P.1 

OAR Box 1830 

Prepped by Ollie Stewart 

Document Number: 

17) IV-B-13 

Docket Number: 

A-87-11 

Printed 11/13/2008 7:20:51 AM Sheet 17 of 232 
P.2 

NOV 2 2 !988 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

ANN ARBOR. MICHIGAN 48105 

M-Q-13 

OFFICE OF 

AIR AND RADIATION 

MEMORANDUM 

SUBJECT: 

FROM: 

Results of Rollover Tests on EPA "Simple System' 

Onboard Vapor Vent/Rollover Valve 

Jean Schwendeman, Mechanical Engineer 

Standards Development and Support Branch 

^<U^>ik, 

TO: 

THRU: 

Public Dockets A-87-11 and A-85-21 

John F. Anderson, Senior Project Manager 

Standards Development and Support Branch 

Chester J. France, Chief Sv~>~-

Standards Development and Support Branch 

Prototype valves were built for EPA by GT Products of Ann 

Arbor, MI. GT Products manufactures current production valves 

for various automobile companies including Ford Motor Company. 

These valves must be able to pass the FMVSS 301 rollover 

leakage test found in the Federal Register (Vol. 40, No. 200) 

and specific manufacturer specifications related to this test. 
P.3 

The FMVSS rollover test is performed on an entire vehicle after 

it has been through the crash portion of the test (Attachment 

1). The test requires that the tank be filled from 90 to 95 

percent of capacity with Stoddard solvent. The vehicle is 

rotated from 0° to 270° at a rate of 1 to 3 minutes for each 

90° of rotation with a 5 minute hold at each 90° increment. 

The requirements state that leakage from the entire vehicle 

shall be less than 5 ounces by weight of stoddard solvent 

during the first 5 minutes of testing at each 90° increment and 

less than one ounce per minute during the remaining time at 

that increment. This one ounce per minute average requirement 

is equal to approximately 20 cubic centimeters (cc) of solvent 

from the entire vehicle. Since the rollover valve is only one 

of the components which could contribute to overall leakage, 

Ford sets its own specification for this part at 4 cc per 

minute. 

GT Products tests the valves they produce for Ford by 

mounting them on a small cylindrical container and rotating the 

container rather than a fuel tank or an entire vehicle. The 

container holds approximately one gallon of stoddard solvent 

which is pressurized to 10 inches of water in order to simulate 

the liquid head of an actual fuel tank. At the start of the 

test, the container is completely full, so that the valve is 

actually closed. This is done in order to test the ability of 

the valve to seal in the upright position. GT then quickly 

rotates the container to 90°, observes any leakage then quickly 

rotates it to 180° and observes the leakage there. The results 

obtained on the EPA simple system valve by GT using this test 

method are shown in Attachment 2 under the heading "Liquid 

Testing-Rollover at 10 in. of H2O". 

This standard test method used by GT may not adequately 

describe the level of rollover protection provided by the valve 

in a worst case situation because the level of liquid .and the 

pressure in the test device cause the valves to be already 

completely shut at the start of the test. However, if the 

valve was not completely shut at the start of rollover (as 

would be the case in most situations) then a higher rate of 

leakage might occur as the valve was rotated. Because of this, 

EPA asked GT to test the simple system valves with a modified 

test procedure in which the container is only filled to the 

90-95 percent level, which was taken to be the point where the 

valve float has just become buoyant but was not yet closed. 

The rollover device was also left at atmospheric pressure. 

This probably makes it more difficult for the valve to meet the 

leakage specifications than if it were on an actual fuel tank, 

since the liquid head helping to close and seal the valve 

during rollover is less in the small container than it would be 

in a full-size fuel tank. EPA also asked GT to perform the 

test according to the timing and rotation rates of the FMVSS 

301 test. 
P.4 

The data obtained by GT on its two prototype valves is 

included in Attachment 2. Both valves leaked much less than 

Ford's specification of 4 cc per minute. The first valve 

tested had no leakage over the 24 minute test period. The 

second valve tested leaked 4.1 cc during the first 5 minutes of 

testing (0.82 cc/min) and a total of 4.3 cc over the 24 minute 

test period (0.18 cc/min). 

