P.1 

OAR Box 1147 

Prepped by Ollie Stewart 

Document Number: 

147) IV-E-20 

Docket Number: 

A-87-11 

Printed4/22/2008 2:42:55 PM Sheet 147 of 242 
•r 

} -ta-. ^ mj 

% 

P.2 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

ANN ARBOR. MICHIGAN 48105 

JAN 2 0 1988 

OFFICE OF 

AIR AND RADIATION 

MEMORANDUM 

SUBJECT: 

FROM: 

TO: 

THRU: 

EPA/FORD Meeting Regarding Onboard control Systems 

Glenn W. Passavant, Senior Project Manager XJ^SM^CA XLM&u+Jr^T 

Standards Development and Support Branch ' 

Public Docket A-87-11 

Chester J. France, Chief 

Standards Development and nch 

On October 14, 1987 several representatives of Ford Motor 

Co. met with EPA engineers at the Motor Vehicle Emission 

Laboratory in Ann Arbor, Michigan to discuss EPA's work on 

liquid seals and other related topics This meeting was 

arranged as a follow-up to a September 16, 1987 meeting with 

Ford regarding onboard vapor recovery held at ECS Laboratories 

in Livonia, Michigan. A list of attendees is attached. 

A number of items of interest were discussed at the 

meeting. First, regarding liquid seals, EPA explained to Ford 

that liquid seals had been tested on a vehicle and that the 

test data are available in public docket A-84-07. Ford 

expressed concern that the test data in a December 1986 EPA 

technical report entitled "Evaluation of the Feasibility of 

Liquid Fillneck Seals" did not meet EPA's proposed refueling 

emissions standard. EPA explained that the purpose of the work 

was to demonstrate the feasibility of the concept of liquid 

seals and that no attempts were made to optimize the design of 

our system in order to the meet any possible emission standard. 
P.3 

tt •-

In fact, the currently proposed emission standard had not been 

developed when the testing was being conducted. We mentioned 

that the American Petroleum Institute had developed an 

optimized liquid seal type onboard system which showed test 

data which met the proposed standard. We discussed EPA's views 

on the advantages of liquid seals versus mechanical seals as 

they are detailed in our rulemaking documents. Ford mentioned 

that they may have data on a 1979 vehicle with a submerged 

fill. They said they would check on this and provide us with 

any available data. We discussed the relationship between the 

required fill height for a liquid seal and fuel tank back 

pressure, and talked over ideas on how fill height might be 

minimized. 

Several other onboard related issues were discussed. We 

reviewed the statements in the NPRM and supporting documents 

concerning leadtime requirements. EPA questioned Ford about 

the advantages of plastic fuel tanks. Ford responded that 

their light weight in comparison to steel tanks is the main 

advantage, and, it is also possible that in certain crash modes 

plastic tanks are more crashworthy. Also, we discussed the 

potential safety benefits of bladder tanks, such as flexibility 

which may allow it to remain intact even when the steel tank 

shell is broken open in a crash. 

Finally, Ford mentioned that a Society of Automotive 

Engineers Committee is working with nozzle manufacturers to 

ensure that nozzle spout and vehicle fillneck changes are 

compatible. In Ford's view, a key issue is the length of the 

spring found on the outside of the nozzle spout, stating that 

if it is too long it could interfere with and /or damage a 

mechanical seal. Ford also stated that the committee is also 

trying to ensure that Stage II nozzle spout lengths are 

compatible with onboard systems. 

Attachment 
P.4 

EPA/FORD Meeting Regarding Onboard Control Systems 

October 14, 1987 

List of Attendees 

FORD 

George Lavoie 

Mike Tokarsky 

Mike Harrington 

Mike Schwarz 

Walt Kreucher 

EPA 

Glenn Passavant 

John Anderson 

Jean Schwendeman