P.1 

OAR Box 1830 

Prepped by Ollie Stewart 

Document Number: 

126) IV-C-92 

Docket Number: 

A-87-11 

Printed 11/13/2008 7:20:58 AM Sheet 126 of 232 
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-•*!>». 

JAM 

fl-87-34. 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

ANN ARBOR. MICHIGAN 48105 . 

Mr. Hal E. Moore, Manager, 

Calgon Carbon Corporation 

P.O. Box 717 

Pittsburgh , PA 15230-0717 

OFFICE OF 

AIR AND RADIATION 

National Accounts 

Dear Mr. Moore: 

In a Federal Register notice dated August 19, 1987 

(enclosed), EPA proposed that the gasoline vapors displaced 

from automotive fuel tanks during refueling be controlled by 

using onboard vapor recovery systems. As is shown on page 

31174 of the enclosed notice, the onboard vapor recovery system 

involves several modifications to the existing evaporative 

control system. The primary changes include a fillneck seal to 

prevent release of gasoline vapors to the atmosphere during 

refueling, the incorporation of a rollover/vent valve, and an 

enlarged carbon canister. In order to control these additional 

vapors, canisters with approximately three times as much 

activated carbon as the current evaporative canisters would be 

needed. 

EPA has examined the question of the ability of the 

activated carbon manufacturers to produce the additional 

amounts of automotive type carbon required for onboard controls 

and the amount of leadtime needed to supply the market. Our 

preliminary conclusion is that this additional amount can be 

supplied from current excess capacity, since it appears to 

represent approximately, a 20-25 percent increase in overall 

demand. In an October 30, 1987 letter to EPA, Congressman John 

Dingell requested that EPA contact the activated carbon 

manufacturers and solicit their comments on this issue. Please 

refer to the following in the enclosed information: 

Question 87 of Congressman Dingell's October 30, 

1987 letter 
P.3 

\ 

MAR 2 7 jOnsoooooo:^ 
P.4 

t 

*•• 

Item #4 of. the Motor Vehicle Manufacturers 

Association September 22, 1987 response to 

Congressman Dingell 

EPA's '/preliminary conclusions concerning the 

activated carbon market stated in the response to 

Question #4 in the July 21, 1987 response to 

Congressman John Dingell 

Please send your written views and comments to Congressman 

Dingell of the U.S. House of Representatives Subcommittee on 

Oversight and Investigation of the Committee on Energy and 

Commerce. Please also send copies of your comments to the 

Administrators of the National Highway Traffic Safety 

Administration and the Federal Highway Administration and to 

myself at the addresses listed on the enclosed page. 

Please contact Jean Schwendeman of EPA at (313) 668-4432 

if you have any questions concerning this request. Your 

cooperation is greatly appreciated. 

Sincerely yours, 

tSt*^£<!* 

Charles L. Gray ,^-ar .'^Director 

Emission Control Technology Division 

Enclosures 
P.5 

J' 

Enclosure -

Honorable John D. Dingell 

Chairman 

U.S. House of Representatives 

Subcommittee on Oversight and Investigations 

of the Committee on Energy and Commerce 

Washington, D.C. 20515 

Honorable Diane K. Steed 

Administrator 

National Highway Traffic Safety Administration 

Department of Transportation 

400 Seventh Street S.W. 

Washington, D.C. 20590 

Honorable Ray A. Barnhart 

Administrator 

Federal Highway Administration 

Department of Transportation 

400 Seventh Street S.W. 

Washington, D.C. 20590 

Mr. Charles L. Gray, Jr., Director 

Emission Control Technology Division 

2565 Plymouth Road 

Ann Arbor, MI 48105 
P.6 

S.L. Torrence, 

•*::^';|^jMr. Robert. Edwards, Marketing Manger 

o,o^V-;^E[^inerican Norit Co. ,-

•^'zOO •',{"• Ifp.420 Agmac Avenue . " • 

.-^'boMlJacksonville, Florida 32205 Mr.. Edwards_Mr. 

^ "i^nSeneral Manager . . ' .. J 

Westvaco Chemical Division - Carbon Dept. 

Covington, Virginia ^4426 Mr. Torrence_Mr. Jack Georgal, 

i&$t)W[Anderson Development Corp. 

#¥^S 141 5 E* Michigan St.,: 

vS#:-:VP_Adr.ian, Mi 49221 Mr\, Georgal_Mr. William Vogelhuber 

£V^4N| Barneby-Cheney 

.-'*'*« 

:% 

• ^^ P.O. Box 2526 

Columbus, Ohio 43216 Mr. Vogelhuber_Mr. Lou Sorrento, Director 

•*v"i.. of Technical Operations 

J1CECA, Inc. 

•J P.O. Box 1250 ' ,-

V^Pryor, Oklahoma 74362 Mr. Sorrento_Mr. Pat Harrigan 

•Gulf Bio. Systems, Inc. 

5310 Harvest Hill Rd. 

JDallas, Texas 75230 Mr. Harrigan_Mr. Frank Schwartz. 

•^Hbrth American Carbon, Inc. 

432-T McCormick Blvd. 

