OAR Box 1830 

Prepped by Ollie Stewart 

Document Number: 

42) IV-C-8 

Docket Number: 

A-87-11 

Printed 11/13/2008 7:20:53 AM Sheet 42 of 232 

P.1 
P.2 

•or _^ *» 

» 

% M*** 

\ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

ui 

ANN ARBOR. MICHIGAN 48105 

OFFICE OF 

AIR AND RADIATION 

NOV I 01987 

Mr. Kelly Brown, Executive Engineer 

Noise, Emissions, Fuel Economy Planning 

Ford Motor Company 

The American Road 

Dearborn, MI 48121 

Dear Mr. Brown: 

I am writing in response to your testimony at the recent 

onboard/volatility hearing held October 27-29, 1987 in 

Washington, DC. Due to the large number of testifiers and the 

broad range of issues covered by the two proposals, the time 

limits of the hearing prevented us from exploring your 

testimony as fully as we would have liked. In addition, some 

questions were submitted from the floor which we did not have 

time to present. Therefore, we are writing to you with some 

followup questions for inclusion in your written comments. We 

believe that most of these questions are such that they will 

already be included in your written comments. However, we wish 

to insure that these areas, which are of specific concern to 

EPA, are covered. 

Presented in the enclosed list are questions which we have 

been requested to ask by the National Highway Traffic Safety 

Administration (NHTSA). Please include responses to these 

questions in your written comments. In addition, please 

respond to the following questions.-

1. Your statement says that "refueling controls of any 

kind will have too little leverage on the ozone 

non-attainment situation to be cost-effective." The 

usual meaning of cost-effectiveness is the ratio of 

the cost of an action to the emission reduction it 

is expected to produce. Please explain your 

definition of cost-effectiveness which makes it a 

function of the size of the reduction as well as the 

ratio of cost to effect. 

2. What changes could be made to FMVSS 301 to increase 

the possibility that onboard safety problems would 

be addressed before production (e.g. increase impact 

speed, more or different types of impacts, changed 
P.3 

-2-

rollover procedures, etc.)? What other steps should 

EPA take to insure that unsafe designs are not used 

on production vehicles? 

3. NHTSA appears to believe that there have been a 

significant number of safety related recalls for 

evaporative control systems. What is your opinion, 

• and what steps are you taking to improve the safety 

of these systems? .-^ • 

4. Please describe, for liquid seals, all other 

approaches being evaluated in addition to the EPA 

prototype "j-tube" design. Include your evaluations 

of simple flapper valves at the end of the fill neck 

inside the fuel tank to form a liquid seal and/or 

control fuel splash back. Also include other liquid 

seal configurations designed to reduce the flow 

restriction of the liquid seal and the entrainment 

of ambient air as well as to allow the use of a 

liquid seal in low profile tanks. 

5. Please provide detailed performance data which you 

have used to determine required canister sizes and a 

full description of your methodology. Describe your 

evaluation of varied geometry and internal vapor 

flow patterns aimed at optimized canister sizing. 

6. Describe any specific safety issues you see related 

to larger vapor lines, considering the fact that 

there will be a shutoff valve at or near the fuel 

tank. Would a system such as described by Toyota at 

the public hearing, which eliminates the external 

vapor line found on most current vehicles, have any 

safety advantage relative to current vehicles? How 

much would the use of a simple flapper valve on the 

fill neck inside the fuel tank of such a system 

enhance safety compared to current designs which do 

not restrict the loss of fuel if the fill neck is 

severed in a crash? 

7. If you believe a liquid/vapor separator is required 

for your onboard system, please detail the need and 

the adverse consequences of not including this 

device. For example, if you believe that small 

droplets of liquid fuel might occasionally be 

carried over to the canister, describe how this 

would happen, why it would be a problem if it did 

and what other techniques are available for dealing 

with it. 

8. Do you believe there is any safety benefit 

associated with containing the vapors and reducing 

spillage during refueling? How can these be 

compared to the risk factors which have been raised? 
P.4 

-3-

9. How are you approaching the choice between 

integrated and separate onboard and evaporative 

control systems? Are there aspects of the test 

procedure which affect this choice? If so, what are 

they and what is the effect they have? How might 

EPA adjust the proposed procedure to encourage the 

use of integrated systems? 

10. Please describe your normal procedures Cor assuring 

the safety of fuel systems. Include a description 

of how you manage fuel system changes which are 

either small evolutionary, changes or larger type 

changes. Also include a detailed presentation of 

the safety analyses conducted when you implemented 

evaporative controls, pressurized fuel systems for 

fuel injection, and vapor vent lines external to the 

fuel filler pipe if you use them, showing all 

problems identified and solutions implemented. 

11. In a recent letter to Congressman Dingell, MVMA 

criticized EPA's estimate that approximately 20 

percent of Class lib HDGVs use dual tanks. Please 

provide the following information. What percentage 

of your Class lib HDGVs use dual gasoline tanks? 

What percentage of your total HDGV sales comes from 

Class lib and III vehicles? What percentage of your 

Class lib and III vehicles are sold to secondary 

manufacturers rather than directly to a retail 

dealer? 

We appreciate your responsiveness in this matter. 

Sincerely yours, 

Charles L. Grayv/J&/ 

Director 

Emission Control Technology Division 

Enclosure 
P.5 

Suggested Questions from NHTSA to ask 

about the Safety of Onboard Systems. 

1. What safety concerns, if any, do you have regarding 

onboard controls? What is the basis of those concerns? 

2. If onboard controls are required, are you likely to make 

additional changes to. the fuel system? If so, what are 

these changes? 

3. Will- you provide an "integrated" system, if onboard 

controls are mandated? If not, why not? '^'' 

4. What safety criteria do you use in designing onboard 

control systems? Do these extend to ease of repair and 

maintenance? 

5. Have you done research regarding fuel tank bladders? If 

so, what is the prognosis for this technology (i.e., 

feasible?, near-term?, etc.)? 

6. Where would the onboard cannisters be located? How do you 

assure that they do not pose any safety hazard? 

7. Do the crash test requirements of Federal Motor Vehicle 

Safety Standard (FMVSS) No. 301 represent a complete 

matrix of crash tests that you use for purposes of 

checking the crash safety/integrity of the fuel systems of 

your vehicles? If not, are there additional tests that 

you believe are needed? 

8. Does the pass/fail criteria of FMVSS 301, post-crash 

liquid fuel leakage, adequately assess the crash 

safety/integrity of the evaporative and/or onboard vapor 

control system? If not, what additional criteria do you> 

believe are needed? 

9. How do you test and evaluate your vehicle fuel systems for 

non-crash fire hazards? 

10. What sensitivity studies do you conduct for onboard 

systems? For example, what range of Reid Vapor Pressure 

(RVP) and ambient temperatures do you consider? 

11. How do you test and evaluate your vehicle fuel systems for 

durability? 

12. How many years or miles of maintenance-free life can be 

expected for the rubber, plastic, metal, charcoal, and 

other components of your onboard system? 
P.6 

13. What sorts of maintainance, if any, could be required for 

your onboard system over the life of the vehicle? if 

maintainance would be required, please submit details on 

expected cost and frequency. 

14. Is there any incentive for an. owner and/or mechanic to 

disconnect or tamper with your onboard system to improve 

performance or facilitate repairs to other vehicle systems? 

15. Is there any incentive to repair or replace damaged or 

disconnected portions of your onboard system? can the 

system be checked after repair, or periodically) as to its 

safety/integrity and function? 

16. Identify and describe all significant modifications to 

fuel and emission systems which will be required if 

onboard systems are to be installed? 

17. Explain why certain design alternatives may have been 

selected, e.g., liquid versus mechanical seal. 

18. How many prototypes have you developed? Describe each. 

Pro.vide a summary of the results of testing conducted on 

these prototypes. 

19. Furnish your opinion of any additional safety risks 

involved with onboard systems. Include an assessment of 

the following: 

a) the causal or contributory factors which could 

, increase the chances of a defect or 

non-compli ance, 

b) the failure mode, 

c) the risk to motor vehicle safety 

d) any forseeable warning to drivers of the problem.. 

20. Identify (by NHTSA recall number) all safety-related 

defect campaigns which have been conducted due to the 

design, construction and/or performance of systems and/or 

components which are similar in design or function as 

those which will be utilized in any onboard vapor recovery 

system. Provide a summary of the problem or failure 

involved and the number of known incidents, accidents and 

fatalities involved with each such recall campaign. 

21. Provide copies of all service bulletins and/or other 

communications to dealer/owners which were issued due to 

the design, construction and/or performance of systems 

and/or components which are similar in design or function 

as those which will be utilized in any onboard vapor 

recovery system. Provide a summary of the problem or 

failure involved and the number of known incidents, 

accidents and fatalities involved with each such bulletin 

or communication. 
P.7 

ft ' 

$ sf%\ \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

* t PRO* 0 

? ANN ARBOR. MICHIGAN 48105 

OFFICE OF 

AIR AND RADIATION 

M0V I Q :93T 

Mr. Brian O'Neill, President 

Insurance Institute for Highway Safety 

Watergate 600 

Washington, DC 20037 

Dear Mr. O'Neill: 

I am writing in response to your testimony at the recent 

onboard/volatility hearing held October 27-29, 1987 in 

Washington, DC. Due to the large number of testifiers and the 

broad range of issues covered by the two proposals, the time 

limits of the hearing prevented us from exploring your 

testimony as fully as we would have liked. In addition, some 

questions were submitted from the floor which we did not have 

time to present. Therefore, we are writing to you with some 

followup questions for inclusion in your written comments. We 

believe that most of these questions are such that they will 

already be included in your written comments. However, we wish 

to insure that these areas, which are of specific concern to 

EPA, are covered. 

Presented in the enclosed list are questions which we have 

been requested to ask by the National Highway Traffic Safety 

Administration (NHTSA). Please include responses to these 

questions in your written comments. In addition, please 

respond to the following questions. 

1. What changes could be made to FMVSS 301 to increase 

the possibility that onboard safety problems would 

be addressed before production (e.g. increase impact 

speed, more or different types of impacts, changed 

rollover procedures, etc.)? What other steps should 

EPA take to insure that unsafe designs are not used 

on production vehicles? 

2. Do you believe there is any safety benefit 

associated with containing the vapors and reducing 

spillage during refueling? How can these be 

compared to the risk factors which have been raised? 
P.8 

-2-

3. In its testimony, GM stated that to insure safety, 

only evolutionary changes can be made in fuel 

systems and that "responsible safety engineering 

cannot reconcile a new revolutionary fuel system in 

high volume production which does not have field 

experience..." Do you agree with this statement? 

Do you believe that the adoption of onboard controls 

is revolutionary? If not, why not? How would you 

compare the adoption of onboard controls to such 

changes as the conversion to electronic engine 

controls or pressurized fuel systems? 

We appreciate your responsiveness in this matter. 

Sincerely yours, 

Charles L. Gray, 

Director 

Emission Control Technology Division 

Enclosure 
P.9 

Suggested Questions from NHTSA to ask 

about the Safety of Onboard Systems. 

1. What safety concerns, if any, do you have regarding 

onboard controls? What is the basis of those concerns? 

2. If onboard controls are required, are you likely to make 

additional changes to the fuel system? If so, what are 

these changes? 

3. Will" you provide an "integrated" system if onboard 

controls are mandated? If not, why not? •:;*••'-' 

4. What safety criteria do you use in designing onboard 

control systems? Do these extend to ease of repair and 

maintenance? 

5. Have you done research regarding fuel tank bladders? If 

so, what is the prognosis for this technology (i.e., 

feasible?, near-term?, etc.)? 

6. Where would the onboard cannisters be located? How do you 

assure that they do not pose any safety hazard? 

7. Do the crash test requirements of Federal Motor Vehicle 

Safety Standard (FMVSS) No. 301 represent a complete 

matrix of crash tests that you use for purposes of 

checking the crash safety/integrity of the fuel systems of 

your vehicles? If not, are there additional tests that 

you believe are needed? 

8. Does the pass/fail criteria of FMVSS 301, post-crash 

liquid fuel leakage, adequately assess the crash 

safety/integrity of the evaporative and/or onboard vapor 

control system? If not, what additional criteria do yoi* 

believe are needed? 

9. How do you test and evaluate your vehicle fuel systems for 

non-crash fire hazards? 

10. What sensitivity studies do you conduct -for onboard 

systems? For example, what range of Reid Vapor Pressure 

(RVP) and ambient temperatures do you consider? 

11. How do you test and evaluate your vehicle fuel systems for 

durability? 

12. How many years or miles of maintenance-free life can be 

expected for the rubber, plastic,, metal, charcoal, and 

other components of your onboard system? 
P.10 

13. What sorts of maintainance, if any, could be required for 

your onboard system over the life of the vehicle? If 

maintainance would be required, please submit details on 

expected cost and frequency. 

14. Is there any incentive for an. owner and/or mechanic to 

disconnect or tamper with your onboard system to improve 

performance or facilitate repairs to other vehicle systems? 

15. Is there any incentive to repair or replace damaged or 

disconnected portions of your onboard system? can the 

system be checked after repair, or periodically) as to its 

safety/integrity and function? 

16. Identify and describe all significant modifications to 

fuel and emission systems which will be required if 

onboard systems are to be installed? 

17. Explain why certain design alternatives may have been 

selected, e.g., liquid versus mechanical seal. 

18. How many prototypes have you developed? Describe each. 

Provide a summary of the results of testing conducted on 

these prototypes. 

19. Furnish your opinion of any additional safety risks 

involved with onboard systems. Include an assessment of 

the following: 

a) the causal or contributory factors which could 

increase the chances of a defect or 

non-compliance, 

b) the failure mode, 

c) the risk to motor vehicle safety 

d) any forseeable warning to drivers of the problem.. 

20. Identify (by NHTSA recall number) all safety-related 

defect campaigns which have been conducted due to the 

design, construction and/or performance of systems and/or 

components which are similar in design or function as 

those which will be utilized in any onboard vapor recovery 

system. Provide a summary of the problem- or failure 

involved and the number of known incidents, accidents and 

fatalities involved with each such recall campaign. 

21. Provide copies of all service bulletins and/or other 

communications to dealer/owners which were issued due to 

the design, construction and/or performance of systems 

and/or components which are similar in design or function 

as those which will be utilized in any onboard vapor 

recovery system. Provide a summary of the problem or 

failure involved and the number of known incidents, 

accidents and fatalities involved with each such bulletin 

or communication. 
P.11 

y

) 

* A r i UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

j 

ANN ARBOR. MICHIGAN 48105 

OFFICE OF 

AIR AND RADIATION 

NfflM:aw. 

Mr. Richard Wiehl, Chairman 

Petroleum Marketers Association of America 

1120 Vermont Avenue, NW 

Suite 1130 

Washington, DC 20005 

Dear Mr. Wiehl: 

I am writing in response to your testimony at the recent 

onboard/volatility hearing held October 27-29, 1987 in 

Washington, DC. Due to the large number of testifiers and the 

broad range of issues covered by the two proposals, the time 

limits of the hearing prevented us from exploring your 

testimony as fully as we would have liked. In addition, some 

questions were submitted from the floor which we did not have 

time to present. Therefore, we are writing to you with some 

followup questions for inclusion in your written comments. We 

believe that most of these questions are such that they will 

already be included in your written comments. However, we wish 

to insure that these areas, which are of specific concern to 

EPA, are covered. 

Presented in the enclosed list are questions which we have 

been requested to ask by the National Highway Traffic Safety 

Administration (NHTSA). Please include responses to these 

questions in your written comments. In addition, please 

respond to the following questions. 

1. Your testimony about Stage II customer inconvenience 

costs cites API studies demonstrating that 

inconvenience cost can exceed a penny per gallon. 

Would you please supply these studies for the 

record? Your testimony also indicates that you have 

received numerous consumer complaints about Stage II 

equipment. Please supply evidence documenting these 

complaints and their frequency of occurrence. Also, 

please supply documentation of what you cite as 

customer actions which defeat the proper operation 

of the vapor recovery equipment. Is there data 

showing how frequently such actions occur? Finally, 

please supply copies of the studies which you 

reference as revealing that motorists may prefer 

full-service rather than self-service when Stage II 

equipment is installed. 
P.12 

-2-

2. Your testimony indicates that Stage II 

implementation might require seven years. Please 

detail your basis for this figure. Please provide 

documentation for your statement that it took seven 

years in San Diego. Also, please document the 25 

percent cost increases which you state have occurred 

since storage tank regulations went into effect. 

We appreciate your responsiveness in this mat-tjtr* 

Sincerely yours, 

Charles L. Gray,-ar'X 

Director 

Emission Control Technology Division 

Enclosure 
P.13 

Suggested Questions from NHTSA to ask 

about the Safety of Onboard Systems• 

1. What safety concerns, if any, do you have regarding 

onboard controls? What is the basis of those concerns? 

2. If onboard controls are required, are you likely to make 

additional changes to the fuel system? If so, what are 

these changes? 

3. Will-- you provide an "integrated" system. , if onboard 

controls are mandated? If not, why not? •^•'-' 

4. What safety criteria do you use in designing onboard 

control systems? Do these extend to ease of repair and 

maintenance? 

5. Have you done research regarding fuel tank bladders? If 

so, what is the prognosis for this technology (i.e., 

feasible?, near-term?, etc.)? 

6. Where would the onboard cannisters be located? How do you 

assure that they do not pose any safety hazard? 

7. Do the crash test requirements of Federal Motor Vehicle 

Safety Standard (FMVSS) No. 301 represent a complete 

matrix of crash tests that you use for purposes of 

checking the crash safety/integrity of the fuel systems of 

your vehicles? If not, are there additional tests that 

you believe are needed? 

8. Does the pass/fail criteria of FMVSS 301, post-crash 

liquid fuel leakage, adequately assess the crash 

safety/integrity of the evaporative and/or onboard vapor 

control system? If not, what additional criteria do you. 

believe are needed? 

9. How do you test and evaluate your vehicle fuel systems for 

non-crash fire hazards? 

10. What sensitivity studies do you conduct for onboard 

systems? For example, what range of Reid Vapor Pressure 

(RVP) and ambient temperatures do you consider? 

11. How do you test and evaluate your vehicle fuel, systems for 

durability? 

12. How many years or miles of maintenance-free life can be 

expected for the rubber, plastic, metal, charcoal, and 

other components of your onboard system? 
P.14 

13. What sorts of maintainance, if any, could be required for 

your onboard system over the life of the vehicle? if 

maintainance would be required, please submit details on 

expected cost, and frequency. 

14. Is there any incentive for an: owner and/or mechanic to 

disconnect or tamper with your onboard system to improve 

performance or facilitate repairs to other vehicle systems? 

15. Is there any incentive to repair or replace damaged or 

disconnected portions of your onboard system? Can the 

system be checked after repair, or periodically, as to its 

safety/integrity and function? 

16. Identify and describe all significant modifications to 

fuel and emission systems which will be required if 

onboard systems are to be installed? 

17. Explain why certain design alternatives may have been 

selected, e.g., liquid versus mechanical seal. 

18. How many prototypes have you developed? Describe each. 

Provide a summary of the results of testing conducted on 

these prototypes. 

19. Furnish your opinion of any additional safety risks 

involved with onboard systems. Include an assessment of 

the following: 

a) the causal or contributory factors which could 

increase the chances of a defect or 

non-compliance, 

b) the failure mode, 

c) the risk to motor vehicle safety 

d) any forseeable warning to drivers of the problem.. 