Because of the critical nature of rollover protection, EPA 

repeated the test for one of the valves using the same 

equipment. The results reinforced those obtained by GT 

(Attachment 3). The highest leakage rate during the test was 

0.91 cc per minute and no leakage occurred after 180° of 

rotation. A video tape of this test is available. 

Following completion of these tests, Ford questioned how 

well the test equipment simulated the performance on an actual 

fuel tank. In -response to this questioning it was decided to 

test the valve on an actual fuel tank. For this test, EPA 

selected the same valve as was used for the Ford Taurus 

demonstration refueling system. Valve performance for this 

test was equivalent to earlier tests (Attachment 4). The 

highest leakage/rate was 0.48 cc per minute which occurred 

during the first 5 minutes of the test. Once again no leakage 

occurred after 180° of rotation. This test was also documented 

on video tape. 

Based upon both the supplier's and EPA's tests, the 

rollover performance of the EPA simple system valve is 

excellent. All tests showed that these valves easily met 

current Ford rollover valve specifications, and allowed little 

or no leakage. 

Attachments 

6518W 
P.5 

4S.'tol Attachment 1 

gust 31. 1977. shall meet all the require-' 

ments ol £6.1 in a perpendicular impact 

only. SC.2. and SG.4. Each of these types 

of vehicles manufactured on or after 

September 1. 1977. shall meet all the requirement- of SO. except S6.5. 

55.3 Vehicles with GVWR oj more 

than 0.000 pounds but not more than 

10.000 pounds. Each multipurpose passenger vehicle, truck, nnd bus with a 

GVWR of more than 6,000 pounds but 

not more than 10.000 pounds manufactured from September 1, 1976. to August 31. 1977. shall meet the requirements of S6.1 in a perpendicular impact 

only. Each vehicle manufactured on or 

after September 1. 1977. shall meet all 

the requirements of S6. except S6.5. 

55.4 Schoolbuscs with a GVWR greater 

than 10.000 pounds. Each schoolbus with 

a GVWR greater than 10.000 pounds 

manufactured on or after July 15, 1976, 

shall meet the requirements of S6.5. 

' S5.5 Fuel spillage: Barrier crash. Fuel 

spillage in any fixed or moving barrier 

crash test shall not exceed 1 ounce by 

• weight from impact until motion of the 

•vehicle has ceased, and shall not exceed 

a total of 5 ounces by weight in the 

5-minute period following cessation of 

motion. For the subsequent 25-minute 

period fuel spillage during any 1-minute 

interval shall not exceed 1 ounce by 

weicht. 

S5.G Furl spill ape: Rollover. Fuel spillr.ee in any rollover test, from the onset 

of rotational motion, shall not exceed 

a total of 5 ounces by weight for the 

first 5 minute? of testing nt ench successive 90' increment. For the remaining testing rcriod. at each increment of 

SO' fuel spillage during any 1-mlnute 

ir.'.crvrd .'.hall not exceed 1 ounce by 

weight. 

S6. Test requirements. Each vehicle 

with a GVWR of 10,000 pounds or less 

shall b» capable of meeting the requirements of any applicable barrier crash test 

followed by a static rollover, without alteration of the vehicle during the test 

sequence. A particular vehicle need not 

meet further requirements after having 

beer, subjected to a single barrier crash 

test and a static rollover test. 

SJ.l Frontal barrier crash. When the 

vehicle traveling longitudinally forward 

at any sp°ed up to and including 30 mph 

impacts a fixed collision barrier that is 

perpendicular to the line of travel of the 

vehicle, or at any angle up to 30° in 

either direction from the perpendicular 

to the line of travel of the vehicle, with 

50th-pcrccntile test dummies as specified 

in Part 572 of this chapter at each front 

outboard designated seating position and 

at any other position whose protection 

system Is required to be tested by a dummy under the provisions of Standard No. 

2C8. under the applicable conditions of 

S7, fuel spillage shall not exceed the limits of S5.5. 

