P.1 

OAR Box 1147 

Prepped by Ollie Stewart 

Document Number: 

213)IV-E-87 

Docket Number: 

A-87-11 

Printed 4/22/2008 2:42:58 PM Sheet 213 of 242 
P.2 

m^Sr*% ^^S ^ 

|> A \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

\^M-£r/

 AN N

 ARBOR. MICHIGAN 48105 

FEB I 4 1989 

MEMORANDUM 

\ # 

i ^ 

r-'\ 

OFFICE OF 

AIR AND RADIATION 

r\. 

SUBJECT: Meeting With GM Personnel;' Refueling Test Procedure 

FROM: 

TO: 

Peter Hutchins, Mechanical Engineer 

Standards Development and Support Branch 

Docket A-87-11 

In response to a request by GM, I met with GM personnel on 

January 5, 1989 to review questions posed by GM on details of 

EPA's proposed onboard test procedure. The questions as posed 

by GM are contained in Attachment 1. GM personnel in 

attendance were John Bjelobrk, Lisa Fior and Kevin Cullen. 

At the start of the meeting GM personnel were advised that 

comments provided would not be official EPA responses to their 

questions. They were encouraged to incorporate these and any 

other questions in GM comments on the test procedure when the 

supplemental notice was published. 

GM personnel 

test invalidation 

wording of an EPA 

is reconnected prior 

(§86.133-xx(a)(10)(i)). GM 

pointed out that corporate policy required 

whenever a test failed to meet the exact 

test procedure; e.g., if refueling canister 

to gas cap installation 

personnel went on to point out that 

since they were performing refueling emissions testing they 

were desirous of understanding EPA intentions on the 

performance of the details of the test so that their test 

validators could be appropriately advised. 
P.3 

Each of the questions posed by GM were reviewed on the 

basis of the above. As a result of this review it is apparent 

that GM had correctly noted some minor discrepancies in the 

supplemental proposal between the figures and the written 

regulations and between some sections within the document. 

Some of these discrepancies; e.g., times between test events, 

can cause confusion and will be corrected prior to SNPRM 

publication. Other discrepancies; e.g., differences in allowed 

engine starting under similar test conditions, are of little 

significance and can be incorporated following EPA review of 

comments. 

Attachment 

6754W 
P.4 

fi.TTfiCHtfEA'T i 

Milford 

Proving Ground 

Current Product Engineering 

General Motors Corporation 

December 21, 1988 

Mr. John Anderson 

U.S. Environmental Protection Agency 

2565 Plymouth Road 

Ann Arbor, Michigan 48105 

Dear Mr. Anderson: 

Enclosed is a copy of our partial list of questions regarding the EPA's Test 

Procedure on Evaporative and Refueling Emissions in addition to the Test 

Procedure Flow Diagrams depicting ' the test sequence, as proposed on 

September 1, 1988. 

We appreciate the opportunity to review and clarify these issues with you on 

January 5, 1989. 

Sincerely, 

Kevin Cullen 

Test Systems Engineering 

Mil ford-Vehicle Emission Laboratory 

Enclosures 

cc: E. E. Conner 

L. M. Fior-EAS 
CONCERNS ANO QUESTIONS REGARDING THE 

PROPOSED TEST PROCEDURES 

FOR 

EVAPORATIVE AND REFUELING EMISSIONS 

(EPA DRAFT DATED SEPTEMBER 1, 1988) 

(PARTIAL LIST) 

Page 1 

[TEM 

1. Vehicle 

Preconditioning 

PROPOSED REQUIREMENT 

86.132-xx(a)...During any period that 

the vehicle is parked in the test area 

awaiting testing, the fuel tank cap(s) 

may be in place... 

CONCERN/QUESTION EPA'S CLARIFICATION 

• Uhat practice will EPA follow 

regarding the fuel tank 

cap(s): 

- Uhen the vehicle is brought inside 

of the lab to anbient temperature 

of 68°F-86°F and before the initial 

fuel draining is completed? 

- After the initial fuel draining is 

completed? 

- During the Tenperature Stabilization? 

- After the Canister Saturation and 

before the fuel draining activity for 

the FTP Prep? 

