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OAR Box 1142 

Prepped by Ollie Stewart 

Document Number: 

18) IV-F-16 

Docket Number: 

A-87-11 

Printed 4/23/2008 10:21:21 AM Sheet 18 of 30 
STATEMENT ON BEHALF OF 

EXXON COMPANY, U.S.A. 

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'A-87-11 

\ OCT-?*991 

PRESENTED BY R. W. UPCHURCH 

BEFORE THE ENVIRONMENTAL PROTECTION AGENCY 

HEARINGS ON REFUELING EMISSION 

REGULATIONS FOR GASOLINE-FUELED 

LIGHT DUTY VEHICLES 

ROMULUS, MICHIGAN 

SEPTEMBER 27, 1991 
P.3 

GOOD MORNING. MY NAME IS BILL UPCHURCH, AND I AM VICE 

PRESIDENT FOR REFINING AT EXXON COMPANY, U.S.A. WE APPRECIATE THE 

OPPORTUNITY TO PRESENT OUR VIEWS ON THIS IMPORTANT VAPOR RECOVERY RULEMAKING. 

WE ARE APPEARING HERE TODAY BECAUSE OF EXXON'S LONG 

EXPERIENCE IN DEVELOPING PROTOTYPE AUTOMOTIVE EMISSION CONTROL 

TECHNOLOGY. 

WE RECOGNIZE THAT THE ALLEGED SAFETY RISK PRESENTED BY 

ONBOARD REFUELING CONTROL IS THE MAJOR FOCUS OF THIS HEARING--AND 

WE WILL ADDRESS OUR VIEW OF NHTSA'S CONCERNS ON THIS ISSUE. WE 

ALSO WANT TO STRONGLY SUPPORT THE VIEWS EXPRESSED BY BILL O'KEEFE 

OF API THAT ONBOARD REFUELING CONTROL REGULATIONS SHOULD BE 

PROMULGATED BY EPA, AS REQUIRED BY THE CLEAN AIR ACT AMENDMENTS. 

IF, FOR SOME REASON, THE CONCERNS EXPRESSED ABOUT THE SAFETY OF 

THESE SYSTEMS ARE NOT PUT TO REST BY THESE HEARINGS, WE SUPPORT 

THE GENERAL ACCOUNTING OFFICE'S (GAO) RECOMMENDATION TO PROCEED 

WITH THE RULEMAKING--AND RESOLVE THESE SAFETY CONCERNS DURING 

THE 3-4 YEAR PERIOD OF DEVELOPMENT BEFORE COMMERCIAL SYSTEMS ARE 

OFFERED FOR SALE. 

THE ONBOARD REFUELING EMISSIONS CONTROL TECHNOLOGY 

WHICH WE ARE DISCUSSING TODAY DOES NOT REPRESENT A RADICALLY NEW 

EMISSION CONTROL APPROACH, BUT IS SIMPLY THE EVOLUTION OF TECHNOLOGY, FOLLOWING A STEADY PROGRESSION OF TECHNICAL DEVELOPMENTS 

WHICH BEGAN OVER 25 YEARS AGO. THE PETROLEUM INDUSTRY AND EXXON 

HAVE BEEN A PART OF THE EFFORT TO DEVELOP SAFE, EFFECTIVE PROTOTYPE CONTROL SYSTEMS THAT HAVE CONTRIBUTED TO THIS SERIES OF 

IMPROVEMENTS-WHICH HAVE RESULTED IN LOWER VEHICLE EMISSIONS. 
P.4 

MANY PANEL MEMBERS ARE FAMILIAR WITH OUR WORK ON 

EVAPORATIVE EMISSION CONTROL SYSTEMS, INCLUDING WORK UNDER CONTRACT WITH EPA IN THE 1970'S THAT RESULTED IN EVAPORATIVE EMISSION 