_Columbus, Ohio 43213 Mr. Schwartz_Mr. Paul Valencik, President 

Transpacific Carbon Co. 

.431 Hatchery Road 

\Blue Lake, California 95525 Mr. Valencik_Mr. James Allen, Vice 

^President 

carb, Inc. 

Route #5, P.O. Box 275 

iDunnellan, Florida 32630 Mr. Allen_Mr. Itaru Nishimura, 

["Manager, Export Dept. 

IKuraray Chemical Co., LTD 

NO. 1-4-14, Shibata 

Kita-Ku, Osaka Japan Mr. Nishimura_Mr. Yoshimi Shibata, Senior 

J=Mahager 

Technology-Activated Carbon 

;Carbon Products Division 

Mitsubishi Chemical Industries, LTD 

5-2 Marunouchi 2 Chome 

Chiyoda-Ku, Tokyo Japan Mr. Shibata_Mr. Hal E. Moore, Manager, 

vHational Accounts { Calgon Carbon Corporation 

P.O. Box 717 

Pittsburgh, PA 15230-0717 Mr. Moore 

.•-^DO; : cuv;K^:;..^°^ u °$b¥y. 

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P.7 

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U.S. fuuc if TUjHumuHM. 

jManffitas oi Oocnl^t Ml faxitiptists 

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CHWatfft • 8B | B*1 CflODKRI 

tt-utakgtn, 9 C 20fif 

nana 

Octobtr 30, 1987 

Tha Honorabla Laa N. Thomaa 

Adainiatrator 

Bnvironaental Protection Agancy 

waterside nail — waat Towar 

401 it street, 9. w. 

Washington, D. C. 20460 

Tha Honorabla Diana K, Staad 

Adainiatrator 

National Highway Traffic Safety Administration 

Dapartaant of Transportation 

400 Savanth Straat, 3. W. 

Washington, D. c. 20590 

Tha Honorabla Kay A, larnhart 

Adainiatrator 

Pedaral Highway Adainiatration 

Dapartaant of Tranaportation 

400 Savanth Straat S.W. 

Washington, D, C. 20590 

Oaar Haaara. Thoaaa and Barnhart and na. Steedi 

Sncloaad for your information ia a copy of tha urfaditad 

portion of tha tranacript of our subcomaittaa'a Ootobar 2, 1987 

haaring concarning tha Subeoaaitteo's continuing invaatigation of 

non-attainment iaauaa, including refueling/volatility iaauaa 

(pagaa 140-173). Tha tranacript (p. 147-148) includaa ay 

inquiriea about a propoaad manorandua of undtrstanding draftad by 

tha Environmantal Protaetion Agancy (EPA) and tha National 

Highway Traffic Safety Adainiatration (NHTSA). EPA and NHTSA 

proaiaad to provide) tha draft (aa wall as tha final product) and 

thj^coaaaJ^s. HBia-Har, alaoat a month haa paaaad and those 

focuaenta hava not be-an provided, x requaat thia w4thln,tiltnajct 

fl dlYI V"* ' »hP"fh Ah * memorandum may nov be,final. Reaaasar, "' 

contlnua to ba skeptical about tha adequacy and permanency of 

rae EPA and NHTSA jointly plan to publish it in 

tfn-rsrlarnl fts^-tatar? if not- why not. 

I obaarva that earlier thia month tha Board of Directors of 

tha National Safaty Council became che fourth highly regarded 

safety organization to cast serious safety doubts about onboard 

controls. Tha Council said: 
P.8 

'ft9a 2 

while tha National Council supjocti efforta to 

reduca-hydrocarbon lavali in tha atmosphere, aariout 

iafejty*tn4 haalth concerns hava baan ralaad concerning 

theMpropoaed rulemaking by tha if A on vapor recovery 

aytteas and ralatad issues. 

* • •'* • 

The Council takai no petition on any of tht 

nropottd tschnologies to tolvt tht pcoblta. Howe var, 

tha National Safaty Council oppotat tha adoption- of any 

propoaad rula unless and until tueh technologiat hava 

baan deaonstratad not to incraaaa risk of dtath, 

illnaaa or injury. 

Surely- ao aany safety agencies cannot ba wrong. (I might 

add that Z undarttand that tha Govt mo c of California recently 

vatoad onboard control legislation for that Stata on aafaty and 

othar groundi.) Only tht Csnter for Auto Safaty raaehad a 

somewhat diffarant conclusion last March citing soaa of tha saaa 

inforaation aa ia contained in tha IPA't final Tachnieal reportincluding tha uaa of eollapsibla bladdara. rot tha intaraat of 

EPA, I ancloia an October 20 latter froa NHTSA which dlacuaaaa 

tha Center's eoaaants. As to bladders, t believe our hearing 

shows that they ara not the readily available technology IIA 

expected. * 

Z baliava tha Council is right in stating opposition to tha 

proposed rula "until such technologies hava baan demonstrated not 

to increase risk of death, illness or injury." 

X observe that on October 27 the insurance Institute for 

Highway Safaty once again raised these safety eoncarna. Tha 

Institute said: 

Autoaobile crash deaths and injuries ara 

every bit aa important environmental health 

problems as air quality. With this in mind, IPA 

mustn't ignore tha hazards associated with 

on-board vapor recovery systems. Mandating thaa 

now would amount to siaply trading off one public 

health problem for another. 