S6.2 Rear moving barrier crash. When 

the vehicle is impacted from the rear by 

a bnn-icr moving at 30 mph, with test 

dummies as specified in Part 572 of this 

chapter at each front outboard designated seating position, under the appliRULES AND REGULATIONS 

cable conditions cf 57. fuel spillage shall 

not exceed the lin.its of S5.5. 

SG.3 Lateral 77ti;t;::i<7 barrier crash. 

When the vehicle is impacted laterally on 

either side by a barrier moving at 20 mph 

with 50th-pcrccntile test dummies as 

specified in Part 572 of this chapter at 

positions required for testing to Standard No. 208, under the applicable conditions of S7. fuel spillage shall not exceed 

the limits of S5.5. 

56.4 Static rollover. When the vehicle 

is rotated on its longitudinal axis to each 

successive increment of 90', following an 

impact crash S6.1, SG.2. or SG.3, fuel spillage shall not exceed the limits of S5.6. 

56.5 Moving contoured barrier cras7i. 

When the moving contoured barrier assembly traveling longitudinally forward 

at any speed up to and including 30 mph 

impacts the test, vehicle (schoolbus with 

a GVWR exceeding 10,000 pounds) at any 

point and angle, under the applicable 

conditions of S7.1 and S7.5, fuel spillage 

shall not exceed the limits of S5.5. 

S7. Test conditions. Tne requirements 

of S5 and S6 shall be met under the following conditions. Where a range of conditions is specified, the vehicle must be 

capable of meeting the requirements at 

all points within the ranee. 

S7.1 General test conditions. The following conditions apply-to all tests. 

57.1.1 The fuel tank is filled to any 

level from 90 to 95 percent of capacity 

with Stoddard solvent, having the physical and chemical properties of type 1 

solvent. Table I ASTM Standard D484-

71, "Standard Specifications for Hydrocarbon Dry Cleaning Solvents." 

57.1.2 Tne fuel system other than the 

fuel tank Is filled with Stoddard solvent 

to its normal operating level. 

57.1.3 In meeting the requirements of 

S6.1 through S6.3. if the vehicle has an 

electrically driven fuel pump that normally runs when the vehicle's electrical 

system is activated, it is operating at the 

time of the barrier crash. 

57.1.4 The parking brake is disengaged 

and the transmission is in neutral, except that in meeting the requirements 

of SG.5 the parking brake is set. 

57.1.5 Tires are inflated to manufacturer's specifications. 

57.1.6 The vehicle, including test devices and instrumentation, is loaded as 

fellows: 

(a) Except as specified in S7.1.1. a passenger car is loaded to its unloaded vehicle weight plus its rated cargo and luggage capacity weight, secured in the luggage area, plus the necessary test dummies as specified in SC. restrained only 

by means that are installed in the vehicle for protection at its seating position. 

<b) Except as specified in S7.1.1, a 

multipurpose .passenger vehicle, true!:, or 

bus with a GVWR of 10.000 pounds or 

less is loaded to its unloaded vehicle 

weight, plus the necessary test dummies, 

as specified in S6., pius 300 pounds or its , 

rated cargo and luggage capacity weight, 

whichever is less, secured to the vehicle 

and distributed so that the weight on 

ea:h axle as measured at the tire-ground 

interface Is in proportion to its GAWR. 

If the weight on any axle, when the vehicle is loaded to unloaded vehicle wcinht 

plus dummy weicht. exceed", the axle's 

proportional share of the test weight, the 

remaining weight shall be Dlaced so tha t 

the weight on that axle remains the 

same. Each dummy shall be rest mined 

only by menus lh:<t arc ir.-.t.allrd in the 

vehicle for protection ut :.r:itnii; po.'.ition. 

(c) Except ns specified in S7.1.1, a 

schoolbus with a GVWR greater than 

10.000 pounds is loaded to its unloaded 

vehicle weight, plus 120 pounds of unsecured weight at each designated seating position. 

57.2 Lateral moving barrier crash test 

conditions. The lateral moving barrier 

crash test conditions are those specified 

in S8.2 of Standard No. 203. 49 CFR 

571.208. 

