p.1 

OAR Box 1147 

Prepped by Ollie Stewart 

Document Number: 

177) IV-E-50 

Docket Number: 

A-87-11 

Printed 4/22/2008 2:42:57 PM Sheet 177 of 242 
P.2 

yr.. . - T S.3 j t ' ^ 'mf0 

M 2 01987 

BBBOJlAffDOH 

SUBJECTi KPA/FOIU) nestin g Regardin g Onboard Vapor Recovery 

FROHt 

TOJ 

Glenn W. Passavant, Senior Project Manager 

Standards Development and Support Branch 

Public Docket A-87-11 

THRU: Chester J. France, Chief 

Standards Developoent and Support Branch 

were also present 

attached. ECS was 

Ford to test their 

Cn Septenber 16, 1987 several representatives of EPA's 

Office of Mobile Sources set with Ford at Engine and control 

Systems, Inc. (ECS) Laboratories in Livonia, Michigan to 

discuss their design and testing efforts for both canister 

based and bladder tank onboard refueling control systems. 

Representatives of ECS and PA Technology of Princeton, N.J. 

at the meeting. An attendees list is 

present because they are under contract to 

bladder systems. Ford hired PA Technology 

to help determine the feasibility of bladder aystens by further 

investigating potential bladder materials and designs. A copy 

of the handout which includes the agenda followed at the 

weeting ia attached. Fotd -ilso provided other design and test 

information which they specified as confidentU:i material. 

Several points were raised during the .Jiscujssions at t'-e 

seeting. At the tine of tne meeting Ford had a relatively 

saall project underway to assess designs for onboard vapor 

systens. Tvo fuel systea engineers were assigned to 

and light 

recovery 

designing onooard systeins for Ford's passenger car 

truck fuel systens. in the- course or the discussions Ford 

stated that their cesi^n options were socewhat limited because 

constraint that onboard systems could D** 

•titer the i:.inai rule is signe.o. 

. ti'. ::csit:un on loadtine id stated 

to t:.e i-Pi^K, zidimi ^nco-jra-jeu i-'ord to pfovios 

of the perceived 

required as soon 

In response, LPA 

JS .2. year 

in the Preamble 

cownents on the 

in ayattm utsign. 

C C X .3 t X c n -.j : i i c •.•c-t''.:i'tr. J.ml t XTM -.i r. a c n o l c s s 
P.3 

Pord also stated that they felt that . the perceived 

leadtime constraint forced then to target at systea designs 

which could be applied quickly to as many vehicle models as 

possible. At this tine this led thes to prefer mechanical 

B**1* over liquid seals since tbe application of liquid seals 

would 1» some cases require tank codifications not needed for 

sechanical seals. We briefly discussed tbe merits of 

mechanical and liquid seals and invited Pord to visit tPA's Ann 

Arbor lab to further discuss application of the J-Tube systea 

developed by KPA. BPA expressed concern that tha J-tube systea 

pictured by Pord in their handout was not applied la tbe Banner 

envisioned by BPA* Pur ther, pord stated that up to this 

point they had not conducted an independent assessaent of fill 

height requirements for their vehicle models, but vera using 

those presented by BPA in their liquid seals tech report. 

As part of the discussion regarding bladders, Pord stated 

that the major impetus for investigating the approach was to 

reduce refueling eaissions. Two tests were conducted by pord 

during its demonstration yielding reductions of 80-85 percent, 

but these were relatively simple prototypes and work was needed 

to make tbe designs feasible for use on vehicles and to further 

reduce emissions if possible. 

Attachments 
P.4 

V ' 

' ' ' ' 1 - •;, -

/••' 

/.' 

