comments from H. T. Me Adams


     This report was formally peer reviewed by two peer reviewers
(H. T. McAdams and Harold Haskew).   In this appendix, comments
from H. T.  McAdams are reproduced in plain text,  and EPA's
responses to those comments are interspersed in indented italics.
Comments from the other peer reviewer appear in the following
appendix (Appendix H).

     This peer review included two appendices.   These have been
renumbered as Appendix G-l and Appendix G-2.

               ************************************

    Modeling Hourly Diurnal Emissions and Interrupted Diurnal
            Emissions Based on Real-Time Diurnal Data

                               By
                         Larry C. Landman

                     Report Number  M6.EVP.001

                       Review and Comments
                               By
                          H.  T. McAdams
1.  INTRODUCTION

Report Number M6.EVP.002 is herein reviewed in accordance with a
letter postmarked May 25, 1999 from Mr. Philip A. Lorang,
Environmental Protection Agency (EPA) to Mr. H. T. McAdams,
AccaMath Services. The reviewer is instructed to address report
clarity, overall methodology, appropriateness of the data sets
used, statistical and analytical methodology and the
appropriateness of conclusions, with specific attention to data
stratification and predictive equations. The review follows
precedents set in the previous review of other, related MOBILE6
draft documents  (see References 1 - 7)  .

Number M6.EVP.002 can be thought of as an extension, and to no
small degree a repetition,  of material in the previously reviewed
reports M6.EVP.001 and M6.EVP.005. Accordingly, this review will
focus primarily on analytical deficiencies unique to the current
report, M6.EVP.002. These include what is considered to be a
flawed application of stepwise regression methodology and a
simplistic view of interrupted diurnals that stops short of its
objective.

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It is admitted at the outset that there are significant
philosophical differences between EPA's conception of modeling
and the reviewer's conception,  particularly in the present
instance.   It is hoped that these views may be reconciled,
however, after both have been fairly presented and evaluated.

     EPA believes that a major source of these "philosophical
     differences" is the reviewer's belief that he has a
     substantially superior approach to modeling these hourly
     diurnal emissions.  That is, he suggests:

          using  (continuous) cumulative emissions rather than
          (discrete) incremental emissions and

       --  using time as the primary independent variable rather
          than temperature differences.

     Even though these changes might produce estimates of diurnal
     emissions that more closely approximate the actual test
     data, they do not lend themselves to estimating the hourly
     emissions over different temperature cycles (including
     interrupted cycles).   Therefore, both of these approaches
     were rejected by EPA.
2. HOURLY DIURNAL EMISSIONS: TWO MODELING APPROACHES

Hourly diurnal emissions can be viewed as separate and discrete
events associated with hour-long time intervals spanning a 24-
hour period.  Alternatively, they can be deduced from a continuum
in which cumulative emissions up to a given time are expressed as
a continuous function of time over 24 hours.

EPA chose the interval approach, as discussed in Section 2.1
below. Characteristic of the approach is its discrete
representation of emissions and its reliance on linear stepwise
regression.


That discussion will be followed by a presentation, in Section
2.2, of an alternative approach based on cumulative emissions. It
is characterized by a continuous representation of emissions and
its openness to either intuitive or analytical nonlinear curve
fitting.

     2.1 The EPA Perspective

Though extensively used in modeling a variety of processes,
stepwise regression is not universally accepted by professional
statisticians.  This lack of enthusiasm is evidenced in the
following quotation from the SYSTAT manual  (see Reference 8).

     Stepwise regression is probably the most abused
     computerized statistical technique ever devised.

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                               -62-
     If you think you need automated stepwise regression
     to solve a particular problem, it is almost certain
     that you do not. Professional statisticians rarely
     use automated stepwise regression because it does
     not find (a) the "best" fitting model,  (b)  the
     "real" model, or (c)  alternative "plausible"
     models.  Furthermore, the order in which variables
     enter or leave a stepwise program is usually of no
     theoretical significance. You are always better off
     thinking about why a model could generate your data
     and then testing that model.

Undaunted,  however, EPA makes their position clear on page 12 of
Report M6.EVP.002:

     EPA chose to use stepwise linear regressions
     to identify the variables that were the most
     influential in  determining the shape of the
     hourly diurnal emissions.

What is meant by "the shape of the hourly diurnal emissions" is
not clear,  but the phrase is presumed to refer to the shape of a
plot of hourly diurnal emissions vs hour considered, as in Figure
4-1 [renamed Figure here as 4-3].

     That is correct.  The text has been revised to eliminate
     that potential ambiguity.

Stepwise regression can make its selections only from the set of
variables submitted to it as candidate variables.  It is at this
point that the analyst must call upon whatever intellectual
resources are at his command pertinent to the response variable
and the factors that might influence it.  Once a variable has been
put forward, the analyst then needs to consider whether that
variable might affect the response nonlinearly as well as
linearly and must postulate what he considers to be viable
options.

In resolving this question, too often one simply resorts to a
multinomial, power-series expansion of the response function on
the assumption that powers of a variable will accomodate
nonlinearities and that products of two or more variables will
accomodate what statisticians refer to as interactions.   Though
not unique to stepwise regression, this practice can be more
insidious when the choice of terms is performed automatically by
a stepwise algorithm.  The response variable for the seven
regression equations that evolved from this modeling exercise is
current hourly emissions expressed as a fraction (or percent) of
total daily emissions.  Predictor variables are presumed to be of
two types,  one related to fuel properties, the other to the
temperature cycle. These interact to determine vapor pressure,
the ultimate driving force for producing evaporative emissions.

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                               -63-
In the previously reviewed document M6.EVP.001,  EPA used fuel RVP
(Reid Vapor Pressure)  to estimate the vapor pressure of the fuel
at each time in the temperature cycle. In the paper presently
under review,  EPA chooses to use a quantity referred to as
"midpoint VP"  derived as follows (see page 9 in M6.EVP.002):

     If we calculate the mean of the VP at the highest
     and lowest temperatures, then that midpoint value
     incorporates both the temperature cycle and the
     fuel RVP.

Other predictor variables consist of temperature changes (deltas)
that occur during specific hours in the emission time history.
Indeed, an equation may use the current hour's temperature delta,
the previous hour's temperature delta, and the sum of all hourly
temperature deltas before that.

The fact that  there is a time lag between temperature rise and
corresponding  emissions tends to support the inclusion of these
lagged terms.  Also, it is reasonable to expect temperature deltas
to have a different effect on emissions for low and high midpoint
VP. However, it is difficult to justify some of the more complex,
temperature-related terms such as squared temperature deltas and
products of temperature deltas occurring at different points in
time. No reason for their inclusion in the model is offered by
Landman other  than that these terms were found to be
"statistically significant" by the stepwise regression algorithm
"fishing expedition."   Presumably he is relying on the time-
honored tradition of using higher-order terms to accomodate
nonlinearities and thus to adjust the "shape" of the emission
plot.

     The product-terms  (including second-degree terms) were
     included in the list of potential variables to account for
     likely interactions.  Some of these product terms made it
     from the  list of candidate variables to the list of actual
     variables because their presence significantly improved the
     ability of the resulting equations to predict the means of
     the actual hourly data.

What is wrong  with this picture?

First,  all of  the time-related predictor "variables" are attached
to a specific  hour in the temperature cycle and conspire to
estimate emissions for the current hour only. Thus they can not
determine the  "shape"  of the curve in the usual sense because
they are fixed to a single point and have nothing to do with the
shape of the plot as a whole.  If there is any doubt of this
conclusion,  consider what it is possible for a square term to do.
Certainly an equation of second degree can not generate a plot as
complex as Figure 4-1  [renamed Figure here as 4-3].   In fact,
there is really no "shape," as such,  to be dealt with, just a set

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                               -64-
of discrete estimates for specific intervals in time, there being
no inputs for time intervals other than these.

     On the contrary, these equations  (from Appendix D) do, in
     fact, generate plots with the necessary complexity, as is
     illustrated in Figure 4-3 and the graphs newly added to
     Appendix D.

Secondly,  what is considered to be "statistically significant" is
an artifact of the choice of significance level.   However we
resolve this age-old dilemma,  an aura of uncertainty remains,
spawned by an unavoidable arbitrariness. Even more troubling,
though, is the realization that if other terms had been proposed
for inclusion in the model,  they might have been just as likely
to succeed.

     Granted, while the selected level of significance  (i.e.,
     five percent) is arbitrary, it is also fairly standard.
     Also the set of candidate variables was chosen to include
     all of the relevant variables that were likely to be
     available  (to MOBILE6).   The "clock time" was not considered
     to be a relevant variable.

These objections do not exhaust the list.  It is the belief of
this reviewer that the approach used in M6.EVP.002 contains a
number of substantial flaws,  that certain statistical procedures
are misused and/or misinterpreted, and that stepwise regression
has gone where stepwise regression has never gone before.

To illustrate some of these points,  we shall first examine the
models as developed by Landman and shall comment on what is
considered to be their deficiencies.  After that, we shall sketch
a different approach to the modeling of hourly evaporative
emissions - an approach that is believed to be more direct, less
complex and more readily interpreted in physical terms.