In the absence of political constraints, an 

obvious and practical alternative exists to 

control refueling vapors. Capturing them at the 

gaaolina pump would Improve air quality without 

having to rig motor vehicles with more complicated 

fuel syttaaa. It would accomplish EPA's ai: 

quality objactives without risking additional 

motor vehicle deaths and injuries. The technology 

exists to control vapors at the pump — in fact, 

this is already being done in California and the 

District of Columbia, and It could be dene 

elsewhere, too. Political constraints and 

enforcement problems night delay nationwide 
P.9 

paga l 

programs on this kind of program- out such 

obataclea could surely ba solved faatar than tha 

10 to 20 years it will take until all vehicles on 

tha road ara equipped with on-board systama. 

Unfortunately, thii rulemaking saema to ba. aa 

much about political constraints aa about tha 

technical merit! of alternatives to improve air 

quality. Politics seem to ba driving tha agency 

toward on-board vapor recovery systems — not only 

an irresponsible poliey direction but alao an 

inhumane one because it would mean mora paopla 

burning in motor vehicle fires. 

1. EPA's rinal Technical report of laat June ia referenced in 

the proposed rulemaking of August 19, 19-07 and relied upon by IPA 

in the preparation of the proposed rule. Mr. Thomas, at paga 149 

of tha transcript, you state that EPA has "completed a aafety 

analysis" and that CPA's engineers have "designed alternative 

eyatema to incorporate onboard" controla in vehicles. But, as 

you testified, the unidentified systems have not been "road 

teated." You then stats: 

MR. THOMAS, x believe the certification procossea * 

that are required by NHTSA aa well as our agancy would 

require those kinds of teets. 

I am uncertain what you mean by this statement. Pleaaa 

explain. 

Also, I rsquest that EPA identify each of the alternative 

systama (other than the collapsible bladder) referenced in the 

testimony, that were relied upon by EPA in the final technical 

report and explain the status of each alternative, including the 

testing conducted prior to last Juns. 

2. (a) I request, considering IPA's claims of improved safety 

In the June Report, that SPA project how many lives are 

anticipated to be saved from such onboard controls, exclusive of 

the volatility rule, if EPA is unable to do so, please explain 

why and also explain the basis fior SPA'S claim of improved 

safety. 

(b) . I understand that EPA has asked the motor vehicle 

Industry and others to quantify the safety risk from onboard 

controls. X note that the insurance Institute discussed this 

issue beginning at page 2 of its October 27 statsment. I requeet 

NHTSA's and EPA's coan«n:s on the problems of such quantification 

and whether such quantification Is necessary. 

3. In tha hearing, E?A sa;d: 

MS. DINGELL. Can you make a flat statement as to 

how they would wor< in a finished system which 
P.10 

paga 4 

would,fee aarkatad and which would b*e run through 

tha .freduction syataa? 

«t* fSOMAS. No, but x feel we hava got to coma to 

that conclusion before wa hava a final rula. I 

alio ftal that both under our certification 

requirements and Nt. Steed's, thota conclutiont 

have to bt drawn by tht auto makers before tht 

vehicles can bt told. 

X aa aoaawhat comforted by the statement' that EPA mutt hava an 

appreciation how onboard controls will work "before" there ia a 

"final rule." But X am puszled by the laat aantanea of Hr. 

Thomas' reply becauaa X understand that under the NHTSA 

administered law, tha certification proeess ia not type 

certification, but self certification, is SPA suggesting (and 

does NHTSA agree) that this self certification proceaa would be 

an acceptable way to find out if onboard controla parfora 

properly and aafaly once the vehiclea ara aold in commerce? 

Plaaaa explain. 

4. in the hearing, EPA said the agancy looked at models of . 

onboard systama designed by EPA engineers and concluded that they 

ara a "relatively simple upgrade of the existing evaporative * 

control system with an enlarged canieter." The American 

Petroleua inatitute (API), in the enclosed statement, made a 

similar comment. API claims "considerable expartiee" on behalf 

of member flrma in designing onboard systems and states that API 

"haa tested these in a number of vehiclea over the laat several 

yeara." NHTSA taatified about the safety of two of those systems 

on October 2. The enclosed document from the Motor Vehicle 

Manufacturara Association appears to take issue with SPA and APX. 

Does NHSTA agree with EPA's and API's commenta? If not, why not? 

saaad on NHTSA's recall experience, are these evaporative syatama 

"fail-safe"? what safaty recalls have been made regarding theae 

systems? Please take into account API's three points on pagea 

17-18 of Its statement, as well as NHTSA's comments on pages 

164-167 of the enclosed transcript. 

5. SPA said (p. 149) that onboard systems "have been road 

tested."- Please identify those systems and explain when EPA saw 

them tested. Plaaaa describe the tests, Including who conducted 

them, under what conditione they were run, on what kinda of 

vehiclea thay wart conducted, and what results were obtained. If. 

a report of the road tests was prepared, please provide a copy. 

