P.1 

OAR Box 1147 

Prepped by Ollie Stewart 

Document Number: 

143) IV-E-16 

Docket Number: 

A-87-11 

Printed 4/22/2008 2:42:55 PM Sheet 143 of 242 
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

ANN ARBOR. MICHIGAN 48105 

NOV 2 3 I98T 

OFFICE OF 

AIR AND RADIATION 

MEMORANDUM 

SUBJECT: 

FROM: 

EPA/IIHS Meeting 

Emission Controls 

Regarding Onboard Refueling 

TO: 

THRU: 

9 •+-

Glenn W. Passavant, Senior Project Manager 

Standards Development and Support Branch 

Public Docket A-87-11 

Chester J. France, Chief/ 

Standards Development a n-o/ Suyp 

On October 20, 1987 representatives of the Insurance 

Institute for Highway Safety net with representatives of EPA's 

Office of Mobile Sources at the Motor Vehicle Emission 

Laboratory in Ann Arbor, Michigan to discuss onboard refueling 

emission controls. A copy of the briefing that was presented 

and a list of attendees are attached. 

At the beginning of the meeting, Charles Gray, the 

Director of the Emission Control Technology Division, reviewed 

the rationale used by EPA in making the decision between 

onboard and Stage II vapor control systems. (This rationale is 

described fully in the Preamble to the Aug. 19, 1987 NPRM). He 

also gave a broad perspective on how the onboard and volatility 

proposals work together to reduce the ozone level. 

After the issues in the briefing v/ere discussed, there was 

a lab tour. Onboard refueling control system hardware was 

displayed, and a carbon canister flammability test was 

performed. In this test, both spark and flame sources were 

applied to carbon from an evaporative system canister that was 

thoroughly saturated with hydrocarbon vapor. The test showed 

that the carbon can sometimes light with a flame source but not 

with a spark source and that the canister is*not explosive. 
P.3 

Before the meeting closed, we asked IIHS for their 

suggestions on how to best perform a risk analysis of onboard 

refueling control systems. IIHS suggested a possible 

contractor, Failure Analysis Associates (FAA). IIHS mentioned 

that their experience has shown that implementing new 

technology can lead to recalls, even if the technology is 

intended for safety purposes. As an example they cited the 

recall of Mercedes-Benz vehicles equipped with air bags. 

IIHS suggested that analyzing current accident data to try 

to quantify the possible increase in vehicle fires that might 

occur with onboard refueling controls v/ould be difficult if not 

impossible. The reason for this is that the available accident 

data are very "noisy", and it is not always possible to 

identify the source or cause of a vehicle fire. IIHS also 

speculated that any increased risk of fires due to onboard 

systems would likely be lost in the noise of the data. 

IIHS suggested that phasing in any new requirement on cars 

is usually advantageous. Without a phase-in a manufacturer may 

put low grade systems on cars planned for elimination in the 

near future. Hov/ever, IIHS said that even with a phase-in of 

in, 25, 40 and 100 percent the FMVSS 208 standard for passive 

restraints still ran into problems when some manufacturers 

decided not to eliminate vehicle lines that were originally 

intended to be eliminated at the time that the phase-in began. 

Problems occurred when the decision not to eliminate these 

vehicle lines v/as made without leaving sufficient time for well 

integrated, high quality passive restraint systems to be 

designed for these particular vehicle lines. 
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Attendees List 

IIHS/EPA Mtg. 10/20/87 

IIHS 

Brian O'Neill 

Saami Shaibani 

John Cook 

EPA 

Charles Gray 

Chester France 

John Anderson 

Glenn Passavant 

Kathleen Steilen" 

Jean Schwendeman 

Paul Laing 
P.5 

ONBOARD REFUELING EMISSION CONTROLS 

A BRIEFING FOR THE INSURANCE 

INSTITUTE FOR HIGHWAY SAFETY 

OCTOBER 20, 1987 

by 

ENVIRONMENTAL PROTECTION AGENCY 

OFFICE OF AIR AND RADIATION 

OFFICE OF MOBILE SOURCES 
P.6 

OVERVIEW OF THE BRIEFING 

Background 

Control System Technology 

Questions for Discussion 
P.7 

BACKGROUND 

Ozone Formation and Nonattainment 

Addressing the Ozone Problem 

Why Control Refueling Emissions? 