20. Identify (by NHTSA recall number) all safety-related 

defect campaigns which have been conducted due to the 

design, construction and/or performance of systems and/or 

components which are similar in design or function as 

those which will be utilized in any onboard vapor recovery 

system. Provide a summary of the problem or failure 

involved and the number of known incidents, accidents and 

fatalities involved with each such recall campaign. 

21. Provide copies of all service bulletins and/or other 

communications to dealer/owners which were issued due to 

the design, construction and/or performance of systems 

and/or components which are similar in design or function 

as those which will, be utilized in any onboard vapor 

recovery system. Provide a summary of the problem or 

failure involved and the number of known incidents, 

accidents and fatalities involved with each such bulletin 

or communication. 
P.15 

-J 

~ \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

ISEZ S 

^ OV |i-0 

ANN ARBOR. MICHIGAN 48105 

XP^ W |i-0 I987? 

OFFICE OF 

Mr. Nick Nikilla , Staff Directo r AIR AND RADIATION 

Air Pollutio n Control Program 

P.O. Box 176 

Jefferson City, MO 65102 

Dear Mr. Nikilla: •-*'

 :; 

I am writing in response to your testimony at the recent 

onboard/volatility hearing held October 27-29, 1987 in 

Washington, DC. Due to the large number of testifiers and the 

broad range of issues covered by the two proposals, the time 

limits of the hearing prevented us from exploring your 

testimony as fully as we would have liked. In addition, some 

questions were submitted from the floor which we did not have 

time to present. Therefore, we are writing to you with some 

followup questions for inclusion in your written comments. We 

believe that most of these questions ar- such that they will 

already be included in your written comments. However, we wish 

to insure that these areas, which are cf specific concern to 

EPA, are covered. 

Presented in the enclosed list are ruestions which we have 

been requested to ask by the National {ighway Traffic Safety 

Administration (NHTSA). Please includ? responses to these 

questions in your written comments. In addition, please 

respond to the following questions. 

1. Can you provide any data on the number of service 

stations that have gone out f business due td\ the 

St. Louis area stage II requirements? Can it be 

provided up through the end of this year? 

2. Can you provide data on :he extent to which 

transport from ozone attainme t areas contributes to 

ozone non-attainment in the S :. Louis area, and how 

much refueling controls in .ttainment areas would 

alleviate non-attainment in it. Louis? Could the 

same results be achieved by enlarging or redrawing 

the boundaries of AQCRS? 

We appreciate your responsiveness ir. this matter. 

Sincerely yours, 

Charles L. Gray ./.J, 

Director 

Emission Control Technolog- Division 

Enclosure 
P.16 

Suggested Questions from NHTSA to ask 

about the Safety of Onboard Systems. 

1. What safety concerns, if any, do you have regarding 

onboard controls? What is the basis of those concerns? 

2. If onboard controls are required, are you likely to make 

additional changes to the fuel system? If so, what are 

these changes? 

3. Will-- you provide an "integrated" system if onboard 

controls are mandated? If not, why not? ;-*-:-

4. What safety criteria do you use in designing onboard 

control systems? Do these extend to ease of repair and 

maintenance? 

5. Have you done research regarding fuel tank bladders? If 

so, what is the prognosis for this technology (i.e., 

feasible?, near-term?, etc.)? 

6. Where would the onboard cannistefs be located? How do you 

assure that they do not pose any safety hazard? 

7. Do the crash test requirements of Federal Motor Vehicle 

Safety Standard (FMVSS) No. 301 represent a complete 

matrix of crash tests that you use for purposes of 

checking the crash safety/integrity of the fuel systems of 

your vehicles? If not, are there additional tests that 

you believe are needed? 

8. Does the pass/fail criteria of FMVSS 301, post-crash 

liquid fuel leakage, adequately assess the crash 

safety/integrity of the evaporative and/or onboard vappr 

control system? If not, what additional criteria do you; 

believe are needed? 

9. How do you test and evaluate your vehicle fuel systems for 

non-crash fire hazards? 

10. What sensitivity studies do you conduct for onboard 

systems? For example, what range of Reid Vapor Pressure 

(RVP) and ambient temperatures do you consider? 

11. How do you test and evaluate your vehicle fuel systems for 

durability? 

12. How many years or miles of maintenance-free life can be 

expected for the rubber, plastic, metal, charcoal, and 

other components of your onboard system? 
P.17 

13. What sorts of maintainance, if any, could be required for 

your onboard system over the life of the vehicle? if 

maintainance would be required, please submit details on 

expected cost and frequency. 

14. Is there any incentive for an. owner and/or mechanic to 

disconnect or tamper with your onboard system to improve 

performance or facilitate repairs to other vehicle systems? 

15. Is there any incentive to repair or replace damaged or 

disconnected portions of your onboard system?. Can the 

system be checked after repair, or periodically) as to its 

safety/integrity and function? 

16. Identify and describe all significant modifications to 

fuel and emission systems which will be required if 

onboard systems are to be installed? 

17. Explain why certain design alternatives may have been 

selected, e.g., liquid versus mechanical seal. 

18. How many prototypes have you developed? Describe each. 

Provide a summary of the results of testing conducted on 

these prototypes. 

19. Furnish your opinion of any additional safety risks 

involved with onboard systems. Include an assessment of 

the following: 

a) the causal or contributory factors which could 

increase the chances of a defect or 

non-compliance, 

b) the failure mode, 

c) the risk to motor vehicle safety 

d) any forseeable warning to drivers of the problem.. 

20. Identify (by NHTSA recall number) all safety-related 

defect campaigns which have been conducted due to the 

design, construction and/or performance of systems and/or 

components which are similar in design or function as 

those which will be utilized in any onboard vapor recovery 

system. Provide a summary of the problem or failure 

involved and the number of known incidents, accidents and 

fatalities involved with each such recall campaign. 

21. Provide copies of all service bulletins and/or other 

communications to dealer/owners which were issued due to 

the design, construction and/or performance of systems 

and/or components which are similar in design or function 

as those which will be utilized in any onboard vapor 

recovery system. Provide a summary of the problem or 

failure involved and the number of known incidents, 

accidents and fatalities involved with each such bulletin 

or communication. 
P.18 

1 • 

/[ P A \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

I ^|^ i r ANN ARBOR. MICHIGAN 48105 x^/ 

OFFICE OF 

AIR AND RADIATION 

;^/;rCfi98?7 

Mr. Sam Leonard 

Auto Emission Control 

Environmental Activities Staff 

General Motors Corporation 

30400 Mound Road 

Warren, MI 48090-9015 

Dear Mr. Leonard: 

I am writing in response to your testimony at the recent 

onboard/volatility hearing held October 27-29, 1987 in 

Washington, DC. Due to the large number of testifiers and the 

broad range of issues covered by the two proposals, the time 

limits of the hearing prevented us from exploring your 

testimony as fully as we would have liked. In addition, some 

questions were submitted from the floor which we did not have 

time to present. Therefore, we are writing to you with some 

followup questions for inclusion in your written comments. We 

believe that most of these questions are such that they will 

already be included in your written comments- However, we wish 

to insure that these areas, which are of specific concern to 

EPA, are covered. 

-\ 

Presented in the enclosed list are questions which we have 

been requested to ask by the National Highway Traffic Safety 

Administration (NHTSA). Please include responses to these 

questions in your written comments. In addition, please 

respond to the following questions. 

1. Your statement says that ozor.a reductions year round 

in attainment areas or in non-ozone season months in 

non-attainment areas have no value. Please explain 

this position, including a detailed review of the 

literature on welfare effec.s and an analysis of 

ozone transport from ttainment areas to 

non-attainment areas. 

2. During its testimony GM indicated that Design 

Failure Mode and Effect ^alyses are done to 

evaluate safety issues. Pie?se provide the detailed 

DFMEAs that were done for th; following: 1) the 1985 

Buick Qentury fuel system, 2) the addition of 
P.19 

-2-

external vapor vent lines to fuel tanks, 3) the 

switch to pressurized fuel systems with the fuel 

pump located in the fuel tank, 4) the Mobil oil 

prototype onboard system, and 5) the use of 

partially submerged fill systems on some of your 

fuel tanks. 

Your statement also indicates that to insure safety, 

only evolutionary changes can be made in fuel 

systems and that "responsible safety engineering 

cannot reconcile a new revolutionary fuel system in 

high volume production which does not have field 

experience..." Please define the term 

"revolutionary" in this context and how it applies 

to onboard controls, considering ,the fact that 

current vehicles already employ vapor lines to 

direct vapors from the fuel tank to a canister, 

carbon canisters, purge control systems, and 

rollover protection valves. Was the conversion to 

electronic engine controls or pressurized fuel 

systems revolutionary and how were these reconciled 

with responsible safety engineering? 

Your statement says that canisters on many of your 

cars will have to be mounted in the rear quarter 

panel area, which is susceptible to dirt and water 

contaminants. Provide a model by model analysis of 

why such a location would require "major 

modification of the body sheet metal," why no 

alternatives exist, and how current canisters 

mounted in this location are protected from dirt and 

water contaminants. ^ 

Your statement says that for either mechanical or 

liquid seal, body structure and sheet metal changes 

would be required where the filler neck attaches to 

the body to accommodate the vapor vent control 

valve. Please detail all changes needed and 

describe alternative designs which you have 

evaluated to eliminate the changes. Include 

evaluations of valving size and physical location in 

the fill neck area as well as in the fuel tank area. 

What changes could be made to FMVSS 301 to increase 

the possibility that onboard safety problems would 

be addressed before production (e.g. increase impact 

speed, more or different types of impacts, changed 

rollover procedures, etc.)? What other steps should 

EPA take to insure that unsafe designs are not used 

on production vehicles? 
P.20 

-3-

7. NHTSA appears to believe that there have been a 

significant number of safety related recalls for 

evaporative control systems. What is your opinion, 

and. what steps are you taking to improve the safety 

of these systems? 

8. Please describe, for liquid seals, all other 

approaches being evaluated in addition to the EPA 

prototype "j-tube" design. Include youjE. evaluations 

of simple flapper valves at the end of the fill neck 

inside the fuel tank to form a liquid seal and/or 

control fuel splash back. . Also include other liquid 

seal configurations designed to reduce the flow 

restriction of the liquid seal and the entrainment 

of ambient air as well as to allow the use of a 

liquid seal in low profile tanks. 

9. Please provide detailed performance data which you 

have used to determine required canister sizes and a 

full description of your methodology. Describe your 

evaluation of varied geometry and internal vapor 

flow patterns aimed at optimized canister sizing. 

10. Describe any specific safety issues you see related 

to larger vapor lines, considering the fact that 

there will be a shutoff valve at or near the fuel 

tank. Would a system such as described by Toyota at 

the public hearing, which eliminates the external 

vapor line found on most current vehicles, have any 

safety advantage relative to current vehicles? How 

much would the use of a simple flapper valve on the 

fill neck inside the fuel tank of such a system 

enhance safety compared to current designs which do; 

not restrict the loss of fuel if the fill neck is 

severed in a crash? 

11. In discussing safety, Ford stated that canister 

location is not a safety issue, and that under-hood 

is an acceptable location. Chrysler stated.that its 

concerns about fire safety are not associated with 

the canister, but with other fuel system 

components. What is your opinion, considering the 

fact that current canisters are generally under the 

hood? 

12. If you believe a liquid/vapor separator is required 

for your onboard system, please detail the need and 

the adverse consequences of not including this 

device. For example, if you believe that small 

droplets of liquid fuel might occasionally be 

carried over to the canister, describe how this 

would happen, why it would be a problem if it did 

and what other techniques are available for dealing 

with it. 
P.21 

/ -4-

13. Do you believe there is any safety benefit 

associated with containing the vapors and reducing 

spillage • during refueling? How can these be 

compared to the risk factors which have been raised? 

14. How are you approaching the choice between 

integrated and separate onboard and evaporative 

•control systems? Are there aspects of the test 

procedure which affect this choice? If.-iso, what are 

they and what is the effect they have? How might 

EPA adjust the proposed procedure to encourage the 

use of integrated systems? 

15. Regarding the proposed test procedure, do you agree 

that the stabilized canister operating level reached 

by the cyclic drive-down for integrated systems is 

independent of whether or not the canister is loaded 

to breakthrough at the beginning of the test? If 

not, why not? If it is, how does the requirement to 

pre-load the canister "effectively eliminate, one 

strategy available to design engineers..."? Do you 

see this requirement performing a function other 

than insuring that the purge system is, in fact, 

functioning properly? 

16. In a recent letter to Congressman Dingell, MVMA 

criticized EPA's estimate that approximately 20 

percent of Class lib HDGVs use dual tanks. Please 

provide the following information. What percentage 

of your Class lib HDGVs use dual gasoline tanks? 

What percentage of your total HDGV sales comes from 

Class lib and III vehicles? What percentage of ,,your 

Class lib and III vehicles are sold to secondary 

manufacturers rather than directly to a retail 

dealer? 

We appreciate your responsiveness in this matter. 

Sincerely yours, 

Charles L. Gray, 

Director 

Emission Control Technology Division 

Enclosure 
y Suggested Questions from NHTSA to ask 

. about the Safety of Onboard Systems• 

1. What safety concerns, if any, do you have regarding 

onboard controls? What is the basis of those concerns? 

2. If onboard controls are required, are you likely to make 

additional changes to the fuel system? If so, what are 

these- changes? 

3. Will-- you provide an "integrated" system .if onboard 

controls are mandated? If not, why not? '**''"' 

4. What safety criteria do you use in designing onboard 

control systems? Do these extend to ease of repair and 

maintenance? 

5. Have you done research regarding fuel tank bladders? If 

so, what is the prognosis for this technology (i.e., 

feasible?, near-term?, etc.)? 

6. Where would the onboard cannistefs be located? How do you 

assure that they do not pose any safety hazard? 

7. Do the crash test requirements of Federal Motor Vehicle 

Safety Standard (FMVSS) No. 301 represent a complete 

matrix of crash tests that you use for purposes of 

checking the crash safety/integrity of the fuel systems of 

your vehicles? If not, are there additional tests that 

you believe are needed? 

8. Does the pass/fail criteria of FMVSS 301, post-crash 

liquid fuel leakage, adequately assess the crash 

safety/integrity of the evaporative and/or onboard vapor 

control system? If not, what additional criteria do you> 

believe are needed? 

9. How do you test and evaluate your vehicle fuel systems for 

non-crash fire hazards? 

10. What sensitivity studies do you conduct for onboard 

systems? For example, what range of Reid Vapor Pressure 

(RVP) and ambient temperatures do you consider? 

11. How do you test and evaluate your vehicle fuel systems for 

durability? 

12. How many years or miles of maintenance-free life can be 

expected for the rubber, plastic, metal, charcoal, and 

other components of your onboard system? 
P.23 

/ 13. What sorts of maintainance, if any, could be required for 

your onboard system over the life of the vehicle? if 

maintainance would be required, please submit details on 

expected cost and frequency. 

14. Is there any incentive for an. owner and/or mechanic to 

disconnect or tamper with your onboard system to improve 

performance or facilitate repairs to other vehicle systems? 

15. Is there any incentive to repair or replace damaged or 

disconnected portions of your onboard system?.. Can the 

system be checked after repair, or periodically) as to its 

safety/integrity and function? 

16. Identify and describe all significant modifications to 

fuel and emission systems which will be required if 

onboard systems are to be installed? 

17. Explain why certain design alternatives may have been 

selected, e.g., liquid versus mechanical seal. 

18. How many prototypes have you developed? Describe each. 

Provide a summary of the results of testing conducted on 

these prototypes. 

19. Furnish your opinion of any additional safety risks 

involved with onboard systems. Include an assessment of 

the following: 

a) the causal or contributory factors which could 

increase the chances of a defect or 

non-compliance, 

b) the failure mode, 

c) the risk to motor vehicle safety 

d) any forseeable warning to drivers of the problem.. 

20. Identify (by NHTSA recall number) all safety-related 

defect campaigns which have been conducted due to the 

design, construction and/or performance of systems and/or 

components which are similar in design or function as 

those which will be utilized in any onboard vapor recovery 

system. Provide a summary of the problem or failure 

involved and the number of known incidents, accidents and 

fatalities involved with each such recall campaign. 

21. Provide copies of all service bulletins and/or other 

communications to dealer/owners which were issued due to 

the design, construction and/or performance of systems 

and/or components which are similar in design or function 

as those which will be utilized in any onboard vapor 

recovery system. Provide a summary of the problem or 

failure involved and the number of known incidents, 

accidents and fatalities involved with each such bulletin 

or communication. 
P.24 

4 . 

\ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY l *' aa.m ^ 

\jS*e>J AN N ARBOR. MICHIGAN 48105 

NOV 1 0 1987" 

OFFICE OF 

AIR AND RADIATION 

Mr. Gordon E. Allardyce, Manager .v.- • 

Certification & Regulatory Programs 

Chrysler Corporation 

418-02-36 

P.O. Box 1118 

Detroit, MI 48288 

Dear Mr. Allardyce: 

I am writing in response to your testimony at the recent 

onboard/volatility hearing held October 27-29, 1987 in 

Washington, DC. Due to the large number of testifiers and the 

broad range of issues covered by the two proposals, the time 

limits of the hearing prevented us from exploring your 

testimony as fully as we would have liked. In addition, some 

questions were submitted from the floor which we did not have 

time to present. Therefore, we are writing to you with some 

followup questions for inclusion in your written comments. We 

believe that most of these questions are such that they will 

already be included in your written comments. However, we wish 

to insure that these areas, which are of specific concern to 

EPA, are covered. 

Presented in the enclosed list are questions which we^havebeen requested to ask by the National Highway Traffic Safety 

Administration (NHTSA). Please include responses to these 

questions in your written comments. In addition, please 

respond to the following questions. 

1. What changes could be made to FMVSS 301 to increase 

the possibility that onboard safety problems would 

be addressed before production (e.g. increase impact 

speed, more or different types of impacts, changed 

rollover procedures, etc.)? What other steps should 

EPA take to insure that unsafe designs are not used 

on production vehicles? 

2. NHTSA appears to believe that there have been a 

significant number of safety related recalls for 

evaporative control systems. What is your opinion, 

and what steps are you taking to improve the safety 

of these systems? 
P.25 

-2-

3. Please describe, for liquid seals, all other 

approaches being evaluated in addition to the EPA 

prototype "j-tube" design. Include your evaluations 

of simple flapper valves at the end of the fill neck 

inside the fuel tank to form a liquid seal and/or 

control fuel splash back. Also include other liquid 

seal configurations designed to reduce the flow 

• restriction of the liquid seal and the entrainment 

of ambient air as well as to allow i^ne' use of a 

liquid seal in low profile tanks. 

4. Please provide detailed performance data which you 

have used to determine required canister sizes and a 

full description of your methodology. Describe your 

evaluation of varied geometry and internal vapor 

flow patterns aimed at optimized canister sizing. 

5. Describe any specific safety issues you see related 

to larger vapor lines, considering the fact that 

there will be a shutoff valve at or near the fuel 

tank. Would a system such as described by Toyota at 

the public hearing, which eliminates the external 

vapor line found on most current vehicles, have any 

safety advantage relative to current vehicles? How 

much would the use of a simple flapper valve on the 

fill neck inside the fuel tank of such a system 

enhance safety compared to current designs which do 

not restrict the loss of fuel if the fill neck is 

severed in a crash? 

