P.1 

OAR Box 1147 

Prepped by Ollie Stewart 

Document Number: 

234)IV-E-109 

Docket Number: 

A-87-11 

Printed 4/22/2008 2:42:59 PM Sheet 234 of 242 
P.2 

' j^ 8* * . 

KWJ 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

ANN ARBOR. MICHIGAN 48105 

AUG 0 6 1993 

A-87-11 

OFFICE OF 

AIR AND RADIATION 

MEMORANDUM 

SUBJECT: Meeting with Toyota Regarding Onboard Refueling 

Test Procedures 

FROM: Michael J. Samulski, Mechanical Engine 

Engine and Vehicle Regulations Branch 

THRU: Joanne I. Goldhand, Chief 

Engine and Vehicle Regulations 

TO: Public Docket A-87-11 

On July 27, 1993 members of the Environmental Protection 

Agency (EPA) staff met with representatives of Toyota to discuss 

potential changes to the refueling emission test procedures as laid 

out in EPA's recently published Federal Register notice on this 

issue (May 27, 1993, 58 FR 30731). The meeting which was held at 

the EPA lab in Ann Arbor was in follow-up to the Onboard Refueling 

Vapor Recovery Hearing of July 19, 1993. 

The material presented by Toyota is attached. Discussions 

focused on shortening the test procedure to reduce labor costs and 

on the effects of initial canister loading on purge. 

The following persons attended: 

NAME 

Joanne Goldhand 

Mike Samulski 

Matthew Kevnick 

Kazuo Takeuchi 

Nobutaka Morimitsu 

Edmund Brune 

AFFILIATION 

EPA 

EPA 

Toyota 

Toyota 

Toyota 

Toyota 
P.3 

COMMENTS ON 

ORVR RULEMAKING 

July 22 1993 

Toyota Technical Center, USA Inc. 

K. TAKEUCHI 

M. KEVNICK 

Toyota Motor Corporation 

N. MORIMITSU 

m 

COMMENTS OM 

ORVR RULEMAKING 

July 22 1993 

1. Good afternoon, Gentlemen. My name is Mat Kevnick of Toyota 

Technical Center USA. 

With me today are Kazuo Takeuchi of TTC USA, Nobutaka Morimitsu, 

manager of TMC Japan. 

On behalf of Toyota, I'd like to present our comments with respect to the 

ORVR proposal rule. 
P.4 

OUTLINE 

/. Introduction 

A) General Comment 

B) Implementation 

//. Test Procedure Comments 

A) General Comment 

B) Option "B1" 

C) Toyota Idea 

C1. Integrated System 

C2. Non-Integrated System 

///. Other Issues 

A) Partial Refueling 

B) Constant Purge 

C) Puff Loss 

HV. Conclusion 

m 

OUTLINE 

2. As shown on this outline, our comments will consist of: 

First is introduction, General Comment, Toyota position and opinion on 

Implementation. 

Secondly, test procedure comments will include Option Bl and Toyota's 

Idea for abbreviated test sequence. 

Then we would like to state our position regarding, Partial Refueling, 

Constant Purge and Puff Loss, and then conclude the presentation. 
P.5 

GENERAL 

1 TOYOTA recognizes need to control Refueling Emissions. 

2.TOYOTA believes STAGE II to be safer than ORVR. 

3.While we respect the judgement of the Court, the safety 

issue remains. 

TOYOTA believes that ORVR regulation should be 

developed to minimize this concern. 

4.Implementation of ORVR must proceed cautiously and 

judiciously to provide adequate leadtime and consider 

vehicle phase in. 

m 

GENERAL 

3.1 would like to state Toyota's general position with regards to the 

ORVR regulation. 

While Toyota recognizes the health and environmental benefits 

associated with the control of gasoline refueling vapors, Toyota believes 

as we have stated previously, that stage II provides a safer control 

methodology, for accomplishing this means. 

Since the safety issues remains, Toyota states that the ORVR regulation 

should be developed to minimize this safety concern. 

It is our position that implementation of ORVR must proceed cautiously 

and judiciously in a manner which addresses safety while providing 

adequate lead tie and vehicle phase in consideration. 
P.6 

IMPLEMENTATION 

1. We request that an exemption be allowed for small 

sales volume vehicle models. 