     2.1 How EPA Applies Stepwise Regression to Time Series

Hourly diurnal evaporative emissions is an example of a time
series, for which there are specific applicable statistical
procedures.  These analytical procedures almost universally
acknowledge the fact that the value of a time-series response
variable at a particular point in time is determined, to greater
or lesser degree, by the value of that variable at preceding
points in time. Serial correlation often plays an important role
in the analysis, as does also certain autoregressive procedures
such as ARIMA  (AutoRegressive Integrated Moving Average) models.

     For the three temperature cycles used in the testing
     programs  (see Appendix A), all of the temperature
     differences  (at a given time) are equal; thus, a time-series
     approach does seem reasonable.   However, since the results
     must apply to other temperature cycles, EPA intentionally
     ignored "clock time" as a potential variable and

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                               -65-
     concent rated on temperature changes.  The introductory
     section of this report has been revised to emphasize this.

In a garden-variety time series, responses at adjacent points in
time are usually most highly correlated. With increasing "lag,"
the correlation decreases until it approaches zero at a distance
known as the "decorrelation interval."  This behavior works to
our advantage if we are attempting to compute current or future
responses in terms of past responses.  If the decorrelation
interval is short, it would not be necessary to look back very
far in time in order to make reasonable predictions.

At first look,  Landman's approach to the modeling of hourly
emissions seems to incorporate some of the predictive aspects of
time-series analysis.  Instead of looking at prior emissions,
however, the EPA model looks at the prior temperature deltas that
drive the emissions.

Because the temperature deltas are fixed, they have the same
correlation structure regardless of the emission response to
those deltas.  Viewed in this light, correlation between various
temperature deltas may work to our disadvantage because of
"creeping collinearity"(see Appendix I  [renamed here as Appendix
G-l]) .  The correlation between current and previous deltas is
0.92,  a fact that suggests that either one has almost as much
predictive power as both used together.  Similarly, there is a
correlation of 0.92 between previous delta and its product with
the sum of all deltas prior to that. Indeed, it is shown that the
six lagged variables used by Landman in his models have the
effect of only three, or at most four, independent variables.

     Although using  "emission response"  (or "prior emissions") as
     a variable could be useful in predicting full-day diurnals,
     their use would actually be counter productive when trying
     to estimate interrupted  (partial-day) diurnals.  Therefore,
     the regression analyses continue to focus on temperature
     changes rather than on prior emissions.

     The presence of collinearity among the several variables
     related to temperature differences is an unfortunate result
     of the nature of the three temperature cycles  (from Appendix
     A).  A future testing program might use substantially
     different temperature cycles, thus, producing additional
     data having reduced collinearity.  However, until that
     additional data become available, we will continue to use
     this approach and live with the presence of collinearity.

The page 12 footnote on how stepwise regression works is
misleading.  If the predictor variables are orthogonal (that is,
independent), then of course the order of predictive
contributions would be consistent with the order of the
magnitudes of their correlation with the response variable. But,
of course, in that instance there would be no need for stepwise

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                               -66-
regression. The intercorrelation of predictor variables and the
non-additivity of sums of squares is the very reason stepwise
regression came to be. The apparent contribution of predictor
variables depends, computationally, on the order in which they
are introduced into the model. Indeed, there may be two or more
sets of variables that give essentially the same performance, so
far as R-square is concerned.

     The footnote has been revised.

Clearly, therefore, the stepwise algorithm is not infallible in
its effort to simplify a model by eliminating, from among the
variables submitted,  those that contribute little to the model's
prediction capability.  Another approach to model simplification
is provided by a spin-off from random-balance experiment design
(see Reference 12).

Not only is there correlation between near-neighbor values of a
time series,  but there may also be correlation between near-
neighbor residuals from a fitted model.  In spite of the fact that
residuals should be examined in any regression analysis, Landman
gives relatively little attention to this concern,  and then in an
unconventional manner.

     The examination of the residuals might have been done in an
     "unconventional manner," but the residuals were examined.
     However, the examination did not check to determine if there
     was a time-related correlation.  We had not considered
     checking this aspect since we were not (and still are not)
     interested in treating diurnal emissions as a function of
     clock time.

For example,  according to plots of "Predicted Versus Actual
Values"  (see Appendix D of the report),  the implication is that
model performance is quite good. The author is quick to point
out, though,  that his plots are not the usual "scatter plots," in
which observed data are shown as points scattered about the
computed curve. The actual values are not plotted in relation to
the predicted curve but with regard to what Landman calls the
"unity line."

     The scatter plots are graphs of the actual hourly ratios
     versus the predicted ratios  (not the "unity line") .  The
     "unity line" is present only to illustrate how far off  (or
     how close to) a  "perfect" prediction the regression is.

Such plots are highly suspect, because the sequential relation
between actual and predicted emissions is lost. The "unity line"
plot can look very symmetric, even though the usual scatterplot
may show substantial "lack of fit." For example, consider the
fact that the Landman models attempt to incorporate the effects
of time and fuel vapor pressure. Suppose that predictions for
RVP = 6.8 run mostly too high, whereas predictions for RVP = 9.0
run mostly too low.  The situation is a classic case of lack of

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                               -67-
fit.  When the two cases are pooled, however, the magnitudes of
the actual and predicted values may follow the "unity" line quite
well, an observation that proves nothing in particular.

     If one of the seven equations over-estimates the hourly
     fractions for one RVP and under-estimate for the other
     tested RVP, then the scatter plot would appear to be a "good
     fit" when, in fact, it is not.  This is a valid concern.
     Fortunately, it does not occur.

In another instance (see Figure 4-1 [renamed Figure 4-3]), a plot
of "actual" vs "predicted" values is presented, this time in the
usual way except that the "actual" values are plotted as a bar
graph rather than as a scatter plot of points. The width of the
bars tricks the eye into believing that the agreement is better
than is actually the case. See Appendix II  [renamed here as
Appendix G-2] of this review document for further detail.

     Each bar  (in Figure 4-3) represents the total diurnal
     emissions occurring in each full hour.  Therefore, each bar
     is approximately one hour in width.

In addition to the matters of principle discussed above, there
are questions that need to be raised about some of the
computations and their numerical results.

Consider, for example, the following detailed results extracted
from Appendix D.

 Stratum  Page No.  Reg. d.f.  Resid.  d.f.  Res. SS  R-square.

   1        36         3         110       0.000215    0.916
   2        37         3         110       0.000141    0.951
   3        38         5         108       0.000154    0.935
   4        39         5         108       0.000355    0.852
   5        40         4         109       0.000138    0.959
   6        41         2           3       0.43039     0.956*
   7        42         2          16       0.000049    0.962
     * Discordant with table heading information indicating
        degrees of freedom (8 and 114) and s = 0.0120

Stratum #6, FI Vehicles Failing ONLY the Purge Test, is out of
line with other strata,  and the coefficients and analysis of
variance obviously do not go together.

     Correct.  There was an error in  "pasting" the data into the
     regression table template.  The incorrect table  (in Appendix
     D) has now been corrected.

Evidently the highlighted case (Stratum #6) is just a
computational or transcription error,  but a more serious flaw
pervades the data for the other strata as well.

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                               -68-
The report states that the models for each stratum (except #7) is
based on 114 average hourly emissions:

     2 RVPs x 3 temperature cycles x 19 hourly intervals = 114

In reality, an "honest" regression should be based on individual
observations rather than averagers,  in which case the number of
degrees of freedom would be one less than:

     2 RVPs x 3 temperature cycles x 19 hourly intervals x N

where N is the Number of Tests as shown in Table 4-3. N ranges
from 13 to 73. Thus there could be as many as 73 x 114 = 5402 and
at least as many as 13 x 114 = 1482  data points in the scatter
plot to be consolidated by a regression model. By averaging the
data points, one removes the major source of variance in the data
and exaggerates R-square, thereby making the model look much
better than it actually is.  Moreover, the averaging process
makes it appear that the model for one group of observations is
just as good as for another group, even though one might be based
on several times as much data as the other.

     Correct.  A note/caution has been added to the end of
     Section 4.2.1 to emphasize this.

Now recall that all the model does is to attempt to recapitulate
the individual hourly average emissions, since the domain of the
response function is discrete and there is no continuity from one
hourly estimate to the next.  Therefore, the average emissions
for each hour is the best discrete estimate possible and already
exists or is implied in Table 4-1.

     Yes.  If MOBILE6 needed only to estimate full-day  (no
     interrupted) diurnals over these three temperature cycles
      (from Appendix A) using fuels with only RVPs of 6.8 or 9.0
     psi, then we would simply code these averages into the
     model.  However, since MOBILE6 must extrapolate over a wide
     range of fuel RVP and a wide range of temperature cycles
      (including interrupted cycles), some type of modeling  (i.e.,
     regression analysis) was necessary.

Finally, one needs to give attention to some of the conclusions
drawn with regard to what terms are "significant" and what terms
are not. Of particular interest is the proclaimed "universality"
of the variable "total change in temperature prior to the
previous hour."

The fact that this term appears to be universally applicable to
all seven strata should come as no surprise.  If emissions for
any given hour are dependent on emissions from the previous hour,
and if this relation is recursive, then the current hour's
emissions must be dependent on all previous hours, even though
that dependence may decay exponentially as one looks back in

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                               -69-
time. This lemma seems even more plausible when hourly emissions
are viewed cumulatively,  as will be done in the following section
of this review.

To summarize, perhaps the most disturbing aspect of the
application of stepwise regression is that it can select
variables only as a subset of the set of variables submitted to
it as candidates for inclusion in the model. There is no
assurance that there may be other factors not dreamed of in our
philosophy and other pathways to follow in our search for the
Holy Grail.