If a report waa not prepared, please explain where EPA obtained 

tha information about the tests. 

6. I gather from the testimony and our correspondence that the 

final EPA technical report did not reflect much, if any, of the 

issues and concerns expressed by NHTSA in its June 11 letter to 

SPA. X request that NHTSA review the Final Report and identify 

all portions thereof where NHTSA still has concerns or disagrees 

in whole or in part and explain :r.e oasis for. the concerns and 
P.11 

Page 5 

disagreement, x aa particularly interested in sections iv 

through YWVo S tht report. ~ 

7. V X request that EPA, fHA, and NHTSA indicate to what extent 

they ware- or were net aware of tht information provided by MVMA 

in tht eneloeed letter whan tht SPA'a Final Technical Report waa 

issued. X particularly call to EPA's attention "Xtaar--*--

Charcoal and Canister iaauaa" and request that SPA provide tht 

MVMA information (together with thia latter and EPA's tarliar 

correspondence with tha Subcommittee on carbon) to each of tht 

carbon makers and obtain their written views and coaaenta for 

SPA, NHTSA, and the Subcoaaittee. Please note that MVMA states i 

A conaiderable portion of the total carbon 

capacity la currently devoted to production of carbon 

producta that are unsuitable for uaa in evaporative 

emission or refueling eontrol applicationa. Thus, it 

is somewhat optimistic at thia point to assume that 

sufficient carbon, of appropriate quality, cam bt aada 

available. 

The carbon makers should discuss this availability iaaut in taraa 

of tha proposed rule as it appliee to all vehiclea of all alset 

beginning 24 months after the rule is Hopted, not on the baela 

of any potential extension of the leadtime. 

8. During the hearing, we discussed the possibility that liquid 

fuel might reach the canister in soae way. SPA waa not aware 

that this situation would cauae any problems; however, na. Steed 

indicated that it waa her understanding that liquid fuel—if it 

reached the caniater somehow—could render the charcoal 

ineffective. Could you pleaae comment on this iaaut. Pltaaa 

adviae whether liquid fuel would damage the canister's ability te 

purge the vapors, if the liquid fuel were to reach the caniater. 

If ao, la that damage peraanent? would that affect the air 

quality benefits? How likely ia it that liquid fuel could reach 

the canister? 

9. At my request, EPA's Ann Arbor office provided an October 

20, 1987 memorandum of an SPA meeting on September 16 with ford 

Motor Company representatives and others to discuaa rord's 

"design and testing efforts for both canister based and bladder 

tank onboard refueling control systems." The EPA memorandua 

sasaa to bt critical of rord for having what EPA describes aa a 

"relatively stall project underway to assess designs for onboard 

vapor recovery syatama." 

X assuae that it is not EPA's view that each automaker 

should devote substantial time, effort, engineering talent, and 

money to refueling ideas that have been perculating at EPA since 

the 1970s and never reached a proposed rulemaking stage until 

1987, particularly in light of the serious safety hazards 

expected from these EPA regulatory ideas. If my assumption is 

incorrect, please explain why. if it is correct, then what is 

the basis for the EPA criticism? 
P.12 

page 6 

The EPA.memorandum also statesi ~ 

•

rXn tht course of tht discussions Ford stated that 

thtif dttlgn options were somewhat limited because of 

the perceived constraint that onboard systems could ba 

required aa icon aa 2 years after tha final rule-ta 

signed. In response, IPA reiterated ita position on 

leadtime aa stated in the preamble to the NPSH, and 

encouraged ford to provide comment! on the relationship 

between leadtime and the choicea in.system design. 

X aa again troubled by the suggestion ln the BPA comment. 

The proposed rule unquestionably calls for a 24-month leadtime. 

It ia not a "pereelved constraint." Xt is quite real. EPA's 

proposed rule constantly defends that leadtime ae being 

"sufficient" while somswhat grudgingly stating that "soma 

uncertainty exiata (especially related to safety)" about thia 

leadtime. 

foreign and domestic vehicle manufacturers cannot plan in.a 

vacuum or respond to a proposed rule by betting that SPA will 

expand tha leadtime. Even if the expanalon takea place, no 

responsible member of the public can predict what that expansion 

will be or whether it will be adequate. Xn short, SPA after 

struggling over this matter for years and falling to adequately 

address the safety issue, apparently wants Ford and othera to do 

their job. I think that is improper on the part of EPA. 

The EPA rule encourages commenters "to provide specific 

suggestions for changes to any aspect of the proposal that thay 

believe need to be modified or improved." One such change ia 

complete abandonment of the proposed rule becauae, aa proposed, 

it faila to even come close to meeting the requirements of 

section 202(a)(6) of the Clean Air Act. That lav specifies that 

a rule "shall not becoae effective until the introduction to the 

model year for which it would be feasible to Implement such 

standards, taking into consideration compliance costs and the 

restraints of an adequate leadtime for design and production." 