2. With regard to the extension of ORVR application 

beyond LDV, TOYOTA believes that this issue 

should be discussed after issuing the LDV 

ORVR final rule, because of time concerns. 

m 

IMPLEMENTATION 

4. EPA has requested comments regarding implementation of ORVR. 

Toyota feels that, in order to address the limited opportunity for incorp. 

ORVR onto low sales volume vehicles, an exemption be allowed for 

whose types of vehicle models. 

With regard to the extension of ORVR application beyond LDV, 

TOYOTA believes that this issue should be considered after issuance of 

the LDV ORVR final rule, primary due to time concerns. 

In addition to providing some relief to manufacturers, this consideration 

would ensure effectiveness, integrity, and above all, the safety of ORVR 

system application to LDT's and HDVs. 
P.7 

TEST PROCEDURE 

COMMENTS 

B 

TEST PROCEDURE COMMENTS 

5. At this time, I'd like to direct our comments to the test procedure 

issues. 

*«.-
P.8 

GENERAL COMMENTS ON TEST 

PROCEDURE 

1 The purpose of the test is to verify design integrity and 

system performance. 

2.Test should be capable of evaluating refueling emissions 

either independently or in conjunction with evap. and 

tailpipe emission measurement. 

3Test procedure should be simple and consider Real World 

Conditions. 

4.Canister preconditioning is the most critical concern. 

H 

GENERAL COMMENTS ON TEST PROCEDURE 

6. TOYOTA feels that, first,the purpose of the test should be to verify 

design integrity and system performance.Second, to address the resource 

burden, test should be capable of evaluating refueling emissions either 

independently or in conjunction with evap. and tailpipe emission 

measurement. 

Third, to permit design flexibility for addressing safety concern, the test 

procedure should be simple yet effective and consider Real World 

Condition. 

And fourth, since the refueling test procedure itself has been under 

consideration for some time, it is most important at this point to consider 

the manner in which canister preconditioning is treated. 
P.9 

EPA's PROPOSALS WILL TAKE 

APPROX. 4 DAYS 

MON 

TUE 

THU 

Integrated System 

Option Bl 

Canister 

Preconditioning 

12-36h 

V RT inpT-Unn ^- V B.T. Loadi 

LA-4 Cold/Hot 

^ Running Loss Drive] 

W E D fr brain dueling 10%] 

Option A 

Canister 

Preconditioning Rtj Preconditioning 

12-36h 

£ Orain / 

•ino 

LA-4 Cold/Hot 

Fuelino 10%] 

Option B 

Drain / dueling 40%k 

Canister 

12-36h 

,1.5'W.C Loading 

1 l A-dCnWHp> j O 

Running Loss Drive , 

praiip / Fijqllnr m%j 

i : SOAK 6-12h . i SOAK 6-12h *. 

^s J; 

Non-integrated 

System 

Drain / Fueling 40%y 

SOAK12-36JT""Ss 

Re(.Can.=1.5-W.C 

Evap.Can.=BT R '. 

—^.:: 

Purge Cycles 

EPA's PROPOSALS WILL TAKE 

APPROX. 4 DAYS 

7. This chart depicts the time required for completion of the test 

proposals that EPA has described in the Federal Register. 

TOYOTA thinks that it is unreasonable to request such a time consuming 

and complicated test procedure in order to accomplish canister and 

vehicle preconditioning before the refueling test. 

TOYOTA feels that the ORVR test could be simplified from the 4 day 

length without a compromise to the test integrity. We would now like to 

address our preferences to accomplish this. 
P.10 

EPA Option B1 is preferable y 

with some modification 

Integrated 

Onboard / Evaporative 

Test Options 

Objectives of modifications: 

a) Vapor loading and 

Canister purge which 

represents real world. 

b) Reduce test time burden. 