     The list of candidate variables was comprised of all the
     variables  (and their products to account for interactions)
     that were likely to be included in MOBILE6 (either entered
     by the user or hard-coded).  While other variables may, in
     fact, be significant in predicting hourly diurnal emissions,
     they would not be readily available to the users of MOBILE6.
     Thus, the analyses were limited to predicting the hourly
     emissions using only the information/data available to
     MOBILE6.


     2.2 A Road Less Traveled By: A Proposed Alternative

            Two roads diverged in a wood, and I
            I took the one less traveled by ...

                      --  Robert Frost

In view of the difficulties and circularities of the above
approach,  it seemed legitimate to explore a different route to
modeling hourly emissions.

To begin,  we ask the question, "What are we modeling, anyway?"

Evidently we seek a model that expresses hourly emissions as a
function of time:

               Hourly emission fraction = f(time)

More specifically,  for any given hour in the test cycle, we want
to know what fraction (or percent)  of the total daily emissions
is represented by the emissions given off during that (the
current) hour.  Further,  we want to know how this emission vs
time relation varies from stratum to stratum,  and how it is
influenced by fuel vapor pressure.

     As noted in comments at the end of the introduction of this
     review, predicting hourly diurnal emissions as a function of
     clock time would not lend itself to estimating the hourly
     emissions over interrupted cycles.

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Truth begins with Table 4-1 and could very well end there.  In
the table, four "critical times" are presented for each of 24
groups of vehicles.  Evidently these critical times were
interpolated from a plot of cumulative average emissions vs time
for each intersection of strata, RVP and temperature cycle.  By
taking successive differences between times tn  and  t^ for n = 1,
2, 3, ...  ,  24, one obtains, for each hour,  an estimate of
hourly emissions as a ratio of total daily emissions.

But that is exactly what the modeling effort set out to do!

Why complicate the matter by a circuitous stepwise regression
that serves only to bring us back to the point of our beginning?

There are possibly two reasons for the regression effort.  One
deals with the precision of the hourly averages and with whether
that precision is somehow improved by regressing the hourly
estimates on features of the temperature cycle and the midpoint
VP.   The other concerns whether the model is to be used for
interpolation purposes - that is, for estimating hourly emission
ratios for situations for which there was no actual data.  Table
4-1 offers data for RVP = 6.8 and RVP =9.0.   Is the model
expected to provide estimates at intermediate values of RVP,  such
as 7.4 or 8.5? Presumably so, but the same can not be said for
"intermediate hours."

Evidently, according to the protocol set forth in M6.EVP.002,
interpolation at times other than hours 1, 2, 3, ...  is not
contemplated.  Accordingly, the mean of all measurements in a
given stratum and for a given midpoint VP is the least-squares
best estimate of emissions for that scenario.  This assertion is
easily proved as an elementary statistical exercise.

In ordinary least-squares regression, it is true that the
precision of estimates at some points in the predictor space is
enhanced by information drawn from adjacent points in that space.
However, much depends on the form and validity of the model that
is assumed or possibly forced upon the data.

For example,  if it is known that a response variable y is a
strictly linear function of a uniformly-spaced predictor variable
x, then a straight-line regression would make for a more precise
estimate of y at the midpoint of the range of x, and precision
would deteriorate as one moves toward the minimum or maximum
values of x.

In the case of emissions as a function of time, no such model is
known, especially when one attempts to model incrementally the
emissions for a given hour as a fraction of the total emissions
for the day.   As will be shown later, the prospect is more
favorable if one models cumulative rather than incremental
emissions as a function of time.

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                               -71-
All that can be said here is that the M6.EVP.002 models exhibit
"reasonable" R-squares ranging from 0.852 to 0.962 but provide
only segmented, "point" estimates of emissions at discrete hourly
intervals in the time cycle.  But that is exactly what the
averaged "raw data" provides! What assurance is there that the
Landman model is any better or that it is any closer to the
"real" model? Certainly it is no less segmented than the
representation obtained by plotting the averaged "raw data"
against hours.

Now, suppose that the model, however it was developed, passes
exactly through each of the hourly averages of all observations
for that hour.   Is it possible to conceive of a "better" model
than that? The answer is left as an "exercise for the student."
In any event, it can be argued that the mean hourly values are
viable candidate estimates of the hourly fraction of daily
emissions, subject, of course, to sample-size limitations.

Still unresolved,  though, is the question of how to include vapor
pressure VP into the model.  Ostensibly,  that variable could be
incorporated into the "average raw data"  model in much the same
way as it is incorporated in Landman's model - that is, as an
interaction.  In Landman's models, the interactions are between
midpoint VP and hourly temperature deltas or functions thereof.
In the alternative model the interaction would be with the hourly
averages as computed for some "base level" VP.  Results for other
values of VP would consist of adjustments to those base-level
results.

          2.2.1 Discrete vs Continuous Space

Much of the difficulty in modeling the hourly emission fractions
of total daily emissions resides in the discrete nature of the
Landman models.  It is believed that the modeling effort would be
considerably simplified if the problem were approached
cumulatively.  Instead of designing a model for estimating
emissions within a given hour in the time cycle, why not design
the model to estimate emissions up to a particular hour in the
cycle.  The relation would now be continuous, rather than
segmented, and it is to be expected that the function or "curve"
tying emissions to time would be much simpler and smoother than
the curve based on incremental hourly observations.  This
continuum approach is the heart of the proposed alternative
model.

     Actually,  the hourly RTD emission measurements are
     cumulative (i.e., continuous), and they were then processed
     to obtain the incremental  (discrete) measurements that we
     actually analyzed.  Because MOBILE6 will estimate emissions
      (incrementally) for each hour, we chose to analyze the
     incremental hourly emissions rather than the smooth
      (continuous)  cumulative emissions.

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                               -72-
To illustrate, the models as presented in Report M6.EVP.002 are
capable of estimating hourly fractions of total daily emissions
only for time intervals from 6:00 AM to 7:00 AM, 7:00 AM to 8:00
AM, etc.  but not from 6:30 AM to 7:30 AM or from 7:08 AM to 8:08
AM.  The instant rebuttal to this criticism, of course, is that,
under the testing protocol, there is no need for such a
capability.  Nonetheless, it can hardly be denied that such a
revision would represent an extension or generalization of the
model.  But, what is more important, is the fact that the problem
can be addressed in a continuum with tools not applicable in
discrete space.

The key to the continuum approach is simply to view emissions
cumulatively over time rather than in fixed time intervals.  The
point is well illustrated by Table 4-1 in the report.  The table
recognizes the cumulative aspect of diurnal emissions and makes
it clear that there is a cumulative percent of total emissions
associated with every point in time.  Moreover, it is made
evident that the relation between emissions and time is a
positive-valued, non-decreasing function anchored to 0% and 100%
at the beginning and ending times, respectively.  These
constraints narrow considerably the uncertainty to be dealt with
in model development.

But there are further constraints that work to our advantage.
All the cumulative curves are S-shaped and exhibit the greatest
possibility for variation at the "belly of the curve,"
specifically near the inflection point of the curve, where its
slope changes from increasing to decreasing, and the hourly
emissions are at maximum.

          2.2.2 Linear vs Nonlinear

With all of these "built-in" constraints, it would seem that
relatively few parameters would be required to particularize a
function to specific emission data.  But S-shaped curves are
nonlinear and not particularly responsive to linearization by
transformation, as is so conveniently done when dealing with
exponential response functions by transforming the response
variable to logarithms.

A typical family of such S-shaped curves sometimes goes by the
name "logistic" or "inhibited growth" curves.  For example, in a
town of limited population a few inhabitants become infected with
a communicable disease.  As time passes, other inhabitants become
infected, and the epidemic grows at an increasing rate because of
the increasing number of "carriers." After some time, however,
the rate begins to decrease, simply because there are fewer
people to become infected.  The result: the ubiquitous S-shaped
curve.

The resemblance of the cumulative emission curves to curves of
inhibited growth is fairly evident.  If one examines the factors

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                               -73-
influencing emissions, it also becomes evident that similar
driving mechanisms are at work in the two situations.  Certainly
emissions up to a certain point in time, when expressed as a
fraction of the total day's emissions, depend to greater or
lesser degree on emissions prior to that time.  Once cumulative
emissions reach, say, 25% of the day's total, subsequent
emissions must bring the total cumulative to a higher (or at
least equal) percent.  On the other hand, the higher the
cumulative becomes, the less "room" there is for further
increase.

The general form of the logistic function is fairly simple:

 P(t) = a / (b + c exp(-kt))

The three parameters make it possible to match three points on
the curve to available observations and, at the same time, to
represent a relatively wide range of curves of this type.

For example, here is a simple logistic curve that could easily
represent a diurnal test.

 P(t) = 1 / (1 + 100 exp(-0.8 t))

The 25% cumulative break point occurs at 4.38 hours, the 50%
break point at 5.76 hours, the 75% break point at 7.13 hours and
the maximum (inflection point)  comes at 5.7 hours.  Compare with
strata tests #6 and #9 in Table 4-1 of the report.