- During the cold soak and before the 

fuel draining activity for.the diurnal? 

- After the refueling measurement is 

completed and until the test data is 

validated? 

• Can the inner seals in the fuel tank 

filler necks (if so equipped) be disabled 

at the points where the fuel cap removal is 

allowed for the systems which do not utilize 

the inner seals? 

86.132-xx(a)(1)...Canister(s) shall 

not be purged prior to beginning 

this sequence... 

• Uhat sequence is EPA referring 

to? 

TJ 

" bi 
CONCERNS AND QUESTIONS REGARDING THE 

PROPOSED TEST PROCEDURES 

FOR 

EVAPORATIVE AND REFUELING EMISSIONS 

(EPA DRAFT DATED SEPTEMBER 1, 1988) 

(PARTIAL LIST) 

Page 2 

ITEM PROPOSED REQUIREMENT 

Vehicle 

Temperature 

Stabilization 

86.132-xx(a)(1)(ii)...This tenperature 

stabilization step may be omitted 

on vehicles uhich are already 

temperature stabilized as a result 

of storage in the test area. 

CONCERN/QUESTION 

• Uhen does the vehicle temperature 

stabilization start: 

- Uhen the vehicle is brought 

inside of the lab to ambient 

temperature of 68*F-86*F? 

- After the vehicle fuel tanks 

are drained and the fuel tank 

cap(s) are installed? 

• Uhen the vehicle is parked in 

the soak area? 

- Is a vehicle that has just completed 

the refueling measurement temperature 

stabiIi zed? 

EPA'S CLARIFICATION 

Canister 

Saturation 

86.132-xx(a)(1)(iii)(B)(4)... 

(canister breakthrough is defined 

as a point at which the hydrocarbon concentration in the SHED 

increases by a factor of three 

or greater in one minute or less),... 

• How will EPA insure non-premature 

termination of canister saturations 

(i.e. possible hardware leaks and 

non-homogeneous mixing)? 

• Why is the mixing (before 

sampling) required during the 

refueling test and not daring 

the canister saturation? 

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TJ 

CD 
CONCERNS AND QUESTIONS REGARDING THE 

PROPOSED TEST PROCEDURES 

FOR 

EVAPORATIVE AND REFUELING EMISSIONS 

(EPA DRAFT DATED SEPTEMBER 1, 1988) 

(PARTIAL LIST) 

Page 3 

ITEM PROPOSED REQUIREMENT 

Canister 

Saturation 

(continued) 

86.132-xx(a)(1)(iii)(B)(4)...The fuel 

dispensing rate shall be between 3.0 

and 5.0 gal/min (11.3 and 18.9 l/min)... 

- (saturation) 

86.233(e)(6)...The dispensing rate shall 

be between 3.0 and 10.0 gal/min (11.4 to 

37.9 l/min)... - (refueling) 

CONCERN/QUESTION 

• Uhat is the reason for different 

fuel flow rates during the canister 

saturation and refueling 

measurement? 

EPA'S CLARIFICATION 

86.132-xx(a)(1)(iii)(B)(4)...If canister 

breakthrough does' not occur during the 

first full fueling operation, the SHED 

shall be opened, the vehicle removed 

without starting the engine,... 

• Must the vehicle always be removed 

from the SHED even if the draining 

can be performed in the SHED? 

86.132-xx(a)(1)(iii)(B)(5)...If the vehicle • How is EPA planning to accomplish 

is equipped with dual fuel tanks and a 

common canister, either fuel tank may be 

filled first... 

this activity? 

• How will the opening on the SHED 

wall for the primary fuel tank be 

sealed Uiile the secondary fuel 

tank is being filled? 

• Uill the spilled fuel mixing blower 

be used during the canister 

saturation? 

86.207(a)(1)(i0(B)(4)...An exploston3 

proof blower of 100-200 ft /min 3 (2.8-5.7 m /min) capacity is required 

to enhance mixing of vapors of spilled 

fuel through the enclosure atmosphere 

during tests. The discharge from this 

blower shall be... 

• Uill more than one blower be used? 

• If only one blower is used how can 

it be repositioned for the secondary 

fuel tank fueling? 