STANDARDS AND TEST PROCEDURES THAT ARE ESSENTIALLY IDENTICAL 

WITH TODAY'S REQUIREMENTS. DURING THIS PERIOD OF INTENSIVE 

RESEARCH, EXXON ACQUIRED A CONSIDERABLE BACKGROUND ON EMISSION 

CONTROL SYSTEM PERFORMANCE, ALTERNATIVE APPROACHES TO EMISSION 

CONTROL, AND THE COST-EFFECTIVENESS OF SUCH CONTROLS. TO OUR 

KNOWLEDGE, THE SAFETY RISK TO THE DRIVING PUBLIC POSED BY THESE 

EMISSION CONTROLS HAS NEVER BEEN A SIGNIFICANT ISSUE. FOR THE PAST 

TWO DECADES, THE AUTOMOTIVE INDUSTRY HAS ADOPTED AND USED THIS 

TECHNOLOGY ON A WIDE-SCALE BASIS WITHOUT ANY SUBSTANTIAL EXPRESSION OF SAFETY CONCERNS. 

IT IS OF NOTE THAT, FROM THE BEGINNING OF OUR VEHICLE PROTOTYPE WORK IN THE MID-1960'S TO THE USE OF COMMERCIAL CARBON 

CANISTER VEHICLES SOLD IN CALIFORNIA IN 1970; LESS THAN FIVE YEARS 

HAD ELAPSED. THE ONBOARD REFUELING CANISTER DEBATE HAS BEEN 

GOING ON FOR MORE THAN TEN YEARS--AND IT IS TIME TO MOVE FORWARD. 

BACKGROUND 

IN THE LATE 1970'S ATTENTION WAS FOCUSED ON 

HYDROCARBON EMISSIONS FROM REFUELING. WHEN WE CONSIDERED WHAT 

MIGHT BE DONE TO CONTROL THESE REFUELING EMISSIONS, THE SAME TYPE 

OF CANISTER TECHNOLOGY ALREADY IN USE FOR EVAPORATIVE EMISSIONS 

WAS AN OBVIOUS LOGICAL EXTENSION. IT WAS A SIMPLER, MORE COST 

EFFECTIVE APPROACH THAN STAGE II VAPOR RECOVERY AT SERVICE 

STATIONS. IN 1984, EXXON AND MOBIL, UNDER AN API CONTRACT, BEGAN 
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WORK TO ASSESS WHETHER THE PROVEN CANISTER TECHNOLOGY COULD BE 

MODIFIED TO CAPTURE REFUELING EMISSIONS. 

TWO SIGNIFICANT TECHNICAL ISSUES WERE IDENTIFIED AT THE 

OUTSET. 

FIRST, WE HAD TO ASSURE THAT REFUELING VAPORS WOULD BE 

ROUTED TO THE CANISTER, AND NOT FORCED BACK OUT THROUGH THE 

FILLPIPE INTO THE ATMOSPHERE. 

SECOND, THE CANISTER CAPACITY FOR HYDROCARBON VAPOR 

ADSORPTION HAD TO BE ENHANCED TO ACCOMMODATE THE LARGER 

VOLUME FOR A REFUELING EVENT, COMPARED TO THE EVAPORATIVE 

CONTROL SYSTEM. WE ESTIMATE THAT 50 TO 100 GRAMS OF VAPOR 

WOULD BE DISPLACED IN A 10-20 GALLON REFUELING, COMPARED TO 30-40 

GRAMS IN AN EVAPORATIVE CONTROL SEQUENCE. 

OUR SOLUTIONS TO BOTH OF THESE ISSUES HAVE BEEN PUBLISHED IN THE TECHNICAL UTERATURE-AND VEHICLES EQUIPPED WITH PROTOTYPE ONBOARD REFUELING CONTROL SYSTEMS HAVE BEEN WIDELY 

DEMONSTRATED--TO EPA, NHTSA, AND MANY OF THE OTHER GROUPS 

APPEARING BEFORE THIS PANEL TODAY. WE WILL BE SUBMITTING OUR LABORATORY AND OTHER TEST DATA TO THE DOCKET. I DO WANT TO EMPHASIZE THAT WE HAVE SUCCESSFULLY DEVELOPED AND TESTED DEMONSTRATION SYSTEMS WHICH RELY ON CONVENTIONAL AND COMMERCIALLY-AVAILABLE TECHNOLOGY. WE HAVE NOT CLAIMED THAT THESE VEHICLE SYSTEMS 

ARE PRODUCTION-READY, ONLY THAT THESE APPROACHES ARE FEASIBLE, 

COST-EFFECTIVE, AND WE BELIEVE, SAFE. 