It is not unreasonable to believe that this type of curve could
model all the data available in M6.EVP.002 to sufficient
precision for emission assessment.  The curve could be
approximated at the hourly points by group averages, as was
previously pointed out, and could be smoothed manually (with the
assistance of a French curve),  or by the use of cubic spline
interpolation.  If the averaging procedure is not considered to
be acceptable, the curve could be fitted by non-linear least
squares or other procedures available for this purpose.

Further details pertinent to alternative approaches to modeling
hourly diurnal emissions are given in Appendix 2  [renamed here as
Appendix G-2] of this review.  It is not too presumptive to say
that by means of an extension of Table 4-1 a model already exists
that would yield essentially the same information as the more
involved pseudo-autogressive models provided in M6.EVP.002.  If
the times for 25%, 50% and 75% of full-day emissions are
interpolable,  then all other benchmarks should be interpolable.
Cubic spline interpolation for this purpose should be explored,
as well as the applicability of a logistic curve as a closed-form
equation.

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                               -74-
And don't forget human intuition.  A model is not a model because
it is mathematical but because it works.  Slide rules are not
"bad," just obsolete.  The same can be said for French curves.

3.   INTERRUPTED DIURNALS

The methodology proposed by EPA for estimating interrupted
diurnals is heavily assumption laden, but that is not its most
serious difficulty.  Assumptions must necessarily be used when
facts are not available, else we must abandon the chase.  There
is an aspect of interrupted diurnals, however, not addressed by
either fact or assumption, and that is the characterization of
the diurnal sample space and its attendant probability
distribution.

Put more succinctly,  the problem is this: how will the
calculation of interrupted diurnals be used in MOBILE6? How many
different interrupted profiles must be considered, and how can
these be weighted to reflect their relative frequency in the
space of all diurnals? Unless these questions are answered, it is
not evident what purpose will be served by being able to compute
interrupted diurnals, even if those estimates are error free.  In
short, it is not evident how the computation would help to
inventory hydrocarbon emissions or assess their impact on air
quality.

     Correct.  The frequency  (or weighting) of the interrupted
      (along with the frequencies of full-day and multi-day)
     diurnals are not addressed in this report.  They are all
     dealt with in the report entitled  "Soak Length Activity
     Factors for Diurnal Emissions"  (report number M6.FLT.006).
     Section 5.2 has been revised to reference that report.

It appears that what is lacking is a "vehicle use cycle"
comparable to the existing "standard driving cycle." Every
vehicle user has his own driving cycle, dictated by his job
commute, his Little League obligations and other factors, and it
is not likely to duplicate the standard cycle.  Still, it is not
possible to take into account the behavior of each and every
vehicle user.

Similarly, every driver has his own associated "use pattern" -
that is, when he drives the vehicle,  when he has it in the
garage, and when it is "resting" in a parking lot.  His driving
cycle is just a subset of this more inclusive use pattern that
determines the extent of diurnal emissions, running losses,
resting losses, etc.   Again,  it is not possible to take into
account the whims of every individual vehicle user.  Ergo, the
need for one or more standard "use cycles."

This reviewer is well acquainted with the limitations of the
standard driving cycle, having been involved for several years in
assessing the "shortfall" in real-world fuel economy relative to

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                               -75-
the "sticker values" based on laboratory tests according to the
standard driving cycle (see References 9 and 11).   His experience
also includes development of a "modal emission model" to estimate
emissions and fuel consumption for an arbitrary driving cycle,
given only modal estimates (see Reference 11).   The teachings of
these exercises is that a compromise has to be made in the level
of detail that is practical and cost effective in addressing such
problems.  It is not practical to include the experience of every
vehicle user in an inventory of pollutants or fuel consumption,
but it is also unreasonable to believe that all driving patterns
can be mapped into a single,  characteristic driving cycle.  A
suitable tradeoff must be found and the accompanying errors
accepted.

A very similar dilemma must be resolved in the assessment of the
"non-driving" aspects of vehicle use - that is, diurnal
emissions,  resting losses, etc.  In view of the multiplicity of
use patterns, perhaps interrupted diurnal computation is too
detailed.  On the other hand, even further detail could be
considered.

For example,  it is stated in M6.EVP.002 that interrupting the
diurnal with a trip causes a temporary increase in fuel tank
temperature.   The time required to regain temperature equilibrium
depends, says the report, on "duration of the trip, fuel delivery
system, fuel tank design, fuel tank materials,  air flow, etc."
One might also add location of the fuel tank, how full it is, and
other factors.  However,  rather than going into this level of
detail, EPA elected to use a fixed time of exactly two hours as
the time required to stabilize temperature.  In a sense, for this
"micromodel"  or "submodel" EPA invoked a "standard" response into
which all other responses are arbitrarily mapped.

It seems reasonable and necessary, therefore, that the
distribution of the total use cycle of automobiles be addressed
in considering the driving and non-driving contributions to
vehicle emissions.

4.   SUMMARY AND OVERALL REPORT ASSESSMENT

Because of the significant departure of this reviewer's point of
view from EPA's perception of the modeling of hourly diurnal
emissions,  this summary and overall assessment of M6.EVP.002 was
intentionally delayed until the two approaches could be
explicated, compared and put into perspective.   We now present
our position.

     4.1 Clarity

The style of this report is quite similar to that of reports
M6.EVP.001 and M6.EVP.005 that were previously reviewed.  The
writing is logically clear but somewhat pedestrian in places,

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                               -76-
particularly where it is necessary to talk about such concepts
as:

     * Product of the delta in previous hour's temperature
       times the total  (change in temperature) prior to the
       previous hour

     * Product of the VP times the delta in previous hour's
       temperature times the total prior to the previous hour

Though there may be some advantage in avoiding mathematical
symbolism wherever possible, here is a place where it might help
"keep the record straight." Why not use a convention of
subscripts to index points in time, where n denotes "now", n-1
denotes one step back, and s denotes summation over all time
intervals prior to that? Thus dn  means  "change in  current  hour's
temperature," dn_1  denotes  "change in  previous  hour's  temperature,
and ds  denotes  the sum of  all  temperature deltas prior  to  that
(see Appendix I [renamed here as Appendix G-2]} .

     Sections 4.2.1, 4.2.2, and 4.2.3 were revised to include
     this format for the seven equations.

Other suggestions made in the reviews of M6.EVP.001 and
M6.EVP.005 are applicable here also.

     4.2 Overall Methodology

Several modifications of overall methodology are suggested in the
discussion of interrupted diurnals.  The specifics of diurnal
computation, however, serve only as a vehicle for addressing the
larger issues of appropriate level of detail in any modeling
effort.  Balance detail against gains in precision and cost.

     4.3 Datasets Used

No comment is made with regard to the database, because this
topic has been treated previously in the review of M6.EVP.001 and
M6.EVP.005.  As in those reports, we should make the most of what
data we have.  This has not always been done;  directions for
improvement are implicit in Section 2,  Stepwise Regression, Its
Pros and Cons.  A particular instance is that of modeling hourly
emissions cumulatively rather than incrementally.   The cumulative
approach is capable of wringing more information from the data
than is the incremental approach.

     4.4 Statistical Methodology / Conclusions

Some fairly sweeping changes in statistical methodology are
recommended.  These directly impinge on the appropriateness of
the conclusions set forth in M6.EVP.002.

     * Forget about stepwise regression.

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                               -77-
     Regardless of the statistical approach being used, the
     analyst must identify:

          the variables that are likely to have an effect on the
          result  (i.e., hourly diurnal emissions) and

          which of those variables will actually be available
          when running MOBILE'6.

     Once such a list of candidate variables has been created,
     some method must be used to limit that set to a smaller
     subset of the variables having a significant affect on
     diurnal emissions.  If the data set of  (hourly) test results
     were diverse enough,  we could identify a subset of the set
     of variables that was linearly independent.  Until we obtain
     that truly diverse data set, we will continue to use the
     stepwise regression method  (in spite of its short comings)
     to help identify that subset of the set of significant
     variables.

     * Re-structure the model: let the output be cumulative
emissions as a function of time.

     While a cumulative output would not be useful for the MOBILE
     model, some aspects of a cumulative model could be useful.
     Using a logistic growth curve to model the cumulative
     emissions as a function of time is an interesting concept.
     Just as using averaged test results (as in these analyses)
     can simplify the analysis by removing the vehicle-to-vehicle
     variability, using such a cumulative model would permit
     additional smoothing of the data.

     If we can create logistic models that closely approximate
     the hourly  (averaged) cumulative emissions, then those
     models would produced "processed" hourly incremental
     emissions.   Those "processed" emissions could then be used
     to generate  (hopefully)  more accurate models of hourly
     diurnal emissions as functions of temperature cycle and fuel
     RVP.  Granted, this is not what the reviewer had in mind
     when he suggested using cumulative emissions as a function
     of time.

     In any event, using that approach must wait for a later
     analysis, possibly once more data become available.

     * Re-examine the role played by sequential hourly
temperature increments as predictor variables.  Do they really
serve any useful purpose?

     Yes, they do.

     * Try to minimize model complexity; seek a parsimonious
model form consistent with the relatively simple form of the

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                               -78-
cumulative emission vs time curves.
inhibited growth model .
                                     Examine, e.g., logistic /
     Granted that a model of cumulative emissions as a function
     of time is much less complicated than the models used in
     these analyses, such a  (simpler) model would not meet the
     needs of MOBILES.

