p.1 

OAR Box 1147 

Prepped by Ollie Stewart 

Document Number: 

205) IV-E-79 

Docket Number: 

A-87-11 

Printed 4/22/2008 2:42:58 PM Sheet 205 of 242 
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t09 % 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

ANN ARBOR. MICHIGAN 48105 

NOV '988 

OFFICE OF 

AIR AND RADIATION 

MEMORANDUM 

SUBJECT: Ford Meeting With the Administrator 

FROM: John F. Anderson, Senior Project Manager 

Standards Development and Support Branch 

TO: Docket A-87-11 

//• ^ 

In my. memo of October 26, 1988 I indicated that Ford had 

not left copies of its presentation to the Administrator from 

its meeting of October 24, 1988. Subsequent to that memo, a 

copy of the presentation was received. That material is 

attached. 

Attachment 

0783w 
P.3 

FINDINGS . 

OF THE 

EVALUATION 

OF 

EVAPORATIVE EMISSIONS 

RUNNING LOSSES 

REFUELING EMISSIONS 

OCTOBER , 1988 
P.4 

TEST DESCRIPTIONS 

VEHICLES TESTED 

1- 1987 TAURUS LX SEDAN - 3.OL PORT INJECTION 

2- 1987 F-250 PICKUP - 5-OL PORT INJECTION 

SAME TEST SERIES FOR BOTH VEHICLES 

TEST PROGRAM 

1- FUEL TANK FILL QUALITY (OEM AND "SIMPLE" SYSTEMS) 

2- STATIC ROLLOVER (OEM AND "SIMPLE") 

3- REFUELING EMISSIONS ("SIMPLE" SYSTEM ONLY) 

EXHAUST/EVAPORATIVE/RUNNING LOSS EMISSIONS (OEM AND "SIMPLE") 
P.5 

FORD POSITION 

RUNNING LOSSES AND EVAPORATIVE EMISSIONS ARE AN IMPORTANT 

ENVIRONMENTAL CONCERN 

•• 25-30 % OF LOCAL VOC INVENTORIES 

.. REFUELING IS APPROXIMATEL Y 1% 

2 DIFFERENT DESIGN APPROACHES ARE REQUIRED TO CONTROL EITHER 

RUNNING LOSSES OR REFUELING LOSSES 

WE BELIEVE THAT WE COULD SUCCESSFULLY CONTROL RUNNING LOSSES 

WITHOUT SIGNIFICANT INCREASED SAFETY CONCERNS IF 

•• OBVR CONTROLS ARE NOT REQUIRED 

•• MODES T RVP LIMITS ARE IMPOSED 

WE BELIEVE THAT CONTROL OF REFUELING VAPORS UNAVOIDABLY 

INTRODUCES SAFETY RISKS THAT ARE NOT ASSOCIATED WITH THE 

CONTROL OF EVAPORATIVE EMISSIONS AND RUNNING LOSSES 

THE "SIMPLE" SYSTEM HAS THE SAME, IF NOT GREATER, SAFETY 

CONCERNS AS OTHER PREVIOUSLY REVIEWED PROTOTYPE REFUELING 

CONTROL SYSTEMS 

THE "SIMPLE" SYSTEM GENERATES A GREATER AMOUNT OF VAPORS AT A 

FASTER RATE UNDER "OZONE DAY" CONDITIONS 
P.6 

TEST PROGRAM FINDINGS 

FUEL TANK FILL QUALITY 

THE "SIMPLE" SYSTEM DID NOT ACHIEVE DESIGN OBJECTIVES FOR 

FILLABILITY 

- 12 GALLONS PER MINUTE - CORPORATE 

- 10 GALLONS PER MINUTE - ARB 

THE "SIMPLE" SYSTEM FILL RATE IS AFFECTED BY CHOICE OF 

FILLER NOZZLE 

HIGH REFUELING VAPOR FLOW RATES LEAD TO LIQUID CONDENSATION 

IN THE VAPOR LINESLIQUID FUEL CAN ALSO ENTER THE VENT LINES UNDER 

NON-REFUELING CONDITIONSTHE "SIMPLE" SYSTEM REQUIRED A NUMBER OF RESTARTS OF THE 

FILLER NOZZLE UNDER SOME CONDITIONSFUEL SPITBACK WAS NOTED ON 25% OF THE TESTS ON THE TRUCK 

EQUIPPED WITH THE "SIMPLE" SYSTEM-
P.7 

TEST PROGRAM FINDINGS 

2- STATIC ROLLOVER 

THE "SIMPLE" SYSTEM VALVE LEAKED 28 oz- OF FLUID IN THE 

FIRST 5 MINUTES OF THE TEST COMPARED TO FMVSS 301 LIMIT OF 

5 OZ- IN 5 MINUTESTHE OEM SYSTEM MEETS THE FMVSS 301 STANDARD-
TEST PROGRAM FINDINGS 

3- REFUELING EMISSIONS 

THE "SIMPLE" SYSTEM EMITS BURSTS OF HYDROCARBON VAPOR AT 

EACH NOZZLE SHUTOFF 

THE "SIMPLE" SYSTEM SEAL FORMATION IS INCONSISTENT AT LOW 

FILL RATES 
P.9 

TEST PROGRAM FINDINGS 

4- EXHAUST/EVAPORATIVE/RUNNING LOSS EMISSIONS 

THE "SIMPLE" SYSTEM GENERATES MORE HYDROCARBON VAPOR THAN 

THE PRODUCTION VEHICLES 

THE "SIMPLE" SYSTEM GENERATES HYDROCARBON VAPORS AT A 

FASTER RATE THAN PRODUCTION VEHICLES UNDER "OZONE DAY" 

