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OAR Box 1830 

Prepped by Ollie Stewart 

Document Number: 

192) IV-C-159 

Docket Number: 

A-87-11 

Printed 11/13/2008 7:21:01 AM Sheet 192 of 232 
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

\ , J? WASHINGTON. D.C. 20460 

FE? 2 8 1989 

THE ADMINISTRATOR 

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Honorable John D. Dingell lUi. K IQRQ 

Chairman, Subcommittee on Mill MW 0 ra^ 

Oversight and Investigations 

Committee on Energy and Commerce I L* _ ..« nftCKET 

House of Representatives 1 EPAA»2_i_! • 

Washington, DC 20515 

Dear Mr. Chairman: 

This is in response to your letter of November 30, 1988 in 

which you raised concerns in several areas pertaining to EPA's 

analysis of onboard control system safety and running loss 

emissions. Your letter raised issues in five main areas: 1) 

National Transportation Safety Board (NTSB) comments on EPA's 

draft revised onboard safety analysis, "Summary and Analysis of 

Comments Regarding the Potential Safety Implications of Onboard 

Vapor Recovery Systems", 2) NTSB comments on Battelle1s draft 

failure modes and effects analysis (FMEA) entitled "Fuel System 

Comparative Risk Assessment", 3) EPA work on running loss 

emissions, 4) briefings, studies and reports which EPA should 

provide to various parties, and 5) recent EPA interactions with 

Ford Motor Company regarding the simple onboard system 

concept. Our response is organized into the same five topics. 

Unfortunately, neither NTSB nor NHTSA provided a copy of 

the NTSB comments directly to EPA for our consideration. 

However, after receiving the copy which was enclosed with your 

letter, we contacted Dr. Merritt Birky, the NTSB representative 

who reviewed the two documents. We were able to clarify some 

of the statements which he made concerning the analyses. The 

enclosed memo to the record, which was coordinated with NTSB, 

details that follow-up conversation. In general, we do not 

disagree with NTSB's concluding comment that sufficient 

leadtime must be given in order to deal directly with the 

issues raised regarding onboard safety. However, like you, we 

were also concerned about some of the statements made by the 

NTSB regarding the draft revised onboard safety analysis and 

the Battelle FMEA. 
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First, a specific concern raised in your letter was in 

regard to NTSB's comment on an apparent bias and lack of 

objectivity in the EPA draft revised onboard safety analysis. 

In our conversation, Dr. Birky said that this impression 

stemmed from his review of the fire and recall data analysis 

sections of the draft safety analysis. As we explained to 

Dr. Birky, we also had some reservations about using these data 

which were stated in at least three different points in the 

report. However, there were several reasons why we felt use of 

these data was appropriate and necessary. First, it was 

supplied to us by NHTSA and characterized by them as the best 

available information. Second, both NHTSA and other commenters 

used these data to support their concerns regarding onboard and 

evaporative system safety. Third, our use of the data was 

constrained only to respond to the safety comments based upon 

the same data. The only conclusions we drew from our analysis 

of the data were that it is not possible to determine that 

evaporative control systems have degraded safety. In any 

event, our goal is to conduct an objective, unbiased assessment 

of these important issues. We are therefore concerned that 

NTSB viewed our draft report otherwise and we will work closely 

with them to assure an objective analysis. 

NTSB also commented that the potential for an increase in 

vehicle safety with the advent of onboard systems discussed in 

the draft revised onboard safety analysis is not yet proven and 

is not solely limited to onboard systems since much of the 

claimed improvement could also be achieved if modifications 

were made to current evaporative control systems. It is true 

that manufacturers could achieve some of these potential safety 

improvements by modifying their current systems without an 

onboard requirement. However, they have as yet not done so and 

past experience suggests that such measures will not 

necessarily be taken unilaterally. 

The second main issue raised in your letter was in regard 

to NTSB's concern that Battelle's FMEA failed to address the 

safety related issues of: 1) the performance of an onboard 

system durinq collision/rollover and 2) the driveability of an 

onboard-equipped vehicle. As we discussed with NTSB in our 

follow-up conversation, collision and rollover are incorporated 

in the analysis as is apparent in Table 4-3, Operating State 

Characteristics and the different FMEA analysis tables. 

Further discussion with Dr. Birky revealed that the focus of 

his comment was that these issues should be dealt with from an 

experimental perspective as well as in Battelle's engineering 

analysis. Such testing is, however, outside the scope of a 

FMEA". It is correct that the potential effects of onboard 

systems on driveability were not evaluated by Battelle in this 

study, since this would not be possible within the scope of 

traditional failure modes analysis techniques. 
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With regard to the aforementioned Battelle FMEA briefing, 

our follow-up conversation with NTSB confirmed that NTSB did 

not actually request that NHTSA attend the briefing but merely 

suggested it as a possibly convenient measure to reduce the 

number of briefings which EPA would need to give. NTSB and 

NHTSA were not briefed together primarily due to scheduling 

conflicts between the two groups. They did both attend the 

briefing given to your staff. 

The third issue discussed in your letter is that of EPA's 

work on running loss emissions. You are correct in stating 

that EPA continues to study running losses; more testing is 

being done in order to develop a better fleet average 

representation of running losses. The fact that our testing 

continues should not be taken to imply that we do not 

understand the sources of running losses or the need for 

control. The cause of running losses is inadeouate purge to 

deal with vapors being generated in the fuel tank during 

vehicle operation. 

In the fourth main area of your letter you requested that 

various briefing documents and draft reports be provided to 

various parties. You asked that EPA send a copy of the draft 

3attelle FMEA report to foreign and domestic manufacturers. In 

response, EPA has sent copies of the draft Battelle report to 

MVMA, AIA, and API, and a copy has been placed in the docket. 

You also asked that the November, 1988 Battelle/Office of 

Mobile Sources update briefing on EPA's analysis of onboard 

control safety issues be provided to the NTSB, NHTSA, your 

Subcommittee, the affected industry and the public. This 

material was presented by EPA and Battelle at the briefings 

given to NHTSA and NTS3 in November. The briefing materials 

will also be placed in the public docket for review by other 

interested parties. 

Finally, you expressed concern about EPA's October 21, 

1988 letter "to Ford regarding Ford's application of a 

simplified onboard control system design to a Ford Taurus fuel 

tank. We regret our response can be viewed as "defensive and 

aggressive." We only intended to convey our view that Ford's 

claims regarding the performance and feasibility of the 

EPA-type simple control system were not correct. We assure you 

that our interactions with Ford and other manufacturers will be 

on an objective, technical basis. 
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In closing, we would like to state that we share your 

concerns for both the safety of vehicles and the 

the environment. We hope that this letter 

intentions and addresses your concerns. 

protection of 

clarifies our 

Enclosure 

cc: The Honorable Diane K. Steed 

Administrator, NHTSA \ 

The Honorable James L. 

Acting Chairman, NTSB 

Kolstead