Refueling Control Options 

Why is Onboard the Preferred Option? 
P.8 

OZONE FORMATION 

Ozone is formed in a complex photochemical reaction 

involving oxides of nitrogen (NOx) and volatile organic 

compounds (VOC) 

The chief way to control ozone is to reduce VOC emissions 

Large variety of sources but main ones are transportation 

and industrial processes 
P.9 

OZONE NONATTAINMENT 

Ozone air quality problems are significant and widespread; 

76 major urban nonattainment areas with a total population 

affected in excess of 77 million (see Figure 1) 

Most of these areas are expected to fail to meet the Clean 

Air Act's attainment deadline of the end of this year -

this is despite many years of Federal, State, and local 

control efforts 

Reduction of 10 percent to greater than 70 percent will be. 

needed to bring all areas into compliance (see Figure 2) 
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P.12 

ADDRESSING THE OZONE PROBLEM 

The refueling and volatility controls represent two 

national programs that will provide VOC reductions of 10 

percent 

This 10 percent reduction combined with the 20 percent 

reduction expected from current Federal Motor Vehicle 

Control Programs will provide enough of the needed 

reductions for some areas to reach the ozone standard (see 

Figure 2) 

Many other areas will need significant additional 

reductions 

The States have a major responsibility in implementing 

local control measures to address the ozone problem 
P.13 

WHY CONTROL REFUELING EMISSIONS? 

Provides a two percent VOC reduction 

Few remaining VOC control strategies can provide more 

reduction 

Reductions can be achieved cost effectively when compared 

to other available control alternatives 

Reduces exposure to toxic vapors during refueling -

benzene is a known human carcinogen and gasoline vapors in 

general are a concern 

Our annual incident reduction estimates for controlling 

refueling emissions are 4 with just benzene, 14 if benzene 

and C6 above, and 42 if benzene and all gas vapors 
P.14 

REFUELING CONTROL OPTIONS 

Two options for controlling refueling emissions: 

service station controls - Stage II, or 

vehicle controls - Onboard 

Both onboard and Stage II are technically feasible and 

cost effective 
P.15 

WHY IS ONBOARD THE PREFERRED OPTION? 

Onboard will provide a greater in-use control 

effectiveness: 83 percent vs, 48-66 for Stage II 

Onboard is national in scope providing VOC and toxic 

benefits to all areas of the country 

Stage II arguably could be implemented quicker, but this 

is unlikely in many areas and its overall effectiveness is 

heavily dependent on a long-term commitment of substantial 

government enforcement.resources - any short-term Stage II 

advantage is highly speculative and quickly overshadowed 

by onboard's greater control effectiveness 

Onboard can be singly implemented or as an add-on to our 

Federal Vehicle Certification Program while Stage II would 

require each state to adopt regulations covering their 

service stations 

Onboard avoids the geographic boundary competitiveness 

problem of Stage II 

Onboard avoids consumer inconvenience of Stage II 
P.16 

CONTROL SYSTEM TECHNOLOGY 

Fuel systems prior to controls 

Evaporative control system 

Onboard control technique description 

Onboard hardware (lab) 
P.17 

FUEL SYSTEMS PRIOR TO CONTROLS (PRE-1972) 

Fuel System Emission Sources: fuel metering system 

(carburetor) and fuel tank (see Figure 3) 

Main source of fuel metering emissions is carburetor float 

bowl vent - vented to engine compartment or carburetor 

inlet/air cleaner 

Fuel tanks were vented to the atmosphere either through 

the filler cap or a vent tube with an outlet somewhere 

under the body of the car 
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Figur e 3 

F-LJEI - SYSTEM S F' R I O R T O CONTRO I 

BOWL VENT CONFIGURATIONS 

TYPICAL TANK CONFIGURATION 

CAP. FILLER TUBE 

FUEL GAUGE (TANK UNIT) 
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EVAPORATIVE CONTROL SYSTEM 

Controls required on Federal vehicles in 1972 

Control System Description (see Figure 4) 