     * Reconsider the stratification of the data.  Though
physical differences  (e.g.,  carburetted vs FI) are logical bases
of classification, consider whether the models for candidate
strata differ enough to merit separate strata.  This topic has
been discussed in more detail in the review of the parallel
reports M6.EVP.001 and M6.EVP.005.

     The original draft version of this report, in fact, combined
     all six "non-Gross Liquid Leaking" strata into a single
     stratum on the assumption that the differences among the
     strata were small.
5 .   REFERENCES

1)  Landman, L.  C., Modeling Hourly Diurnal Emissions  and
Interrupted Diurnal Emissions Based on Real -Time Diurnal Data.
Document Number M6.EVP.002  (Draft) May 5, 1999
2)  Landman, L.C.
Using RTD Tests.
1998

3)  McAdams, H.T.
1999
                  Evaluating Resting Loss and Diurnal Emissions
                  Document Number M6.EVP.001  (Draft) November 20,
                  Review of Draft Report M6.EVP.001.  February,
4)  Landman, L.C., Modeling Diurnal and Resting Loss Emissions
from Vehicles Certified to the Enhanced Evaporative Standards.
Report Number M6.EVP.005  (Draft)  October 1, 1998
5)  McAdams, H.
1999.
                T., Review of Draft Report M6.EVP.005 February,
6)  Enns, P., Evaluating Multiple Day Diurnal Evaporative
Emissions Using RTD Tests.  Report Number M6.EVP.003  (Draft)
January, 1999.

7)  McAdams, H.  T., Review of Draft Report M6.EVP.003 March, 1999

8)  Wilkinson, Leland.  SYSTAT: The System for Statistics.
Evanston, IL: Systat, Inc., 1990

9)  McAdams, H.  T., Comparison of EPA and In-Use Fuel Economy
Results for 1974-1978 Automobiles - An Analysis of Trends.  Paper
No.  790932, Society of Automotive Engineers October, 1979  (Co-
authored with B. D. McNutt and R. Dulla)

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                               -79-
10)  McAdams, H.  T., A Comparison of EPA and In-Use MPG - 1980
Update.  Paper presented at SAE Annual Meeting, February, 1981
(Co-authored with B. D. McNutt, R. Dulla and R. Crawford)

11)  McAdams, H.  T.  An Exhaust Emission Model.  Paper No.
740538, Society of Automotive Engineers (Co-authored with P.
Kunselman,  M. Williams and C. Domke) 1974

12)  McAdams, H.  T., A Random Balance for Simplifying A Complex
Model.  1995 Proceedings of the Section on Statistics and the
Environment, American Statistical Association,  71-74.


H.   T.  McAdams

6-25-99

Editorial note: On page 8 of the report, third paragraph from the
bottom, "appear to be effected" should read "affected." Also,
there are places in the report where strata should read stratum
and vice versa.

     Those grammatical errors have been corrected.

htm

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                               -80-
                          APPENDIX  G-l

        CORRELATION STRUCTURE OF TIME-DEPENDENT VARIABLES
Following are the six time-related, temperature-delta variables
that are used in the EPA models of hourly diurnal emissions.
       ABC
   Prev. Hr.  Curr. Hr. Sum of
    delta      delta  prior dels
     d_       d        d
A Sqr.
B Sqr.
A * C

0
3
4
4
4
3
2
0
0
0
1
2
3
3
2
1
1
1
1
1
0
0
0
0
.5000
.0000
.8000
.9000
.2000
.7000
.0000
.7000
.2000
.5000
.4000
.4000
.1000
.1000
.7000
.9000
.9000
.8000
.4000
.1000
.8000
.6000
.7000
0
3
4
4
4
3
2
0
0
-0
-1
-2
-3
-3
-2
-1
-1
-1
-1
-1
-0
-0
-0
-0
.5000
.0000
.8000
.9000
.2000
.7000
.0000
.7000
.2000
.5000
.4000
.4000
.1000
.1000
.7000
.9000
.9000
.8000
.4000
.1000
.8000
.6000
.7000
.6000

0
3
8
13
17
21
23
23
24
23
22
19
16
13
10
8
7
5
3
2
1
1
0
0
.5000
.5000
.3000
.2000
.4000
.1000
.1000
.8000
.0000
.5000
.1000
.7000
.6000
.5000
.8000
.9000
.0000
.2000
.8000
.7000
.9000
.3000
.6000

0
9
23
24
17
13
4
0
0
0
1
5
9
9
7
3
3
3
1
1
0
0
0
0
.2500
.0000
.0400
.0100
.6400
.6900
.0000
.4900
.0400
.2500
.9600
.7600
.6100
.6100
.2900
.6100
.6100
.2400
.9600
.2100
.6400
.3600
.4900
0
9
23
24
17
13
4
0
0
0
1
5
9
9
7
3
3
3
1
1
0
0
0
0
.2500
.0000
.0400
.0100
.6400
.6900
.0000
.4900
.0400
.2500
.9600
.7600
.6100
.6100
.2900
.6100
.6100
.2400
.9600
.2100
.6400
.3600
.4900
.3600

0
10
39
64
73
78
46
16
4
-11
-30
-47
-51
-41
-29
-16
-13
-9
-5
-2
-1
-0
-0
0
.2500
.5000
.8400
.6800
.0800
.0700
.2000
.6600
.8000
.7500
.9400
.2800
.4600
.8500
.1600
.9100
.3000
.3600
.3200
.9700
.5200
.7800
.4200
The associated correlation matrix is:
1.0000
0.9320
0.1282
0.6452
0.5652
0.9202
0.9320
1.0000
-0.1416
0.5822
0.6536
0.8030
0.1282
-0.1416
1.0000
0.1717
-0.0159
0.1349
0.6452
0.5822
0.1717
1.0000
0.7921
0.5312
0.5652
0.6536
-0.0159
0.7921
1.0000
0.2691
0.9202
0.8030
0.1349
0.5312
0.2691
1.0000
Note that the temperature deltas for the current and previous
hours are highly correlated (0.9320); also the previous hour and
the product of the previous hour and all hours prior to that

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                               -81-
(0.9202).  These high correlations and other sizable off-diagonal
entries suggest that the correlation structure of the variables
is such that the information afforded has dimensionality less
than the number of variables. How much less can be revealed by
computing the eigenvalues of the correlation matrix:

        Eigenvalue    % of trace     Cumulative % of trace

          3.7093        61.82               61.82
          1.0825        18.04               79.86
          0.9284        15.47               95.73
          0.2529         4.21               99.94
          0.0161         0.27              100.21
          0.0100         0.17              100.38

The sum of the eigenvalues is 6; the largest eigenvalue indicates
that its associated eigenvector accounts for over 60% of the
trace and hence over 60% of the variance among the six variables.
Similarly, three eigenvectors account for all but about 4% of the
variation among the variables.  Clearly, therefore,  there is a
considerable amount of redundancy in the time-related variables
selected for inclusion in the EPA models.

If independent vectors, such as the eigenvectors of the
correlation matrix, were used as terms in the regression
equation, an orthogonal model would result, and there would be no
need for stepwise regression.

6-24-99
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                               -82-
                          APPENDIX  G-2

            SOME OBSERVATIONS ON GROSS LIQUID LEAKERS
            AS  AN  EXAMPLE OF AN ALTERNATIVE  APPROACH
           TO THE MODELING OF HOURLY DIURNAL EMISSIONS

Since evaporative emissions are viewed in M6.EVP.002 as depending
on midpoint VP,  via fuel RVP and temperature cycle, it it logical
that interaction of VP with time-related variables be included in
the model. Given a fixed fuel RVP and temperature cycle,  though,
it is not clear that the time-related temperature deltas in
M6.EVP.002 actually do anything,  so far as providing better
estimates of hourly diurnal emissions are concerned.

Inasmuch as the emission response of gross liquid leakers is
independent of VP,  the data for this stratum (#7) provides a
realistic opportunity to examine the consequences of time-related
temperature deltas in an environment free from other influences.

First,  the models provide only discrete hourly estimates for the
first 18 hours of the emission cycle.  They are based on
regression of the current hourly estimate on temperature deltas
for previous hours (and sometimes the current temperature delta)
as well as products of these temperature deltas.  Data are
obtained from as many vehicles as possible in a given stratum.

As a result of the test data sequence, estimates are available
for each hour for each vehicle tested.  Thus there are available
already multiple estimates of hourly diurnal emissions.  All that
remains to be done, therefore,  is to provide the best linear
unbiased estimate for each hour (the EPA model does no more than
this).

By the theory of least squares, quite apart from regression, the
mean of a set of observations is the best estimate of the
expected value of the population from which the sample is drawn.
Regression analysis is invoked when one wants a model for
interpolating responses at predictor values for which there are
no observations. In the overall situation, estimation of the
response at a given point in x-space draws on information from
other points in that space in such a way that optimum estimates
are obtained.

In the present situation, however,  it is only the original points
in x-space that are of interest - that is, the hourly
observations.  It is a fair question to ask how emissions at the
second, third,  ...  etc. hours improve the estimate for - say -
the sixth hour,  when direct observations for that hour are
already available.  Using a regression model based on antecedent
times,  therefore, seems to carry an element of circularity. Also,
there seems to be no real gain in succinctness. Though the number

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                               -83-
of parameters in the equation may be less than the number of
hours in the day, information for each of those hours is drawn
upon in computing emissions for a given hour.