•>' 

/ 

' 

r 

'•y%& • 

PORD ^S*#:'" 

Hike Tokarski 

Nika Barrigan 

Kike Schvarta 

Kelly Brown 

Boa Buist 

Walt Kreuchar 

Chris Lilly 

Bill ling 

BC* Laboratory 

Prad Narsea 

PA Technology 

John Kline 

Joe Terrell 

EPA 

Jean Schwendeman 

Kathy Steilen 

Paul Lalng 

Lee Jones 

John Anderson 

Glenn Passavant 

Chet France 

Cnarles Gray 

Dick Wilson 

Attendees List 

Pord/BPA Mtg 9-16-87 

• 
P.5 

COLLAPSIBLE BLADDER FUEL TANK 

DESIGN STATUS BRIEFING 

WIIH EPA 

September 17, 1987 

Livonia, Michigan 

1. Agenda 

2. Hardware Overview 

3. Unresolved Bladder Issues 

4. Ford Test Results 

5. Hardware Demonstrations 

£-01334 

WMK..53 
P.6 

INTRODUCTION AND OVERVIEW 

REMARKS 

HARDWARE OVERVIEW 

Liquid Seal System 

Nozzl e Seal System 

Bladder Tank System 

AGENDA 

D. R. Buist 

R. D. Wilson 

M. E. Tokarsky 

UNRESOLVED BLADDER ISSUES 

Partner s 

Future Plans 

R. Nawrocki 

FORD TEST RESULTS 

HARDWARE DEMONSTRATIONS 

F. Mar se e (ECS) 

M. E. Tokarsky 

WMK.53 
Slide:X16531-01 Opid: Job#:C 153 DDS:6000 Size:126 Tue Aug 11 21:21:01 1987 

ON BOARD VAPOR RECOVERY 

(OBVR) 

HARDWARE OVERVIEW 

TJ 

^1 
CURRENT SYSTEM 

FUEL TANK VENT 

& ROLLOVER VALVE 

CURRENT MODEL 

CANISTER 

P 

l oo 
Slide:X16531-02 Opid: Job#:C 153 DDS:6000 Size:480 Tue Aug 11 21:21:47 1987 

TECHNICAL REQUIREMENTS 

• PREVENT REFUELING VAPORS FROM ESCAPING TO 

THE ATMOSPHERE 

• VENT THE FUEL SYSTEM DURING REFUELING AND 

DURING VEHICLE OPERATION 

• STORE AND/OR DISPOSE OF THE FUEL VAPORS 

• ANTICIPATE AND MINIMIZE ADDED SAFETY RISK 

TJ 

CO 
ilide:Xl6531-0 3 Opid: 

Job#:C 153 DDS:6000 Size:22 2 Tue Aug 11 21:23:0 2 1987 

APPROACHES 

LIQUID SEAL 

IN-TANK BLADDER 

MECHANICAL NOZZLE SEAL 

o 
31ide:Xl6531-04 Opid: Job#:C 153 DDS:6000 Size:532 Tue Aug 11 21:23:42 1987; 

LIQUID SEAL 

FUNCTION 

FILLER OUTLET UNDER FUEL SURFACE OR "J" 

TRAP SEALS THE SYSTEM 

COLUMN OF FUEL IN THE FILLER PIPE DURING 

REFUELING FORCES THE VAPOR INTO AN 

ACTIVATED CHARCOAL CANISTER 

CANISTER STORES THE FUEL VAPOR FOR LATER 

CONSUMPTION BY THE ENGINE 
EPA LIQUID SEAL SYSTEM 

FUEL TANK VENT 

& ROLLOVER VALVE 

NOZZLE ACTIVATED 

VALVE 

PURGE TO ENGINE COMBINED REFUELING 

AND EVAP EMISSION 

CANISTER 

|F3 
Job#-C 153 DDS:6000 Size:508 Tue Au.j 11 21:27:38 1987 

Slide:X16531-06 Opid:

 u * 

MECHANICAL NOZZLE SEAL 

FUNCTION 

SEALS THE FILLER INLET TO CLOSE OFF THE 

NORMAL ESCAPE PATH FOR THE VAPORS 

FUEL BEING PUMPED IN FORCES THE VAPORS OUT 

THROUGH AN ACTIVATED CHARCOAL CANISTER 

THE CANISTER STORES THE VAPORS FOR LATER 

CONSUMPTION BY THE ENGINE 
MECHANICAL NOZZLE SEAL 

ORVR VENT TUBE 

,TO ENGINE INTAKE 

FUEL TANK VENT & 

ROLLOVER VALVE 

CARRYOVER 

CANNISTER 

ORVR PURGE LINE 

TO ENGINE INTAKE 

PURGE AIR HEATER 
Slide:X16531-05 Opid: Job#:C 153 DDS:6000 Size:1082 Tue Aug 11 21:25:04 1987 

IN-TANK BLADDER 

THEORETICAL FUNCTION AS ENVISIONED BY EPA 

A FLEXIBLE, FUEL RESISTANT, TOUGH, DURABLE, NONPERMEABLE 

MEMBRANE ENVELOPES THE ENTIRE FUEL SURFACE INSIDE A 

CONVENTIONAL FUEL TANK 

THE MEMBRANE RIDES UP AND DOWN ON THE FUEL SURFACE AS 

THE FUEL IS USED 

THE MEMBRANE-FUEL INTERFACE PREVENTS FUEL VAPOR 

FORMATION THAT OCCURS AT AN AIR-FUEL INTERFACE. NO FUEL 

TANK VENTING OR CANISTER SYSTEMS ARE REQUIRED 

THE BLADDER REINFLATES DURING REFUELING; NO VAPOR IS 

DISPLACED OR EVOLVED. NO VENTING OR CANISTER SYSTEM IS 

REQUIRED 

IN CRASH SITUATIONS THE BLADDER PROVIDES ADDITIONAL 

PUNCTURE PROTECTION FOR THE FUEL SYSTEM 
IN-TANK BLADDER 

VENT WITH ROLLOVER 

PROTECTION 

BLADDER 
Slide:Xl6531-07 Opid: Job#:C 153 DDS:6000 Size:1314 Tue Aug 11 21:29:07 1987 

LIQUID SEAL 

EVALUATION 

ADVANTAGES 

• NO ISSUES WITH SEAL DURABILITY OR TAMPERING 

• NO OVERPRESSURE RELIEF REQUIRED DURING REFUELING 

• NO CHANGE FOR VEHICLE OWNER 

DISADVANTAGES 

• FILLER NECK VULNERABILITY 

• CANNOT PACKAGE FILLER HEIGHT TO MEET EPA REQUIREMENTS 

(10 GPM FILL RATE) 

• MANY FUEL TANKS ARE TOO SHALLOW FOR "J" TRAP ABOVE THE FUEL 

• INCREASED RISK OF SPIT BACK AND FUEL EXPULSION 

• HIGHER COMPLEXITY SYSTEM FOR ADDED VALVES AND CONTROLS TO 

MINIMIZE SPITBACK AND FUEL EXPULSION 

• GENERATES MORE VAPORS DURING REFUELING REQUIRING LARGER 

CANISTER CAPACITY 

• REQUIRES FUEL TANK AND FILLER PIPE REDESIGN 

•LIQUID/VAPOR SEPARATOR RELIABILITY 
Slide:Xl6531-10 Opid: Job#:C 153 DDS-.6000 Size:772 Tue Aug 11 21:37:00 1987 

MECHANICAL NOZZLE SEAL 

EVALUATION 

ADVANTAGES 

• MINIMUM CHANGE TO THE TOTAL SYSTEM 

• ALL PARTS CONTAINED IN ONE UNIT AT 

THE FILLER INLET 

• SIMPLE MECHANICAL ACTIVATION 

DISADVANTAGES 

• FILLER INLET VULNERABILITY 

• NOZZLE SEAL DURABILITY AND TAMPERING 

• REQUIRES OVERPRESSURE RELIEF VALVE 

• LIQUID VAPOR SEPARATOR RELIABILITY 
Slide:Xl6531-08 Opid: Job#:C 153 DDS:6000 Size:1446 Tue Aug 11 21:31:53 198*7 

IN-TANK BLADDER 

EVALUATION 

ADVANTAGES 

• MIGHT PROVIDE ADDITIONAL PUNCTURE PROTECTION UNDER A LIMITED NUMBER 

OF CIRCUMSTANCES 

DISADVANTAGES 

• DOES NOT PERFORM AS THEORIZED. A NOZZEL SEAL SYSTEM MUST BE ADDED. 

