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OAR Box 1830 

Prepped by Ollie Stewart 

Document Number: 

169) IV-C-136 

Docket Number: 

A-87-11 

Printed 11/13/2008 7:21:00 AM Sheet 169 of 232 
J. 

/ A \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

t ^W£ ? ANN ARBOR. MICHIGAN 48105 

\ / 

R_. 

B-87-/ ( ! 

OCT 211988 

OFFICE OF 

AIR AND .RADIATION 

Mr. Kelly Brown, Executive Engineer 

Noise, Emissions, Fuel Economy Planning 

Ford Motor Company 

The American Road 

Dearborn, MI 48121 

Dear Mr. Brown: 

This letter is intended to summarize the results of our 

meeting earlier today. At that meeting we described for you 

the results of our recent efforts to apply our simplified 

onboard refuleing control concepts to a Ford Taurus fuel tank. 

We had undertaken this task in an attempt to resolve issues 

which you had raised in an earlier presentation to us and 

others documenting Ford's inability to successfully apply this 

approach to either a Ford Taurus or a F-250 light-duty truck. 

In your presentation, to EPA of .September 26, 1988, there 

were three key issues which emerged. As experienced on your 

system, these were poor fill quality (i.e., frequent premature 

shutoffs and fuel spitback), the inability to obtain a liquid 

seal over a wide range of fill conditions and the failure of 

your test valve to function properly during a rollover test. 

Our work since that time, as presented to you today, Has fully 

resolved all of those issues. 

The first two issues concern the basic applicability of 

the simplified refueling concept to Ford vehicles. Beginning 

less than two weeks ago, our staff has adapted the same 

hardware used for the General Motors demonstration tank to a 

Ford Taurus system. In our presentation we described our 

development program and gave you copies of the test data we 

have generated. We included detailed descriptions of the 

several hardware variations which we evaluated and our 

conclusion that the basic system as used on the General Motors 

tank also demonstrated fully successful performance on the 

Taurus tank. Our hardware has no spitback or premature shutoff 

problems, and develops a liquid seal over the full range of 

fill conditions specified in our draft test procedures. 

Overall emissions are near zero for most tests. We also showed 

you our hardware and offered to allow you to perform a 

refueling test yourselves (which you declined to do, indicating 

that you did not doubt its performance). . .• ..'^o^0 

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In our discussions you were unable to explain why Ford has 

had such difficulty building a properly performing system on 

either of your two vehicles. You were also unable to supply us 

with engineering data on your system, such as the pressure drop 

traces we showed you for our tank, canister and fillpipe 

sensors. This makes it impossible for us to fully diagnose 

your difficulties. However, as we offered at our meeting, if 

you provide your system for us to evaluate, we would be willing 

to diagnose it for you. 

The results of our testing show clearly that the simple 

refueling control concept is readily adaptable to your 

vehicles. It has taken us less than two weeks to develop a 

fully functioning system, which you have personally seen. At 

our meeting, you identified no problem areas or issues which in 

any way indicate that the same could not be done for the 

vehicle which you have developed. In addition, in your 

development process Ford overlooked some key concerns, which we 

raised in our September 29, 1988 letter to Mr. Buist. You 

indicated today that these have still not been addressed. It 

is, therefore, no longer appropriate for Ford to make 

representations that this concept has difficulties when used on 

Ford products. With the information which Ford now has 

available, it would be a gross misrepresentation to so contend. 

The last issue concerns the proper functioning of the 

vapor control valve during rollover. In your September 26 

presentation you showed a video tape of a rollover test on a 

hand modified valve. This test showed that the valve did not 

seal properly and leaked substantially during rollover 

testing. At that meeting we indicated to you our belief that 

your test was highly misleading, since the valve had not been 

designed for rollover function, and we had clear assurances 

from the valve supplier that this function is a relatively easy 

task for a production design valve. 

Since your presentation we have met again with your valve 

supplier and been assured that the relatively modest increase 

in orfice size used for our valves compared to your production 

valve does not present any significant sealing problems. They 

have also informed us that the valve which you tested had a 

defective seal, and that Ford has declined the opportunity to 

test a replacement. The valve had been leak checked by the 

vendor using a standard Ford test, but we do not believe that 

such a test adequately evaluates the valve performance. 

Rollover tests performed to qualify the EPA prototype valves 

have been designed to exercise the full valve closure mechanism 

in a fashion which is probably more rigorous than a FMVSS 301 

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"test. We have also.had the valve supplier repeat the rollover 

testing which they performed on the prototype valves they 

produced for EPA. We personally witnessed the tests and can 

once again state that the two valves produced for EPA, which 

are themselves only first attempts at full rollover protection, 

easily met the same specifications as your stock valve. 

Thus, once again, we do not believe the facts justify 

continuation of Ford's current position on rollover 

protection. Based upon present knowledge, the presentation in 

your video tape is highly misleading and we believe that it 

would be unconscionable for Ford to continue its use. I 

therefore hope that you will make no further use of that 

presentation. 

In summary, our work in the period since your September 

26, 1988 presentation has resolved the issues which you raised 

about the workability and safety of our simple system concept. 

If you desire any further information, or wish to discuss these 

matters further, please feel free to contact me again. 

Sincerely yours, 

••"""" yf/r J 

Charles L. Gray, Jr. 

Director ' 

Emission Control Technology Division 

c c . Don Buist 

Dick Wilson 

Docket A-87-11 

6499W