rr-r-rjTnSa 

mUim 3 

••••"•— -

'••" - f " c aim 

ITvitunnnTT 

7?.M F aiarMr* 

0 

REFUBJNO 

OPTION B1 ur-i>ur-itn 

R&uaN Q

 IUOOS.2WCC. UOCS 

OPTTONA ' I i 

WRtTP. 4* * IK 

G 

-t 

c s 

s 

c 

IV«t m ml 

uoos.2mcc.UDOa 

3 

REFUEUNG 

OPTON8 © 

Orin' 10% » / soak 

Ratwq M I 

Own /10% II f H U 

| V«nci MH | 

EU 

EPA Option B1 is preferable 

with some modification 

8. Of the options provided, TOYOTA thinks that EPA OPTION Bl 

would be preferable provided some modification were permitted. A 

diagram of this proposal as provided in the Federal Register is shown 

here. These modifications would address canister preconditioning 

specially to consider vapor loading and canister purge representing real 

world, abbreviating test time burden. 
P.11 

CANISTER LOAD in EPA's Option B1 

TEST SEQUENCE 

Fual drain 1 HI 

•RVP, 40% « l 

VaMdoSoak 

68-8«P 

Preconditioning drlvo 

ona UOOScyda 

Fual drain 1 IM 40% 

VaMdaSoak 

Cold atari axhauat teat 

Hoi atari atchauat laat 

Additional driving 

U003. 7 NYCC. UD03 

Drain/10% HI 

•' i n 

So«k 

ZZZZZZZZZ Rvfuafln-g to«t 

INTEGRATED CANISTER 

LOAD CONDITION 

CANISTER LOAD in EPA's Option B1 

9. Before I discuss TOYOTA'S idea on these modifications, I'd like to 

provide for reference purposes, an estimation of the canister condition at 

each phase of the EPA Bl test procedure. 

The Bl test sequence is on the left. The steps above are considered as 

preconditioning before actual refueling test. And canister preconditioning 

represent 2g break through. 

TOYOTA's proposal considers a shorter test sequence which will 

provided a similar severity for canister load condition and one in which it 

is more representative of actual events. 
P.12 

fEPA Option Bf} 

Start 

t-ual drain & I 

9RVP. 40% fil 

3T~ 

TOYOTA 

PROPOSAL 

| Vehicle Soak 68-86 F| 

Preconditioning drive 

ona UDDS cyde 

c Fual drain & fill 40% 

I Vehicle Soak "t 

•^^T^TT^tTTyTli|.^^T^TTTT*^TW^Tf. 

Disconnect Canister 

Canister preconditioning 

2g Break Through 

Connect Canister 

| iaia sari ixnausi iasi \ 

| Hoi stag exnaust test \ 

T 

(

Additional driving 

UODS^NYCCJJDD: j Disconnect Canister 

( Drain/10% fill 

f f Vehicle Soak 

„__ _ 

c Refueling test 

Fuel to >95% 

Connect Canister 

<5" 

< LOADING 

^ftiflWJS^^jQ^^I 

I 

I PURGING 

"xnaseeea J 

VEHICLE 

! SETUP 

Load Canister 

3DBL eauivalent 

5C H lailpip»fcvaporative lest! 

Completion of 3BDL I 

]ft. short trio ouroe 1 UDOSJ 

I urainTRw ueung as'iE" 

Disconnect Canister 

Bench Purging 

Purge volume is determined 

by using purge rate. 

(Option B1 equivalent) 

( Drain/Refueling 10% _ 

( Vehide Soak 6-24 hr , 

G Refueling Test in SHED 

(5" 

Connect Canister 

H 

TOYOTA'"" 

PROPOSAL 

10. The figure shows EPA's option Bl on the left and center is 

addressing to three phase, Loading , Purging, and Vehicle Set Up. On the 

right side, TOYOTA's proposal is shown which contains: 

Preferable loading of a 3 day DBL equivalent which we believe is most 

severe conditions of real world, a short trip purge cycle, then 95% 

refueling. 

And a purge rate recommendation to be performed via a bench operation 

using a purge volume to be equivalent to the Bl R/L test. 
P.13 

GENERAL IDEA 

FOR ABBREVIATED SEQUENCE 

1. Purging ability is sufficiently evaluated in tailpipe/ 

evaporative test procedure. 

2. In ORVR test, loading of canister during preconditioning 

and evaluation of vapor capture performance are most 

important. 

3. To load canister to WC*1.5 is unreasonable. Vapor loading 

should be done by actual refueling process. 

QD 

GENERAL IDEA 

FOR ABBREVIATED SEQUENCE 

11. I'd like to take a moment and explain the rationale used for 

developing this TOYOTA proposal. 

First, because of the design of the enhanced evap test, purging ability is 

already sufficiently evaluated in this procedure, so the provision to use 

bench purging should be reasonable and acceptable. 

Second, In consideration of the ORVR abbreviated test sequence, loading 

of the canister during preconditioning and evaluation of vapor capture 

performance were determined to be the most important parameters. 

