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OAR Box 1830 

Prepped by Ollie Stewart 

Document Number: 

157) IV-C-124 

Docket Number: 

A-87-11 

Printed 11/13/2008 7:20:59 AM Sheet 157 of 232 
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[ 222. ^ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY j— . . ^ 

\ . y WASHINGTON. D.C. 20460 

"*l PH0& 

| JUL 2 5 1988 

THE ADMINISTRATOR 

Honorable John D. Dingell 

Chairman, Subcommittee on 

Oversight and Investigations 

Committee on Energy and Commerce 

House of Representatives 

Washington, DC 20515 

Dear Mr. Chairman: 

This is in response to your letter of May 31, 1988 in 

which you requested information on whether the simplified 

onboard hardware design which we have developed can be applied 

to all vehicles covered by our proposed rule. You also 

requested that EPA explain the "safety problems" associated 

with the proposed onboard test procedure as identified by the 

auto makers and indicate what EPA is doing to correct them. 

The safety issue to which you referred was characterized in a 

letter from the Motor Vehicle Manufacturers Association (MVMA) 

to you as one of non-conformance of the proposed test procedure 

with state and local fire codes. 

With respect to your question on the applicability of the 

simplified onboard hardware, it is our expectation that the 

basic design would be usable on essentially all 

gasoline-powered vehicles. The very simplicity of the design 

makes it broadly applicable. Of course, the various aspects of 

the overall system such as type of liquid seal, valve placement 

and size, canister size and location, etc. would have to be 

optimized for proper performance on differing vehicle types. 

However, the basic concept of using a liquid seal system with a 

tank mounted vapor control/rollover valve is a very adaptable 

approach. The only case which we know of where use of a liquid 

seal might be difficult is for a small fraction of heavy-duty 

gasoline trucks equipped with side mounted, saddle-type tanks. 

These tanks have a very short fillpipe, making it difficult to 

use liquid seals. Such tanks, however, are generally used on 

diesel trucks and are relatively rare on gasoline-fueled trucks 

affected by our proposal. 
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It is important to keep in mind that we have proposed a 

refueling performance standard and not a design standard. 

EPA's simplified onboard hardware is an example of one 

potential design. Motor vehicle manufacturers will be free to 

develop other designs should an onboard requirement be 

promulgated. 

Your second question concerned possible safety problems 

with the proposed test procedure raised by MVMA and some 

individual manufacturers in their comments. In our review of 

the comments, we found that safety-related comments, which were 

few, largely involved pointing out areas where fire codes would 

need to be considered in proper facility design. We agree that 

this needs to be done to insure a safe workplace and would 

expect manufacturers to fully comply with all applicable fire 

codes. This is not an unusual situation. Many of our existing 

test procedures involve safety-related issues, such as handling 

flammable liquids and testing vehicles in enclosed areas. 

Clearly one must use caution in designing equipment and 

developing operating procedures to insure safety in conducting 

these tests. Of course, EPA is also interested in minimizing 

the safety-related considerations presented by the refueling 

test procedure whenever possible. As I noted, we have received 

some comments on testing safety, which we plan to fully 

consider as we proceed with the rulemaking. We may be able to 

incorporate changes into the procedure which will simplify the 

safety-related aspects of testing. 

I trust that the preceding information responds to the 

requests in your letter. Should you have other questions or 

concerns pertaining to our proposed rule, please let us know. 

Sincerely, 

j,eeMo. Hwaaa.. 

Lee M. Thomas 

cc: Docket A-87-11