6. If you believe a liquid/vapor separator is required, 

for your onboard system, please detail the needv and 

the adverse consequences of not including this 

device. For example, if you believe that small 

droplets of liquid fuel might occasionally be 

carried over to the canister, describe how this 

would happen, why it would be a problem if it did 

and what other techniques are available for dealing 

with it. 

7. Do you believe there is any safety benefit 

associated with containing the vapors and reducing 

spillage during refueling? How can these be 

compared to the risk factors which have been raised? 

8. How are you approaching the choice between 

integrated and separate onboard and evaporative 

control systems? Are there aspects of the test 

procedure which affect this choice? If so, what are 

they and what is the effect they have? How might 

EPA adjust the proposed procedure to encourage the 

use of integrated systems? 
P.26 

-3-

9. - Please describe your normal procedures for assuring 

the safety of fuel systems. Include a description 

of how you manage fuel system changes which are 

either small evolutionary changes or larger type 

changes. Also include a detailed presentation of 

the safety analyses conducted when you implemented 

evaporative controls, pressurized fuel systems for 

' fuel injection, and vapor vent lines external to the 

fuel filler pipe if you use them, Showing all 

problems identified and solutions implemented. 

10. In a recent letter to Congressman Dingell, MVMA 

criticized EPA's estimate that approximately 20 

percent of Class lib HDGVs use dual tanks. Please 

provide the following information. What percentage 

of your Class lib HDGVs use dual gasoline tanks? 

What percentage of your total HDGV sales comes from 

Class lib and III vehicles? What percentage of your 

Class lib and III vehicles are sold to secondary 

manufacturers rather than directly to a retail 

dealer? 

We appreciate your responsiveness in this matter. 

Sincerely yours, 

•- '/ y . . ••' (_ st-a \ L ,;_>- ( 

Charles L. 

Director 

Emission Control Technology Division 

Enclosure 
P.27 

Suggested Questions from NHTSA to ask 

about the Safety of Onboard Systems• 

1. What safety concerns, if any, do you have regarding 

onboard controls? What is the basis of those concerns? 

2. If onboard controls are required, are you likely to make 

additional changes to the fuel system? If so, what are 

these changes? 

3. Will-- you provide an "integrated" system. y if onboard 

controls are mandated? If not, why not? '*•*""' 

4. What safety criteria do you use in designing onboard 

control systems? Do these extend to ease of repair and 

maintenance? 

5. Have you done research regarding fuel tank bladders? If 

so, what is the prognosis for this technology (i.e., 

feasible?, near-term?, etc.)? 

6. Where would the onboard cannisters be located? How do you 

assure that they do not pose any safety hazard? 

7. Do the crash test requirements of Federal Motor Vehicle 

Safety Standard (FMVSS) No. 301 represent a complete 

matrix of crash tests that you use for purposes of 

checking the crash safety/integrity of the fuel systems of 

your vehicles? If not, are there additional tests that 

you believe are needed? 

8. Does the pass/fail criteria of FMVSS 301, post-crash 

liquid fuel leakage, adequately assess the crash 

safety/integrity of the evaporative and/or onboard vapor 

control system? If not, what additional criteria do you: 

believe are needed? 

9. How do you test and evaluate your vehicle fuel systems for 

non-crash fire hazards? 

10. What- sensitivity studies do you conduct for onboard 

systems? For example, what range of Reid Vapor Pressure 

(RVP) and ambient temperatures do you consider? 

11. How do you test and evaluate your vehicle fuel systems for 

durability? 

12. How many years or miles of maintenance-free life can be 

expected for the rubber, plastic, metal, charcoal, and 

other components of your onboard system? 
P.28 

13. What sorts of maintainance, if any, could be required for 

your onboard system over the life of the vehicle? if 

maintainance would be required, please submit details on 

expected cost and frequency. 

14. Is there any incentive for an. owner and/or mechanic to 

disconnect or tamper with your onboard system to improve 

performance or facilitate repairs to other vehicle systems? 

15. Is there any incentive to repair or replace damaged or 

disconnected portions of your onboard system? Can the 

system be checked after repair, or periodically, as to its 

safety/integrity and function? 

16. Identify and describe all significant modifications to 

fuel and emission systems which will be required if 

onboard systems are to be installed? 

17. Explain why certain design alternatives may have been 

selected, e.g., liquid versus mechanical seal. 

18. How many prototypes have you developed? Describe each. 

Provide a summary of the results of testing conducted on 

these prototypes. 

19. Furnish your opinion of any additional safety risks 

involved with onboard systems. Include an assessment of 

the following: 

a) the causal or contributory factors which could 

increase the chances of a defect or 

non-c omp1i ance, 

b) the failure mode, 

c) the risk to motor vehicle safety 

d) any forseeable warning to drivers of the problem.. 

20. Identify (by NHTSA recall number) all safety-related 

defect campaigns which have been conducted due to the 

design, construction and/or performance of systems and/or 

components which are similar in design or function as 

those which will be utilized in any onboard vapor recovery 

system. Provide a summary of the problem or failure 

involved and the number of known incidents, accidents and 

fatalities involved with each such recall campaign. 

21. Provide copies of all service bulletins and/or other 

communications to dealer/owners which were issued due to 

the design, construction and/or performance of systems 

and/or components which are similar in design or function 

as those which will be utilized in any onboard vapor 

recovery system. Provide a summary of the problem or 

failure involved and the number of known incidents, 

accidents and fatalities involved with each such bulletin 

or communication. 
P.29 

^ 

\ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

\$a*WerJ ANN ARBOR. MICHIGAN 48105 

%PRO* & 

OFFICE OF 

AIR AND RADIATION 

N0WIQI9S7 

Mr. David Doniger -••?-:-

;' 

Natural Resources Defense Council, Inc. 

Suite 300 

1350 New York Avenue, NW 

Washington, DC 20005 

Dear Mr. Doniger: 

I am writing in response to your testimony at the recent 

onboard/volatility hearing held October 27-29, 1987 in 

Washington, DC. Due to the large number of testifiers and the 

broad range of issues covered by the two proposals, the time 

limits of the hearing prevented us from exploring your 

testimony as fully as we would have liked. In addition, some 

questions were submitted from the floor which we did not have 

time to present. Therefore, we are writing to you with some 

followup questions for inclusion in your written comments. We 

believe that most of these questions are such that they will 

already be included in your written comments. However, we wish 

to insure that these areas, which are of specific concern to 

EPA, are covered. 

Presented in the enclosed list are questions which we have 

been requested to ask by the National Highway Traffic Safety 

Administration (NHTSA). Please include responses to these 

questions in your written comments. In addition, please 

respond to the following questions. 

1. In its testimony, General Mcv.ors argued that ozone 

reductions in attainment areas have no value. GM 

also stated that ozone reductions in non-attainment 

areas are only of value during the ozone season. 

Does NCAC agree with this position? If not, what 

value do you believe should oe used for hydrocarbon 

reductions of these sorts? ?lease substantiate any 

suggested value with quantitative supporting 

analysis. 

2. Some commenters have argued that the potential 

safety risks associated with onboard systems would 

act to offset the other benefits of refueling 

controls. Please provide your views on this issue. 
P.30 

-2-

3. In its testimony, GM stated that to insure safety, 

only evolutionary changes can be made in fuel 

systems and that "responsible safety engineering 

cannot reconcile a new revolutionary fuel system in 

high volume production which does not have field 

experience..." Do you agree with this statement? 

Do you believe that the adoption of onboard controls 

.is revolutionary? If not, why not? How would you 

compare the adoption of onboard controls to such 

changes as the conversion to electronic engine 

controls or pressurized fuel systems? 

We appreciate your responsiveness in this matter. 

Sincerely yours, 

/ 7 / >i:-i C -"'My .Jjn 

Charles L. Grayray, / Jr. 

Director 

Emission Control Technology Division 

Enclosure 
P.31 

Suggested Questions from NHTSA to ask 

about the Safety of Onboard Systems• 

1. What safety concerns, if any, do you have regarding 

onboard controls? What is the basis of those concerns? 

2. If onboard controls are required, are you likely to make 

additional changes to the fuel system? If so, what are 

these changes? 

3. Will-- you provide an "integrated" system if onboard 

controls are mandated? If not, why not? ••;•*—' 

4. What safety criteria do you use in designing onboard 

control systems? Do these extend to ease of repair and 

maintenance? 

5. Have you done research regarding fuel tank bladders? If 

so, what is the prognosis for this technology (i.e., 

feasible?, near-term?, etc.)? 

6. Where would the onboard cannisters be located? How do you 

assure that they do not pose any safety hazard? 

7. Do the crash test requirements of Federal Motor Vehicle 

Safety Standard (FMVSS) No. 301 represent a complete 

matrix of crash tests that you use for purposes of 

checking the crash safety/integrity of the fuel systems of 

your vehicles? If not, are there additional tests that 

you believe are needed? 

8. Does the pass/fail criteria of FMVSS 301, post-crash 

liquid fuel leakage, adequately assess the crash 

safety/integrity of the evaporative and/or onboard vappr 

control system? If not, what additional criteria do you; 

believe are needed? 

9. How do you test and evaluate your vehicle fuel systems for 

non-crash fire hazards? 

10. What sensitivity studies do you conduct -for onboard 

systems? For example, what range of Reid Vapor Pressure 

(RVP) and ambient temperatures do you consider? 

11. How do you test and evaluate your vehicle fuel systems for 

durability? 

12. How many years or miles of maintenance-free life can be 

expected for the rubber, plastic, metal, charcoal, and 

other components of your onboard system? 
P.32 

13. What sorts of maintainance, if any, could be required for 

your onboard system over the life of the vehicle? if 

maintainance would be required, please submit details on 

expected cost and frequency. 

14. Is there any incentive for an. owner and/or mechanic to 

disconnect or tamper with your onboard system to improve 

performance or facilitate repairs to other vehicle systems? 

15. Is there any incentive to repair or replace damaged or 

disconnected portions of your onboard system? Can the 

system be checked after repair, or periodically) as to its 

safety/integrity and function? 

16. Identify and describe all significant modifications to 

fuel and emission systems which will be required if 

onboard systems are to be installed? 

17. Explain why certain design alternatives may have been 

selected, e.g., liquid versus mechanical seal. 

18. How many prototypes have you developed? Describe each. 

Provide a summary of the results of testing conducted on 

these prototypes. 

19. Furnish your opinion of any additional safety risks 

involved with onboard systems. Include an assessment of 

the following: 

a) the causal or contributory factors which could 

increase - the chances of a defect or 

non-compliance, 

b) the failure mode, 

c) the risk to motor vehicle safety 

d) any forseeable warning to drivers of the problem,. 

20. Identify (by NHTSA recall number) all safety-related 

defect campaigns which have been conducted due to the 

design, construction and/or performance of systems and/or 

components which are similar in design or function as 

those which will be utilized in any onboard vapor recovery 

system. Provide a summary of the problem- or failure 

involved and the number of known incidents, accidents and 

fatalities involved with each such recall campaign. 

21. Provide copies of all service bulletins and/or other 

communications to dealer/owners which were issued due to 

the design, construction and/or performance of systems 

and/or components which are similar in design or function 

as those which will be utilized in any onboard vapor 

recovery system. Provide a summary of the problem or 

failure involved and the number of known incidents, 

accidents and fatalities involved with each such bulletin 

or communication. 
P.33 

* " 4 A \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

ANN ARBOR. MICHIGAN 48105 

\ 0 I98T 

OFFICE OF 

AIR AND RADIATION 

Mr. Clarence Ditlow .;.s- • 

Center for Auto Safety 

2001 S Street NW, Suite 410 

Washington, DC 20009 

Dear Mr. Ditlow: 

I am writing in response to your testimony at the recent 

onboard/volatility hearing held October 27-29, 1987 in 

Washington, DC. Due to the large number of testifiers and the 

broad range of issues covered by the two proposals, the time 

limits of the hearing prevented us from exploring your 

testimony as fully as we would have liked. In addition, some 

questions were submitted from the floor which we did not have 

time to present. Therefore, we are writing to you with some 

followup questions for inclusion in your written comments. We 

believe that most of these questions are such that they will 

already be included in your written comments. However, we wish 

to insure that these areas, which are of specific concern to 

EPA, are covered. 

Presented in the enclosed list are questions which we have 

been requested to ask by the National Highway Traffic Safety 

Administration (NHTSA). Please include responses to these 

questions in your written comments. In addition, please 

respond to the following questions. 

1. What changes could be made to FMVSS 301 to increase 

the possibility that onboard safety problems would 

be addressed before production (e.g. increase impact 

speed, more or different types of impacts, changed 

rollover procedures, etc.)? What other steps should 

EPA take to insure that unsafe designs are not used 

on production vehicles? 

2. Do you believe there is any safety benefit 

associated with containing the vapors and reducing 

spillage during refueling? How can these be 

compared to the risk factors which have been raised? 

3. In its testimony, GM stated that to insure safety, 

only evolutionary changes can be made in fuel 

systems and that "responsible safety engineering 

cannot reconcile a new revolutionary fuel system in 
P.34 

-2-

high volume production which does not have field 

experience..." Do you agree with this statement? 

Do you believe that the adoption of onboard controls 

is revolutionary? If not, why not? How would you 

compare the adoption of onboard controls to such 

changes as the conversion to electronic engine 

controls or pressurized fuel systems? 

We appreciate your responsiveness in this matte%V 

Sincerely yours, 

Charles L. Gray /J Jr./ 

Director

 l/ 

Emission Control Technology Division 

Enclosure 
P.35 

2. 

3. 

4. 

Suggested Questions from NHTSA to ask 

about the Safety of Onboard Systems. 

What safety concerns, if any, do you have regarding 

onboard controls? What is the basis of those concerns? 

If onboard controls are required, are you likely to make 

additional changes to the fuel system? If so, what are 

these changes? 

Will- you provide an "integrated" system if onboard 

controls are mandated? If not, why not? .;JJ' 

What safety criteria do you use in designing onboard 

control systems? Do these extend to ease of repair and 

maintenance? 

Have you done research regarding fuel 

so, what is the prognosis for this 

feasible?, near-term?, etc.)? 

tank bladders? If 

technology (i.e., 

6. Where would the onboard cannisters be located? How do you 

assure that they do not pose any safety hazard? 

7. Do the crash test requirements of Federal Motor Vehicle 

Safety Standard (FMVSS) No. 301 represent a complete 

matrix of crash tests that you use for purposes of 

checking the crash safety/integrity of the fuel systems of 

your vehicles? If not, are there additional tests that 

you believe are needed? 

8. Does the pass/fail criteria of FMVSS 301, post-crash 

liquid fuel leakage, adequately assess the crash 

safety/integrity of the evaporative • and/or onboard vapor 

control system? If not, what additional criteria do you 

believe are needed? 

9. How do you test and evaluate your vehicle fuel systems for 

non-crash fire hazards? 

10. What sensitivity studies do you conduct for onboard 

systems? For example, what range of Reid Vapor Pressure 

(RVP) and ambient temperatures do you consider? 

11. How do you test and evaluate your vehicle fuel systems for 

durability? 

12. How many years or miles of maintenance-free life can be 

expected for the rubber, plastic, metal, charcoal, and 

other components of your onboard system? 
P.36 

13. What sorts of maintainance, if any, could be required for 

your onboard system over the life of the vehicle? if 

maintainance would be required, please submit details on 

expected cost and frequency. 

14. Is there any incentive for an. owner and/or mechanic to 

disconnect or tamper with your onboard system to improve 

performance or facilitate repairs to other vehicle systems? 

15. Is there any incentive to repair or replace damaged or 

disconnected portions of your onboard system! Can the 

system be checked after repair, or periodically) as to its 

safety/integrity and function? 

16. Identify and describe all significant modifications to 

fuel and emission systems which will be required if 

onboard systems are to be installed? 

17. Explain why certain design alternatives may have been 

selected, e.g., liquid versus mechanical seal. 

18. How many prototypes have you developed? Describe each. 

Provide a summary of the results of testing conducted on 

these prototypes. 

19. Furnish your opinion of any additional safety risks 

involved with onboard systems. Include an assessment of 

the following: 

a) the causal or contributory factors which could 

increase the chances of a defect or 

non-compli ance, 

b) the failure mode, 

c) the risk to motor vehicle safety 

d) any forseeable warning to drivers of the problem.. 

20. Identify (by NHTSA recall number) all safety-related 

defect campaigns which have been conducted due to the 

design, construction and/or performance of systems and/or 

components which are similar in design or function as 

those which will be utilized in any onboard vapor recovery 

system. Provide a summary of the problem or failure 

involved and the number of known incidents, accidents and 

fatalities involved with each such recall campaign. 

21. Provide copies of all service bulletins and/or other 

communications to dealer/owners which were issued due to 

the design, construction and/or performance of systems 

and/or components which are similar in design or function 

as those which will be utilized in any onboard vapor 

recovery system. Provide a summary of the problem or 

failure involved and the number of known incidents, 

accidents and fatalities involved with each such bulletin 

or communication. 
P.37 

^°>, 

» 

% "W*0 

^ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

Si 

_.* ANN ARBOR. MICHIGAN 48105 

N»!j0!95f 

OFFICE OF 

AIR AND RADIATION 

Mr. Glenn Moore, Vice President 

OPW 

Fueling Components Group 

9393 Princeton-Glendale Road 

P.O. Box 405003 

Cincinnati, OH 45240-5003 

Dear Mr. Moore: 

I am writing in response to your testimony at the recent 

onboard/volatility hearing held October 27-29, 1987 in 

Washington, DC. Due to the large number of testifiers and the 

broad range of issues covered by the two proposals, the time 

limits of the hearing prevented us from exploring your 

testimony as fully as we would have liked. In addition, some 

questions were submitted from the floor which we did not have 

time to present. Therefore, we are writing to you with some 

followup questions for inclusion in your written comments. We 

believe that most of these questions are such that they will 

already be included in your written comrents. However, we wish 

to insure that these areas, which are of specific concern to 

EPA, are covered. 

Presented in the enclosed list are questions which we have 

been requested to ask by the National Highway Traffic Safety 

Administration (NHTSA). Please include responses to these 

questions in your written comments. In addition, please 

respond to the following questions. 

1. There has been testimony tha- many motorists do not 

wait the required 10 seconds after pumping to 

withdraw the Stage II nozzle from the auto's fill 

pipe. Is any wait required for the equipment to be 

fully effective? How long a wait? What is the 

effect of not waiting? If a wait was necessary only 

with older equipment, when did the waiting 

requirement become obsolete and why do the nozzles 

still carry a warning that the user should wait 

after shut-off? 
P.38 

-2-

2. Would you expect the costs of stage II nozzles and 

other equipment to fall significantly if EPA 

required- stage II controls in 26 additional urban 

areas? What if they were required nationwide? How 

much of a reduction would you anticipate under each 

scenario? Does experience with conventional 

equipment shed any light on this? 

We appreciate your responsiveness in this matifef. 

Sincerely yours, 

^'>it'V Q£h*uu _JL . 

Charles L. Gray/ Jj. 

Director 

Emission Control Technology Division 

Enclosure 
P.39 

Suggested Questions from NHTSA to ask 

about the Safety of Onboard Systems. 

1. What safety concerns, if any, do you have regarding 

onboard controls? What is the basis of those concerns? 

2. If onboard controls are required, are you likely to make 

additional changes to the fuel system? If so, what are 

these changes? 