• _ * __.._- . - . — J _ . ..-..b .-•-.- a l - . y _.. - - . ... -< J A... 1 U1 „ _- . te 

t. , w.-. i>uukif i i. tww^iu. t V.1KH, wit» Lilian, u. l v.*-***. |«WII.U. I u>>«-a>. 

this test, but at the moment, the automakers and tho public can 

only react to what Is presented by ERA. They cannot reasonably 

respond on the baaia of speculation or the unknown. They respond 

to the rule aa proposed. I request the views of NHTSA, FHA, and 

EPA on thia aatter. 

10. If the leadtime is extended to 48 months or more, what ia 

the impact on the benefits of the rule and cn costs? 

11. Enclosed It a copy of the former Secretary of 

Transportation's letter of August 17 to the Subcommittee 

concerning the rulemaking. I call attention to the Secretary's 

reply to my question 2 and admit some confusion about the role 

of, and extent of input into, the rule by the Federal Highway 
P.13 

NOV.09 '87 08:49 EPA p_g 

Page 7 

Administration under section 202(a)(6) of the clean1Air Act 

insofar a* heavy duty vehicles ara concerned. To this date, X 

have ttdriittlt evidence of concern or input by the FHA into 

thetts important safety mattera. what are the viewa and coneerna 

of tht F1A7 Hov is FHA preparing to address them?. 

12. in the eaea of recreational vehiclea, the Secretary sayst 

Recreational vehicles of 10,000 lba. OVWR or 

lesa must aeet the requirement of FMVSS 301. 

Recreational vehicles over 10,000 lbs. OVWR are 

not currently addressed by FMVSS 301. The safety 

of the fuel aystems of the heavier recreational 

vehielea ia currently addressed through tha defect 

provisions of the National Traffic and Motor 

Vehicle Safaty Act of 1966, and through tha 

produet liability responsibilities of the 

recreational vehicle manufacturers. The 

installation of onboard controls on these vehielea 

would preeent safety problems similar to thoae 

encountered in other vehicle categories, including 

the riaks of non-crash fires which are not 

addraaaed by FMVS S 301. 

Which eafaty ageney hae the responsibility for thaae vehiclea? 

Haa EPA discussed the safety and othor impacta of onboard 

controls for these vehicles with the manufacturera of thaae 

vehiclea and the appropriate safety agency? if yea, when and 

what waa the reault? If no, please explain why not. Please 

identify the manufacturers, is 24 months adequate leadtime for 

theae vehiclea from a safety and any other standpoint? 

in reply to question 2(d), the FHA agrees with the MVMA but 

then adda that it lacks the "expertise" on these matters. Again, 

how are these safety issues to be addressed at the Department of 

Transportation and the EPA? 

13. While I again stress my longheld view that a nationwide 

Stage II control program is not needed and I do not urge It ln 

any State, I encloee a recent report by the South Coast Air 

Quality Management District for SPA's review and comment. The 

document statesi 

While 11,000 sources are a burden to inspect, 

that number is mors manageable than the 

10,000,OOO* vehicular sources we would have In the 

South Coaat basin. On the other hand, If onboard 

controla were In place In lieu of Stage II, It 

wouldn't be the District's obligation to inspect 

those vehicular sources, so it would free up 

manpower to be used in other areas. The point to 

be made, however, is that by District inspection 

and enforcement, we have control over the 

compliance rate and effectiveness of the controls. 
P.14 

Page 8 

If the contrail are in vehiclea which may ba 

either not inspected, or poorly inspected, we have 

no asaurance that the controls will be in place 

and operating properly. 

With Stage XX controls, maximum eaission _* 

reductions take effect immediately upon 

•installation of the equipment. There is no 

waiting for vehicle fleet turnover to accomplish 

the full reduction, which eould take ten yeara or 

more. 

Maintenance of stage II equipment ia 

relatively eaay, albeit frequent. 

Xf onboard controla are aa effective, it 

would make aanse to move away from Stage II once 

onboard is fully implemented. We have coneerna 

that onboard is no panacea, but lt would eaae our 

job and enable us to divert resources into ether 

areas. 

Regardless of any determinations with retptct 

to onboard controls, our Stage IX. systems will 

likely be retained for at least 10 yeara after 

onboard controls begin appearing in the vehicle 

fleet. While it is manpower intensive and createe 

substantial conflicts with service station 

dealera, it works, it provides an effective means 

of controlling VOC emissions during gasoline 

refueling operationa. Tha equipment is readily ' 

inspected, maintenance is relatively eaay, and 

compliance can be directly effected by District 

actions. Onboard controls may have none of these 

advantages, and whatever advantages it does have, 

it will certainly take some time before full 

control of gasoline vapors emitted during 

refueling operations can be accomplished by 

onboard systems, for that reason alons, I would 

expect that the Stage XI vapor recovery program In 

California will be with us for many years to come. 

I request EPA's comments in light of its statements in the 

preamble relative to the advantages of onboard controls. 

14. I understand that some are concerned about safety at service 

stations relative to the no22le, etc., and onboard controls. I 

understand that at least ore member of the public raised this 

issue. Is refueling safety covered in Occupational Safety and 

Health Regulations and/or State flammable Liquid Codes? Is the 

National fire Protection Association (NFPA) Code 30A applicable 

in many States? Has SPA or NHTSA sought NFVA'S technical 
P.15 

i-iOv 09 'o7. 00-50 £r.rt 

P. 13 

Page f*-. 