WHILE WE HAVE WORKED ON A NUMBER OF VEHICLES OVER THE 

YEARS, WE WANT TO FOCUS OUR COMMENTS ON THE MOST RECENT WORK 

ON VEHICLES MORE REPRESENTATIVE OF CURRENT NEW CAR PRODUCTION. 
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IN OUR EARLY WORK, WE PLACED THE REFUELING CANISTER ON 

THE TEST VEHICLES IN THE SAME LOCATION AS USED FOR THE PRODUCTION 

EVAPORATIVE CONTROL SYSTEM--IN THE UNDERHOOD SPACE IN THE ENGINE 

COMPARTMENT. BUT IN THIS LOCATION, THE PROXIMITY TO HOT ENGINE 

PARTS RAISED CONCERNS ABOUT POSSIBLE RUPTURE OF THE CANISTER WITH 

SUBSEQUENT FIRE IN CASE OF A COLLISION. ALSO, WE WERE CONCERNED 

ABOUT THE POSSIBLE EFFECT OF AN ACCIDENT IN WHICH THE CAR MIGHT 

ROLLOVER, POTENTIALLY CAUSING LIQUID FUEL TO REACH THE CANISTER. 

BOTH OF THESE ISSUES WERE ADDRESSED THROUGH MODIFICATIONS TO THE MORE ADVANCED VEHICLE DESIGNS PRESENT IN LATER 

MODEL VEHICLES, SUCH AS A 1987 BUICK LESABRE AND A 1988 FORD 

TAURUS. WE SIMPLY MOVED THE CANISTER FROM THE ENGINE COMPARTMENT TO A MORE PROTECTED LOCATION ADJACENT TO THE FUEL TANK. 

[FOR THE TAURUS, THE SITE CHOSEN WAS NEXT TO THE FUEL TANK IN THE UBEAM WHICH ACTS AS THE REAR SUSPENSION ATTACHMENT SUBFRAME. IN 

THE BUICK, WE LOCATED THE CANISTER IN A CUT-OUT PORTION OF THE FUEL 

TANK ITSELF.] 

WE ALSO INSTALLED ROLLOVER VALVES IN THE SHORT LINES 

BETWEEN THE FUEL TANK AND THE CANISTER. IN SIMULATED ROLLOVER 

TESTS, WE FOUND THESE VALVES PREVENTED FUEL SPILLAGE. 

AN IMPROVED, SAFER DESIGN INVOLVING A SINGLE ONBOARD 

CANISTER WAS TESTED FOR EMISSIONS CONTROL. USING A 10.5 PSI REID 

VAPOR PRESSURE FUEL WE STILL ACHIEVED 98+ PERCENT CONTROL OVER 

REFUELING EMISSIONS, AT A FUELING RATE OF 10 GALLONS PER MINUTE. IN 

OUR TESTING FACILITIES, THE MODIFIED VEHICLES MET ALL TAILPIPE AND 

EVAPORATIVE EMISSIONS STANDARDS, AND WE FOUND THE CO EMISSIONS 

FOR THE ONBOARD CANISTER VEHICLES WERE SUBSTANTIALLY LOWER. EVEN 
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USING WHAT WE CONSIDER TO BE AN UNREALISTICALLY SEVERE TESTING 

CYCLE, WE FOUND THE ADSORPTIVE CAPACITY OF THE CANISTERS WAS 

READILY REGENERATED BY THE PURGE SCHEDULE ALREADY USED IN THE 

PRODUCTION-MODEL CAR. INCIDENTALLY, WITH MODERN ELECTRONIC CONTROL SYSTEMS, FURTHER IMPROVEMENTS TO THE PURGE SCHEDULE ALSO 

SHOULD BE WELL WITHIN THE CAPABILITY OF AUTOMOTIVE ENGINEERS. 

ADDITIONALLY WE MEASURED THE RUNNING LOSSES FROM THE 

ONBOARD VEHICLES VERSUS THE SAME MODEL CARS AS PRODUCED WITH 

ONLY THE EVAPORATIVE CONTROL CANISTERS. RUNNING LOSSES WERE 

REDUCED BY 90, 97 AND 97 PERCENT, RESPECTIVELY WITH THE ONBOARD 

BUICK, DODGE, AND FORD VEHICLES. 