CONDITIONS 

THE HIGH QUANTITY OF VAPOR FROM THE "SIMPLE" SYSTEM EXCEEDS 

THE CAPABILITY OF TODAY'S EXHAUST EMISSION CONTROL SYSTEM-
COMPUTER PROJECTION 

TYPICAL OZONE DAY 

FUEL VAPOR GENERATION 

SIMPLE SYSTB4 

PRODUCTION TRUCK SYSTEM 

PRODUCTION CflR SYSTEM 

11.5 RVP g.o RVP 

FUEL VOLATILITY 

O 
P.11 

"SIMPLE" SYSTEM CONCERN 

THE FLOW RATE NEEDED TO PROVIDE ACCEPTABLE REFUELING PERFORMANCE 

RESULTS IN: 

1) THE GENERATION OF MORE HYDROCARBONS DURING VEHICLE 

OPERATION 

2) INCREASED EXHAUST EMISSIONS ON "OZONE DAYS" 

3) POTENTIAL DRIVEABILITY CONCERNS AS A RESULT OF INCREASED 

FUEL ENRICHMENT UNDER MORE SEVERE VEHICLE OPERATING 

CONDITIONS 

4 ) A LARGER FUEL TANK VENT OPENING THAT NEEDS TO BE SEALED 

DURING ROLLOVER 
P.12 

PROBABLE DOUBLE DIURNAL 

EVAPORATIVE EMISSIONS 

PLUS RUNNING LOSS HARDWARE 

FOR LIGHT DUTY VEHICLES 

MORE SOPHISTICATED ELECTRONIC PURGE CONTROL 

FUEL TANK HEAT SHIELDS 

AND/OR INCREASED FUEL SYSTEM COOLING 

4- AND/OR MEASURES TO REDUCE FUEL SYSTEM HEAT 

5- ENLARGED CARBON CANISTER (APPROXIMATELY 1-2 LITERS) 

1) ASSUMES THE USE OF SAFETY VENT VALVES WILL BE 

PERMITTED 

2) ASSUMES MODEST RVP CONTROLS 

TFR102188 
P.13 

PROBABLE HARDWARE TO 

CONTROL REFUELING VAPOR 

FOR LIGHT-DUTY VEHICLES 

1) ENHANCED PURGE CONTROL 

LIKELY TO BE SAME AS REQUIRED FOR RUNNING 

LOSS CONTROL 

2) FILLER PIPE VENT CONTROL MODULE 

3) NOZZLE SEAL MECHANISM 

4) LIQUID/VAPOR SEPARATOR 

5) OVER-PRESSURE RELIEF MECHANISM 

6) LARGER CARBON CANISTER 

-Two SYSTEMS 

- ABOUT 3 LITERS FOR 9-0 PSI FUEL 

7) LARGER DIAMETER VAPOR TUBES TO CANISTER 

ASSUMES MODEST RVP CONTROLS 
P.14 

FORD POSITION 

RUNNING LOSSES AND EVAPORATIVE EMISSIONS ARE AN IMPORTANT 

ENVIRONMENTAL CONCERN 

-- 25-30% OF LOCAL VOC INVENTORIES 

•- REFUELING IS APPROXIMATELY 1% 

2 DIFFERENT DESIGN APPROACHES ARE REQUIRED TO CONTROL EITHER 

RUNNING LOSSES OR REFUELING LOSSES 

WE BELIEVE THAT WE COULD SUCCESSFULLY CONTROL RUNNING LOSSES 

WITHOUT SIGNIFICANT INCREASED SAFETY CONCERNS IF 

•- OBVR CONTROLS ARE NOT REQUIRED 

•- MODES T RVP LIMITS ARE IMPOSED 

WE BELIEVE THAT CONTROL OF REFUELING VAPORS UNAVOIDABLY 

INTRODUCES SAFETY RISKS THAT ARE NOT ASSOCIATED WITH THE 

CONTROL OF EVAPORATIVE EMISSIONS AND RUNNING LOSSES 

THE "SIMPLE" SYSTEM HAS THE SAME, IF NOT GREATER, SAFETY 

CONCERNS AS OTHER PREVIOUSLY REVIEWED PROTOTYPE REFUELING 

CONTROL SYSTEMS 

THE "SIMPLE" SYSTEM GENERATES A GREATER AMOUNT OF VAPORS AT A 

FASTER RATE UNDER "OZONE DAY" CONDITIONS