•^0&W±n&ff&*±+.- -•... • ••- . .. • • 

---"committee advice? XS not, when will theae agencies do so? what 

r: about the. Underwriters Laboratories? Haa EPA or NHTSA sought 

<*<•*•*•. « informat ' ^ and* comments froa OSHA? if not, whan will these 

agenoiet 

15. API'S! testimony of October 28 (page S - 14) haa raised a 

number objections or concerns relative to fuel volatility, 

including suggeatlona of independent firms being "forced out of 

business," the need for increased gaaolina production, longer 

leadtime requlreaanta for transition, seaaonability enforcement, 

and distribution problems, and cost and balance of trade impaets. 

Theae are important concerns, as is the question of blende of 

alcohol and volatility, eafety, and the ultimate certification 

fuel level should the final rule adopt a higher RVP number. X 

request SPA'a and NHTSA's comments on these mattera. 

X request your reply to the above mattera within 45 daya 

after receipt of thia letter. Please provide a copy thereof to 

the OAO, the Insurance institute for Highway Safety, and the 

National Tranaportation Safety Board for their conaideration and 

comment to the Subcommittee. 

X assume that this letter (and the encloeures) and the • 

reply, aa well as our earlier correepondence, will also be added 

to the EPA docket established some time ago. 

X underatand that some witnesses have 

time beyond January 11 to provide written c 

fact that three major holidays oceur betwee 

(Including two when the motor vehicle Indus 

shut down for an extended period), I presum 

a reasonable extenaion of another 30 days a 

this is not an unusual request in the cass 

rulemakings. After 13 years, another few 

Please adviae me within 20 days about this 

with best wishes. 

sought an extension of 

ommenta. Qiven the 

n now and January 11 

cry ia traditionally 

e that SPA will grant 

t loaat. X note that 

of other EPA 

months ia not much, 

requeet* 

JOHN D. DINGELL 

Chairman 

Subcommittee on 

Oversight and investigations 

Enclosures 

cc: The Honorable Thomas J. Bliley, Jr., Ranking Minority Member 

Subcommittee on Oversight and investigations 
P.16 

». . ' MOTOR VEHICLE MANUFACTURERS ASSOCIATION 

of ihe United States. Inc. 

300 .NEW CENTER etl'-OlNC • DETROIT. .MICH!CA.N 48202 • Afl£A 3 13-8:2-4311 

7LX.NO. 1OO97T0 ALT0MAK2RS SET 

DONALD E. PETERSEN. CA«inn.M- . , --,., , 

THOMAS H. HANNA. Prmdtnt ini Chi4f Extrw OtTictr S e p t e.r.0 e r .-. Z , -33 7 

The Honorable John D. Dingell., Chairman 

Subcommittee on Oversight and Investigations 

Committee on Energy and Commerce 

United States House of Representatives 

Washington, D.C. 2C515 

Dear Mr. Dingell: 

The Motor Vehicle Manufacturers Association of the United 

States, Inc. (MVMA), whcse m.iibsr companies produce 98 percent of 

all domestic vehicles, responds herewith to your letter of 

July 29, 1987 which requested comments concerning issues relative 

to the Environmental Protection Agency's (EPA) efforts to control 

refueling vapors and gasoline volatility, for clarification 

purposes, MVMA's responses are preceded by the respective 

questions posed in your letter. 

Because of the vital importance to MVMA of the issues 

discussed in your letter, we appreciate the opportunity to 

continue participating in the national dialogue on these 

subjects. If you or your staff have any questions on the 

enclosed comments, please feel free to ::-lcact me. 

very truly yours, 

IX Thomas H. Hanna 

Enclosure 

cc: The Honorable Thomas J. 31iley, Jr., ?.ar.kmg Minority Member 

Subcommittee on Oversight and Investigations 

The Honorable Lee M. Thomas, Administrator 

Environmental Protection Agency 

The Honorable riane X. Steed, Administrator 

National Highway Traffic Safety Administration 

Department of Transportation 

The Honorable James C. Miller III, Tirsrtor 

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Item 4-Charcoal and Canister Issues 

Question 

"In commenting on these matters, please address EPA's resoonse to 

our questions 4(a), (b), (c), and (d) in our May 8 letter" 

regarding charcoal and canisters." 

MVMA Response 

In responding to this question we believe EPA underestimated the 

fuel tank capacities for most of the classes. Setting aside the 

methodology EPA used to back into its estimates of future 

light-duty vehicle fuel tank capacities, which appears to 

underestimate tank size, and focusing on heavy-duty trucks, we 

believe EPA has seriously underestimated fuel tank sizes for this 

class of vehicle. In addition, the EPA estimate that 85% of 

class vi trucks operate on a single tank is totally 

inappropriate. It is our understanding .'-.at the estimates of 

dual tank usage for heavy-duty trucks were extrapolations from 

the entire light-duty truck database, rather than from the subset 

(i.e., class Ila) that most closely represents heavy-duty 

vehicles. The percent of class Ila vehicles using dual tanks is 

approximately 75% and we would approximate the class lib and vi 

usage to be at least as high, if not higher. In addition, we 

cannot support the EPA estimates for fuei tank sizes for these 

heavy-duty vehicles. Currently, the minimum fuel tank size for 

heavy-duty vehicles is 35 gallons with the majority of trucks 

being sold with 50 gallon or larger tanks. 