- REFUELING VAPORS EXCEEDED EPA RULES 

- THE PURE BLADDER SYSTEM WILL NOT FILL 

- VAPORS FROM INSIDE THE BLADDER DURING NORMAL VEHICLE OPERATION 

- KNOWN MEMBRANE MATERIALS ARE PERMEABLE 

- - VAPOR LOSS COULD EXCEED EPA RULES 

- - LIQUID FUEL COULD CONDENSE BETWEEN THE BLADDER AND THE TANK 

- ALL KNOWN BLADDER MATERIALS WILL NOT FUNCTION PROPERLY BELOW 

BLADDER MATERIAL DURABILITY IS UNKNOWN 

WATER CONDENSATION BETWEEN TANK AND BLADDER POSES A CORROSION 

RISK AND ICE FORMATION COULD CUT THE BLADDER 

NEW FUEL TANK MANUFACTURING PROCESSES MUST BE DEVELOPED 

REQUIRES NEW CONCEPT FUEL PICK UP AND FUEL GAGE SENDER 

0°F 

CO 
Slide:Xl6531-09 Opid: Job#:C 153 DDS:6000 Size:718 Tue Aug 11 21:35:10 1987' 

IN-TANK BLADDER 

(EVALUATION CONTINUED) 

• BLADDER MATERIAL DURABILITY IS UNKNOWN 

• WATER CONDENSATION BETWEEN TANK AND BLADDER POSES A 

CORROSION RISK AND ICE FORMATION COULD CUT THE BLADDER 

• ALL OF THE HARDWARE REQUIRED FOR A MECHANICAL NOZZLE 

SEAL SYSTEM WILL BE REQUIRED 

• NEW FUEL TANK MANUFACTURING PROCESSES MUST BE 

DEVELOPED 

• REQUIRES NEW CONCEPT FUEL PICK UP AND FUEL GAGE SENDER 
Slide:X16531-ll Opid: Job#:C 153 DDS-.6000 Size:752 Tue Aug 11 21:38:23 1987' . 

SUMMARY OF HARDWARE EVALUATION 

• EACH SYSTEM HAS ADVANTAGES AND DISADVANTAGES 

• EACH SYSTEM ADDS COMPLEXITY AND ADDITIONAL 

SOURCES FOR POTENTIAL IGNITION 

• EACH SYSTEM REQUIRES: 

- FURTHER DESIGN WORK TO RESOLVE KNOWN 

SHORTFALLS 

- TESTING TO EVALUATE CONFORMANCE TO 

STANDARDS AND DISCOVER ADDITIONAL POTENTIAL 

FAILURE MODES 

- REDESIGN AND RETEST TO VERIFY THAT THESE 

INVENTIONS MEET AND EXCEED ALL STANDARDS 

i 
LEADTIME 

DUE TO COMPRESSED LEADTIME REQUIREMENTS ASSUMED BY EPA 

MANUFACTURERS ARE FORCED TO INTRODUCE COMPROMISES 

IDEALLY ALL MECHANICAL MECHANISMS SHOULD BE CONTAINED 

AT THE FUEL TANK 

FUEL TANK REDESIGN LEADTIME IS 52 MONTHS MINIMUM 

ASSUMING ALL DESIGNS CAN BE PHASED IN 
P.23 

COLLAPSIBLE BLADDER FUEL TANKS 

EPA Position: As stated in the March 1987 Draft report entitled "Safety 

Implications of Onboard Refueling Vapor Recovery Systems", EPA concludes that a "collapsible bladder tank could be used to meet the 

onboard requirement" adding that "a bladder tank could eliminate essentially all of the safety concerns raised regarding control of refueling 

emissions. This is because a vapor space would not be present in a 

bladder tank, and without a vapor space, refueling emissions would not 

occur." 