3. will-- you provide an "integrated" system if onboard 

controls are mandated? If not, why not? ••:•*—•' 

4. What safety criteria do you use in designing onboard 

control systems? Do these extend to ease of repair and 

maintenance? 

5. Have you done research regarding fuel tank bladders? If 

so, what is the prognosis for this technology (i.e., 

feasible?, near-term?, etc.)? 

6. Where would the onboard cannisters be located? How do you 

assure that they do not pose any safety hazard? 

7. Do the crash test requirements of Federal Motor Vehicle 

Safety Standard (FMVSS) No. 301 represent a complete 

matrix of crash tests that you use for purposes of 

checking the crash safety/integrity of the fuel systems of 

your vehicles? If not, are there additional tests that 

you believe are needed? 

8. Does the pass/fail criteria of FMVSS 301, post-crash 

liquid fuel leakage, adequately assess the crash 

safety/integrity of the evaporative and/or onboard vapor 

control system? If not, what additional criteria do youbelieve are needed? 

9. How do you test and evaluate your vehicle fuel systems for 

non-crash fire hazards? 

10. What sensitivity studies do you conduct for onboard 

systems? For example, what range of Reid Vapor Pressure 

(RVP) and ambient temperatures do you consider? 

11. How do you test and evaluate your vehicle fuel systems for 

durability? 

12. How many years or miles of maintenance-free life can be 

expected for the rubber, plastic,, metal, charcoal, and 

other components of your onboard system? 
P.40 

13. What sorts of maintainance, if any, could be required for 

your onboard system over the life of the vehicle? if 

maintainance would be required, please submit details on 

expected cost and frequency. 

14. Is there any incentive for an. owner and/or mechanic to 

disconnect or tamper with your onboard system to improve 

performance or facilitate repairs to other vehicle systems? 

15. Is there any incentive to repair or replace damaged or 

disconnected portions of your onboard system? Can the 

system be checked after repair, or periodically) as to its 

safety/integrity and function? 

16. Identify and describe all significant modifications to 

fuel and emission systems which will be required if 

onboard systems are to be installed? 

17. Explain why certain design alternatives may have been 

selected, e.g., liquid versus mechanical seal. 

18. How many prototypes have you developed? Describe each. 

Provide a summary of the results of testing conducted on 

these prototypes. 

19. Furnish your opinion of any additional safety risks 

involved with onboard systems. Include an assessment of 

the following: 

a) the causal or contributory factors which could 

increase the chances of a defect or 

non-compliance, 

b) the failure mode, 

c) the risk to motor vehicle safety 

d) any forseeable warning to drivers of the problem.. 

20. Identify (by NHTSA recall number) all safety-related 

defect campaigns which have been conducted due to the 

design, construction and/or performance of systems and/or 

components which are similar in design or function as 

those which will be utilized in any onboard vapor recovery 

system. Provide a summary of the problem or failure 

involved and the number of known incidents, accidents and 

fatalities involved with each such recall campaign. 

21. Provide copies of all service bulletins and/or other 

communications to dealer/owners which were issued due to 

the design, construction and/or performance of systems 

and/or components which are similar in design or function 

as those which will be utilized in any onboard vapor 

recovery system. Provide a summary of the problem or 

failure involved and the number of known incidents, 

accidents and fatalities involved with, each such bulletin 

or communication. 
P.41 

. i •* 

' •*"> . 

P A \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY W ANN ARBOR. MICHIGAN 48105 

OFFICE OF 

AIR AND RADIATION 

NOV I 0 19$ 

Mr. Vic Rasheed •.;#••-

Service Station Dealers Association 

304 Pennsylvania Avenue, SE 

Washington, DC 20003 

Dear Mr. Rasheed: 

I am writing in response to your testimony at the recent 

onboard/volatility hearing held October 27-29, 1987 in 

Washington, DC. Due to the large number of testifiers and the 

broad range of issues covered by the two proposals, the time 

limits of the hearing prevented us from exploring your 

testimony as fully as we would have liked. In addition, some 

questions were submitted from the floor which we did not have 

time to present. Therefore, we are writing to you with some 

followup questions for inclusion in your written comments. We 

believe that most of these questions are such that they will 

already be included in your written comments. However, we wish 

to insure that these areas, which are of specific concern to 

EPA, are covered. 

Presented in the enclosed list are questions which we have 

been requested to ask by the National Highway Traffic Safety: 

Administration (NHTSA). Please include responses to these 

questions in your written comments. In addition, please 

respond to the following questions. 

1. In your testimony you testified that insurance costs 

increased $20 per nozzle with Stage II systems. Can 

this be documented? Is it due to the increased 

amount of equipment or to increased liability? 

2. Your testimony states "Stage II has been responsible 

for thousands of accidents which have harmed 

motorists and cost dealers money." Can this 

statement be documented? Your testimony also states 

that problems continue with state-of-the-art 

equipment. Can this be documented? How many 

incidents are happening on an annual basis? Can the 

examples given in the testimony be documented, along 

with other examples? 
P.42 

J- ' 

s 

- 2-

3. Your testimony indicated a minimum leadtime for 

Stage II of 5 years. Please provide an explanation 

of the basis for this period. 

We appreciate your responsiveness in this matter. 

Sincerely yours, 

Charles L. Gray^lAJry. 

Director 

Emission Control Technology Division 

Enclosure 
P.43 

Suggested Questions from NHTSA-to ask 

about the Safety of Onboard Systems. 

1. What safety concerns, if any, do you have regarding 

onboard controls? What is the basis of those concerns? 

2. If onboard controls are required, are you likely to make 

additional changes to the fuel system? If so, what are 

these changes? 

3. Will-- you provide an "integrated" system- if onboard 

controls are mandated? If not, why not? -^-; 

4. What safety criteria do you use in designing onboard 

control systems? Do these extend to ease of repair and 

maintenance? 

5. Have you done research regarding fuel tank bladders? if 

so, what is the prognosis for this technology (i.e., 

feasible?, near-term?, etc.)? 

6. Where would the onboard cannisters be located? How do you 

assure that they do not pose any safety hazard? 

7. Do the crash test requirements of Federal Motor Vehicle 

Safety Standard (FMVSS) No. 301 represent a complete 

matrix of crash tests that you use for purposes of 

checking the crash safety/integrity of the fuel systems of 

your vehicles? If not, are there additional tests that 

you believe are needed? 

8. Does the pass/fail criteria of FMVSS 301, post-crash 

liquid fuel leakage, adequately assess the crash 

safety/integrity of the evaporative and/or onboard vappr 

control system? If not, what additional criteria do you. 

believe are needed? 

9. How do you test and evaluate your vehicle fuel systems for 

non-crash fire hazards? 

10. What sensitivity studies do you conduct for onboard 

systems? For example, what range of Reid Vapor Pressure 

(RVP) and ambient temperatures do you consider? 

11. How do you test and evaluate your vehicle fuel, systems for 

durability? 

12. How many years or miles of maintenance-free life can be 

expected for the rubber, plastic, metal, charcoal, and 

other components of your onboard system? 
P.44 

13. What sorts of maintainance, if any, could be required for 

your onboard system over the life of the vehicle? if 

maintainance would be required, please submit details on 

expected cost and frequency. 

14. Is there any incentive for an. owner and/or mechanic to 

disconnect or tamper with your onboard system to improve 

performance or facilitate repairs to other vehicle systems? 

15. Is there any incentive to repair or replace damaged or 

disconnected portions of your onboard system? Can the 

system be checked after repair, or periodically) as to its 

safety/integrity and function? 

16. Identify and describe all significant modifications to 

fuel and emission systems which will be required if 

onboard systems are to be installed? 

17. Explain why certain design alternatives may have been 

selected, e.g., liquid versus mechanical seal. 

18. How many prototypes have you developed? Describe each. 

Provide a summary of the results of testing conducted on 

these prototypes. 

19. Furnish your opinion of any additional safety risks 

involved with onboard systems. Include an assessment of 

the following: 

a) the causal or contributory factors which could 

increase the chances of a defect or 

non-compli ance, 

b) the failure mode, 

c) the risk to motor vehicle safety 

d) any forseeable warning to drivers of the problem.. 

20. Identify (by NHTSA recall number) all safety-related 

defect campaigns which have been conducted due to the 

design, construction and/or performance of systems and/or 

components which are similar in design or function as 

those which will be utilized in any onboard vapor recovery 

system. Provide a summary of the problem or failure 

involved and the number of known incidents, accidents and 

fatalities involved with each such recall campaign. 

21. Provide copies of all service bulletins and/or other 

communications to dealer/owners which were issued due to 

the design, construction and/or performance of systems 

and/or components which are similar in design or function 

as those which will be utilized in any onboard vapor 

recovery system. Provide a summary of the problem or 

failure involved and the number of known incidents, 

accidents and fatalities involved with each such bulletin 

or communication. 
P.45 

1 

^ \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

'"< PRO'*'0 

? ANN ARBOR. MICHIGAN 48105 

OFFICE OF 

AIR AND RADIATION 

NOV I 0 I98T 

Mr. Karl-Heinz Ziwica, General Manager ••-*-

Environmental Engineering 

BMW of North America 

BMW Plaza 

Montvale, NJ 07645 

Dear Mr. Ziwica: 

I am writing in response to your testimony at the recent 

onboard/volatility hearing held October 27-29, 1987 in 

Washington, DC. Due to the large number of testifiers and the 

broad range of issues covered by the two proposals, the time 

limits of the hearing prevented us from exploring your 

testimony as fully as we would have liked. In addition, some 

questions were submitted from the floor which we did not have 

time to present. Therefore, we are writing to you with some 

followup questions for inclusion in your written comments. We 

believe that most of these questions are such that they will 

already be included in your written comments. However, we wish 

to insure that these areas, which are of specific concern to 

EPA, are covered. 

Presented in the enclosed list are questions which we.have. 

been requested to ask by the National Highway Traffic Safety 

Administration (NHTSA). Please include responses to these 

questions in your written comments. In addition, please 

respond to the following questions. 

1. During testimony, you indicated that BMW has 

increased fuel system complexity in the past (e.g. 

addition , of fuel injection) without affecting 

safety. Please detail the safety analyses done in 

this or other examples to assure safety was 

maintained. 

2. What changes could be made to FMVSS 301 to increase 

the possibility that onboard safety problems would 

be addressed before production (e.g. increase impact 

speed, more or different types of impacts, changed 

rollover procedures, etc.)? What other steps should 

EPA take to insure that unsafe designs are not used 

on production vehicles? 
P.46 

t 

-2-

3. NHTSA appears to believe that there have been a 

significant number of safety related recalls for 

evaporative control systems. What is your opinion, 

and what steps are you taking to improve the safety 

.of these systems? 

4. Please describe, for liquid seals, all other 

approaches being evaluated in addition to the EPA 

• prototype "j-tube" design. Include you.c evaluations 

of simple flapper valves at the end of the fill neck 

inside the fuel tank to form a liquid seal and/or 

control fuel splash back. . Also include other liquid 

seal configurations designed to reduce the flow 

restriction of the liquid seal and the entrainment 

of ambient air as well as to allow the use of a 

liquid seal in low profile tanks. 

5. Please provide detailed performance data which you 

have used to determine required canister sizes and a 

full description of your methodology. Describe.your 

evaluation of varied geometry and internal vapor 

flow patterns aimed at optimized canister sizing. 

6. Describe any specific safety issues you see related 

to larger vapor lines, considering the fact that 

there will be a shutoff valve at or near the fuel 

tank. Would a system such as described by Toyota at 

the public hearing, which eliminates the external 

vapor line found on most current vehicles, have any 

safety advantage relative to current vehicles? How 

much would the use of a simple flapper valve on the 

fill neck inside the fuel tank of such a system 

enhance safety compared to current designs which do 

not restrict the loss of fuel if the fill neck is 

severed in a crash? 

7. If you believe a liquid/vapor separator is required 

for your onboard system, please detail the need and 

the adverse consequences of not including this 

device. For example, if you believe that small 

droplets of liquid fuel might occasionally be 

carried over to the canister, describe how this 

would happen, why it would be a problem if it did 

and what other techniques are available for dealing 

with it. 

8. Do you believe there is any safety benefit 

associated with containing the vapors and reducing 

spillage during refueling? How can these be 

compared to the risk factors which have been raised? 
P.47 

1 

-3-

9. - How are you approaching the choice between 

integrated and separate onboard and evaporative 

control systems? Are there aspects of the test 

procedure which affect this choice? If so, what are 

they and what is the effect they have? How might 

EPA adjust the proposed procedure to encourage the 

use of integrated systems? 

10. In discussing safety, Ford stated that' canister 

location is not a safety issue, and that under-hood 

is an acceptable location. Chrysler stated that its 

concerns about fire safety are not associated with 

the canister, but with other fuel system 

components. What is your opinion, considering the 

fact that current canisters are generally under the 

hood? 

We appreciate your responsiveness in this matter. 

Sincerely yours, 

- / M 

( /u1 \ &••* Cyjuu/ ,0u, 

Charles L. Gray.^/Tr.y' 

Director 

Emission Control Technology Division 

Enclosure 
P.48 

Suggested Questions from NHTSA to ask 

about the Safety of Onboard Systems. 

1. What safety concerns, if any, do you have regarding 

onboard controls? What is the basis of those concerns? 

2. If onboard controls are required, are you likely to make 

additional changes to. the fuel system? If so, what are 

these changes? 

3. Will-- you provide an "integrated" system- if onboard 

controls are mandated? If not, why not? ' •'-'""'' 

4. What safety criteria do you use in designing onboard 

control systems? Do these extend to ease of repair and 

maintenance? 

5. Have you done research regarding fuel tank bladders? If 

so, what is the prognosis for this technology (i.e., 

feasible?, near-term?, etc.)? 

6. Where would the onboard cannistefs be located? How do you 

assure that they do not pose any safety hazard? 

7. Do the crash test requirements of Federal Motor Vehicle 

Safety Standard (FMVSS) No. 301 represent a complete 

matrix of crash tests that you use for purposes of 

checking the crash safety/integrity of the fuel systems of 

your vehicles? If not, are there additional tests that 

you believe are needed? 

8. Does the pass/fail criteria of FMVSS 301, post-crash 

liquid fuel leakage, adequately assess the crash 

safety/integrity of the evaporative and/or onboard vapor 

control system? If not, what additional criteria do you: 

believe are needed? 

9. How do you test and evaluate your vehicle fuel systems for 

non-crash fire hazards? 

10. What sensitivity studies do you conduct for onboard 

systems? For example, what range of Reid Vapor Pressure 

(RVP) and ambient temperatures do you consider? 

11. How do you test and evaluate your vehicle fuel, systems for 

durability? 

12. How many years or miles of maintenance-free life can be 

expected for the rubber, plastic, metal, charcoal, and 

other components of your onboard system? 
P.49 

13. What sorts of maintainance, if any, could be required for 

your onboard system over the life of the vehicle? if 

maintainance would be required, please submit details on 

expected cost and frequency. 

14. Is there any incentive for an. owner and/or mechanic to 

disconnect or tamper with your onboard system to improve 

performance or facilitate repairs to other vehicle systems? 

15. Is there any incentive to repair or replace damaged or 

disconnected portions of your onboard system? can the 

system be checked after repair, or periodically, as to its 

safety/integrity and function? 

16. Identify and describe all significant modifications to 

fuel and emission systems which will be required if 

onboard systems are to be installed? 

17. Explain why certain design alternatives may have been 

selected, e.g., liquid versus mechanical seal. 

18. How many prototypes have you developed? Describe each. 

Provide a summary of the results of testing conducted on 

these prototypes. 

19. Furnish your opinion of any additional safety risks 

involved with onboard systems. Include an assessment of 

the following: 

a) the causal or contributory factors which could 

increase the chances of a defect or 

non-compliance, 

b) the failure mode, 

c) the risk to motor vehicle safety 

d) any forseeable warning to drivers of the problem.. 

20. Identify (by NHTSA recall number) all safety-related 

defect campaigns which have been conducted due to the 

design, construction and/or performance of systems and/or 

components which are similar in design or function as 

those which will be utilized in any onboard vapor recovery 

system. Provide a summary of the problem or failure 

involved and the number of known incidents, accidents and 

fatalities involved with each such recall campaign. 

21. Provide copies of all service bulletins and/or other 

communications to dealer/owners which were issued due to 

the design, construction and/or performance of systems 

and/or components which are similar in design or function 

as those which will be utilized in any onboard vapor 

recovery system. Provide a summary of the problem or 

failure involved and the number of known incidents, 

accidents and fatalities involved with each such bulletin 

or communication. 
P.50 

^

t0S % 

A \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

SET 

<n 

\jmMa>* ANN ARBOR. MICHIGAN 48105 

"""ItoV TO W 

OFFICE OF 

AIR AND RADIATION 

Mr. William Cooper, President 

Cooper Oil Company 

P.O. Box 869. 

Farmington, MO 63640 

- '• • ^•-•• ' 

Dear Mr. Cooper: 

I am writing in response to your testimony at the recent 

onboard/volatility hearing held October 27-29, 1987 in 

Washington, DC. Due to the large number of testifiers and the 

broad range of issues covered by the two proposals, the time 

limits of the hearing prevented us from exploring your 

testimony as fully as we would have liked. In addition, some 

questions were submitted from the floor which we did not have 

time to present. Therefore, we are writing to you with some 

followup questions for inclusion in your written comments. We 

believe that most of these questions are such that they will 

already be included in your written comments. However, we wish 

to insure that these areas, which are of specific concern to 

EPA, are covered. 

Presented in the enclosed list are questions which we have 

been requested to ask by the National Highway Traffic Safety 

Administration (NHTSA). Please include responses to these 

questions in your written comments. In addition, please 

respond to the following questions. 

1. In your testimony you stated that Mobil Oil lost 40% 

of its business after installing Stage II equipment 

and was therefore forced to remove it. Please 

provide material documenting this statement. You 

also stated that there would be approximately 400 

station closures in the St. Louis area due to Stage 

II requirements. Pleas-a provide evidence 

documenting this statement. 

We appreciate your responsiveness in. this matter. 

Sincerely yours. 

Charles L. Gray^/Ji/ 

Director 

Emission Control Technology Division 

Enclosure 
P.51 

Suggested Questions from NHTSA to ask 

about the Safety of Onboard Systems. 

1. What safety concerns, if any, do you have regarding 

onboard controls? What is the basis of those concerns? 

2. If onboard controls are required, are you likely to make 

additional changes to the fuel system? If so, what are 

these changes? 

3. Will-' you provide an "integrated" system, if onboard 

controls are mandated? If not, why not? ;^;; 

4. What safety criteria do you use in designing onboard 

control systems? Do these extend to ease of repair and 

maintenance? 

5. Have you done research regarding fuel tank bladders? If 

so, what is the prognosis for this technology (i.e., 

feasible?, near-term?, etc.)? 

6. Where would the onboard cannistefs be located? How do you 

assure that they do not pose any safety hazard? 

7. Do the crash test requirements of Federal Motor Vehicle 

Safety Standard (FMVSS) No. 301 represent a complete 

matrix of crash tests that you use for purposes of 

checking the crash safety/integrity of the fuel systems of 

your vehicles? If not, are there additional tests that 

you believe are needed? 

8. Does the pass/fail criteria of FMVSS 301, post-crash 

liquid fuel leakage, adequately assess the crash 

safety/integrity of the evaporative and/or onboard vapor 

control system? If not, what additional, criteria do you: 

believe are needed? 