1ICLBnlinii 

TJ 
CONCERNS AND QUESTIONS REGARDING THE 

PROPOSED TEST PROCEDURES 

FOR 

EVAPORATIVE AND REFUELING EMISSIONS 

(EPA DRAFT DATED SEPTEMBER 1, 1988) 

(PARTIAL LIST) 

Page 4 

ITEM 

Canister 

Saturation 

(continued) 

PROPOSED REQUIREMENT 

86.132-xx(a)(1)(i i 0(B)(6).. .Remove the 

vehicle from the SHED without starting 

the engine. 

CONCERN/QUESTION 

• Uhy shouldn't the engine be started 

after the canister saturation in order 

to move the vehicle to the fueling area 

when it can be started after the 

refueling is done to move the vehicle 

to the prep dynamometer? 

EPA'S CLARIFICATION 

4. Drain/Fi U for 

FTP Prep 

86.132-xx(a)(2)...Uithin one hour of 

loading the canister(s) to breakthrough, 

the refueling emission canister(s) shall 

be disconnected (gasoline-fueled 

vehicles only)... 

• Figure Bxx-lOa is not consistent with 

the text. The maximum of one hour 

requirement is shown from the canister 

breakthrough to the beginning of the 

Fuel Drain & Fill activity. Uhat is 

correct? 

• If the time is measured to the point at 

which the emission canister is 

disconnected, how soon should then the 

fuel drain/fill activity start? 

• How soon after completion of the fuel 

drain/fill activity should the refueling 

emission canister be connected? 

$i§M ifeliaMl i 

TJ 

00 
CONCERNS AND QUESTIONS REGARDING THE 

PROPOSED TEST PROCEDURES 

FOR 

EVAPORATIVE ANO REFUELING EMISSIONS 

(EPA DRAFT DATED SEPTEMBER 1, 1988) 

(PARTIAL LIST) 

Page 5 

ITEM 

5. Drain/Fill for 

Diurnal 

PROPOSED REQUIREMENT 

86.133-xx(a)(6)...Immediately prior to 

the diurnal breathing loss test, the 

refueling emissions canister(s) shall 

be disconnected or a diverter valve 

opened, if so equipped, to prevent the 

flow... 

CONCERN/QUESTION 

• If the diverter valve is open, can 

the fuel vapors from the fuel tank 

be routed to the atmosphere? 

• Uhat does the "immediately" in this 

case mean? 

EPA'S CLARIFICATION 

86.133-xx(a)(10)(i)...Install fuel tank 

cap(s) and reconnect refueling emissions 

control canister(s)... 

• Can order of these events be 

reversed and is it important? 

Hot Soak 86.138-xx(j)...Utilizing the access port(s) 

in the side of the enclosure, the fuel 

tank cap(s) shall be removed for a period 

not less than 5 seconds nor longer than 

20 seconds to relieve any pressure in the 

tank and then be reinstalled and tightened. 

This operation shall be completed within 

five minutes of engine shutdown. 

• Uhen is the cap considered 

"removed" and when is it 

considered "reinstalled"? 

• Uhat is the difference between 

the "reinstalled" and "tightened"? 

• Can a valve be installed on the 

fuel cap to accomplish the 

"pressure" release and to provide 

possible automation? 

• Should the fuel cap of the secondary 

fuel tank be removed even though the 

fuel frcm this tank is not used 

during the FTP test? 

7. Prep for Refueling 86.232(a)(2)...and the vehicle shall be 

driven, using minimum throttle, off of the 

dynamometer and to the fuel drain 

equipment. 

• Uhen is the engine turned off after 

the prep is completed? 

• Can the engine be restarted if 

turned off before the refueling 

canister is disconnected? 

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TJ 

in 
CONCERNS ANO QUESTIONS REGARDING THE 

PROPOSED TEST PROCEDURES 

FOR 

EVAPORATIVE ANO REFUELING EMISSIONS 

(EPA DRAFT DATED SEPTEMBER 1, 1988) 

(PARTIAL LIST) 

Page 6 

ITEM 

8. Vehicle Cool Down 

PROPOSED REQUIREMENT 

86.232(a)(3)...Uithin 10 minutes of 

completing the drive, the refueling 

emissions canister(s) shall be 

disconnected or a diverter valve opened, 

if so equipped, to prevent the flow of 

vapor from the fuel tank to the refueling 

canister. If disconnected, the open end 

of the vapor line leading to the refueling 

canister shall be plugged. The fuel tank 

cap(s) shall then be removed, the vehicle 

grounded,... 