57.3 Rear moving barrier test conditions. The rear moving barrier test conditions are those specified in S8.2 of 

Standard No. 208. 49 CFR 571.208, except for the positioning of the barrier 

and the vehicle. The barrier and test vehicle are positioned so that at impact— 

(a) The vehicle is at rest in its normal 

attitude: 

(b) The barrier is traveling at 30 mph 

with Its face perpendicular to the longitudinal ecntcrlinc of the vehicle: and 

(e) A vertical plane through the geometric center of the barrier impact surface and perpendicular to that surface 

coincides with the longitudinal centctiinc of the vehicle. 

57.4 Static rollover test cnitdtions. 

The vehicle is rotated r.bju'. its )?:-.=itucinal axis, with the nxis kept hcriranis.1. to each successive increment of 90". 

180'. and 270' at a uniform r?te. w',.h 00' 

of rotation taking place in any time interval from 1 to 3 minutes. After ic.v.liing each 90° increment the vehicle is 

held in that position for 5 mir.tr.c-. 

57.5 Moving contoured barrirr .'.-.'? 

conditions. The following conditions ?pply to the moving contoured barrier 

crash test. 

57.5.1 Tne movinc barrier, \vr.kh j« 

mounted nn a carriage a = specified in 

figure 1, is of rigid construction, svmmetrical about a vertical 'longitudinal 

plane. Tne contoured impact surface, 

which is 24.75 inches hich and 73 inches 

wide, conforms to the c';:n;cnsij::.- ;;io".vn 

in ficurc 2. and is attached to the carriage as shown in that, figure. The ground 

clearance to trie lower edge of the impart 

surface is 5.25 :t 0.5 inches. The wheelbase is 120 -t 2 inches. 

57.5.2 The moving contoured barrior. 

Including the impact surface, supporting 

structure, and carriage, weighs 4.000 

— 50 pounds with the weight distributed 

so that 900 g: 25 pounds is at each rear 

wheel and 1100 ± 25 pounds is at ep.ch 

front wheel. The center of gravity is located 54.0 -: 1.5 inches rearward of the 

front wheel axis, in the vertical longitudinal plane of symmcuy. 15.3 inches 

above the ground. The moment of inertia about the center of gravity is: 

J, = 2" i 13.0 flue ft3 

J, =:3475 = 17-1 slug ft' 

f»K 

FEDERAL REGISTER. VOL. <0. NO. 200—WEDNESDAY, OCT03E!t 13, 1075 
P.6 

Attachment 2 

G.T.PRODUCTS 

ANN ARBOR,MI 

PART # 08001 EPA VALVE 

AIR FLOW 

FLOW CURVE - see graph 

IN of H20 

0 

2 

4 

6 

8 

10 

12 

14 

16 

ROLLOVER 9 10 

90 DEGREES 

180 DEGREES 

LIQUID TESTING 

0" H20 

0 

90 

180 

FLOW 

iH of. 

0 

82 

105 

120 

140 

160 

175 

190 

205 

SCFH 

SCFH 

SCFH 

SCFH 

SCFH 

SCFH 

SCFH 

SCFH 

SCFH 

H20 

CC/MIN 

0 

0 

TANK 90* 

LESS THAN 

FULL 

4 CC/MIN 

LEAKAGE (Y/N) 

Y 

Y 

Y 

TOTAL LEAKAGE 0 CC_ (0 - 360 DEGREES OVER 24 MIN.) 

ROLLOVER AT 10" of H20 

0 

90 

180 

SLOSH TANK TEST 

Y 

Y 

Y 

OK - LIGHT ASPIRATION 

PETE BELANGER 

10/4/88 
250 

200 

100 

50 

rt 

G.T. PRODUCTS 

E.P.A. VALVE 

FLOW <SCFH) 

/ _ • 

U 

0 

i i i 

• • 

Attachmen

t 2 

5 10 15 20 

PRESSURE (INCHES OF WATER) 

— PART #08001 

< 

10/4/88 
P.8 

Attachment 2 

G.T.PRODUCTS 

ANN ARBOR,MI 

PART # 08002 

AIR FLOW 

EPA VALVE 

FLOW CURVE - see graph 

FLOW DATA: 

0 

2 

4 

6 

8 

10 

12 

14 

ROLLOVER 9 10 

90 DEGREES 

180 DEGREES 

LIQUID TESTING 

0" H20 

0 

90 

180 

FIRST 5 MIN. 