9. How do you test and evaluate your vehicle fuel systems for 

non-crash fire hazards? 

10. What sensitivity studies do you conduct - for onboard 

systems? For example, what range of Reid Vapor Pressure 

(RVP) and ambient temperatures do you consider? 

11. How do you test and evaluate your vehicle fuel systems for 

durability? 

12. How many years or miles of maintenance-free life can be 

expected for the rubber, plastic, metal, charcoal, and 

other components of your onboard system? 
P.52 

13. What sorts of maintainance, if any, could be required for 

your onboard system over the life of the vehicle? if 

maintainance would be required, please submit details on 

expected cost and frequency. 

14. Is there any incentive for an. owner and/or mechanic to 

disconnect or tamper with your onboard system to improve 

performance or facilitate repairs to other vehicle systems? 

15. Is there any incentive to repair or replace damaged or 

disconnected portions of your onboard system? Can the 

system be checked after repair, or periodically) as to its 

safety/integrity and function? 

16. Identify and describe all significant modifications to 

fuel and emission systems which will be required if 

onboard systems are to be installed? 

17. Explain why certain design alternatives may have been 

selected, e.g., liquid versus mechanical seal. 

18. How many prototypes have you developed? Describe each. 

Provide a summary of the results of testing conducted on 

these prototypes. 

19. Furnish your opinion of any additional safety risks 

involved with onboard systems. Include an assessment of 

the following: 

a) the causal or contributory factors which could 

increase the chances of a defect or 

non-compliance, 

b) the failure mode, 

c) the risk to motor vehicle safety 

d) any forseeable warning to drivers of the problem,. 

20. Identify (by NHTSA recall number) all safety-related 

defect campaigns which have been conducted due to the 

design, construction and/or performance of systems and/or 

components which are similar in design or function as 

those which will be utilized in any onboard vapor recovery 

system. Provide a summary of the problem- or failure 

involved and the number of known incidents, accidents and 

fatalities involved with each such recall campaign. 

21. Provide copies of all service bulletins and/or other 

communications to dealer/owners which were issued due to 

the design, construction and/or performance of systems 

and/or components which are similar in design or function 

as those which will be utilized in any onboard vapor 

recovery system. Provide a summary of the problem or 

failure involved and the number of known incidents, 

accidents and fatalities involved with each such bulletin 

or communication. 
P.53 

/ 

~ \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

ANN ARBOR. MICHIGAN 48105 

_ , OFFICE OF 

NOV I 0-19SI' AIR AND RADIATION 

Mr. Gary Mar fin •-••* ••-• 

c/o American Petroleum Institute 

1220 L Street, NW 

Washington, DC 20005 

Dear Mr. Marfin: 

I am writing in response to your testimony at the recent 

onboard/volatility hearing held October 27-29, 1987 in 

Washington, DC. Due to the large number of testifiers and the 

broad range of issues covered by the two proposals, the time 

limits of the hearing prevented us from exploring your 

testimony as fully as we would have liked. In addition, some 

questions were submitted from the floor which we did not have 

time to present. Therefore, we are writing to you with some 

followup questions for inclusion in your written comments. We 

believe that most of these questions are such that they will 

already be included in your written comments. However, we wish 

to insure that these areas, which are of specific concern to 

EPA, are covered. 

Presented in the enclosed list are questions which we have 

been requested to ask by the National Highway Traffic Safety 

Administration (NHTSA). Please include responses to these 

questions in your written comments. In addition, please 

respond to the following questions. 

1. With regards to the onboard refueling system you 

have designed: 

a) How many working prototypes have been 

constructed and tested? 

b) How many miles of driving? 

c) How many refueling cycles? 

d) Have there been changes/repairs to the 

prototypes since the original construction? 

e) What is the life of all components? 

f) Does API believe that onboard can be put in 

place by manufacturers without need for 

recalls to correct design, performance and/or 

manufacturing problems? 

g) What is the basis for this belief? 
P.54 

-2-

NHTSA appears to believe that there have been a 

significant number of safety related recalls for 

evaporative control systems. Could you please 

include a detailed analysis of the NHTSA evap recall 

data in your final comments? 

Do you believe there is any safety benefit 

associated with containing the vapors and reducing 

spillage during refueling? How can these be 

compared to the risk factors which have Been raised? 

What changes could be made to FMVSS 301 to increase 

the possibility that onboard safety problems would 

be addressed before production (e.g. increase impact 

speed, more or different types of impacts, changed 

rollover procedures, etc.)? What other steps should 

EPA take to insure that unsafe designs are not used 

on production vehicles? 

Describe any specific safety issues you see related 

to larger vapor lines, considering the fact that 

there will be a shutoff valve at or near the fuel 

tank. Would a system such as described by Toyota at 

the public hearing, which eliminates the external 

vapor line found on most current vehicles, have any 

safety advantage relative to current vehicles? How 

much would the use of a simple flapper valve on the 

fill neck inside the fuel tank of such a systemenhance safety compared to current designs which do 

not restrict the los,s of fuel if the fill neck is 

severed in a crash? 

If you believe a liquid/vapor separator is required 

for your onboard system, please detail the need and 

the adverse consequences of not including this 

device. For example, if you believe that small 

droplets of liquid fuel might occasionally be 

carried over to the canister, describe how this 

would happen, why it would be a problem if it did 

and what other techniques are available for dealing 

with it. 

In its testimony, GM stated that to insure safety, 

only evolutionary changes can be made in fuel 

systems and that "responsible safety engineering 

cannot reconcile a new revolutionary fuel system in 

high volume production which does not have field 

experience..." Do you agree with this statement? 

Do you believe that the adoption of onboard controls 

is revolutionary? If not, why not? How would you 

compare the adoption of onboard controls to such 
P.55 

-3-

changes as the conversion to electronic engine 

controls or pressurized fuel systems? 

We appreciate your responsiveness: in this matter. 

Sincerely yours, 

Charles L. Grayp'Jr/ 

Director 

Emission Control Technology Division 

Enclosure 
P.56 

Suggested Questions from NHTSA-to ask 

about the Safety of Onboard Systems. 

1. What safety concerns, if any, do you have regarding 

onboard controls? What is the basis of those concerns? 

2. If onboard controls are required, are you likely to make 

additional changes to the fuel system? If so, what are 

these changes? 

3. Will- you provide an "integrated" system if onboard 

controls are mandated? If not, why not? ' ^"'"' 

4. What safety criteria do you use in designing onboard 

control systems? Do these extend to ease of repair and 

maintenance? 

5. Have you done research regarding fuel tank bladders? If 

so, what is the prognosis for this technology (i.e., 

feasible?, near-term?, etc.)? 

6. Where would the onboard cannistefs be located? How do you 

assure that they do not pose any safety hazard? 

7. Do the crash test requirements of Federal Motor Vehicle 

Safety Standard (FMVSS) No. 301 represent a complete 

matrix of crash tests that you use for purposes of 

checking the crash safety/integrity of the fuel systems of 

your vehicles? If not, are there additional tests that 

you believe are needed? 

8. Does the pass/fail criteria of FMVSS 301, post-crash 

liquid fuel leakage, adequately assess the crash 

safety/integrity of the evaporative and/or onboard vapor 

control system? If not, what additional criteria do you: 

believe are needed? 

9. How do you test and evaluate your vehicle fuel systems for 

non-crash fire hazards? 

10. What sensitivity studies do you conduct for onboard 

systems? For example, what range of Reid Vapor Pressure 

(RVP) and ambient temperatures do you consider? 

11. How do you test and evaluate your vehicle fuel systems for 

durability? 

12. How many years or miles of maintenance-free life can be 

expected for the rubber, plastic, metal, charcoal, and 

other components of your onboard system? 
P.57 

13. What sorts of maintainance, if any, could be required for 

your onboard system over the life of the vehicle? if 

maintainance would be required, please submit details on 

expected cost and frequency. 

14. Is there any incentive for an. owner and/or mechanic to 

disconnect or tamper with your onboard system to improve 

performance or facilitate repairs to other vehicle systems? 

15. Is there any incentive to repair or replace damaged or 

disconnected portions of your onboard system?; Can the 

system be checked after repair, or periodically) as to its 

safety/integrity and function? 

16. Identify and describe all significant modifications to 

fuel and emission systems which will be required if 

onboard systems are to be installed? 

17. Explain why certain design alternatives may have been 

selected, e.g., liquid versus mechanical seal. 

18. How many prototypes have you developed? Describe each. 

Provide a summary of the results of testing conducted on 

these prototypes. 

19. Furnish your opinion of any additional safety risks 

involved with onboard systems. Include an assessment of 

the following: 

a) the causal or contributory factors which could 

increase the chances of a defect or 

non-compli ance, 

b) the failure mode, 

c) the risk to motor vehicle safety 

d) any forseeable warning to drivers of the problem,. 

• ~ \ 

20. Identify (by NHTSA recall number) all safety-related 

defect campaigns which have been conducted due to the 

design, construction and/or performance of systems and/or 

components which are similar in design or function as 

those which will be utilized in any onboard vapor recovery 

system. Provide a summary of the problem or failure 

involved and the number of known incidents, accidents and 

fatalities involved with each such recall campaign. 

21. Provide copies of all service bulletins and/or other 

communications to dealer/owners which were issued due to 

the design, construction and/or performance of systems 

and/or components which are similar in design or function 

as those which will be utilized in any onboard vapor 

recovery system. Provide a summary of the problem or 

failure involved and the number of known incidents, 

accidents and fatalities involved with each such bulletin 

or communication. 
P.58 

*' A \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

ANN ARBOR. MICHIGAN 48105 

NOV T 01987;

 OFRCEOF 

AIR AND RADIATION 

Mr. Richard Penna 

1111 19th Street, NW 

Suite 1000 

Washington, DC 20036 

Dear Mr. Penna: 

I am writing in response to your testimony at the recent 

onboard/volatility hearing held October 27-29, 1987 in 

Washington, DC. Due to the large number of testifiers and the 

broad range of issues covered by the two proposals, the time 

limits of the hearing prevented us from exploring your 

testimony as fully as we would have liked. In addition, some 

questions were submitted from the floor which we did not have 

time to present. Therefore, we are writing to you with some 

followup questions for inclusion in your written comments. We 

believe that most of these questions are such that they will 

already be included in your written comments. However, we wish 

to insure that these areas, which are of specific concern to 

EPA, are covered. 

Presented in the enclosed list are questions which we have 

been requested to ask by the National Highway Traffic Safety 

Administration (NHTSA). Please include responses to t)hese 

questions in your written comments. In addition, please 

respond to the following questions. 

1. On March 19, 1986 Toyota maca a presentation to the 

EPA entitled "Toyota's Information on Refueling 

Vapor Recovery." The handout used at the 

presentation contains a drawing of a refueling vapor 

line valve inside a fillneck. However, in Toyota's 

onboard system presented at the onboard/volatility 

hearings, the refueling vapor line valve sits on top 

of the fuel tank instead of inside the fillneck. 

For what reason did Toyota :hoose not to present a 

system with the valve located inside the fillneck? 

To what extent has Toyot -. developed the valve 

located inside the fillneck: Has it been designed 

built and tested? Are engineering drawings of the 

valve available? If so, --lease provide EPA with 

these drawings. 
'*/ 

-2-

2. . What changes, could be made to FMVSS 301 to increase 

the possibility that onboard safety problems would 

be addressed before production (e.g. increase impact 

speed, more or different types of impacts, changed 

rollover procedures, etc.)? What other steps should 

EPA take to insure that unsafe designs are not used 

on production vehicles? 

3. NHTSA appears to believe that there.have been a 

significant number of safety related recalls for 

evaporative control systems. What is your opinion, 

and what steps are you taking to improve the safety 

of these systems? 

4. Please describe, for liquid seals, all other 

approaches being evaluated in addition to the EPA 

prototype "j-tube" design. Include your evaluations 

of simple flapper valves at the end of the fill neck 

inside the fuel tank to form a liquid seal and/or 

control fuel splash back. Also include other liquid 

seal configurations designed to reduce the flow 

restriction of the liquid seal and the entrainment 

of ambient air as well as to allow the use of a 

liquid seal in low profile tanks. 

5. Please provide detailed performance data which you 

have used to determine required canister sizes and a 

full description of your methodology. Describe your 

evaluation of varied geometry and internal vapor 

flow patterns aimed at optimized canister sizing. 

6. Describe any specific safety issues you see related 

to larger vapor lines, considering the fact that 

there will be a shutoff valve at or near the fuel 

tank. Would a system such as described by Toyota at 

the public hearing, which eliminates the external 

vapor line found on most current vehicles, have any 

safety advantage relative to current vehicles? How 

much would the use of a simple flapper valve on the 

fill neck inside the fuel tank of such a system 

enhance safety compared to current designs which do 

not restrict the loss of fuel if the fill neck is 

severed in a crash? 

7. If you believe a liquid/vapor separator is required 

for your onboard system, please detail the need and 

the adverse consequences of not including this 

device. For example, if you believe that small 

droplets of liquid fuel might occasionally be 

carried over to the canister, describe how this 

would happen, why it would be a problem if it did 

and what other techniques are available for dealing 

with it. 
P.60 

A 4 * 

-3-

8. .Do you believe there is any safety benefit 

associated with containing the vapors and reducing 

spillage during refueling? How can these be 

compared to the risk factors which have been raised? 

9. How are you approaching the choice between 

integrated and separate onboard and evaporative 

•control systems? Are there aspects of the test 

procedure which affect this choice? If ;sa; what are 

they and what is the effect they have? How might 

EPA adjust the proposed procedure to encourage the 

use of integrated systems? -

10. Please describe your normal procedures for assuring 

the safety of fuel systems. Include a description 

of how you manage fuel system changes which are 

either small evolutionary changes or larger type 

changes. Also include a detailed presentation of 

the safety analyses conducted when you implemented 

evaporative controls, pressurized fuel systems, for 

fuel injection, and vapor vent lines external to the 

fuel filler pipe if you use them, showing all 

problems identified and solutions implemented. 

11. In discussing safety, Ford stated that canister 

location is not a safety issue, and that under-hood 

is an acceptable location. Chrysler stated that its 

concerns about fire safety are not associated with 

the canister, but with other fuel system 

components. What is your opinion, considering the 

fact that current canisters are generally under the 

hood? , 

12. Your onboard system includes a water separator on 

the refueling canister. Explain the function of 

this component and why it is needed for the 

refueling canister but not the evaporative canister. 

• 13. Please describe any increased risk due to damage to 

your vapor vent valve that would not also damage the 

existing fuel tank. Could this risk be eliminated 

by locating the valve inside the fuel tank or by 

shielding the valve? How do you compare the risk of 

damage to this valve to the risk of damage to the 

external vapor vent line on your current fuel tanks? 

14. In addition to explaining your approach to 

determining canister size, please explain why you 

have chosen a heavy steel case, especially in light 

of the potential safety hazard you believe it poses 

for damaging the fuel tank in a crash. 
P.61 

-4-

15. Please explain the aspects of your system 

responsible for your concern about increasing the 

risk of fuel leakage from the filler pipe during a 

crash, since the filler pipe appears essentially 

unchanged from current systems. Would the addition 

of a simple flapper valve at the bottom end of the 

fill neck reduce fuel leakage in a crash compared to 

current systems? 

• : • ~& . • ~-• • 

16. Please explain the hazard you associate with damage 

to the vapor lines in a crash since the vapor vent 

valve would prevent the release of fuel from the 

tank. 

We appreciate your responsiveness in this matter.. 

Sincerely yours, 

Charles L. Gray/ Jr/ 

Director 

Emission Control Technology Division 

Enclosure 
P.62 

Suggested Questions from NHTSA to ask 

about the Safety of Onboard Systems. 

1. What safety concerns, if any, do you have regarding 

onboard controls? What is the basis of those concerns? 

2. If onboard controls are required, are you likely to make 

additional changes to the fuel system? If so, what are 

these changes? 

3. Will-- you provide an "integrated" system, if onboard 

controls are mandated? If not, why not? ^; y 

4. What safety criteria do you use in designing onboard 

control systems? Do these extend to ease of repair and 

maintenance? 

5. Have you done research regarding fuel tank bladders? If 

so, what is the prognosis for this technology (i.e., 

feasible?, near-term?, etc.)? 

6. Where would the onboard cannistefs be located? How do you 

assure that they do not pose any safety hazard? 

7. Do the crash test requirements of Federal Motor Vehicle 

Safety Standard (FMVSS) No. 301 represent a complete 

matrix of crash tests that you use for purposes of 

checking the crash safety/integrity of the fuel systems of 

your vehicles? If not, are there additional tests that 

you believe are needed? 

8. Does the pass/fail criteria of FMVSS 301, post-crash 

liquid fuel leakage, adequately assess the crash 

safety/integrity of the evaporative and/or onboard vapor 

control system? If not, what additional criteria do youbelieve are needed? 

9. How do you test and evaluate your vehicle fuel systems for 

non-crash fire hazards? 

10. What sensitivity studies do you conduct for onboard 

systems? For example, what range of Reid Vapor Pressure 

(RVP) and ambient temperatures do you consider? 

11. How do you test and evaluate your vehicle fuel systems for 

durability? 

12. How many years or miles of maintenance-free life can be 

expected for the rubber, plastic, metal, charcoal, and 

other components of your onboard system? 
P.63 

13. What sorts of maintainance, if any, could be required for 

your onboard system over the life of the vehicle? if 

maintainance would be required, please submit details on 

expected cost and frequency. 

14. Is there any incentive for an. owner and/or mechanic to 

disconnect or tamper with your onboard system to improve 

performance or facilitate repairs to other vehicle systems? 

15. Is there any incentive to repair or replace damaged or 

disconnected portions of your onboard system? Can the 

system be checked after repair, or periodically) as to its 

safety/integrity and function? 

16. Identify and describe all significant modifications to 

fuel and emission systems which will be required if 

onboard systems are to be installed? 

17. Explain why certain design alternatives may have been 

selected, e.g., liquid versus mechanical seal. 

18. How many prototypes have you developed? Describe each. 

Provide a summary of the results of testing conducted on 

these prototypes. 

19. Furnish your opinion of any additional safety risks 

involved with onboard systems. Include an assessment of 

the following: 

a) the causal or contributory factors which could 

increase the chances of a defect or 

non-compliance, 

b) the failure mode, 

c) the risk to motor vehicle safety 

d) any forseeable warning to drivers of the problem.. 

20. Identify (by NHTSA recall number) all safety-related 

defect campaigns which have been conducted due to the 

design, construction and/or performance of systems and/or 

components which are similar in design or function as 

those which will be utilized in any onboard vapor recovery 

system. Provide a summary of the problem or failure 

involved and the number of known incidents, accidents and 

fatalities involved with each such recall campaign. 

21. Provide copies of all service bulletins and/or other 

communications to dealer/owners which were issued due to 

the design, construction and/or performance of systems 

and/or components which are similar in design or function 

as those which will be utilized in any onboard vapor 

recovery system. Provide a summary of the problem or 

failure involved and the number of known incidents, 

accidents and fatalities involved with each such bulletin 

or communication. 
P.64 

J 

!> A \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

\5StfZj ANN ARBOR. MICHIGAN 48105 r

\^y 

OFFICE OF 

NOV i 0 I98T A,RANDRAD,AT,ON 

Mr. Toshio Maeda, Executive Vice President '-'•*'" 

Chief Operating Office 

Nissan Research S> Development, Inc. 