Third, vapor loading is to be done by actual refueling process. In 

particular loading the canister to 1.5 times working capacity is very 

unreasonable. TOYOTA feels that ORVR system designs could be 

compromised with these types of loading requirement. 
P.14 

COMPARISON OF 

TOYOTA AND EPA PROPOSAL 

COMPARISON OF 

TOYOTA AND EPA PROPOSAL 

12. Where providing a representative level of stringency to EPA's Bl 

proposal, the TOYOTA proposal can be accomplished within a 24 hour 

period as shown here. 

Yet the TOYOTA proposal provides canister loading more representative 

of real world conditions as opposed to the unreasonable loading 

procedures now under consideration. 
P.15 

SIMULATE REAL WORLD TRIP 

PATTERN AND CANISTER LOAD 

NORMAL CONDITION 

MON 

TUE 

WED 

PATTERN ASSUMI-HON 

arlting 

.^Driving 

THU 

FRI 

SAT 

SUN 

FUEL 

INTEGRATED SYSTEM 

VAPOR LOAD IMAGE 

EMP B.T. 15*WC 

SEVERE CONDITION 

MON 

TUE 

A/ED 

PATTERN ASSUMPTION 

'aiking 

.Driving 

THU 

FRI 

SAT 

SUN 

_FVEL 

INTEGRATED SYSTEM 

VAPOR LOAD IMAGE 

EMP ai . 1.5*WC 

•t 1 

13 

SIMULATE REAL WORLD TRIP PATTERN AND 

CANISTER LOAD 

13. To support our contention what the current canister loading 

conditions do not duplicate real world conditions. I'd like to provide this 

figure which simulates real world trip pattern and canister load. The left 

side which is labeled "Normal Condition" represents a frequent driver 

who uses his vehicle every day. ( a 7.5 mile FTP estimation was made.) 

We can see that under the column labeled "vapor load", the canister is 

almost always purged and certainly never achieves a break through or 

1.5 times working capacity loaded state. 

The right side is a very severe condition, one is representative of the evap 

procedure, (3 day Diurnal plus Refueling event). Even under this 

condition, the canister load of an enhanced evap system would never 

achieve these types of loadings. 
P.16 

VAPOR DESORPTION 

CHARACTERISTICS 

SATURATED! 0 

DESORPTION 

(g/LiterA.C.) 

-50 

A.C:Activated Carbor 

Bench Purging 

(7.5 BV/min) 

(15BV/min)-

-100 rPurg ng by Vehicle

 — 

Integrated system=150 BV/LA-4 

Nonintegrated system=25 BV/LA-4 

0 250 500 750 1000 

Purge Volume (Bed Volume 0 

VAPOR DESORPTION CHARACTERISTICS 

14. Justification for the use of the bench purge in the TOYOTA proposal 

is offered here. This chart compares the vapor desorption characteristics 

of activated carbon canister subjected to vehicle purge and bench purge. 

Since desorption characteristics depend upon purge air volume, in actual 

vehicles there is no 

difference in desorption characteristics between the integrated system and 

non-integrated system. 

We can see also, that a bench air flow purge rate of 7.5 BV yields the 

same desorption effect provided by vehicle purging. 

Therefore, bench purging can easily simulate vehicle drive purge 

conditions. 
-EJLZL 

ABBREVIATED SEQUENCE 

-INTEGRATED SYSTEMTEST SEQUENCE 

Tailpipe/Evaporative Test ~ | 

Completion of 3DBL | 

1 

START 

Load Canister 

3DBL equivalent 

A snort trip purge ~I | 

1 uuo s I * 

T 

| urainmetueitng 9b-/o \ DISCONNECT 

v ....... . ^ 

I DrairVRetuelina 10% \ 

• 

SOAK 6-24 hr 

Vehicle Temperature 

Conditioning 

* 

Refueling Test in SHED l 

Bench Purginc 

Purge volume is determinedby 

using ITS OWN purge rate. 

(Option B1 equivalent) 

I 

CONNECT 

CANISTER 

LOAD CONDITION 

EMP B 

1 

I _J 

t*ili;*l><X><X>00(J 

; MAXIMVM WADlNfT 

k^« 

T 

Test Time : 24 hr 0 

ABBREVIATED SEQUENCE-INTEGRATED 

SYSTEM15. This figure depicts the TOYOTA abbreviated sequence proposal for 

an integrated system and provides on illustration of the canister load 

condition. 

The sequence of rationale are as follows: 

•Load canister to a 3 day diurnal equivalent level. 

•Drive one LA-4 cycle to simulate a drive to fuel station. 