CONCERN/QUESTION 

• Can the order in Uiich the refueling 

canister and the fuel tank cap(s) 

are removed be reversed and is it 

important? 

EPA'S CLARIFICATION 

86.232(a)(3)...Uithin 60 minutes of 

completing the drive draining of the fuel 

tank(s) shall be completed, and the tank(s) 

fueled with test fuel, specified in 86.113, 

at a temperature of 81.0 to 84.0*F (27.2 to 

28.9*C), to 10 percent of nominal fuel tank 

capacity to the nearest 0.1 U.S. gallon 

(0.38 liter). 

• Figure Cxx-1 is not consistent with 

the text. The maxinun liait of 60 

minutes is shown from the end of the 

Prep cycle to the beginning of the 

temperature stabilization. 

• Uhat is the significance of the 

81.0 to 84.0'F fuel temperature 

requirement when the refueling 

canister(s) are disconnected and the 

vehicle is allowed to soak at 80 ±3*F 

for 6-24 hours? 

• Can the roan temperature fuel be 

used instead? 

TJ 

o 
CONCERNS ANO QUESTIONS REGARDING THE 

PROPOSED TEST PROCEDURES 

FOR 

EVAPORATIVE AND REFUELING EMISSIONS 

(EPA DRAFT DATED SEPTEMBER 1, 1988) 

(PARTIAL LIST) 

Page 7 

ITEM 

8. Vehicle Cool Down 

(continued) 

PROPOSED REQUIREMENT 

86.232(a)(3)...The fuel tank cap(s) shall 

then be replaced, the disconnected vapor 

line leading to the refueling canister 

plugged or the diverter valve closed, and 

the vehicle moved,... 

CONCERN/QUESTION 

• How soon should the fuel tank cap(s) 

be replaced after the fueling is 

completed? 

• Figure Cxx-1 is not consistent with 

the text. It appears in the text 

that the refueling canister line 

should be reconnected after the 

refueling is done. However, in the 

Figure, the refueling canister is 

reconnected after 6-24 hours of soak. 

• If the refueling canister is required 

to be reconnected, is the order in 

which the fuel tank cap(s) and 

refueling canister are connected 

inportant? 

EPA'S CLARIFICATION 

86.232(a)(3)...and the vehicle moved, 

without starting the engine, to the 

area of the test laboratory where it 

will undergo temperature stabilization 

at a temperature of 80.0 t3.0*F 

(27.0 t1.7*C). The duration of 

temperature stabilization shall be 

between 6 hours and 24 hours. 

• Uhen does the temperature 

stabilization start if the 

refueling area is kept at 

80.0 ±3*F? 

• Uhen does the temperature 

stabilization end: 

- At the start of the refueling 

test? 

- Uhen the fuel tank cap is 

removed? 

• Uhat is the significance of 80 i3*F 

temperature requirement when the 

refueling test can be performed in 

the SHED at aufcient temperature 

between 68-86*F? 

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Page 8 

CONCERNS AND QUESTIONS REGARDING THE 

PROPOSED TEST PROCEDURES 

FOR 

EVAPORATIVE AND REFUELING EMISSIONS 

(EPA DRAFT DATED SEPTEMBER 1, 1988) 

(PARTIAL LIST) 

ITEM 

9. Refueling Emissions 

Measurement 

PROPOSED REQUIREMENT 

86.233(e)(1)...The line from the fuel 

tank(s) to the refueling emissions 

canister shall be connected. Remove 

the fuel tank cap(s). 

CONCERN/QUESTION 

• Figure Cxx-1 is not consistent with 

the text. The figure indicates 

that the fuel tank cap(s) can be 

removed before the refueling 

canister is connected. 

• Uhy should both of the fuel tank caps be 

removed when 86.233(e)(8) indicates 

that the refueling procedure is 

"performed for each fuel tank"? 