3995 Research Park Drive 

Ann Arbor, MI 48104 

Dear Mr. Maeda: 

I am writing in response to your testimony at the recent 

onboard/volatility hearing held October 27-29, 1987 in 

Washington, DC. Due to the large number of testifiers and the 

broad range of issues covered by the two proposals, the time 

limits of the hearing prevented us from exploring your 

testimony as fully as we would have liked. In addition, some 

questions were submitted from the floor which we did not have 

time to present. Therefore, we are writing to you with some 

followup questions for inclusion in your written comments. We 

believe that most of these questions are such that they will 

already be included in your written comments. However, we wish 

to insure that these areas, which are of specific concern to 

EPA, are covered. 

Presented in the enclosed list are questions which we'have 

been requested to ask by the National Highway Traffic Safety 

Administration (NHTSA). Please include responses to these 

questions in your written comments. In addition, please 

respond to the following questions. 

1. What changes could be made to FMVSS 301 to increase 

the possibility that onboard safety problems would 

be addressed before production (e.g. increase impact 

speed, more or different types of impacts, changed 

rollover procedures, etc.)? What other steps should 

EPA take to insure that unsafe designs are not used 

on production vehicles? 

2. NHTSA appears to believe that there have been a 

significant number of safety related recalls for 

evaporative control systems. What is your opinion, 

and what steps are you taking to improve the safety 

of these systems? 
P.65 

.« ' 

-2-

3. Please describe, for liquid seals, all other 

approaches being evaluated in addition to the EPA 

prototype • "j-tube" design. Include your evaluations 

of simple flapper valves at the end of the fill neck 

inside the fuel tank to form a liquid seal and/or 

control fuel splash back. Also include other liquid 

seal configurations designed to reduce the flow 

-restriction of the liquid seal and the entrainment 

of ambient air as well as to allow the • use of a 

liquid seal in low profile tanks. 

4. Please provide detailed performance data which you 

have used to determine required canister sizes and a 

full description of your methodology. Describe your 

evaluation of varied geometry and internal vapor 

flow patterns aimed at optimized canister sizing. 

5. Describe any specific safety issues you see related 

to larger vapor lines, considering the fact that 

there will be a shutoff valve at or near the fuel 

tank. Would a system such as described by Toyota at 

the public hearing, which eliminates the external 

vapor line found on most current vehicles, have any 

safety advantage relative to current vehicles? How 

much would the use of a simple flapper valve on the 

fill neck inside the fuel tank of such a system 

enhance safety compared to current designs which do 

not restrict the loss of fuel if the fill neck is 

severed in a crash? 

6. If you believe a liquid/vapor separator is required 

for your onboard system, please detail the need^ and 

the adverse consequences of not including this 

device. For example, if you believe that small 

droplets of liquid fuel might occasionally be 

carried over to the canister, describe how this 

would happen, why it would be a problem if it did 

and what other techniques are available for dealing 

with it. 

7. Do you believe there is any safety benefit 

associated with containing the vapors and reducing 

spillage during refueling? How can these be 

compared to the risk factors which have been raised? 

8. How are you approaching the choice between 

integrated and separate onboard and evaporative 

control systems? Are there aspects of the test 

procedure which affect this choice? If so, what are 

. they and what is the effect they have? How might 

EPA adjust the proposed procedure to encourage the 

use of integrated systems? 
P.66 

-3-

9. Please describe your normal procedures for assuring 

the safety of fuel systems. Include a description 

of how you manage fuel system changes which are 

either small evolutionary changes or larger type 

changes. Also include a detailed presentation of 

the safety analyses conducted when you implemented 

evaporative controls, pressurized fuel systems for 

fuel injection, and vapor vent lines external to the 

fuel filler pipe if you use them, .•^.showing all 

problems identified and solutions implemented. 

10. In discussing safety, Ford stated that canister 

location is not a safety issue, and that under-hood 

is an acceptable location. Chrysler stated that its 

concerns about fire safety are not associated with 

the canister, but with other fuel system 

components. What is your opinion, considering the 

fact that current canisters are generally under the 

hood? 

We appreciate your responsiveness in this matter. 

Sincerely yours, 

Charles L. Gray, 

Director 

Emission Control Technology Division 

ay, Jr..y 

Enclosure 
Suggested Questions from NHTSA to ask 

about the Safety of Onboard Systems• 

1. What safety concerns, if any, do you have regarding 

onboard controls? What is the basis of those concerns? 

2. If onboard controls are required, are you likely to make 

additional changes to the fuel system? If so, what are 

these changes? 

3. Will-- you provide an "integrated" system, if onboard 

controls are mandated? If not, why not? •;&•'•••' 

4. What safety criteria do you use in designing onboard 

control systems? Do these extend to ease of repair and 

maintenance? 

5. Have you done research regarding fuel tank bladders? If 

so, what is the prognosis for this technology (i.e., 

feasible?, near-term?, etc.)? 

6. Where would the onboard cannisters be located? How do you 

assure that they do not pose any safety hazard? 

7. Do the crash test requirements of Federal Motor Vehicle 

Safety Standard (FMVSS) No. 301 represent a complete 

matrix of crash tests that you use for purposes of 

checking the crash safety/integrity of the fuel systems of 

your vehicles? If not, are there additional tests that 

you believe are needed? 

8. Does the pass/fail criteria of FMVSS 301, post-crash 

liquid fuel leakage, adequately assess the crash 

safety/integrity of the evaporative and/or onboard vapor 

control system? If -not, what additional criteria do yo\* 

believe are needed? 

9. How do you test and evaluate your vehicle fuel systems for 

non-crash fire hazards? 

10. What sensitivity studies do you conduct for onboard 

systems? For example, what range of Reid Vapor Pressure 

(RVP) and ambient temperatures do you consider? 

11. How do you test and evaluate your vehicle fuel systems for 

durability? 

12. How many years or miles of maintenance-free life can be 

expected for the rubber, plastic, metal, charcoal, and 

other components of your onboard system? 
P.68 

13. What sorts of maintainance, if any, could be required for 

your onboard system over the life of the vehicle? if 

maintainance would be required, please submit details on 

expected cost and frequency. 

14. Is there any incentive for an. owner and/or mechanic to 

disconnect or tamper with your onboard system to improve 

performance or facilitate repairs to other vehicle systems? 

15. Is there any incentive to repair or replace damaged or 

disconnected portions of your onboard system? Can the 

system be checked after repair, or periodically) as to its 

safety/integrity and function? 

16. Identify and describe all significant modifications to 

fuel and emission systems which will be required if 

onboard systems are to be installed? 

17. Explain why certain design alternatives may have been 

selected, e.g., liquid versus mechanical seal. 

18. How many prototypes have you developed? Describe each. 

Provide a summary of the results of testing conducted on 

these prototypes. 

19. Furnish your opinion of any additional safety risks 

involved with onboard systems. Include an assessment of 

the following: 

a) the causal or contributory factors which could 

increase the chances of a defect or 

non-compliance, 

b) the failure mode, 

c) the risk to motor vehicle safety 

d) any forseeable warning to drivers of the problem,. 

20. Identify (by NHTSA recall number) all safety-related 

defect campaigns which have been conducted due to the 

design, construction and/or performance of systems and/or 

components which are similar in design or function as 

those which will be utilized in any onboard vapor recovery 

system. Provide a summary of the problem or failure 

involved and the number of known incidents, accidents and 

fatalities involved with each such recall campaign. 

21. Provide copies of all service bulletins and/or other 

communications to dealer/owners which were issued due to 

the design, construction and/or performance of systems 

and/or components which are similar in design or function 

as those which will be utilized in any onboard vapor 

recovery system. Provide a summary of the problem or 

failure involved and the number of known incidents, 

accidents and fatalities involved with each such bulletin 

or communication. 
P.69 

\ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

ANN ARBOR. MICHIGAN 48105 

OFFICE OF 

AIR AND RADIATION 

NOV I 0 1987 

Mr. Len Rata, Principle Engineer Ti--^ 

Emissions Regulation and Certification 

Volkswagen of America 

888 West Big Beaver Road 

P.O. Box 3951 

Troy, MI 48007-3951 

Dear Mr. Kata: 

I am writing in response to your testimony at the recent 

onboard/volatility hearing held October 27-29, 1987 in 

Washington, DC. Due to the large number of testifiers and the 

broad range of issues covered by the two proposals, the time 

limits of the hearing prevented us from exploring your 

testimony as fully as we would have liked. In addition, some 

questions were submitted from the floor which we did not have 

time to present. Therefore, we are writing to you with some 

followup questions for inclusion in your written comments. We 

believe that most of these questions are such that they will 

already be included in your written comments. However, we wish 

to insure that these areas, which are of specific concern to 

EPA, are covered. 

• \ 

Presented in the enclosed list are questions which we have 

been requested to ask by the National Highway Traffic Safety 

Administration (NHTSA). Please include responses to these 

questions in your written comments. In addition, please 

respond to the following questions. 

1. What changes could be made to FMVSS 301 to increase 

the possibility that onboard safety problems would 

be addressed before production (e.g. increase impact 

speed, more or different types of impacts, changed 

rollover procedures, etc.)? What other steps should 

EPA take to insure that unsafe designs are not used 

on production vehicles? 

2. NHTSA appears to believe that there have been a 

significant number of safety related recalls for 

evaporative control systems. What is your opinion, 

and what steps are you taking to improve the safety 

of these systems? 
-2-

3. Please describe, for liquid seals, all other 

approaches being evaluated in addition to the EPA 

prototype- "j-tube" design. Include your evaluations 

of simple flapper valves at the end of the fill neck 

inside the fuel tank to form a liquid seal and/or 

control fuel splash back. Also include other liquid 

seal configurations designed to reduce the flow 

restriction of the liquid seal and the entrainment 

of ambient air as well as to allow the; use of a 

liquid seal in low profile tanks. 

4. Please provide detailed performance data which you 

have used to determine required canister sizes and a 

full description of your methodology. Describe your 

evaluation of varied geometry and internal vapor 

flow patterns aimed at optimized canister sizing. 

5. Describe any specific safety issues you see related 

to larger vapor lines, considering the fact that 

there will be a shutoff valve at or near the fuel 

tank. Would a system such as described by Toyota at 

the public hearing, which eliminates the external 

vapor line found on most current vehicles, have any 

safety advantage relative to current vehicles? How 

much would the use of a simple flapper valve on the 

fill neck inside the fuel tank of such a system 

enhance safety compared to current designs which do 

not restrict the loss of fuel if the fill neck is 

severed in a crash? 

6. If you believe a liquid/vapor separator is required 

for your onboard system, please detail the need and 

the adverse consequences of not including ^this 

device. For example, if you believe that small 

droplets of liquid fuel might occasionally be 

carried over to the canister, describe how this 

would happen, why it would be a problem if it did 

and what other techniques are available for dealing 

with it. 

7. Do you believe there is any safety benefit 

associated with containing the vapors and reducing 

spillage during refueling? How can these be 

compared to the risk factors which have been raised? 

8. How are you approaching the choice between 

integrated and separate onboard and evaporative 

control systems? Are there aspects of the test 

procedure which affect this choice? If so, what are 

they and what is the effect they have? How might 

EPA adjust the proposed procedure to encourage the 

use of integrated systems? 
P.71 

-3-

9. Please describe your normal procedures for assuring 

the safety of fuel systems. Include a description 

of how you manage fuel system changes which are 

either small evolutionary changes or larger type 

changes. Also include a detailed presentation of 

the safety analyses conducted when you implemented 

evaporative controls, pressurized fuel systems for 

fuel injection, and vapor vent lines external to the 

fuel filler pipe if you use them, ^showing all 

problems identified and solutions implemented. 

10. In discussing safety, Ford stated that canister 

location is not a safety issue, and that under-hood 

is an acceptable location. Chrysler stated that its 

concerns about fire safety are not associated with 

the canister, but with other fuel system 

components. What is your opinion, considering the 

fact that current canisters are generally under the 

hood? 

We appreciate your responsiveness in this matter. 

Sincerely yours, 

• • > 

Wo ,^Li 

Charles L. Gray,xJrc/ 

Director 

Emission Control Technology Division 

Enclosure 
Suggested Questions from NHTSA to ask 

about the Safety of Onboard Systems. 

1. What safety concerns, if any, do you have regarding 

onboard controls? What is the basis of those concerns? 

2. If onboard controls are required, are you likely to make 

additional changes to. the fuel system? If so, what are 

these changes? 

3. Will- you provide an "integrated" system, if onboard 

controls are mandated? If not, why not? •-••#••"••' 

4. What safety criteria do you use in designing onboard 

control systems? Do these extend to ease of repair and 

maintenance? 

5. Have you done research regarding fuel tank bladders? If 

so, what is the prognosis for this technology (i.e., 

feasible?, near-term?, etc.)? 

6. Where would the onboard cannistefs be located? How do you 

assure that they do not pose any safety hazard? 

7. Do the crash test requirements of Federal Motor Vehicle 

Safety Standard (FMVSS) No. 301 represent a complete 

matrix of crash tests that you use for purposes of 

checking the crash safety/integrity of the fuel systems of 

your vehicles? If not, are there additional tests that 

you believe are needed? 

8. Does the pass/fail criteria of FMVSS 301, post-crash 

liquid fuel leakage, adequately assess the crash 

safety/integrity of the evaporative and/or onboard vapor 

control system? If not, what additional criteria do yo\fc 

believe are needed? 

9. How do you test and evaluate your vehicle fuel systems for 

non-crash fire hazards? 

10. What sensitivity studies do you conduct for onboard 

systems? For example, what range of Reid Vapor Pressure 

(RVP) and ambient temperatures do you consider? 

11. How do you test and evaluate your vehicle fuel systems for 

durability? 

12. How many years or miles of maintenance-free life can be 

expected for the rubber, plastic, metal, charcoal, and 

other components of your onboard system? 
P.73 

13. What sorts of maintainance, if any, could be required for 

your onboard system over the life of the vehicle? if 

maintainance would be required, please submit details on 

expected cost and frequency. 

14. Is there any incentive for an. owner and/or mechanic to 

disconnect or tamper with your onboard system to improve 

performance or facilitate repairs to other vehicle systems? 

15. Is there any incentive to repair or replace damaged or 

disconnected portions of your onboard system?, can the 

system be checked after repair, or periodically) as to its 

safety/integrity and function? 

16. Identify and describe all significant modifications to 

fuel and emission systems which will be required if 

onboard systems are to be installed? 

17. Explain why certain design alternatives may have been 

selected, e.g., liquid versus mechanical seal. 

18. How many prototypes have you developed? Describe each. 

Provide a summary of the. results of testing conducted on 

these prototypes. 

19. Furnish your opinion of any additional safety risks 

involved with onboard systems. Include an assessment of 

the following: 

a) the causal or contributory factors which could 

increase the chances of a defect or 

non-compliance, 

b) the failure mode, 

c) the risk to motor vehicle safety 

d) any forseeable warning to drivers of the problem,. 

20. Identify (by NHTSA recall number) all safety-related 

defect campaigns which have been conducted due to the 

design, construction and/or performance of systems and/or 

components which are similar in design or function as 

those which will be utilized in any onboard vapor recovery 

system. Provide a summary of the problem or failure 

involved and the number of known incidents, accidents and 

fatalities involved with each such recall campaign. 

21. Provide copies of all service bulletins and/or other 

communications to dealer/owners which were issued due to 

the design, construction and/or performance of systems 

and/or components which are similar in design or function 

as those which will be utilized in any onboard vapor 

recovery system. Provide a summary of the problem or 

failure involved and the number of known incidents, 

accidents and fatalities involved with each such bulletin 

or communication. 
P.74 

\ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

*< P*Jt^ 

I ANN ARBOR. MICHIGAN 48105 

OFFICE OF 

N0VTQI987 AIR AND RADIATION 

Mr. Richard H. Lucki ::.j--:; 

U.S. Technical Research Company 

1099 Wall Street, West 

Lyndhurst, NJ 07071 

Dear Mr. Lucki: 

I am writing in response to your testimony at the recent 

onboard/volatility hearing held October 27-29, 1987 in 

Washington, DC. Due to the large number of testifiers and the 

broad range of issues covered by the two proposals, the time 

limits of the hearing prevented us from exploring your 

testimony as fully as we would have liked. In addition, some 

questions were submitted from the floor which we did not have 

time to present. Therefore, we are writing to you with some 

followup questions for inclusion in your written comments. We 

believe that most of these questions are such that they will 

already be included in your written comments. However, we wish 

to insure that these areas, which are of specific concern to 

EPA, are covered. 

Presented in the enclosed list are questions which we have 

been requested to ask by the National Highway Traffic Safety 

Administration (NHTSA). Please include responses to these 

questions in your written comments. In addition, please 

respond to the following questions. 

1. What changes could be made to FMVSS 301 to increase 

the possibility that onboard safety problems would 

be addressed before producticn (e.g. increase impact 

speed, more or different types of impacts, changed 

rollover procedures, etc.)? What other steps should 

EPA take to insure that unsafe designs are not used 

on production vehicles? 

2. NHTSA appears to believe, that there have been a 

significant number of safety related recalls for 

evaporative control systems. What is your opinion, 

and what steps are you taking to improve the safety 

of these systems? 
P.75 

-2-

3. . Please describe, for liquid seals, all other 

approaches being evaluated in addition to the EPA 

prototype' "j-tube" design. Include your evaluations 

of simple flapper valves at the end of the fill neck 

inside the fuel tank to form a liquid seal and/or 

control fuel splash back. Also include other liquid 

seal configurations designed to reduce the flow 

• restriction of the liquid seal and the entrainment 

of ambient air as well as to allow tine' use of a 

liquid seal in low profile tanks. 

4. Please provide detailed performance data which you 

have used to determine required canister sizes and a 

full description of your methodology. Describe your 

evaluation of varied geometry and internal vapor 

flow patterns aimed at optimized canister sizing. 

5. Describe any specific safety issues you see related 

to larger vapor lines, considering the fact that 

there will be a shutoff valve at or near the fuel 

tank. Would a system such as described by Toyota at 

the public hearing, which eliminates the external 

vapor line found on most current vehicles, have any 

safety advantage relative to current vehicles? How 

much would the use of a simple flapper valve on the 

fill neck inside the fuel tank of such a system 

enhance safety compared to current designs which do 

not restrict the loss of fuel if the fill neck is 

severed in a crash? 

6. If you believe a liquid/vapor separator is required 

for your onboard system, please detail the need and 

the adverse consequences of not including

 vthis 

device. For example, if you believe that small 

droplets of liquid fuel might occasionally be 

carried over to the canister, describe how this 

would happen, why it would be a problem if it did 

and what other techniques are available for dealing 

with it. 

7. Do you believe there is any safety benefit 

associated with containing the vapors and reducing 

spillage during refueling? How can these be 

compared to the risk factors which have been raised? 

8. How are you approaching the choice between 

integrated and separate onboard and evaporative 

control systems? Are there aspects of the test 

procedure which affect this choice? If so, what are 

they and what is the effect they have? How might 

EPA adjust the proposed procedure to encourage the 

use of integrated systems? 
P.76 

-3-

9. Please describe your normal procedures for assuring 

the safety of fuel systems. Include a description 

of how you manage fuel system changes which are 

either small evolutionary, changes or larger type 

changes. Also include a detailed presentation of 

the safety analyses conducted when you implemented 

evaporative controls, pressurized fuel systems for 

fuel injection, and vapor vent lines external to the 

fuel filler pipe if you use them, showing all 

problems identified and solutions implemented. 