Nowhere in the report is there a genuine consideration of the
residuals for any of the models.  The "unity line" plots do not
provide that information and yet mislead the reader into
believing that the models are "a good fit."

The closest approach to comparing observed and computed values is
in Figure 4-1[renamed Figure here as 4-3], in which the computed
values for gross liquid leakers are plotted as a solid line.  In
the usual scatterplot,  one would expect the observed values to be
plotted as points to show how well the line cuts through the
observed data.   Instead, a bar graph is used to represent the
observed hourly emissions. This bar-graph presentation tends to
obscure the relatively large differences between observed and
calculated responses.

Included in this Appendix is a duplicate of Figure 4-1 [renamed
Figure here as 4-3]  (see Figure II-l),  and, for comparison, a
second plot (Figure II-2) in which the data are presented in the
usual scatter-plot format. In view of the way in which the
calculated values are computed,  it is fair to ask whether the
values computed from the model are any better than the values
computed as means of the observations.

There is another disturbing sense in which the models in
M6.EVP.002 depart from convention.   The line plot, though
continuous, is highly segmented and has discontinuous
derivatives. In fact, it should not be represented as a line at
all. The models provide estimates only on the discrete domain [1
23 ... 22 23 24] and are inapplicable at - say - 3.5 or 12.2.
It is here that some form of smoothing might be considered.
Figure II-3 employs cubic spline interpolation to provide a
continuous version of Figure 4-1  [renamed Figure here as 4-3] of
the report. The smoothed version offers no advantage, however,
and is included only to show that the terms in the EPA model
could not provide a curve as convoluted as Figure II-3.

It is the contention of this reviewer that the emission
observations should not have been discretized in the first place.
It is much easier to deal with emissions as a continuous function
of time rather than as 24 (or 19)  discrete quantities, the hourly
emissions.  A continuous model can be developed, and that model
can then be differentiated or subjected to a differencing
operation to provide hourly emission estimates.

Figure II-4 is a cumulative plot of the modified hourly diurnals
as given in Table 4-4 of the report.  With the exception of a
slight kink in the curve at two hours,  the cumulative is a smooth
S-shaped curve.  If further smoothing were considered necessary,
one could invoke cubic splines for this purpose, or even

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                               -84-
intuitive "fairing" of the curve. It is conjectured,  however,
that the cumulative curves from evaporative emissions will be
smooth and relatively simple.

In Figure II-5 a second plot is added; that is a cumulative plot
of the hourly emissions as computed from the equation 7a of the
report. The fact that the two plots are very close together
indicates that the delta terms in the EPA model are not necessary
and that a smooth curve drawn through the cumulative mean hourly
emissions would suffice as the time-dependent part of the model.

The argument becomes more convincing when it is realized that the
model is just an artifice for reproducing the means of the hourly
emissions. The closer the model-computed hourly emissions
reproduce the average hourly emissions, the higher the R-square
and the happier is the analyst. A model that exactly reproduces
those averages is just a sequential list of those averages,
inasmuch as the model, whatever its form, operates only in the
finite domain  [123 ... 19 ... 24] .

In reality,  the quoted R-square for the Landman model is highly
exaggerated relative to what an "honest" regression model
attempts to do. By averaging the emissions across tests, the
analyst removes the major source of variation.  If each hourly
emission for each test had been regressed on the terms used in
the model, R-square would have been about 0.13, as estimated from
an Analysis of Variance separating the within-hour and between-
hour sums of squares.

Because of its simplicity, gross liquid leaker data was used to
demonstrate the possibility of this simpler approach to modeling
hourly diurnal emissions.  A similar approach can be applied to
the other six strata.  The effects of RVP and temperature cycle
can be incorporated as dummy variables to further desegregate
data within strata or as interactions capable of modifying a
base-level cumulative curve.

6-26-99
htm

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                               -85-
                           Appendix H


          Response to Peer Review Comments from Harold Haskew


     This report was formally peer reviewed by two peer reviewers
(H. T. McAdams and Harold Haskew).   In this appendix, comments
from Harold Haskew are reproduced in plain text, and EPA's
responses to those comments are interspersed in indented italics.
Each of these comments refer to page numbers in the earlier draft
version (dated July 1, 1999)  that do not necessarily match the
page numbers in this final version.  Comments from the other peer
reviewer appear in the preceding appendix  (Appendix G).

     This peer review included its own appendix identified in the
review as Appendix F.  It has been renumbered as Appendix H-l.

               ************************************

                       Comments Concerning

                           M6.EVP.002,
    "Modeling  Hourly  Diurnal  Emissions and  Interrupted Diurnal
            Emissions Based on Real-Time  Diurnal  Data"

                                By

                      Harold  M.   Haskew,P.E.

Overall

This report is difficult to read and comprehend.

A traditional Introduction and a Conclusions Section would help.

Why are we concerned with hourly emissions, or interrupted
diurnals? Why is this information necessary? What new insight is
gained by including this detail into the Mobile6 model? It would
help the reader if this were established in the opening section.

Has the Baltimore-Spokane vehicle operation data been analyzed to
see what the typical vehicle use patterns are? How many vehicles
are driven at least twice before noon? The GM SAE paper suggests
that these vehicles would have no "diurnal."

     Those data have been analyzed  (see report number
     M6.FLT.006).  The analyses in this report suggest that the
     diurnal emissions from those vehicles would be small.

If there is a need to add additional fidelity into the inventory
model, are there sufficient data available to make appropriate
estimates at the detail level suggested? If not, should a
recommendation be made for additional research?

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                               -86-
     Additional testing is being considered.  However, analyses
     based on the results of any future testing will not be
     available for MOBILE6.

The report is strongly biased to another report (M6.EVP.001)
which is not currently available in its updated form.  Would it
help to briefly repeat the conclusions and limitations of 001 in
this report?

     The final version of that report  (M6.EVP.001) is now
     available.  The primary conclusions/results in that report
     were the selection of the equations that MOBILE6 uses to
     model full-day diurnal emissions and hourly resting loss
     emissions.  These equations are repeated in Appendices A-D
     in this report.

Has the author overanalyzed the data set? Statistics and
coefficients are used extensively.  Are the relationships
appropriate? And will future data sets validate the same
relationships?

     These questions seem to be rhetorical in nature and require
     no answers.

Plots of the modeled relationships overplotted with the actual
data points would help the reader to comprehend the success of
the prediction.

     Thirteen new bar charts  (comparing the actual hourly diurnal
     to the predicted) were added to the existing seven scatter
     plots in Appendix D.


Specific Comments

The abstract contains notes and instructions to the reader that
appear to be out of place.  Should not Paragraphs 2 and 3 of the
"Abstract" be in a separate section?

     Those paragraphs (requesting comments from the reader) have
     been dropped from this "final" version of the report.  They
     were present in the draft version of this report because EPA
     was still considering suggestions on how the MOBILE model
     should treat hourly diurnal emissions.  Now that EPA has
     selected its approach, those paragraphs have been dropped.

The 1.0 Introduction leaps quickly to detail and discussions
containing temperature cycles, etc., before establishing what the
report is about.  The right words are there, but need some
rearrangement to help the reader understand the objective and
order of presentation.

Would it help to rearrange the report using the outline below?

-------
                               -87-
     Introduction
          Purpose of the report
          Definitions of terms and concepts
          Limitations of the dataset(s)
          Order of reporting
     Statement of approach
          Availability of hourly data
          High and normal emitters
     Data Available
          EPA program - strengths and limitations
          CRC program - strengths and limitations
          The need to break the analysis by "strata"
     Hourly Emissions
     Interrupted Diurnal
     Examples of Selected Approach with Existing Data
     Conclusions and Recommendations

Page 6, Fig 3-1 illustrates the concept of hourly emissions with
real data, but then at Table 4-1 goes on to present the time to
25%, 50%, and 75% of full day  (the "four critical times").   Why
did the author not stay with the hourly emissions concept?  Have I
mis-interpreted the way the model will handle the data?

     No, the peer reviewer has not misinterpreted the way MOBILE6
     handles diurnal emissions; the emissions are estimated on an
     hourly basis.  Therefore, the analyses (in this report) are
     on that same hourly basis.

     In the section of this report in question  (4.1), EPA
     selected a few "key" values  (namely the hours that
     correspond to the three guartile values and the hour
     corresponding to the peak  (mode) emissions) prior to
     performing the full  (hourly) analyses.  The selection of
     these "key" values was somewhat arbitrary.  This preliminary
     approach was used to simply confirm that the characteristics
     of the hourly diurnal emissions of the individual strata
     were different.  The analyses that resulted in the models
     actually used in MOBILE6 were based on hourly emissions.