WE ALSO PERFORMED TWO TEST PROGRAMS TO DEFINE IF THERE 

WERE ANY CUSTOMER-PERCEIVABLE DRIVEABILITY PROBLEMS WHICH COULD 

BE ATTRIBUTED TO THE ONBOARD CANISTERS. IN BLIND TESTS AT 

INDEPENDENT LABORATORY FACILITIES, NO SIGNIFICANT DIFFERENCES IN 

DRIVEABILITY WERE FOUND, UNDER BOTH WINTERTIME (40°F) AND SUMMERTIME (95°F) DRIVING CONDITIONS, NOR WERE ANY SAFETY CONCERNS 

RAISED. THESE TESTS CONFIRMED OUR BELIEF THAT THE ONBOARD SYSTEM 

SHOULD PRESENT NO OPERABILITY OR SAFETY PROBLEMS FOR THE PUBLIC. 

THE COOL WEATHER DRIVEABILITY DATA ARE IN THE PUBLIC DOCKET; WE 

ARE SUBMITTING THE SUMMERTIME DATA FOR THE RECORD, ALTHOUGH 

THESE DATA HAVE ALREADY BEEN SHARED WITH NHTSA AND EPA. 

THE EMISSION CONTROL RESULTS WE HAVE DESCRIBED WERE 

OBTAINED IN EXXON'S OWN LABORATORIES. THE SCIENTIFIC AND ENGINEERING DATA RESULTING FROM OUR WORK ON THESE PROTOTYPES VEHICLES 

ARE DESCRIBED IN TECHNICAL PAPERS AND REPORTS, THE MOST RECENT 

AND MOST RELEVANT BEING A SOCIETY OF AUTOMOTIVE ENGINEERS PUBLI-
P.8 

CATION [NO. 900155], PUBLISHED IN FEBRUARY OF 1990. THIS PAPER WAS A 

PEER-REVIEWED PUBLICATION, SUBJECT TO TECHNICAL SCRUTINY BY 

KNOWLEDGEABLE MEMBERS OF THE SOCIETY OF AUTOMOTIVE ENGINEERS. 

WE SUBSEQUENTLY PROVIDED THESE VEHICLES TO EPA FOR 

EMISSION TESTING IN THEIR LABORATORIES IN ANN ARBOR. NHTSA CITES 

EVIDENCE THAT THESE VEHICLES FAILED THE PROPOSED EPA REFUELING 

STANDARD. FOR THE RECORD, WE NOTE THAT THE INITIAL EPA TESTS FOR 

THE BUICK YIELDED 0.03 G/TEST VERSUS AN EPA PROPOSED STANDARD OF 

0.1. THE INITIAL TAURUS RESULT WAS 0.13 G/TEST, SLIGHTLY EXCEEDING 

THE TARGET. THE KEY FACTOR IN THESE TESTS IS THE DEGREE TO WHICH 

THE REFUELING CANISTER IS PURGED BETWEEN TESTS WHICH IS NOT 

SPECIFIED IN THE PROPOSED TEST PROCEDURE. THE EPA APPROACH WAS TO 

ACCUMULATE 25-30 MILES BETWEEN REFUELING TESTS, WHICH IS HARD TO 

RECONCILE WITH THE UNLIKELY REAL-WORLD CONDITION OF A MOTORIST 

REFUELING HIS VEHICLE 25-30 MILES AFTER A PRIOR REFUELING. IN SHORT, 

PURGING OF THE CANISTER BETWEEN REFUELING EVENTS WAS CLEARLY INADEQUATE, LEADING TO HYDROCARBON BUILDUP ON THE CANISTER, WITH 

SUBSEQUENT FAILURE TO ACHIEVE THE PROPOSED REFUELING STANDARD IN 

CONSECUTIVE TESTS. EPA SENT US A COPY OF AN INTERNAL MEMO, WHICH 

COMMENTED ON THESE TESTS AS FOLLOWS: "ONLY RELATIVELY MINOR 

PURGE SYSTEM MODIFICATIONS ARE NEEDED TO OBTAIN THE REQUIRED 

PURGE VOLUMES". LATER, AT OUR LABORATORIES WE DOUBLED THE AIR 

PURGE RATE OF THE CANISTER TO HANDLE A SECOND REFUELING AFTER 

ONLY 26 MILES OF DRIVING, AND WE FOUND THIS DID NOT DEGRADE THE 

CONTROL OF TAILPIPE EMISSIONS. WE BELIEVE THIS 26 MILE REGENERATION 

APPROACH, UNDER CONSIDERATION BY EPA, IS UNREALISTIC, GIVEN THAT A 
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FULL REFUELING AFTER THIS MILEAGE ACCUMULATION WOULD BE A RARE 

EVENT. 