General Comments: The EPA position is incomplete in that it fails to recognize 

the limitations and unresolved design issues associated with this emerging 

technology. As anyone who has ever filled a swimming pool equipped with a pool 

liner can attest, it is nearly impossible to completely remove wrinkles from a 

liner, wrinkles that in a fuel system can accumulate to decrease precious tank 

capacity and potentially block the critical openings. Thus while design work 

is continuing in this area there is no immediate hope that the many unresolved 

open issues will permit production usage of this potential technology. Some of 

the open issues include: 

MATERIALS COMPATIBILITY 

The bladder must be compatible with all fuel and fuel blends, and 

alcohol fuels currently available or expected to be available. This 

includes sour fuel, aftermarket additives and entrapped moisture. The 

material must also remain flexible under all conditions, be abrasion 

resistent and have little if any weight. 

ENVIRONMENTAL COMPATIBILITY 

The bladder must remain flexible and abrasion resistent under all 

temperature conditions from extreme cold (minus 50 F and below) to 

extreme hot. 

FUEL SYSTEM SHUTOFF 

The sealed system must be capable of being filled under all 

environmental conditions and under conditions of fuel dispensing nozzle 

failure. Fuel shutoff must result in constant fuel 'full' level under 

all conditions without fuel spitback. 

CONDENSATION 

Because of the potential temperature differential between the bladder 

and the tank, consideration must be given to moisture condensation. 

Provisions must be made to evacuate the moisture. This task is 

complicated by the fact that the bladder by design will seal all 

openings in che surrounding tank and will collapse and expand 

differently each rirre the system is filled. This could cause moisture 

to become permanent]."/ trapped which in turn could limit capacity, 

freeze, which could form ice daggers that potentially could puncture 

the bladder, or cause or contribute to other hazards. 
P.24 

FUEL TANK BLADDER OPEN ISSUES -

FILL RATE LIMITATIONS 

Consideration must be given to insure that the system will fill at an 

acceptable rate under all environmental conditions. Cold temperatures 

could stiffen the bladders thereby increasing the pressure required to 

fill and decreasing the fill rate. Consideration must be given to how 

to shutoff fill to avoid overpressurization. 

ELECTROSTATIC BUILDUP 

The completed system must prevent the buildup of electrostatic charges. 

PRESSURE BUILDUP 

The completed system must be able to readily and safely stabilize any 

pressure buildup resulting from the internal fuel temperatures or 

during fill. 

FUEL LEVEL SENSING 

New technology must be developed to accurately and safely sense the 

fuel level in the tank. 

PERMEABILITY 

Materials must not be permeable to fuel which could become trapped 

between the bladder and the tank liner. 

MANUFACTURING PROCESS 

Entirely new processes must be developed to manufacturer the bladder on 

a mass production basis and to assemble the components in a high 

quality fashion so as to preclude leaks and other defects. Current 

bladder tanks are made one at a time, by hand. 

FUEL RESERVOIR 

Alternative technology for handling the unique issues that occur during 

low fuel conditions need to be explored. 

SHAPE DEPENDENCY 

Expected tank configurations will come in a variety of shapes to 

conform to available space limitations. The bladder must be 

sufficiently flexible to conform to a variety of contours. 

VAPOR ENTRAPMENT 

Current fuels begin to boil (i.e. evaporate) at about 80 F and 

significant amounts of fuel will boil at typical vehicle operating 

temperatures. The vapor generated must be removed if the bladder is to 

reseal itself against the fuel. Increasing fuel volatility, of course, 

exacerbates this problem. Any pressure buildup in the tank must be 

relieved or at a minimum controlled in order to preclude ballooning of 

the tank or fuel expulsion upon cap removal.