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                               -88-
Section 4.2  (Calculating
Hourly Diurnal Emissions  by
Strata) is very tough  to
follow.  Given the  small
amount of data present,
should the model use only
carbureted and fuel injected
as fuel type, normal and
high as conditions, and a
simple sliding adjustment
for the temperature effect?
Figure 4, at right,
illustrates an analysis made
for the CRC E-9 Diurnal
program.  Could this kind of
correlation provide a  better
estimate than the 12 strata
?  Why must one use "fail
pressure", for example, if
those tests are not being
used in the field?
       Diurnal Emissions vs. Model Year
       All Vehicles (less 8 carb. outliers)
 40
 35
2 9S
rn £3
 15
 10
 d Fuel Injected   • Carbureted
= 0.1BB/x+4.20BB y - u.oooox-r u.o
 R2 = 0.0026     R2 = 0.2527
            12    16    20
             Vehicle Age - years

             Figure 4
                           24
     The reviewer makes  a  good point.   In fact, this  (suggested)
     approach is similar to what is used in the portion of
     MOBILES that estimates exhaust (i.e.,  tailpipe) emissions.
     However, in any approach that estimates the emissions within
     individual stratum  (i.e.,  either the suggested or the one
     used in this report),  it is necessary to eventually assemble
     the individual  results by using weighting factors.  We
     already have such factors based upon the purge and pressure
     tests; we do not have the necessary weighting factors based
     on emission levels  (i.e.,  normal emitters, high emitters,  .
     .  .).   In  future analyses,  we may have  the data  necessary to
     develop these recommended weighting factors.

4.2.3 "Gross Liquid  Leaker" really begs a plot of measured
emissions versus age, for  FI and Carb vehicles, with the modeled
result overplotted,  much in the manner of the plot to the right.

     The frequency and emissions of these "Gross Liquid Leakers"
     are analyzed in report M6.EVP.009,  entitled "Evaporative
     Emissions of Gross  Liquid Leakers in MOBILE6."  In that
     report we note  that the only vehicles identified on the RTD
     test as being gross liquid leakers were six carbureted
     vehicles.  We point out that could mean either that
     carbureted and  fuel-injected vehicles are different relative
     to their vulnerability to leaks or that there simply were
     not enough older fuel-injected vehicles in the sample.
     Until more data become available,  EPA will use the second
     assumption.  Therefore,  we do not have separate graphs for
     carbureted and  fuel-injected vehicles.

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                               -89-
     As to any graph of the magnitude of the emissions versus
     age,  we believe that there simply are not enough data to
     support that type of analysis.   (There are three age
     groupings, with the highest emissions coming from the single
     vehicle in the middle age group.)

At 5.1, Interrupted Diurnal,          A  plot  previously
furnished to the Agency (See below) would help to illustrate the
concept.  A full set of these plots, and the text that explains
them is included later in this report.
HOT URBAN DRIVING - THREE TRIPS
GM ENVIRONMENTAL CELL
1989 Cadillac Eldorado
100
u. 80

111
Z)
Seo
a:
S
LU
h-
40


20




•

FUEL TANK TEMP —
AMBIENT TEMP -f


VEHICLE SPEED




CANISTER PURGE —




x-*"

fS



\








1


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; 	 EMPTY











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o
- 20 t£.
- 40 °-
03
-60 |
- 80 g
_ Ann
0 2 4 6 8 10 12 2 4 6 8 10 12
am TIME OF DAY pm
Electronic copies of the sample plot above were previously made
available to the agency, and can be furnished again if requested.

     Section 5.2 of this report has been revised to note this
     phenomenon.   (See similar comment on page 95.)


Report Clarity

This report is difficult to read and comprehend.  Plots, charts,
and numeric examples would help.

     The report has been revised by including more charts and
     plots.
Appropriateness of datasets selected
The real-time diurnal data analyzed appear to be the most
appropriate  (only) data available.  The interrupted diurnal

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                               -90-
analysis begs for a vehicle use factor.  EPA has a large body of
data (e.g.,  Baltimore-Spokane)  collected to study how, and when
during the day,  vehicles are driven.  Has this been analyzed? For
instance, what percentage of the vehicles driven today have one
or more trips before 10AM?

     In a parallel report, M6.FLT.006  (entitled "Soak Length
     Activity Factors for Diurnal Emissions"), EPA analyzes data
     from an instrumented vehicle study conducted in Baltimore,
     Spokane, and Atlanta to determine what percent of the fleet
     is undergoing either full-day or interrupted diurnal at each
     hour of the day.  The fact that the results of that study
     (of activity data) are necessary to weight the hourly
     diurnal emissions has been added to this report both in the
     introduction and at the end of Section 5.2 (pages 1 and 31,
     respectively) .


The Data Analysis

The report as written does not help the reader understand what
analysis was made.

One quarrel with the analysis described in this report comes from
the author's attempt to create relationships where little, or
inappropriate,  data is available.  A strong suggestion that more
tests are required would help.

     We appreciate the reviewer's suggestion that more data are
     required.   Hopefully, those additional data will be
     available when this analysis is revisited.


Conclusions

There are no conclusions, or findings,  offered.

     A conclusion section was added to this version.

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                                -91-
              Appendix F ([renamed here as Appendix H-1])
Ul 200
The estimates  for hourly
resting loss emissions
mentioned  in Appendix F
[renamed here  as Appendix H-1]
appear to  follow a simple
correlation to the ambient
temperature, with an initial
value offset to reflect
various technologies and
conditions.  The plot shown
below and  to the right
presents plots of some of the
combinations listed in
Appendix F  [renamed here as
Appendix H-1],  focusing on
the "pass  pressure"
condition, and the 72 to 96°F
diurnal cycle.

If "resting losses" are for
the main part,  permeation,
why not pursue an exponential
form of temperature
correction? Is the simple form  in Appendix F
Appendix H-1]  appropriate? Why?
          Peer Review of M6.EVP.002
        Appendix F - Resting Loss Estimates
                                19!0_1»»5_C«rti_PP

                                1986_1995_Cirb_PP

                                19etM985_FI_PP
                                1986J995_FI_PP
               10  12  14 16

                Hour of the Test
                         18  20 22
              [renamed  here as
     Over the range of
     applicable temperatures,
     the  linear form accurately
     predicted the actual
     resting loss emissions.

The figure  on the right  (taken
from SAE  1999-01-1463)
illustrates that the temperature
of the  liquid in the fuel tank
lags the  ambient temperature
change  during a real-time
diurnal experience.   The
permeation  from hoses and other
materials must have a similar
time lag  response.  Should the
"resting  loss" estimate emulate
the lag factor seen here? If
not, why?

     If we  assume that time lag
      (one to two hours)
     associated with the resting
        24 Hour Fuel Liquid Temperature Response
                EPA Cycle 72-96 F
                10      15     20
                  Time - hours

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                          -92-
loss emissions, then the temperature cycles  (Appendix A) and
resting loss models  (Appendix F) combine to suggest that the
effect on hourly resting loss emissions would be less than
0.02 grams per hour.   (The sum of the 24 hourly resting
losses, producing the estimate of the full-day's resting
loss, would be virtually unchanged.)  Since the overall
effect of this hypothetical time lag on resting loss
emissions appears to be almost negligible, EPA will not
pursue it until more data become available.

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                               -93-
Measured Performance under Interrupted Diurnal
Conditions  --  SAE891121
HOT URBAN DRIVING - THREE TRIPS
GM ENVIRONMENTAL CELL
1988 Chevrolet Celebrity
100


80
LLJ
K.
D
< 60
£
LLJ
~ 40



20




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JNJELTANK TEMP


AMBIENT TEMP
VEHICLE SPEED



CANISTER PURGE - —

-

bX^
r











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^^K=— *B-^_
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x
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FULL


	
EMPTY











-20
0

•20
-40
-60

4 fl/t
0 2 4 6 8 10 12 2 4 6 8 10 12
                                                       HOT URBAN DRIVING - ONE TRIP
                                                          GM ENVIRONMENTAL CELL
                                                            1988 Chevrolet Celebrity
                                           024
                                                             10   12   2

                                                              TIME OF DAY
TEMPERATURE -F
S £ g S 1 g
HOT URBAN DRIVING - THREE TRIPS
GM ENVIRONMENTAL CELL
1988 Oldsmobile Regency
FUEL TANK TEMP
AMBIENT TEMP
VEHICLE SPEED


r








\
V


EMPTY

| S g S g ° g
GRAMS PURGED
2 4 6 8 10 12 2 4 6 8 10 12'""
am TIME OF DAY pm
                                                      HOT URBAN DRIVING - ONE TRIP
                                                          GM ENVIRONMENTAL CELL
                                                           1988 Oldsmobile Regency
                                              AMBIENT

                                              VEHICLE SPEED
                                            024
                                                         8  10   12  2  4

                                                          am  TIME OF DAY  pm
HOT URBAN DRIVING - THREE TRIPS
GM ENVIRONMENTAL CELL
12(j 1989 Cadillac Eldorado
100

IE. 8°

tr
i M
Q.
UJ
*~ 40


20





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VEHICLE SPEED



CANISTER PURGE — -



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-20
0 g

40 2
CO
80 g

0 2 4 G 8 10 12 2 4 6 8 10 12 ""*
am TIME OF DAY pm
HOT URBAN DRIVING - ONE TRIP
GM ENVIRONMENTAL CELL
1989 Cadillac Eldorado
120
100


u.80
LU
£
D
S 60
S
uj
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H 40




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.^ 	 ' 	 "~^
S*^ *^~ 	
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AMBIENT TEMP

VEHICLE SPEED

; ^_______
CANISTER PURGE 	 ^ 	 ^



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•-20
- 0 S
o
- 20 o:
13
- 40 o-
• 60 |
on &•
• 80 o
. inn
° 0 2 4 6 S 10 12 2 4 6 8 10 12
am TIME OF DAY pm

-------
                               -94-
                         (Excerpted from)
         EVAPORATIVE  EMISSIONS  UNDER REAL-TIME CONDITIONS
                            SAE 891121
GM'S  TEST  PROGRAM  -  To  conduct  the  real  time  test  program,  GM
developed  an  ambient  "high  temperature"  daily   profile   using
published  EPA  data on  Los  Angeles   [19] and  maximum  temperature
limits from the June 30, 1988 workshop.   [7]

The 90th percentile hourly temperature levels for the Los Angeles
area  during  May-October,  inclusive,  are  plotted  as  the  lower
curve in Figure 1.  The lowest  temperature  occurs at 5 a.m.,  and
is  63.2°F.    The highest  temperature is  91.9°F.  at 2  p.m.    The
difference between  the  high and low is  28.7°F.   The temperature
rises from low to high  in 9 hours,  and cools in 15 hours.