IN ADDITION, EPA LABORATORY PERSONNEL MADE CHANGES TO 

THE VAPOR LINES FROM THE EXXON-DESIGNED CONFIGURATION, WHICH WE 

BELIEVE ACCOUNT FOR THE DIFFERENCES BETWEEN OUR DATA AND EPA'S. 

WE REMAIN CONVINCED THAT THESE PROTOTYPE SYSTEMS WHEN PROPERLY 

INSTALLED WILL MEET PROPOSED REFUELING STANDARDS, WHILE MAINTAINING CONTROL OF OTHER EMISSIONS, IF A MORE REASONABLE AND LOGICAL 

TEST PROCEDURE IS USED. 

IN NHTSA'S REPORT, CONSIDERABLE ATTENTION IS DIRECTED TO 

DRIVEABILITY PROBLEMS ASSOCIATED WITH THE ONBOARD-EQUIPPED 

LESABRE, WHEN NHTSA TECHNICAL PERSONNEL TEST-DROVE THE VEHICLE 

UNDER NORMAL ROAD CONDITIONS. AS MENTIONED BY BILL O'KEEFE, THE 

VEHICLE REFUELING EVENT DESCRIBED IN THE REPORT STATES THAT THE 

NHTSA EMPLOYEE OVERROAD THE AUTOMATIC SHUTOFF MORE THAN 100 

TIMES IN ORDER TO FILL THE FUEL TANK--WHICH IS A HIGHLY QUESTIONABLE 

APPROACH AT BEST. IT DID ASSURE THAT LIQUID GASOLINE WOULD BE 

INTRODUCED INTO THE CARBON CANISTER ON THIS EXPERIMENTAL VEHICLE. 

UNDER THESE CONDITIONS, THE SUBSEQUENT DRIVEABILITY PROBLEMS 

ENCOUNTERED ARE READILY UNDERSTANDABLE. 

WE ALSO STRONGLY BELIEVE THAT ONBOARD REFUELING VAPOR 

RECOVERY, USING SYSTEMS ANALOGOUS TO THOSE DEVELOPED BY EXXON 

AND API, DOES NOT REPRESENT AN INCREASED RISK OF FIRES OVER THE 

EXISTING EVAPORATIVE CANISTER SYSTEM. THE ALLEGED SAFETY RISK MENTIONED BY NHTSA HAS NOT BEEN ADDRESSED BY ANYONE, INCLUDING 

NHTSA IN PUBLIC COMMENTS ON THE ENHANCED EVAPORATIVE EMISSION 

CONTROL REGULATORY PROPOSAL. THIS PROPOSAL WILL LIKELY REQUIRE A 
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LARGER CANISTER AND PIPING, INCREASED CANISTER PURGE RATES, AS WELL 

AS THE TACIT ASSUMPTION THAT THE CANISTER WOULD CONTINUE TO BE 

LOCATED IN THE ENGINE COMPARTMENT. 

WE HAVE ALSO WORKED WITH API TO ESTIMATE THE COSTS OF 

THE ONBOARD CANISTER APPROACH TO CONTROLLING REFUELING EMISSIONS 

COMPARED TO THAT OF THE STAGE II SYSTEM AT SERVICE STATIONS. IN 

EVERY ECONOMIC ANALYSIS API HAS DONE, THE ONBOARD CANISTER IS THE 

CLEAR ECONOMIC CHOICE, WITH A NET COST OF ABOUT $1400/TON OF 

EMISSIONS REDUCTION; WHEREAS THE STAGE II COST IS ABOUT $2800/TON. 

