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OAR Box 1147 

Prepped by Ollie Stewart 

Document Number: 

127) IV-E-117 

Docket Number: 

A-87-11 

Printed 4/23/2008 7:21:47AM Sheet 127 of 242 
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A^lCrr /"fl 

January 19, 1994 

MEMORANDUM 

TO: Air Docket A-87-11 

FROM: Richard D. Wilson, Director ff. £. /ffl*^^ 

Office of Mobile Sources Ly^ " v 

SUBJECT: Meeting with Auto Industry Regarding Onboard Refueling 

Vapor Recovery Rulemaking 

On December 29, 1993 EPA officials, including Mary Nichols, 

Assistant Administrator for Air and Radiation, and Richard 

Wilson, met with representatives of General Motors, Ford Motor 

Co. and the American Automobile Manufacturers Association to 

discuss the onboard refueling vapor recovery (ORVR) rulemaking. 

The auto industry representatives discussed a number of issues 

related to this rule. These issues are summarized in the 

attached page presented to EPA at the meeting by the auto 

industry. 

Attachment 

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ONBOARD REFUELING VAPOR RECOVERY 

Background 

• Section 202(a)(6) of the Qean Air Act is limited to passenger cars. 

• NHTSA's July 1991 report concluded ORVR increased the safety risk of vehicles. 

• EPA issued a final rule on April 15,1992, not requiring ORVR based on the NHTSA report 

• D.C Circuit Court remanded EPA's decision not to promulgate an ORVR rule in January 1993. 

• NHTSA updated their July 1991 report and concluded that "there still remains some small 

unquantifiable increase in safety risk from the addition of the ORVR systems," and recommended 

that EPA not expand ORVR to trucks at this time 

• NHTSA also concluded that "at this time, it is impossible to asses all the safety aspects of ORVR 

requirements for LDTs, HDVs, and vehicles powered by fuels other than gasoline." 

• EPA is about to issue a final rule covering LDVs, LDTs. and HDVs. 

AAMA Recommendations and Discussion 

• Limit ORVR to federally-certified gasoline fueled passenger cars 

ORVR test procedure modifications were develop for gasoline fueled passenger cars 

• • trucks and alternative fueled vehicles were not considered due to timing/resource 

constraints 

• • procedure modifications may not allow for design of integrated ORVR/EVAP system 

on trucks 

Trucks generally have more numerous fuel system configurations, larger fuel tanks, a variety 

of operation cycles and engine purge parameters, and unique drive down provisions for 

EVAP testing 

Stage II will eliminate 75-85% of total refueling and fuel spillage VOC emissions by 19% in 

serious severe, and extreme areas 

ORVR on all vehicles will be 5-15% less effective than Stage II and will not reach its peak 

effectiveness until more than ten years after Stage II has reached its peak 

Extending ORVR requirements to LDTs and HDVs will increase refueling emissions in 

Stage II areas due to breathing losses 

Incomplete vehicles finished by second stage manufacturers present special problems - OEMs 

cannot ensure proper installation of ORVR systems on these vehicles 

Stage II is a safer alternative than ORVR on trucks [NHSTA report (Jury 1991) made this 

finding] 

CAA does not mandate ORVR on trucks and extending the rule to trucks cannot be 

supported by analysis of cost, energy, and safety 

• EPA needs to perform safety review before issuing final rule because of lead time constraints