Recent discussion  of  "excess" emissions has focused on a daily
high temperature of 95°F.   For the purposes of GM's  test program,
three degrees were  added to each hourly reading  to maintain  the
"Los  Angeles"   curve   shape  and  reach   a  95°F.  maximum.     The
resulting  test profile  is shown as  the  upper  curve in Figure  1.
Rounding to the nearest degree,  the  low is 66°F. at 5  a.m.,  and
the high is 95°F.   at 2 p.m.  The  resulting 29 degree daily  rise
is more severe than the 24 degree rise in the FTP (60 - 84°F.) .

Some  pertinent  features  of the  vehicles  used  in the  GM   test
program are summarized  in Table 1 below.

                             TABLE 1
                         VEHICLES USED IN
                  HIGH  TEMPERATURE DRIVING  TESTS


BODY TYPE
NOMINAL
TANK
SIZE
(gal.)
PURGE
OVER
HOT LA -4
(ft3)
YEAR  ENG     TYPE

1989  4.5L   V-8 TBI    Cadillac     18.8       7.9
                        Eldorado

1988  3.8L   V-6 PFI    Oldsmobile   18.0      11.2
                        Regency 98

1988  2.5L   L-4 TBI    Chevrolet    15.7       4.2
                        Celebrity

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                               -95-
All  three were  low  mileage  production  vehicles  equipped  with
automatic  transmissions.    Several  specific modifications  were
made  in  the evaporative  control hardware  on each  vehicle,  for
purposes of these tests.

First, the components of  the  evaporative emission control system
of one vehicle,  the Eldorado,  were modified  to  ensure that tank
headspace  pressure   was   maintained  near   atmospheric  levels
throughout  the  testing.     The  modifications   were  performed
specifically for  this test program  because:  1)   some  EPA policy
statements  have  supported  use  of  fuel  and evaporative  system
designs  that  maintain  tank   headspace  pressures  near  ambient
levels, and 2) prior  EPA  users of the PT  Model  may have assumed
that  tank  headspace pressures  were at ambient levels.   [16,  20,
21]

Secondly,   each  vehicle  was  equipped  with  an   in-use  1500  cc
canister.    This  was  done  to approximate  the  conditions  under
which, according  to  EPA's  "excess"  evaporative  analysis,  there
would be  no  capacity left.   An  Agency  spokesperson  at  the June
1988  workshop  had  stated that a "1.8 liter  canister,"  which is
presumably  a   canister  having a nominal  1500  cc   of  activated
carbon, would  be predicted  by  the  EPA staff not  to have  "any
capacity at the end of the day."   [22]

GM began the program  with three  trip  days  for each  vehicle.   For
this  series of tests, the vehicle canisters  were fully loaded to
"break- through"  with butane  the night  before.   A standardized
definition  of  "breakthrough"  loading  does  not   exist  in  the
engineering  community.     Industry   representatives  sometimes
consider   a   canister   "saturated"   when   it   has   reached   a
breakthrough level,  typically two grams,  under laboratory loading
conditions.   EPA at  one  time  proposed  that  canisters be loaded
with  repeated  vehicle diurnal heat  builds  in  a SHED until  the
SHED  concentration  increased  by  a  specified percentage.    [8]
These two methods may give different results.

Three Trip Test Results -  The results of the three trip day tests
are displayed  on  Figures  2,  3,  and  4.  The  canister weight  for
each  vehicle,  measured  at two second  intervals,  is displayed on
the lower  panel  of  each figure,   while the ambient  and fuel tank
liquid temperatures appear  in the upper panel.   A  trace  in  the
middle of each figure identifies   the driving periods.

The data  show  that  each vehicle   ended the three trip day having
lost  canister weight.   In each instance, measurable new canister
capacity was created  during  each LA-4, and the  hot soaks  at  the
end of the LA-4s used only part of  the capacity created  in  the
preceding  drive.   The Eldorado  canister lost 76 grams,  and  the
Regency 98 and  the Celebrity canisters lost 45  and 51  grams,

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                               -96-
respectively.

The fuel  temperature  and canister weight traces  in  Figures 2, 3
and 4  illustrate additional  important  concepts.   One important
point relates to  the  effect  of the 7 a.m.   drive on fuel  system
temperatures.  The  fuel  is heated by vehicle  operation,  and  the
morning diurnal effect is mitigated or eliminated entirely.

On Figure 2, for example, the Eldorado's 23 minute trip at  7 a.m.
increased the fuel  liquid  temperature  from 74  to 84°F.   The fuel
temperature  was   87°F.   at  the  start  of  the noon  trip.    The
measured  canister weight increase  following the initial  7 a.m.
trip's hot  soak  was  one gram.   The  "Partial  Diurnal" (canister
weight gain) for  this day was  one gram  --  effectively zero.   All
three vehicles exhibited the same effects,  although the Celebrity
did not heat the fuel as much during the drives.

A second  fundamental  aspect  of evaporative  control  shown by  the
Eldorado data is the  "back-purge" effect.  As Figure 2 shows,  the
canister  weight  decreased  approximately 9  grams after  the noon
hot soak  to  5 p.m., due  to the "back-purge"  effect caused by  the
fuel tank cooling.    As  the  fuel  tank  cools,  it draws  air back
through the canister in order to achieve an equilibrium condition
in the vapor space, thus purging  the  stored vapors and restoring
previous capacity.

One Trip  Test  Results  -  GM next  ran  real-time tests  on each
vehicle with only a single trip at  5  p.m.   Prior to these  tests,
the canisters  were loaded to  approximately one  third capacity,
not unlike  the  weights  at   the  end  of  the  three-drive days.
Figures 5, 6 and 7 show the results of these tests.

Each vehicle in  the  single  trip tests saw a  complete   diurnal
ambient temperature experience,  and the canisters  gained weight
during the day.  As Figures 5, 6 and 7 clearly show, however,  the
fuel temperatures  did not  experience the  same temperature swing
as did  the  ambient,  and the  canister  weight  increase  was much
less than would  be  predicted  by  using the ambient temperature
swing.   The  weight  loss  resulting from  the canister being purged
during the  5 p.m.   trip was  considerably more  than  the weight
gained during the day.

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                               -97-
                           Appendix I
               Response to Comments from Stakeholders
     The following comments were submitted in response to EPA's
posting a draft of this report on the MOBILE6 website.  The full
text of each of these written comments is available on the
MOBILE6 website.
Comment Number:        68

     Name / Affiliation:   David  Lax /  API

     Date:              December  15,  1997

     Comment:

     EPA should re-assess reliance on a single curve to allocate
     full-day diurnal emissions to each hour of the day for all
     vehicles other than gross liquid leakers."

     EPA's Response:

     Done.   This resulted in the most recent draft version of
     M6.EVP.002 (posted July 1999) .



     Comment:

     The methodology is flawed because it does not consider the
     state of vapor loading on the canister at the beginning of
     the interrupted diurnal.

     EPA's Response:

     We agree that  this was not incorporated.  We have considered
     a testing program to test the hypothesis.  Based on the
     results of that testing, we may later revise our approach.
     Comment:

     More information on the statistical methodology used to
     develop the regression equations shown in M6.EVP.002 should
     be provided to the reader.

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                               -98-
     EPA's Response:

     Appendix D was added to the report to provide  those data.



     Comment:

     RVP should have some effect on diurnal emissions of Gross
     Liquid Leakers.

     EPA's Response:

     EPA believes that any effect of fuel RVP on diurnal
     emissions is minimal compared to the actual  (total) diurnal
     emissions of these gross liquid leakers.  We will  consider
     revising that hypothesis when sufficient test  results over a
     range of fuel RVPs are available.
Comment Number:     N/A.  The  following  question  was  asked during
                    the third workshop  for MOBILE6.

Name / Affiliation:     Harold Haskew / Consultant & Peer Reviewer

     Date:           June 30, 1999

     Question:

     How does EPA's interrupted diurnal  (from Slide  37 of  that
     presentation which corresponds to  Section 5.2 of this
     report) compare to Harold Haskew's SAE paper?

     EPA's Response:

     That SAE report examines both diurnal emissions and  canister
     loading.  Canister loading should  be a factor in interrupted
     diurnals.   (For an interrupted diurnal to occur, the  vehicle
     must have been recently driven.  However, driving the
     vehicle would have resulted in the canister being purged.)
     The data used in EPA's analysis  (of interrupted diurnals)
     was not obtained from vehicles with purged canisters.  This
     is a potential weakness in our analysis.  We will consider
     revising the analysis when sufficient test results  (on
     vehicles with purged canisters) are available.

     This question is similar to one that this individual brought
     up in his peer review  (see page 88) .

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