13 
P.18 

As for dual tank heavy-duty vehicles, the minimum tank capacity 

is approximately 70 gallons and the maximum is LOO gallons. We 

see no indication that fuel tank capacities will be reduced down 

to the estimates used by EPA. 

In addition to the undersizing of fuel tanks, we believe EPA also 

failed to properly consider the implications on canister size of 

the proposed saturation to "at least breakthrough" test procedure 

and canister design efficiency considerations. The sum total of 

these impacts is that E?A has underestimated the demand for 

activated carbon by at least fifty percent. 

It should also be pointed out that all forms of activated carbon 

do not have the same characteristics. The efficiency of carbon 

varies greatly and with it the canister .ize needed to control a 

given amount of vapor. It is therefore .rucial to determine the 

suitability of the current idle capacity for producing automotive 

quality activated carbon. A considerable portion of the total 

carbon capacity is currently devoted to production of carbon 

products that are unsuitable for use in evaporative emission or 

refueling control applications. Thus, it is somewhat optimistic 

at this point to assume that sufficient :a:'::n, of appropriate 

quality, can be made available. 
P.19 

As indicated above, EPA has underestimated the impact on the 

carbon industry, perhaps by as much as fifty percent, in 

addition, EPA assumes that automotive quality carbon is a 

fungible .commodity and that any form of activated carbon will 

suffice. The different uses of activated carbon make much of the 

carbon produced today unsuitable for automotive applications. 

MVMA also believes that E?A is overly optimistic in its estimate 

of economic impact. Throughout the analysis, EPA assumes that 

manufacturers will elect to use high efficiency carbon. The E?A 

estimates of the amount cf carbon required per vehicle assume the 

use of this high quality carbon. Yet EPA also assumes that 

vendors would be willing to sell high quality carbon for the same 

price as their low quality carbon., MVM A celieves that because of 

this and other assumptions regarding careen prices, EPA has 

» 

underestimated the cost of carbon by fifty to one-hundred 

percent. 

By the same token, EPA assumes that ail :f the vapors captured by 

the carbon can be used wi^h the same efficiency as gasoline 

metered through the fuel injection system. This assumption is 

naive at best and unsupported by the record. If the assumption 

were true, then it would be unnecessary for manufacturers to 

install costly cor'.-'..-.; ect ion fuei systems in :rder tc meet 

present fuei economy and emissicn lavs. .-.receding tc this 

theory, any system cf dumping fuel :..:: •.ne engine v.ll crcduce 
P.20 

acceptable results. Clearly, this is not the case. The 

unmetered refueling vapors can be consumed at best with an 

efficiency, of only fifty percent. .Thus, MVMA does not believe 

that EPA has properly accounted for the net energy consumption 

associated with this rule. 
P.21 

/ * " \ 

153E * UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

•<? _ vVASHl*'G~ON 3 Z Z'z-y. 

': «c \.-

THE ADMINISTRATOR 

Honorable John 0. Dingell 

Chairman, Subcommittee on 

Oversight and Investigations 

Committee on Energy and"commerceHouse of~Representatives 

Washington, D.C. 20515 

Dear Mr. Chairman: 

I am writing in response to your letter of May 8, 1987.' 

In your letter, you ceauested that we respond to a number of 

Questions relating to the gas marketing issue. A response 

to those Questions is enclosed. You also asked us to clarify 

our position for the League of Women Voters on sanctions. 

A copy of our sanctions fact sheet which was sent to that 

organization is also enclosed. 

I also wish to take this opportunity to thank you for 

your May 15, 1987 letter. In that letter, you raised the 

issue of the safety of onboard vehicle controls. As I 

stated at the April 27 hearing, EP<\ is giving this issue a 

thorough examination, and we have formally sought the comment 

of the'National Highway Transportation Administration. We 

will be sending-you additional information on the issue 

in our forthcoming response to your letters of June 23 and 

June 29. 

Thank you for your continued interest in these matters. 

Sincerely , 

Lee M* Thomas 

Lee M. Thomas 

Enclosures 

cc: Charles A. 3owsher 

Comptroller General 

General Account ine: office 
P.22 

Tl 

Question 4(a) 

Please identify all of the charcoal suppliers and canister, makers 

for the domestic industry. When and how did these suppliers provide tnis 

response to EPA? Please prc-v-.de the correspondence. If oral, please set 

forth the questions asked. 

Response to Question 4(a) 

The major domestic urDducers of activated cartoon are Calgon, Westvaco, 

ICI (Norit), Atocnem, HUSKY, and Barr-ebey-Cheney. Nortn American Carbon 

is not a producer, but ratr.c.- 3 supplier of in-ported activated carbon. 

To date, we have not requested written responses from these manufacturers 

on the questions you have raised. Specific estimates of such things as 

operating capacity and energy costs are often proprietary because they 

directly relate to competitive marketing issues. 