EPA'S CLARIFICATION 

86.233(e)(2)...Uithin 5 minutes of 

removing the fuel tank cap(s), the 

test vehicle, with the engine shut off, 

shall be moved into the enclosure. The 

test vehicle windows and luggage 

compartment shall be opened. 

• Uhen is the vehicle considered 

moved into the enclosure? 

• Uhat is the significance of the 

5 minute time requirement? 

• How soon should the refueling 

test start after the vehicle is 

moved into the enclosure? 

• How soon should the refueling 

measurement of the secondary fuel 

tank start after completion of the 

primary fuel tank refueling 

measurement? 

• In case of dual tanks, should the 

vehicle be moved from the SHED after 

coapletion of the primary fuel tank 

refueling measurement? 

• How is the 5 minute requirement 

treated in case of dual tank vehicles? 

-

TJ 

t-O 
CONCERNS AND QUESTIONS REGARDING THE 

PROPOSED TEST PROCEDURES 

FOR 

EVAPORATIVE AND REFUELING EMISSIONS 

(EPA DRAFT DATED SEPTEMBER 1, 1988) 

(PARTIAL LIST) 

Page 9 

ITEM 

10. Refueling 

Equi ement 

PROPOSED REQUIREMENT 

86.207(a)(2)...The accuracy of the 

meter for measuring the dispensed fuel 

volume shall be ±2 percent at the test 

flow rate. 

CONCERN/QUESTION 

• Uhat is the calibration method and 

frequency? 

• Uhat is the calibration frequency of 

other major components including the 

SHED? 

EPA'S CLARIFICATION 

11. Fuel Specifications 86.213(b)...Fuel RVP shall be measured 

periodically to assure compliance with 

applicable requirements. At least one 

measurement shall be taken from each 

batch of fuel used in a refueling cart 

or underground storage tank. The results 

of each measurement shall be used for the 

time period since any previous measurement, 

but shall not be used for any subsequent 

time. 

• Uhat is a "batch": 

- Each time fuel is added to the 

refueling cart? 

- Each time fuel is added to the 

underground storage tank? 

- Each time fuel is added to the 

"da/1 (above ground) tank? 

• From where should the fuel sample be 

taken: 

- Underground storage tank? 

• Refueling cart? 

- Day tank? 

• How can we assure valid tests, when 

RVP measurement must be made after 

the testing is done (i.e. "... shall 

be used for the time period since any 

previous measurement, but shall not be 

used for any subsequent time")? 

• Can a modified ASTM method be used 

for the RVP fuel analysis? 

• How will the fuel sample for RVP 

analysis be taken at EPA? 

"ik-mmm. 

TJ 
CONCERNS AND QUESTIONS REGARDING THE 

PROPOSED TEST PROCEDURES 

FOR 

EVAPORATIVE AND REFUELING EMISSIONS 

(EPA DRAFT DATED SEPTEMBER 1, 1988) 

(PARTIAL LIST) 

Page 10 

ITEM 

12. Test Validation 

PROPOSED REQUIREMENT CONCERN/QUESTION 

Not addressed • Uill the emissions and refueling 

portion of the proposed test sequence 

be independently validated from each 

other (i.e. will a "void" refueling 

test automatically "void" an emission 

test and vice versa)? 

• In case of "void" tests, should the 

proposed test sequence always be 

repeated from the beginning (including 

the test measuraii.nts) in order to 

produce a "valid" test? 

• If the "void" test is recognized during 

the test sequence, should the sequence 

be continued or "aborted"? 

• Is the timing of the proposed test 

sequence always referenced to the 

refueling canister activities or fuel 

tank cap activities? 

EPA'S CLARIFICATION 

13. Records Required 86.242(f)...refueling emission canister 

continuous drive purge miles for 

integrated systems and description of 

how mileage is determined,... 

• Uhat drive is EPA referring to? 

86.242(h)...Recorder charts: Identify 

zero, span, and sanple traces. 

• Can the computer system be used 

instead? 

86.242(j)...Temperatures: Soak area; 

dispensed fuel, initial and final. 

• Is the "initial and final" temperature 

referenced to the soak area or dispensed 

fuel or both? 

GM-Mi I ford Vehicle Emission Laboratory 

December 21, 1988 ' TJ