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OAR Box 1147 

Prepped by Ollie Stewart 

Document Number: 

141) IV-E-14 

Docket Number: 

A-87-11 

Printed 4/22/2008 2:42:55 PM Sheet 141 of 242 
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

ANN ARBOR. MICHIGA N 48105 

OEC 7 1987 OFFICE OF 

AIR AND RADIATION 

MEMORANDUM 

SUBJECT: Meeting with API Regarding Onboard NPRM 

FROM: 

TO: 

Kathleen A. Steilen, Chemical Engineer -K<-'-^ 

Standards Development and Support Branch 

Docket A-87-11 

"^ '•' r^mZCmn._j -v"> 

THRU: Glenn VJ. passavant, Senior Project Manager 

Standards Development and Stfppqyt/ Branch 

Chester J 

Standards 

, France, Chief 

Development an. 

tA 

b^^tirnch 

On November 12, 1987, representatives from the 

Environmental Protection Agency (EPA) and the American 

Petroleum Institute (API) met in Ann ?.rbor regarding the 

onboard NPRM. (A listing of the attendees and their 

affiliation is attached.) Since they were in Ann Arbor for a 

MOBILE4 workshop, API requested an impromptu meeting with EPA 

discuss the concerns raised at the recent public hearing 

onboard refueling controls and what 

to address these concerns. In the 

EPA staff and A?i discussed API's 

work, EPA's safety-related concerns, 

to 

regarding the safety of 

information EPA needed 

course of -this meeting, 

onboard safety analysis 

and the time frame of the onboard rulemaking 

their current efforts with respect 

safety risks associated with onboard 

two contractors to analyze some of 

One contractor, Energy Associates, 

ignition sources which exist under 

the hood of a vehicle. Furthermore, they studied whether the 

spark conditions from these ignition sources were sufficient 

enough to generate a fire if a vapor source was present. Their 

First, API summarized 

to assessing the potential 

controls. They have hired 

the onboard safety issues. 

has identified all of the 
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second contractor, ICF Technology, conducted a Failure Modes 

Effects and Analysis for onboard control systems to study the 

potential failures of the systems and their consequences. in 

addition, ICF Technology examined the fire risks associated 

with the carbon canisters. 

Second, EPA staff identified some additional 

safety-related concerns that have been raised and need to be 

examined. Such concerns include the alleged unquantifiable 

increase in fire risk associated with onboard controls, the 

safety of Stage II systems, and the crashworthiness of 

onboard-equipped vehicles. The value of crash testing an 

onboard-equipped vehicle was also discussed. 

Finally, the time frame of the rulemaking was discussed. 

API was told that the comment period is scheduled to end on 

January 11, 1988. After complete analysis of all the 

safety-related comments and as discussed in the NPRM a 

reproposal would be forthcoming keyed specifically to the 

onboard safety issue and the corment period reopened for any 

safety-related comments. Further, EPA indicated that the 

results of any refueling safety research and analyses conducted 

by API beyond January 11, 1988 could be submitted to EPA during 

the reproposal comment period. 

At the close of the meeting, the topic of fuel bladders 

was raised. It was noted that a few motor vehicle 

manufacturers indicated at the hearings that they were studying 

the potential of fuel bladders. 

Attachment 
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EPA/API Meeting - November 12, 1986 

Participant Affiliation 

George Musser Exxon/API 

Bill Koehl Mobile/API 

Jack Freeman Sun/API 

Ed Crockett API 

Glenn Passavant EPA 

John Anderson EPA 

Kathy Steilen EPA 

Jean Schwendeman EPA