You also asked about the producers of canisters for the domestic 

industry. Ford and Chrysler make their own canisters. Rochester Products, 

a subsidiary of GM, makes GM canisters. Evart, a subsidiary of AMC, 

makes AMC canisters. Canisters for foreign cars produced in the U.S. are 

generally made by tne parent c.mpany and imported to the U.S. 
P.23 

Questions 4(b) and 4(c) 

Did the abcwe reply cover all vehicles subject to the proposed rale? 

If not, why not? What is the current size of canisters tor passenger 

vehicles, light duty trucks, and heavy duty vehicles? Also please provide 

the amount of charcoal required. What will be the new canister size and 

charcoal requirement for each such vehicle? 

Response to Questions 4(b) and 4(c) 

Of the current domestic activated carbon suppliers, Calgon and 

westvaco account for an estimated 85 percent of the carbon market for 

domestically produced autancoiles, which is approximately 10-12 million 

pounds per year. This is about five percent of the 200 million pounds 

per year of domestic production of granulated and powdered carbon. The 

amounts of carbon typically used to control evaporative emissions and the 

additional amounts that EPA believes will be needed to control refueling 

emissions for light-duty vehicles, light-duty trucks and heavy-duty 

vehicles are shown in the attached table. (The extemal dimensions of the 

canisters would be about 10 percent greater than the required charcoal 

volunes.) We estimate the total additional amount of carbon required for 

onboard refueling controls for all gasoline-fueled vehicles (light-duty 

vehicles, light-duty trucks, heavy-duty trucks) to be between 23 million 

pounds per year, assuning 9.0 RVP in-use fuel and 30 million pounds per 

year, assuming 11.5 RVP in-use fuei. This amounts to about 10-15 percent 

of current production. Botn in the past and in recent conversations, 

major manufacturers have indicated it would take at most 18 months to two 

years leadtime to increase capacity by this amount. A representative of 

one manufacturer stated that his ccmpany could meet a 30 million pound 

per year requirement with their current idle capacity. He cited a Stanford 

Research Institute study of the carbon industry which indicates that the 

current"domestic market is only at 2/3 of full utilization. Based on 

these comments, EPA believes that activated carbon manufacturers will be 

easily able to meet the increased carbon requirement for all vehicles. 
P.24 

I' 

Question 4(d) 

Your agency's reply regarding the energy use is net responsive. 

American Carbon made specific estimates of the "Btu" needs. I reguest 

that you consult with the Department of Energy (DOE) and the charcoal 

suppliers about the firms's contentions and indicate where you and DOE 

agree or disagree. 

Response to Question 4(a) 

As for the specific energy requirements for producing activated 

carbon, it is difficult to evaluate North American Carbon's estimate of 

the amount of energy used in manufacturing activated carbon since most 

manufacturers consider information regarding their manufacturing processes 

and energy needs to be proprietary. In any case, the energy cost to the 

manufacturer is completely reccvered in the cost of the product. Therefore, 

the impact of this energy use is fully accounted for in our analyses. It 

should also be noted tnat, compared to the energy content of the recovered 

refueling vapors (which are, of course, currently being lost), the 

energy involved in charcoal production is extremely .small. Furthermore, 

the cost of activated carbon is typically only about one dollar per 

pound-, and even with the additional amount required for onboard controls, 

automotive-type carbon accounts for only a small fraction of the total 

activated carbon market. Thus, it does not seem likely that additional 

production of activate carbon cor automotive purposes could be a measurable 

drain to the economy or to the nation's energy reserves. 

Pursuant to your request that we consult with the Department of 

Energy (DOE) on this matter, I have sent a copy of this response to the 

Department of Energy. 
• ^ 

Light-Duty 

Vehicle s 

TABLE REFERENCED IN RESPONSE TO 4(b) and 4(c ) 

Estiiiated Amounts of Activated Cirbon 

Needed t o Control Evaporative and Re fuol ing Quis-iLois 

Light-Duty 

Truck 

(single tank) 

Light-Duty 

Truck 

(dua l tank)^ 

Heavy-Duty 

Truck li b 

(singl e tank ) 

lleavy-Duty 

Truck ID> 

(dual tank) 

Heavy-Duty ll3.v/y-[XityTruck VI. Truck VI 

(singl e tank) (dual, tank) 

Average Fuel 

Tank Size : 12.2 gal. 16.3 gal. 32.6 gal. 20 gal. 40 gal. IO gal. 90 gal. 

Typical Amount 

of Carl-on Presently 

used in Int--*-jrated 

Evaporative 

Canisters: 850 ml 850 ml. 1500 ml 1400 ml 2@ 1400 ml 1400 ml 2(3 1400 ml 

Additional Amount 

of Carbon Needed 

to Control Refueling 

Emissions with: 

11.5 RVP fuel: 

9.0 RVP fuel: 

2440 ml 

2020 ml 

3260 ml 

2700 ml 

6520 ml 

5400 ini 

4000 ml 

3310 ml 

aooo ml 

6630 ml 

5990 ml 

4970 ml 

15900 ml 

1J250 ml