THE ONBOARD REFUELING CANISTER COSTS WOULD BE CONSIDERABLY 

REDUCED IF MEASURED AGAINST THE REQUIRED ENHANCED EVAPORATIVE 

EMISSION CONTROL SYSTEM, WHICH WILL LIKELY REQUIRE A VERY SIMILAR 

SYSTEM. THE SUPERIOR COST-EFFECTIVENESS OF ONBOARD WOULD BE 

FURTHER ENHANCED IF THE CONTROL OF RUNNING LOSSES--A MAJOR COMPONENT OF AUTOMOTIVE VOC EMISSIONS-IS FACTORED INTO THESE CALCULATIONS. 

THE QUESTION OF STAGE II SAFETY VERSUS ONBOARD REFUELING SYSTEM SAFETY HAS BEEN RAISED BY NHTSA. WE TAKE NO EXCEPTION 

TO THE POSITION THAT STAGE II EMISSION CONTROL DOES NOT POSE AN 

UNREASONABLE RISK TO THE PUBLIC. HOWEVER, IN OUR VIEW, ONBOARD 

CANISTER CONTROLS, BOTH EXISTING EVAPORATIVE CONTROL SYSTEMS AND 

PROPOSED REFUELING CONTROL SYSTEMS ALSO DO NOT POSE SUCH A RISK, 

SO THE COMPARISON IS MOOT. API WILL PROVIDE WRITTEN COMMENTS ON 

THE NHTSA SAFETY EVALUATION TO THE DOCKET WHICH WILL POINT OUT 

THE SERIOUSLY FLAWED NATURE OF THE NHTSA STATISTICAL ANALYSIS. 

WE ARE CONTINUING TO WORK ON FURTHER IMPROVEMENTS TO 

THE ONBOARD CANISTER SYSTEM. IN PARTICULAR WE ARE INVESTIGATING 
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THE USE OF NEW ADSORPTIVE MEDIA THAT COULD PROVIDE IMPROVEMENTS 

OVER THE CURRENT ACTIVATED CARBON. THESE NEW MATERIALS COULD 

PROVIDE HIGHER ADSORPTIVE CAPACITY AND LOWER PRESSURE DROPS, 

OFFERING THE PROMISE OF SMALLER CANISTERS. 

IN SUMMARY, WE MAINTAIN THAT THE ONBOARD CANISTER 

TECHNOLOGY, WHICH FIRST EMERGED IN THE LATE 1960'S, HAS CONTINUED 

TO EVOLVE TO MEET CHANGING EMISSIONS CONTROL NEEDS. THE ONBOARD 

CANISTER DESIGNS OF TODAY, WHICH ARE VERY EFFECTIVE IN CONTROLLING 

BOTH REFUELING AND EVAPORATIVE EMISSIONS, WILL CONTINUE TO EVOLVE 

FURTHER, AND WE'RE ALREADY WORKING ON SOME OF THOSE IMPROVEMENTS. 

WE FIRMLY BELIEVE THAT THERE IS NO MEANINGFUL SAFETY 

ISSUE ASSOCIATED WITH ONBOARD REFUELING. API HAS PRESENTED A 

COMPREHENSIVE TECHNICAL ASSESSMENT OF THE INDUSTRY'S VIEW AND 

WILL ADD CONSIDERABLE DETAIL TO THE DOCKET BEFORE THE COMMENT 

PERIOD CLOSES. FOR EXXON, WE WOULD NOT BE AN ADVOCATE OF SUCH 

SYSTEMS IF WE FELT THEY PROVIDED ANY INCREASED RISK TO THE DRIVING 

PUBLIC. 

WE URGE EPA TO GO FORWARD WITH THIS RULEMAKING BY THE 

CLEAN AIR ACT-REQUIRED NOVEMBER 15, 1991, DATE, AND TO WORK 

CLOSELY WITH NHTSA AND THE AUTO INDUSTRY ON THE DEVELOPMENT OF 

EFFECTIVE AND SAFE AUTOMOTIVE VAPOR RECOVERY SYSTEMS THAT WILL 

CAPTURE EVAPORATIVE, REFUELING AND RUNNING LOSSES, WHILE MAINTAINING CONTROL OF EXHAUST EMISSION. 

THANK YOU FOR THIS OPPORTUNITY TO COMMENT ON THIS 

RULEMAKING.