10. In discussing safety, Ford stated that canister 

location is not a safety issue, and that under-hood 

is an acceptable location. Chrysler stated that its 

concerns about fire safety are not associated with 

the canister, but with other fuel system 

components. What is your opinion, considering the 

fact that current canisters are generally under the 

hood? 

We appreciate your responsiveness in this matter. 

Sincerely yours, 

Charles L. Gray/-/JiJ 

Director 

Emission Control Technology Division 

Enclosure 
P.77 

Suggested Questions from NHTSA to ask 

about the Safety of Onboard Systems. 

1. What safety concerns, if any, do you have regarding 

onboard controls? What is the basis of those concerns? 

2. If onboard controls are required, are you likely to make 

additional changes to the fuel system? If so, what are 

these changes? 

3. Will-- you provide an "integrated" system if onboard 

controls are mandated? If not, why not? ••;*•-•' 

4. What safety criteria do you use in designing onboard 

control systems? Do these extend to ease of repair and 

maintenance? 

5. Have you done research regarding fuel tank bladders? If 

so, what is the prognosis for this technology (i.e., 

feasible?, near-term?, etc.)? 

6. Where would the onboard cannisters be located? How do you 

assure that they do not pose any safety hazard? 

7. Do the crash test requirements of Federal Motor Vehicle 

Safety Standard (FMVSS) No. 301 represent a complete 

matrix of crash tests that you use for purposes of 

checking the crash safety/integrity of the fuel systems of 

your vehicles? If not, are there additional tests that 

you believe are needed? 

8. Does the pass/fail criteria of FMVSS 301, post-crash 

liquid fuel leakage, adequately assess the crash 

safety/integrity of the evaporative and/or onboard vapor 

control system? If not, what additional criteria do you 

believe are needed? 

9. How do you test and evaluate your vehicle fuel systems for 

non-crash fire hazards? 

10. What sensitivity studies do you conduct _ for onboard 

systems? For example, what range of Reid Vapor Pressure 

(RVP) and ambient temperatures do you consider? 

11. How do you test and evaluate your vehicle fuel systems for 

durability? 

12. How many years or miles of maintenance-free life can be 

expected for the rubber, plastic, metal, charcoal, and 

other components of your onboard system? 
P.78 

13. What sorts of maintainance, if any, could be required for 

your onboard system over the life of the vehicle? if 

maintainance would be required, please submit details on 

expected cost and frequency. 

14. Is there any incentive for an: owner and/or mechanic to 

disconnect or tamper with your onboard system to improve 

performance or facilitate repairs to other vehicle systems? 

15. Is there any incentive to repair or replace damaged or 

disconnected portions of your onboard system?, Can the 

system be checked after repair, or periodically) as to its 

safety/integrity and function? 

16. Identify and describe all significant modifications to 

fuel and emission systems which will be required if 

onboard systems are to be installed? 

17. Explain why certain design alternatives may have been 

selected, e.g., liquid versus mechanical seal. 

18. How many prototypes have you developed? Describe each. 

Provide a summary of the results of testing conducted on 

these prototypes. 

19. Furnish your opinion of any additional safety risks 

involved with onboard systems. Include an assessment of 

the following: 

a) the causal or contributory factors which could 

increase the chances of a defect or 

non-compliance, 

b) the failure mode, 

c) the risk to motor vehicle safety 

d) any forseeable warning to drivers of the problem,. 

20. Identify (by NHTSA recall number) all safety-related 

defect campaigns which have been conducted due to the 

design, construction and/or performance of systems and/or 

components which are similar in design or function as 

those which will be utilized in any onboard vapor recovery 

system. Provide a summary of the problem- or failure 

involved and the number of known incidents, accidents and 

fatalities involved with each such recall campaign. 

21. Provide copies of all service bulletins and/or other 

communications to dealer/owners which were issued due to 

the design, construction and/or performance of systems 

and/or components which are similar in design or function 

as those which will be utilized in any onboard vapor 

recovery system. Provide a summary of the problem or 

failure involved and the number of known incidents, 

accidents and fatalities involved with each such bulletin 

or communication. 
P.79 

V 

jf& *U>t 

^ A \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

X^eams+J ANN ARBOR. MICHIGAN 48105 

%PR0 ^ 

OFFICE OF 

AIR AND RADIATION 

NOV T O !987r 

Ms. Sherri Fillingham ..->--•• 

c/o National Petroleum Refiners Association 

1899 L Street NW 

Suite 1000 

Washington, DC 20036 

Dear Ms. Fillingham: 

I am writing in response to your testimony at the recent 

onboard/volatility hearing held October 27-29, 1987 in 

Washington, DC. Due to the large number of testifiers and the 

broad range of issues covered by the two proposals, the time 

limits of the hearing prevented us from exploring your 

testimony as fully as we would have liked. In particular, some 

questions were submitted from National Highway Traffic Safety 

Administration (NHTSA) which we did not have time to present. 

These questions are included in the enclosed list. We believe 

that some of these questions are such that they will already be 

included in your written comments. However, we wish to insure 

that these areas, which are of specific concern to EPA, are 

covered. To the extent possible, based upon your knowledge in 

this area, please include responses to these questions in your 

written comments.

 A 

We appreciate your responsiveness in this matter. 

Sincerely yours, 

^ /'L£i.L'<-~*i, •J^'-WTYI •• 

Charles L. Gray, -'Jr. 

Director 

Emission Control Technology Division 

Enclosure 
P.80 

Suggested Questions from NHTSA to ask 

about the Safety of Onboard Systems. 

1. What safety concerns, if any, do you have regarding 

onboard controls? What is the basis of those concerns? 

2. If onboard controls are required, are you likely to make 

additional changes to the fuel system? If so, what are 

these changes? 

3. Will-- you provide an "integrated" system, .if onboard 

controls are mandated? If not, why not? •:&•'•••' 

4. What safety criteria do you use in designing onboard 

control systems? Do these extend to ease of repair and 

maintenance? 

5. Have you done research regarding fuel tank bladders? If 

so, what is the prognosis for this technology (i.e., 

feasible?, near-term?, etc.)? 

6. Where would the onboard cannisters be located? How do you 

assure that they do not pose any safety hazard? 

7. Do the crash test requirements of Federal Motor Vehicle 

Safety Standard (FMVSS) No. 301 represent a complete 

matrix of crash tests that you use for purposes of 

checking the crash safety/integrity of the fuel systems of 

your vehicles? If not, are there additional tests that 

you believe are needed? 

8. Does the pass/fail criteria of FMVSS 301, post-crash 

liquid fuel leakage, adequately assess the crash 

safety/integrity of the evaporative and/or onboard vapor 

control system? If not, what additional criteria do youbelieve are needed? 

9. How do you test and evaluate your vehicle fuel systems for 

non-crash fire hazards? 

10. What sensitivity studies do you conduct for onboard 

systems? For example, what range of Reid Vapor Pressure 

(RVP) and ambient temperatures do you consider? 

11. How do you test and evaluate your vehicle fuel, systems for 

durability? 

12. How many years or miles of maintenance-free life can be 

expected for the rubber, plastic, metal, charcoal, and 

other components of your onboard system? 
P.81 

13. What sorts of maintainance, if any, could be required for. 

your onboard system over the life of the vehicle? if 

maintainance would be required, please submit details on 

expected cost and frequency. 

14. Is there any incentive for an. owner and/or mechanic to 

disconnect or tamper with your onboard system to improve 

performance or facilitate repairs to other vehicle systems? 

15. Is there any incentive to repair or replace damaged or 

disconnected portions of your onboard system?, Can the 

system be checked after repair, or periodically) as to its 

safety/integrity and function? 

16. Identify and describe all significant modifications to 

fuel and emission systems which will be required if 

onboard systems are to be installed? 

17. Explain why certain design alternatives may have been 

selected, e.g., liquid versus mechanical seal. 

18. How many prototypes have you developed? Describe each. 

Provide a summary of the results of testing conducted on 

these prototypes. 

19. Furnish your opinion of any additional safety risks 

involved with onboard systems. Include an assessment of 

the following: 

a) the causal or contributory factors which could 

increase the chances of a defect or 

non-compliance, 

b) the failure mode, 

c) the risk to motor vehicle safety 

d) any forseeable warning to drivers of the problem.. 

20. Identify (by NHTSA recall number) all safety-related 

defect campaigns which have been conducted due to the 

design, construction and/or performance of systems and/or 

components which are similar in design or function as 

those which will be utilized in any onboard vapor recovery 

system. Provide a summary of the problem- or failure 

involved and the number of known incidents, accidents and 

fatalities involved with each such recall campaign. 

21. Provide copies of all service bulletins and/or other 

communications to dealer/owners which were issued due to 

the design, construction and/or performance of systems 

and/or components which are similar in design or function 

as those which will be utilized in any onboard vapor 

recovery system. Provide a summary of the problem or 

failure involved and the number of known incidents, 

accidents and fatalities involved with each such bulletin 

or communication. 
P.82 

, . .^° S% 

USB,' 

•* UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

ANN ARBOR. MICHIGAN 48105 

OFFICE OF 

AIR AND RADIATION 

NOV I 0 1987 

Ms. Betsy"Jasfe 

c/o Milgrim, Thomajan and Lee 

1025 Connecticut Avenue NW 

Suite 1000 

Washington, DC 20036 

Dear Ms. Jasfe: 

I am writing in response to your 

onboard/volatility hearing held Oct 

Washington, DC. Due to the large numbe 

broad range of issues covered by the 

limits of the hearing prevented us 

testimony as fully as we would have lik 

questions were submitted from National 

Administration (NHTSA) which we did nc 

These questions are included in the enc 

that some of these questions are such t 

included in your written comments. Ho\* 

that these areas, which are of specif 

covered. To the extent possible, based 

this area, please include responses to 

written comments. 

testimony at the recent 

3ber 27-29, 1987 in 

- of testifiers and the 

:wo proposals, the time 

from exploring your 

3d. In particular, some 

Highway Traffic Safety 

-, have _ime to present. 

Losed list. We believe 

nat they will already be 

?ver, we wish to insure 

Lc concern to EPA, are 

upon your knowledge in 

these questions in your 

We appreciate your responsiveness in this matter 

Sincerely yours, 

,•• > 

L < U< * C • x ^ - . 

Charles L. Gray/ Q/'z. 

Director 

Emission Control Technolocv Division 

Enclosure 
P.83 

Suggested Questions from NHTSA to ask 

about the Safety of Onboard Systems• 

1. What safety concerns, if any, do you have regarding 

onboard controls? What is the basis of those concerns? 

2. If onboard controls are required, are you likely to make 

additional changes to. the fuel system? If so, what are 

these changes? 

3. Will-- you provide an "integrated" system, if onboard 

controls are mandated? If not, why not? • ^•'-•' 

4. What safety criteria do you use in designing onboard 

control systems? Do these extend to ease of repair and 

maintenance? 

5. Have you done research regarding fuel tank bladders? if 

so, what is the prognosis for this technology (i.e., 

feasible?, near-term?, etc.)? 

6. Where would the onboard cannistefs be located? How do you 

assure that they do not pose any safety hazard? 

7. Do the crash test requirements of Federal Motor Vehicle 

Safety Standard (FMVSS) No. 301 represent a complete 

matrix of crash tests that you use for purposes of 

checking the crash safety/integrity of the fuel systems of 

your vehicles? If not, are there additional tests that 

you believe are needed? 

8. Does the pass/fail criteria of FMVSS 301, post-crash 

liquid fuel leakage, adequately assess the crash 

safety/integrity of the evaporative and/or onboard vapor 

control system? If not, what additional criteria do youbelieve are needed? 

9. How do you test and evaluate your vehicle fuel systems for 

non-crash fire hazards? 

10. What sensitivity studies do you conduct for onboard 

systems? For example, what range of Reid Vapor Pressure 

(RVP) and ambient temperatures do you consider? 

11. How do you test and evaluate your vehicle fuel systems for 

durability? 

12. How many years or miles of maintenance-free life can be 

expected for the rubber, plastic, metal, charcoal, and 

other components of your onboard system? 
P.84 

13. What sorts of maintainance, if any, could be required for 

your onboard system over the life of the vehicle? if 

maintainance would be required, please submit details on 

expected cost and frequency. 

14. Is there any incentive for an. owner and/or mechanic to 

disconnect or tamper with your onboard system to improve 

performance or facilitate repairs to other vehicle systems? 

15. Is there any incentive to repair or replace damaged or 

disconnected portions of your onboard system?, can the 

system be checked after repair, or periodically, as to its 

safety/integrity and function? 

16. Identify and describe all significant modifications to 

fuel and emission systems which will be required if 

onboard systems are to be installed? 

17. Explain why certain design alternatives may have been 

selected, e.g., liquid versus mechanical seal. 

18. How many prototypes have you developed? Describe each. 

Provide a summary of the results of testing conducted on 

these prototypes. 

19. Furnish your opinion of any additional safety risks 

involved with onboard systems. Include an assessment of 

the following: 

a) the causal or contributory factors which could 

increase the chances of a defect or 

non-compliance, 

b) the failure mode, 

c) the risk to motor vehicle safety 

d) any forseeable warning to drivers of the problem.. 

20. Identify (by NHTSA recall number) all safety-related 

defect campaigns which have been conducted due to the 

design, construction and/or performance of systems and/or 

components which are similar in design or function as 

those which will be utilized in any onboard vapor recovery 

system. Provide a summary of the problem or failure 

involved and the number of known incidents, accidents and 

fatalities involved with each such recall campaign. 

21. Provide copies of all service bulletins and/or other 

communications to dealer/owners which were issued due to 

the design, construction and/or performance of systems 

and/or components which are similar in design or function 

as those which will be utilized in any onboard vapor 

recovery system. Provide a summary of the problem or 

failure involved and the number of known incidents, 

accidents and fatalities involved with each such bulletin 

or communication. 
P.85 

:Y 

$ A \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

ANN ARBOR. MICHIGAN 48105 

OFFICE OF 

AIR AND RADIATION 

NOV I 0 1987 

Mr. Scott Fisher, Director of Government Relations;.*-

c/o Texas Oil Marketers Association 

701 West 15th Street 

Austin, TX 78701 

Dear Mr. Fisher: 

I am writing in response to your testimony at the recent 

onboard/volatility hearing held October 2.7-29, 1987 in 

Washington, DC. Due to the large number of testifiers and the 

broad range of issues covered by the two proposals, the time 

limits of the hearing prevented us from exploring your 

testimony as fully as we would have liked. In particular, some 

questions were submitted from National Highway Traffic Safety 

Administration (NHTSA) which we did not have time to present. 

These questions are included in the enclosed list. We believe 

that some of these questions are such that they will already be 

included in your written comments. However, we wish to insure 

that these areas, which are of specific concern to EPA, are 

covered. To the extent possible, based upon your knowledge in 

this area, please include responses to these questions in your 

written comments. 

We appreciate your responsiveness in this matter. 

Sincerely yours, 

/?.* -, , • 

Charles L. Gray, Jr. 

Director 

Emission Control Technology Division 

Enclosure 
Suggested Questions from NHTSA to ask 

about the Safety of Onboard Systems• 

1. What safety concerns, if any, do you have regarding 

onboard controls? What is the basis of those concerns? 

2. If onboard controls are required, are you likely to make 

additional changes to the fuel system? If so, what are 

these changes? 

3. Will-- you provide an "integrated" system- if onboard 

controls are mandated? If not, why not? •-;*••-•' 

4. What safety criteria do you use in designing onboard 

control systems? Do these extend to ease of repair and 

maintenance? 

5. Have you done research regarding fuel tank bladders? If 

so, what is the prognosis for this technology (i.e., 

feasible?, near-term?, etc.)? 

6. Where would the onboard cannisters be located? How do you 

assure that they do not pose any safety hazard? 

7. Do the crash test requirements of Federal Motor Vehicle 

Safety Standard (FMVSS) No. 301 represent a complete 

matrix of crash tests that you use for purposes of 

checking the crash safety/integrity of the fuel systems of 

your vehicles? If not, are there additional tests that 

you believe are needed? 

8. Does the pass/fail criteria of FMVSS 301, post-crash 

liquid fuel leakage, adequately assess the crash 

safety/integrity of the evaporative and/or onboard vapor 

control system? If not, what additional criteria do you 

believe are needed? 

9. How do you test and evaluate your vehicle fuel systems for 

non-crash fire hazards? 

10. What sensitivity studies do you conduct -for onboard 

systems? For example, what range of Reid Vapor Pressure 

(RVP) and ambient temperatures do you consider? 

11. How do you test and evaluate your vehicle fuel systems for 

durability? 

12. How many years or miles of maintenance-free life can be 

expected for the rubber, plastic, metal, charcoal, and 

other components of your onboard system? 
P.87 

13. What sorts of maintainance, if any, could be required for 

your onboard system over the life of the vehicle? if 

maintainance would be required, please submit details on 

expected cost and frequency. 

14. Is there any incentive for an. owner and/or mechanic to 

disconnect or tamper with your onboard system to improve 

performance or facilitate repairs to other vehicle systems? 

15. Is there any incentive to repair or replace damaged or 

disconnected portions of your onboard system? Can the 

system be checked after repair, or periodically, as to its 

safety/integrity and function? 

16. Identify and describe all significant modifications to 

fuel and emission systems which will be required if 

onboard systems are to be installed? 

17. Explain why certain design alternatives may have been 

selected, e.g., liquid versus mechanical seal. 

18. How many prototypes have you developed? Describe each. 

Provide a summary of the results of testing conducted on 

these prototypes. 

19. Furnish your opinion of any additional safety risks 

involved with onboard systems. Include an assessment of 

the following: 

a) the causal or contributory factors which could 

increase the chances of a defect or 

non-compli ance, 

b) the failure mode, 

c) the risk to motor vehicle safety 

d) any forseeable warning to drivers of the problem,. 

20. Identify (by NHTSA recall number) all safety-related 

defect campaigns which have been conducted due to the 

design, construction and/or performance of systems and/or 

components which are similar in design or function as 

those which will be utilized in any onboard vapor recovery 

system. Provide a summary of the problem- or failure 

involved and the number of known incidents, accidents and 

fatalities involved with each such recall campaign. 

21. Provide copies of all service bulletins and/or other 

communications to dealer/owners which were issued due to 

the design, construction and/or performance of systems 

and/or components which are similar in design or function 

as those which will be utilized in any onboard vapor 

recovery system. Provide a summary of the problem or 

failure involved and the number of known incidents, 

accidents and fatalities involved with each such bulletin 

or communication. 
T P.88 

S

 l A \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

• USB. 

o 

'••tppxjtt0 

ANN ARBOR. MICHIGAN 48105 

OFFICE OF 

AIR AND RADIATION 

NOV I 01987 

Mr Douglas Greenhaus, Senior Attorney for Regulatory Affairs 

c/o NADA 

8400 West Park Drive 

Mc Lean, VA 22102 

Dear Mr. Greenhaus: 

I am writing in response to your testimony at the recent 

onboard/volatility hearing held October 27-29, 1987 in 

Washington, DC. Due to the large number of testifiers and the 

broad range of issues covered by the two proposals, the time 

limits of the hearing prevented us from exploring your 

testimony as fully as we would have liked. In particular, some 

questions were submitted from National Highway Traffic Safety 

Administration (NHTSA) which we did not have time to present. 