•Load canister again by refueling, thus a maximum loaded condition 

would be produced. 

•Disconnect canister, and subject to bench purge (equivalent of Bl 

option level). 

•Simultaneously soak vehicle. 

•Reconnect canister and perform refueling test. 

From the canister simulation illustrated here, it can be seen that as severe 

of a loading pattern exists for this required as is contained Bl sequence. 

Yet it is more representative of actual conditions. 

As mentioned previously, this procedure test time is 24 hours. 
P.18 

ABBREVIATED SEQUENCE 

-NON-INTEGRATED SYSTEMTEST SEQUENCE 

START 

A short trip purge 

1 UDDS 

Orain/Refuelina 95% 1 

VEHICLE TEMPERATURE 

CONDITIONING 

DISCONNECT 

CANISTER 

Orain/Hetuelmo 10% 1 

SOAK 6-24 hr 

Vehicle Temperature 

Conditioning 

Bench Purging 

Purge volume is aetarmined 

by using fuel economy, 

tank capacity, purge rate. 

Refueling Test in SHED 

CONNECT 

CANISTER 

LOAD CONDITION 

REFUELING CANISTER 

EMP B.T 

E? ~~~V ^ i i^Ev»por»tive Canister) 

fllfeFUEUNG CANISTER) ' 

Test Time : 24 hr H 

ABBREVIATED SEQUENCE -NON-INTEGRATED 

SYSTEM16. Similarly, the abbreviated sequence can be applied to the 

non-integrated system. 

The sequence and rationale follows in the same manner as integrated 

system. 

The major exception is amount of bench purging to empty the refueling 

canister. 

Canister load condition for the separate refueling canister is shown here 

also. 

Again this sequence could be performed in 24 hours. 
P.19 

MODIFICATION TO CURRENT TAILPIPE/ 

Original Evap 

Start 

FvaA drain 8flU 

9RVF\40% JH 

•\ /ModifiedX EVAP. SEQUENCE 

Fuaidrain&fU 

SRVP, 40% U 

I Vaftda Soak 68-86 F I | Wada Sor"T t 66-86 F | 

' i iLoad Canister 

30BL aativalent 

fracondtioninQ drive 

^npf t i inns rvrtft 

nm ] [ Preoondrtoring drive 

nr-ft Unng fvrtft ] 

I Fu.liani*U.to% I I fual Oram A til &*. I 

1

 • J [ , ., JL ' 

Caristar pracondMoring 

& VaNda Sort 

-RsrasSriiirTOri 

VaMdaSort 68-86 F 

Canrstar disconrwctad 

C«istar connactad Load Caristar 

3DBL aquvalant 

I Cold stan aimausl tast I 

| Hot nan ««hausl taat | 

Ruining toss tost 

UOOS. 2 NYCC. UDOS 

Hot soak tost 

96 +/-5 anto-ient 

3C Vehicle soak 

last 6 hour at 72 F 

Diurnal emission t*st 

3 heat buHd in 72 Hr 

75-96 F excursion 

C^> 

Preconditionng dnve 

ona UDOS cveta J 

/ ruel dram 4 liJ !JS% } 

( huel drain & hll IU% 1 

SOAK 6-24 hr 

VeNde Tenperature 

^^JJjjjjjJtjojjijj^^^ fljjj 

[Bench Purging I 

(Refueling Test in SHED) 

ED 

MODIFICATION TO CURRENT TAILPIPE/EVAP. 

SEQUENCE 

17. Taking this abbreviated sequence proposed one step further, this chart 

shows how the enhanced evap test sequence could be modified to provide 

consistent and more realistic canister loading throughout the test 

sequence while offering reduction in test time from to use other one 

week. 

In addition this procedure provides the opportunity to evaluate evap, 

exhaust and refueling emission in one continuous sequence or provide a 

single ORVR test sequence. 
P.20 

OTHER ISSUES 

18 

OTHER ISSUES 

18. Other issues. 

H i -
P.21 

PARTIAL REFUELING REQUIREMENT 

in Non-Integrated System 

150 

DESORPTION 

(9) 

100 

REFUELING 

100 VAPOR 

GENERATION 

(g) 

—» 50 

20 30 

UDDS CYCLES 

19 

PARTIAL REFUELING REQUIREMENT 

in Non-Integrated System 

19. TOYOTA believes that EPA's consideration of a partial refueling 

requirement for non-integrated system, in order to ensure ORVR systems 

have adequate design margin, is not necessary. 