TOTAL LEAKAGE 

FLOW 

IN of 

0 

92 

105 

125 

140 

158 

175 

180 

H20 

SCFH 

SCFH 

SCFH 

SCFH 

SCFH 

SCFH 

SCFH 

SCFH 

CC/MIN 

20 

0 

TANK 90% 

LESS 

FULL 

THAN 4 CC/MIN 

LEAKAGE (Y/N) 

4. 1 

4.3 

Y 

Y 

Y 

CC. 

CC <0 - 3( 

COMMENTS 

4.1 CC 

TRACE 

<0 - 360 DEGREES OVER 24 MIN.) 

ROLLOVER AT 10M of H20 

0 

90 

180 

SLOSH TANK TEST 

Y 

Y 

Y 

OK LIGHT ASPIRATION 

PETE BELANGER 

10/4/88 
G.T. PRODUCTS 

E.P.A. VALVE 

200 

150 

100 

50 

FLOW (SCFH) 

(to 

O 

or 3 

4 6 8 10 12 

PRESSURE (INCHES OF WATER) 

14 16 

10/4/88 

PART #08002 

TJ 

CO 
Attachment 3 

Rollover Test Results 

October 18., 1988 

Valve Tested: EPA Simple System Valve 

Rollover performed with the valve mounted on a cylindrical container which holds approximately one 

gallon of stoddard solvent. Container was filled to the point at which the float on the valve had 

just become buoyant in the upright position. The liquid in the rollover device was at atmospheric 

pressure. 

Total Leakage 

Cubic 

Grams Centimeters* 

(q) (cc) 

Ounces 

(02) 

Total Time 

of Collection 

(min.) 

3.31 4.57 0.116 

0.46 

0.54 

0.63 

0.75 

0.016 

0.019 

1.5 

Leak Rate 

(cc/min) (oz/min) 

0.91 

0.42 

0.15 

0.023 

Test Period 

and 

Valve Position 

First 5 min. of test 

(1.5 min. travel from 

0° to 90° and 3.5 min. 

hold at 90°) 

Final 1.5 min. 

of the 5 min. 

total hold at 90° 

1.5 min. travel between 

90° and 180° and first 

3.5 min. of 5 min. hold 

at 180° 

No additional leakage occurred during the remaining 1.5 min. of hold at 180° or during the 

subsequent 1.5 minute rotation from 180° to 270° and the 5 min. hold at 270° and the 1.5 minute 

rotation from 270° to 360° and the 5 minute hold at 360°. 

0.011 

0.004 

Density of Stoddard Solvent =1.38 cc/g 
Attachment 4 

Rollover Test Results 

October 22, 1988 

Total Leakage 

Cubic 

Grams Centimeters 

(q) (cc)* 

Ounces 

(oz) 

Total Time 

of Collection 

(min.) 

Leak Rate 

(cc/min) (oz/min) 

1.74 2.4 0.061 

0.26 

0.013 

0.36 

0.018 

0.009 

0.0005 

0.48 .012 

Valve Tested: EPA Simple System Valve 

Rollover performed with the valve mounted on a 15.7 gallon 1986 GM Cutlass Ciera Fuel tank filled 

to 95% capacity with 15.0 gallons of stoddard solvent. 

Test Period 

and 

Valve Position 

First 5 min. of test 

(1.0 min. travel from 

0° to 90° and first 4.0 

min. of 5.0 min hold at 90°) 

Final 1.0 min. 

of the 5.0 min. 

hold at 90° 

1.0 min. travel between 

90° and 180° and first 

4.0 min. of 5.0 min. hold 

at 180° 

No additional leakage occurred during the remaining 1.0 min. of the 5.0 min. hold at 180° or during 

the subsequent 1.0 minute rotation from 180° to 270° and 5 min. hold at 270° and the 1.0 min. 

rotation from 270° to 360° and the 5 min. hold at 360°. 

0.36 

0.0036 

0.009 

0.0001 

Density of Stoddard Solvent = 1.38 cc/g