Seals off fuel system (carburetor or fuel-injector 

and fuel tank) 

Routes vapors to storage device 

Restores capacity of storage device for subsequent 

vapor loadings by purging during vehicle operation 

General Configuration 

Pressure/Vacuum Relief Fill Cap 

Vapor lines (connected to fuel tank, carburetor, 

canister, and intake manifold) 

Carbon Canister (approximately one liter in volume 

for passenger cars) 

Purge Valve(s) (between canister and intake manifold) 

Float/Rollover Valve and Liquid/Vapor. Separator (on 

some configurations) 
Figur e 4 

Typical Current Evaporative System 

PRESSURE/VACUUM 

RELIEF CAP 

EXTERNAL VENT LINE 

FLOAT/ROLLOVE 

VALVE 

C 

3/8" DIA. 

8' LONG 

^ 

05" DIA. LIMITING 

ORIFICE 

PURGE VALVE 

1 LITER 

CARBON 

CANISTER 

TO PURGE 

INDUCTION 

POINT 

14 GALLON FUEL TANK 
P.21 

ONBOARD CONTROL TECHNIQUE DESCRIPTION 

Onboard systems perform the same three basic functions as 

evaporative systems - only during refueling 

Seals off fuel system during refueling 

Routes vapors to a carbon canister 

Restores capacity of canister by purging stored 

vapors and burning them in the engine as fuel 

Since onboard refueling control technique is nearly 

identical to that used on current vehicles to control 

evaporative emissions, a single integrated system can be 

used to control both evaporative and refueling emissions 

(see Figure 5) 

In order to perform the three basic functions. during 

refueling, the current evaporative system requires the 

following modifications: 

Addition of a fillneck seal to prevent vapors from 

escaping during refueling 

Enlargement of vapor lines and canister to capture 

refueling vapors which are generated more quickly 

and in a larger quantity than evaporative emissions ' 

Rollover protection valve for new vent line 
Figur e 5 

Integrated Evaporative/Refueling System 

J - Tube Seal 

PRESSURE/VACUUM 

RELIEF CAP 

NOZZLE ACTUATED 

ROLLOVER/VENT VALVE 

^J-TUBE SEAL 

\ 

DESIGNED SLOW LEAK 

14 GALLON FUEL TANK 

5/8" DIA. 

.05" DIA. LIMITING 

ORIFICE 

PURGE VALVE 

3 LITER 

CARBON 

CANISTER 

TO PURGE 

INDUCTION 

POINT 
P.23 

OTHER SAFETY CONSIDERATIONS 

Service Station Fires 

Reduced spillage and spitback (due to provisions in 

the test procedure and fuel dispensing rate limit) 

Containment of Vapors 

In-Use Performance 

Control of excess evaporative emissions 

Generally lower vapor loading on canisters 

Lower volatility fuels are generally safer 

Implementing onboard controls provides the opportunity to 

modify present systems to improve safety. For example: 

Accelerate transition from rear fill to safer side 

fill 

- Move external vapor vent lines inside fillpipe 

Add flapper valve at fuel tank/fillpipe interface 

Bladder: Possible long-term option - presently 

still in development/conceptual stage 
P.24 

ANALYTICAL QUESTIONS FOR DISCUSSION 

How do we assess the increase in safety risk (if any) that 

can be expected to result from the installation of onboard 

refueling control hardware? 

How do these risks compare in general with other safety 

risks and in particular with other fuel system changes 

(such as fuel injection)? 

What safety engineering solutions are available to 

eliminate or minimize these risks? 

How much leadtime is necessary to provide for necessary 

safety engineering? 

How do we assess the benefit of eliminating existing 

safety risks which might occur in conjunction with onboard 

installation (e.g., excess canister capacity, rear to side 

fill, exposed vent lines)? 

How do. we evaluate the benefits of the potential reduction 

in service station safety risks (from reduced spillage and 

containment of vapors)? 

What safety benefits can we expect from the volatility 

rule?