Vapor generation from refueling increases linearly in proportion to the 

amount of fuel consumed from the number of cycles driven. This is 

shown by the diagonal line. 

On the other hand, the desorption characteristics of the canister change 

exponentially as shown by the curved line. The difference between the 

desorption of the canister and the amount of refueling vapor generation is 

the canister Working Capacity margin. 

Thus margin is smallest in the case of a full-refueling test, as shown on 

the far right . 

Therefore we suggest that anything other than a full refueling would be a 

waste of time. 
P.22 

CONSTANT PURGE REQUIREMENT 

in Non-Integrated System 

200 

150 

DESORPTION 

(9) 

100 

•PURGING BY VEHICLE RUNNING 

200 

150 

REFUELING 

100 VAPOR 

GENERATE 

(g) 

50 

REDUCING 

PURGE RATE 

20 30 

UDDS CYCLES 

20 

CONSTANT PURGE REQUIREMENT 

in Non-Integrated System 

20. We are very concern about EPA's consideration of Constant Purge 

Requirement for Non-integrated System. 

EPA suggests that in order to preclude inappropriate purge strategies, this 

constant purge would be required during each UDDS cycle. 

TOYOTA does not think this requirement is reasonable. Manufacturers 

must have the ability to modify or reduce the purge rate in order to 

minimize the impact that purging of refueling vapors has on tailpipe 

emissions. To require constant purge would present a formidable 

challenge to non-integrated system design. 

TOYOTA believes that purge should be managed from the span of one 

refueling event to the next, and in order to minimize exhaust emission 

interaction. 
P.23 

PUFF LOSS 

1. For control of evaporative emissions during cap removal, 

either Puff Loss or Fuel Tank Pressure Requirement can 

be equally effective. 

2. Since the Tank Pressure Requirement exists in the evap 

emission regulation, the Puff Loss requirement becomes 

redundant and should be eliminated. 

3. TOYOTA believes that, for a system designed to relieve 

tank pressure before the cap is opened, either requirement 

is unnecessary. 

ED 

PUFF LOSS 

21. Next, I'd like to address Puff Loss issue. 

First, for control of evaporative emissions during cap removal, either 

Puff Loss or Fuel Tank Pressure Requirement can be equally effective. 

Since, the tank pressure requirement exists in the evap emission 

regulation, the Puff Loss Requirement becomes redundant and should be 

eliminated. 

In addition, TOYOTA believes that, for a system designed to relieve 

tank pressure before the cap is opened, either requirement is unnecessary. 
P.24 

T ' r '. "• 

SELECTIVE ENFORCEMENT AUDIT 

1. To require SHED for SEA would be a significant burden to 

manufacturers. 

2. SEA testing is not necessary. 

ORVR performance is decided by system design. 

22 

SELECTIVE ENFORCEMENT AUDIT 

22. Next, Selective Enforcement Audit. 

To require SHED for SEA would be a significant burden to 

manufacturers. 

TOYOTA feels that SEA testing is not necessary, because ORVR 

performance is decided by system design. 
P.25 

CONCLUSION 

1 .Prudent and careful consideration be given to ORVR implementation 

phase-in by; 

a) considering LDT, HDV implementation independent. 

b) allowing an ORVR exemption for small sales volume vehicle models. 

2.Establish the ORVR test sequence with the following modifications; 

a) accept a canister loading condition with 3DBL, 1UDDS, 95%fi!l 

as suggested by Toyota, 

b) allow use of "bench" purging instead of actual driving. 

3.Consider modification to the enhanced evaporative emission test procedure 

for vehicles designed with an integrated ORVR system; 

a) canister loading requirement should be consistent with ORVR 

recommendation. 

23 

CONCLUSION 

23. In conclusion, Toyota recommends that: 

First, prudent and careful consideration be given to ORVR 

implementation phase-in by; 

considering LDT and HDV implementation independently, allowing an 

ORVR exemption for small sales volume vehicle models. 

Second, establish the ORVR test sequence with the following 

modifications; . 

accept a canister loading condition, that is 3DBL, one UDDS,and 95% 

fueling as suggested by Toyota, and allow use of "bench" purging 

instead of actual driving. 

Third, consider modification to the enhanced evaporative emission test 

procedure for vehicles designed with an integrated ORVR system, 

canister loading requirement should be consistent with ORVR 

recommendation. 

*=.-
P.26 

24 

END 

24. Thank you for your attention