These questions are included in the enclosed list. We believe 

that some of these questions are such that they will already be 

included in your written comments. However, we wish to insure 

that these areas, which are of specific concern to EPA, are 

covered. To the extent possible, based upon your knowledge in 

this area, please include responses to these questions in your 

written comments. "\ 

We appreciate your responsiveness in this matter. 

Sincerely yours, 

, •-'. " • • <•' / 

i /i'A'i Lr.> C '*H*'-d <jft • 

Charles L. Gray/J/. 

Director 

Emission Control Technology Division 

Enclosure 
T P.89 

Suggested Questions from NHTSA to ask 

about the Safety of Onboard Systems. 

1. What safety concerns, if any, do you have regarding 

onboard controls? What is the basis of those concerns? 

2. If onboard controls are required, are you likely to make 

additional changes to the fuel system? If so, what are 

these changes? 

3. Will" you provide an "integrated" system., if onboard 

controls are mandated? If not, why not? ••;•*-'•'' 

4. What safety criteria do you use in designing onboard 

control systems? Do these extend to ease of repair and 

maintenance? 

5. Have you done research regarding fuel tank bladders? if 

so, what is the prognosis for this technology (i.e., 

feasible?, near-term?, etc.)? 

6. Where would the onboard cannistefs be located? How do you 

assure that they do not pose any safety hazard? 

7. Do the crash test requirements of Federal Motor Vehicle 

Safety Standard (FMVSS) No. 301 represent a complete 

matrix of crash tests that you use for purposes of 

checking the crash safety/integrity of the fuel systems of 

your vehicles? If not, are there additional tests that 

you believe are needed? 

8. Does the pass/fail criteria of FMVSS 301, post-crash 

liquid fuel leakage, adequately assess the crash 

safety/integrity of the evaporative and/or onboard vapor 

control system? If not, what additional criteria do you 

believe are needed? 

9. How do you test and evaluate your vehicle fuel systems for 

non-crash fire hazards? 

10. What sensitivity studies do you conduct for onboard 

systems? For example, what range of Reid Vapor Pressure 

(RVP) and ambient temperatures do you consider? 

11. How do you test and evaluate your vehicle fuel systems for 

durability? 

12. How many years or miles of maintenance-free life can be 

expected for the rubber, plastic, metal, charcoal, and 

other components of your onboard system? 
T 

13. What sorts of maintainance, if any, could be required for 

your onboard system over the life of the vehicle? if 

maintainance would be required, please submit details on 

expected cost.and frequency. 

14. Is there any incentive for an: owner and/or mechanic to 

disconnect or tamper with your onboard system to improve 

performance or facilitate repairs to other vehicle systems? 

15. Is there any incentive to repair or replace damaged or 

disconnected portions of your onboard system! Can the 

system be checked after repair, or periodically, as to its 

safety/integrity and function? 

16. Identify and describe all significant modifications to 

fuel and emission systems which will be required if 

onboard systems are to be installed? 

17. Explain why certain design alternatives may have been 

selected, e.g., liquid versus mechanical seal. 

18. How many prototypes have you developed? Describe each. 

Provide a summary of the results of testing conducted on 

these prototypes. 

19. Furnish your opinion of any additional safety risks 

involved with onboard systems. Include an assessment of 

the following: 

a) the causal or contributory factors which could 

increase the chances of a defect or 

non-compli ance, 

b) the failure mode, 

c) the risk to motor vehicle safety 

d) any forseeable warning to drivers of the problem.. 

20. Identify (by NHTSA recall number) all safety-related 

defect campaigns which have been conducted due to the 

design, construction and/or performance of systems and/or 

components which are similar in design or function as 

those which will be utilized in any onboard vapor recovery 

system. Provide a summary of the problem or failure 

involved and the number of known incidents, accidents and 

fatalities involved with each such recall campaign. 

21. Provide copies of all service bulletins and/or other 

communications to dealer/owners which were issued due to 

the design, construction and/or performance of systems 

and/or components which are similar in design or function 

as those which will be utilized in any onboard vapor 

recovery system. Provide a summary of the problem or 

failure involved and the number of known incidents, 

accidents and fatalities involved with each such bulletin 

or communication. 
P.91 

* 

2 A \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

\lSEgyJ ANN ARBOR, MICHIGAN 48105 

OFFICE OF 

AIR AND RADIATION 

NOV ! 0 i987 

Mr. Steve Jefferies '•••&•• '••> 

c / o AMOCO 

200 East Randall Drive 

Chicago, IL 60601 

Dear Mr. Jefferies: 

I am writing in response to your testimony at the recent 

onboard/volatility hearing held October 27-29, 1987 in 

Washington, DC. Due to the large number of testifiers and the 

broad range of issues covered by the two proposals, the. time 

limits of the hearing prevented us from exploring your 

"testimony as fully as we would have liked. In particular, some 

questions were submitted from National Highway Traffic Safety 

Administration (NHTSA) which we did not have time to present. 

These questions are included in the enclosed list. We believe 

that some of these questions are such that they will already be 

included in your written comments. However, we wish to insure 

that these areas, which are of specific concern to EPA, are 

covered. To the extent possible, based upon your knowledge in 

this area, please include responses to these questions in your 

written comments. 

We appreciate your responsiveness in this matter. 

Sincerely yours, 

/,- */ ( /Ud^l'—r CJ^)^^ T . 

Charles L. Gray, ,Jr. 

Director 

Emission Control Technology Division 

Enclosure 
Suggested Questions from NHTSA to ask 

about the Safety of Onboard Systems. 

1. What safety concerns, if any, do you have regarding 

onboard controls? What is the basis of those concerns? 

2. If onboard controls are required, are you likely to make 

additional changes to the fuel system? If so, what are 

these changes? 

3. Will" you provide an "integrated" system, if onboard 

controls are mandated? If not, why not? ••;-*•-••' 

4. What safety criteria do you use in designing onboard 

control systems? Do these extend to ease of repair and • 

maintenance? 

5. Have you done research regarding fuel tank bladders? If 

so, what is the prognosis for this technology (i.e., 

feasible?, near-term?, etc.)? 

6. Where would the onboard cannisters be located? How do you 

assure that they do not pose any safety hazard? 

7. Do the crash test requirements of Federal Motor Vehicle 

Safety Standard (FMVSS) No. 301 represent a complete 

matrix of crash tests that you use for purposes of 

checking the crash safety/integrity of the fuel systems of 

your vehicles? If not, are there additional tests that 

you believe are needed? 

8. Does the pass/fail criteria of FMVSS 301, post-crash 

liquid fuel leakage, adequately assess the crash 

safety/integrity of the evaporative and/or onboard vapor 

control system? If not, what additional criteria do you 

believe are needed? 

9. How do you test and evaluate your vehicle fuel systems for 

non-crash fire hazards? 

10. What sensitivity studies do you conduct for onboard 

systems? For example, what range of Reid Vapor Pressure 

(RVP) and ambient temperatures do you consider? 

11. How do you test and evaluate your vehicle fuel systems for 

durability? 

12. How many years or miles of maintenance-free life can be 

expected for the rubber, plastic, metal, charcoal, and 

other components of your onboard system? 
P.93 

13. What sorts of maintainance, if any, could be required for 

your onboard system over the life of the vehicle? if 

maintainance would be required, please submit details on 

expected cost and frequency. 

14. Is there any incentive for an. owner and/or mechanic to 

disconnect or tamper with your onboard system to improve 

performance or facilitate repairs to other vehicle systems? 

15. Is there any incentive to repair or replace damaged or 

disconnected portions of your onboard system!. Can the 

system be checked after repair, or periodically) as to its 

safety/integrity and function? 

16. Identify and describe all significant modifications to 

fuel and emission systems which will be required if 

onboard systems are to be installed? 

17. Explain why certain design alternatives may have been 

selected, e.g., liquid versus mechanical seal. 

18. How many prototypes have you developed? Describe each. 

Provide a summary of the results of testing conducted on 

these prototypes. 

19. Furnish your opinion of any additional safety risks 

involved with onboard systems. Include an assessment of 

the following: 

a) the causal or contributory factors which could 

increase the chances of a defect or 

non-compliance, 

b) the failure mode, 

c) the risk to motor vehicle safety 

d) any forseeable warning to drivers of the problem,. 

20. Identify (by NHTSA recall number) all safety-related 

defect campaigns which have been conducted due to the 

design, construction and/or performance of systems and/or 

components which are similar in design or function as 

those which will be utilized in any onboard vapor recovery 

system. Provide a summary of the problem or failure 

involved and the number of known incidents, accidents and 

fatalities involved with each such recall campaign. 

21. Provide copies of all service bulletins and/or other 

communications to dealer/owners which were issued due to 

the design, construction and/or performance of systems 

and/or components which are similar in design or function 

as those which will be utilized in any onboard vapor 

recovery system. Provide a summary of the problem or 

failure involved and the number of known incidents, 

accidents and fatalities involved with each such bulletin 

or communication. 
P.94 

~ \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

ANN ARBOR. MICHIGAN 48105 

OFFICE OF 

AIR AND RADIATION 

NOV ro w 

Mr. Eric Vaughn, President '••-&...< 

Renewable Fuels Association 

201 Massachusetts Avenue, NE 

Washington, DC 20002 

Dear Mr. Vaughn: 

I am writing in response to your testimony at the recent 

onboard/volatility hearing held October 27-29, 1987 in 

Washington, DC. Due to the large number of testifiers and the 

broad range of issues covered by the two proposals, the. time 

limits of the hearing prevented us from exploring your 

testimony as fully as we would have liked. In particular, some 

questions were submitted from National Highway Traffic Safety 

Administration (NHTSA) which we did not have time to present. 

These questions are included in the enclosed list. We believe 

that some of these questions are such that they will already be 

included in your written comments. However, we wish to insure 

that these areas, which are of specific concern to EPA, are 

covered. To the extent possible, based upon your knowledge in 

this area, please include responses to these questions in your 

written comments. 

We appreciate your responsiveness in this matter. 

Sincerely yours., 

//.; , .. 7 r , 

Charles L. Gray/^r. 

Director 

Emission Control Technology Division 

Enclosure 
P.95 

Suggested Questions from NHTSA to ask 

about the Safety of Onboard Systems. 

1. What safety concerns, if any, do you have regarding 

onboard controls? What is the basis of those concerns? 

2. If onboard controls are required, are you likely to make 

additional changes to the fuel system? If so, what are 

these changes? 

3. Will- you provide an "integrated" system-if onboard 

controls are mandated? If not, why not? ••-*'-; 

4. What safety criteria do you use in designing onboard 

control systems? Do these extend to ease of repair and 

maintenance? 

5. Have you done research regarding fuel tank bladders? If 

so, what is the prognosis for this technology (i.e., 

feasible?, near-term?, etc.)? 

6. Where would the onboard cannisters be located? How do you 

assure that they do not pose any safety hazard? 

7. Do the crash test requirements of Federal Motor Vehicle 

Safety Standard (FMVSS) No. 301 represent a complete 

matrix of crash tests that you use for purposes of 

checking the crash safety/integrity of the fuel systems of 

your vehicles? If not, are there additional tests that 

you believe are needed? 

8. Does the pass/fail criteria of FMVSS 301, post-crash 

liquid fuel leakage, adequately assess the crash 

safety/integrity of the evaporative and/or onboard vapor 

control system? If not, what additional criteria do you 

believe are needed? 

9. How do you test and evaluate your vehicle fuel systems for 

non-crash fire hazards? 

10. What sensitivity studies do you conduct for onboard 

systems? For example, what range of Reid Vapor Pressure 

(RVP) and ambient temperatures do you consider? 

11. How do you test and evaluate your vehicle fuel systems for 

durability? 

12. How many years or miles of maintenance-free life can be 

expected for the rubber, plastic, metal, charcoal, and 

other components of your onboard system? 
13. What sorts of maintainance, if any, could be required for 

your onboard system over the life of the vehicle? if 

maintainance would be required, please submit details on 

expected cost and frequency. 

14. Is there any "incentive for an. owner and/or mechanic to 

disconnect or tamper with your onboard system to improve 

performance or facilitate repairs to other vehicle systems? 

15. Is there any incentive to repair or replace damaged or 

disconnected portions of your onboard system! Can the 

system be checked after repair, or periodically) as to its 

safety/integrity and function? 

16. Identify and describe all significant modifications to 

fuel and emission systems which will be required if 

onboard systems are to be installed? 

17. Explain why certain design alternatives may have been 

selected, e.g., liquid versus mechanical seal. 

18. How many prototypes have you developed? Describe each. 

Provide a summary of the results of testing conducted on 

these prototypes. 

19. Furnish your opinion of any additional safety risks 

involved with onboard systems. Include an assessment of 

the following: 

a) the causal or contributory factors which could 

increase the chances of a defect or 

non-compli ance, 

b) the failure mode, 

c) the risk to motor vehicle safety 

d) any forseeable warning to drivers of the problem,. 

20. Identify (by NHTSA recall number) all safety-related 

defect campaigns which have been conducted due to the 

design, construction and/or performance of systems and/or 

components which are similar in design or function as 

those which will be utilized in any onboard vapor recovery 

system. Provide a summary of the problem or failure 

involved and the number of known incidents, accidents and 

fatalities involved with each such recall campaign. 

21. Provide copies of all service bulletins and/or other 

communications to dealer/owners which were issued due to 

the design, construction and/or performance of systems 

and/or components which are similar in design or function 

as those which will be utilized in any onboard vapor 

recovery system. Provide a summary of the problem or 

failure involved and the number of known incidents, 

accidents and fatalities involved with each such bulletin 

or communication. 
f $ sTm\ \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

US&* 

OFFICE OF 

AIR AND RADIATION 

:• -%\WW-J ANN ARBOR. MICHIGAN 48105 

NOV I 0 I987 

Mr. Walter H. Douthit 

c/o Sun Refining and Marketing 

Box 1135 

Marcus Hook, PA 19061 

Dear Mr. Douthit: 

I am writing in response to your testimony at the recent 

onboard/volatility hearing held October 27-29, 1987 in 

Washington, DC. Due to the large number of testifiers and the 

broad range of issues covered by the two proposals, the time 

limits of the hearing prevented us from exploring your 

testimony as fully as we would have liked. In particular, some 

questions were submitted from National Highway Traffic Safety 

Administration (NHTSA) which we did not have time to present. 

These questions are included in the enclosed list. We believe 

that some of these questions are such that they will already be 

included in your written comments. However, we wish to insure 

that these areas, which are of specific concern to EPA, are 

covered. To the extent possible, based upon your knowledge in 

this area, please include responses to these questions in your 

written comments. 

We appreciate your responsiveness in this matter. 

Sincerely yours, 

Charles L. Gray, JTry 

Director 

Emission Control Technology Division 

Enclosure 
P.98 

Suggested Questions from NHTSA-to ask 

about the Safety of Onboard Systems. 

1. What safety concerns, if any, do you have regarding 

onboard controls? What is the basis of those concerns? 

2. If onboard controls are required, are you likely to make 

additional changes to the fuel system? If so, what are 

these changes? 

3. Will-- you provide an "integrated" system if onboard 

controls are mandated? If not, why not? -^ • 

4. What safety criteria do you use in designing onboard 

control systems? Do these extend to ease of repair and 

maintenance? 

5. Have you done research regarding fuel tank bladders? If 

so, what is the prognosis for this technology (i.e., 

feasible?, near-term?, etc.)? 

6. Where would the onboard cannistefs be located? How do you 

assure that they do not pose any safety hazard? 

7. Do the crash test requirements of Federal Motor Vehicle 

Safety Standard (FMVSS) No. 301 represent a complete 

matrix of crash tests that you use for purposes of 

checking the crash safety/integrity of the fuel systems of 

your vehicles? If not, are there additional tests that 

you believe are needed? 

8. Does the pass/fail criteria of FMVSS 301, post-crash 

liquid fuel leakage, adequately assess the crash 

safety/integrity of the evaporative and/or onboard vapor 

control system? If not, what additional criteria do you: 

believe are needed? 

9. How do you test and evaluate your vehicle fuel systems for 

non-crash fire hazards? 

10. What sensitivity studies do you conduct for onboard 

systems? For example, what range of Reid Vapor Pressure 

(RVP) and ambient temperatures do you consider? 

11. How do you test and evaluate your vehicle fuel, systems for 

durability? 

12. How many years or miles of maintenance-free life can be 

expected for the rubber, plastic, metal, charcoal, and 

other components of your onboard system? 
P.99 

13. What sorts of maintainance, if any, could be required for 

your onboard system over the life of the vehicle? if 

maintainance would be required, please submit details on 

expected cost and frequency. 

14. Is there any incentive for an. owner and/or mechanic to 

disconnect or tamper with your onboard system to improve 

performance or facilitate repairs to other vehicle systems? 

15. Is there any incentive to repair or replace damaged or 

disconnected portions of your onboard system?. Can the 

system be checked after repair, or periodically) as to its 

safety/integrity and function? 

16. Identify and describe all significant modifications to 

fuel and emission systems which will be required if 

onboard systems are to be installed? 

17. Explain why certain design alternatives may have been 

selected, e.g., liquid versus mechanical seal. 

18. How many prototypes have you developed? Describe each. 

Provide a summary of the results of testing conducted on 

these prototypes. 

19. Furnish your opinion of any additional safety risks 

involved with onboard systems. Include an assessment of 

the following: 

a) the causal or contributory factors which could 

increase the chances of a defect or 

non-compliance, 

b) the failure mode, 

c) the risk to motor vehicle safety 

d) any forseeable warning to drivers of the problem,. 

20. Identify (by NHTSA recall number) all safety-related 

defect campaigns which have been conducted due to the 

design, construction and/or performance of systems and/or 

components which are similar in design or function as 

those which will be utilized in any onboard vapor recovery 

system. Provide a summary of the problem or failure 

involved and the number of known incidents, accidents and 

fatalities involved with each such recall campaign. 

21. Provide copies of all service bulletins and/or other 

communications to dealer/owners which were issued due to 

the design, construction and/or performance of systems 

and/or components which are similar in design or function 

as those which will be utilized in any onboard vapor 

recovery system. Provide a summary of the problem or 

failure involved and the number of known incidents, 

accidents and fatalities involved with each such bulletin 

or communication. 
P.1 

/ A \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

|^2t£r>

 AN N

 ARBOR. MICHIGAN 48105 

\ . ___r ^«<jtt v 

OFFICE OF 

AIR AND RADIATION 

NOV I 0 I98T 

Mr. Kim H. Bullerdick 

c/o Giant Industries, Incorporated 

P.O. Box 9156 

Phoenix, AZ 85068 

Dear Mr. Bullerdick: 

I am writing in response to your -estimcr.y at the recent 

onboard/volatility hearing held October 27-29, 1987 in 

Washington, DC. Due to the large number of testifiers and the 

broad range of issues covered by the -wo proposals, the time 

limits of the hearing prevented us from exploring your 

testimony as fully as we would have lik£d. In particular, some 

guestions were submitted from National Highway Traffic Safety 

Administration (NHTSA) which we did no*; have time to present. 

These questions are included in the enclosed list. We believe 

that some of these questions are such that they will already be 

included in your written comments. Hov.ever, we wish to insure 

that these areas, which are of specif .c concern to EPA, are 

covered. To the extent possible, basec upon your knowledge in 

this area, please include responses to :hese questions in your 

written comments. 

We appreciate your responsiveness ii this matter. 

Sincerely yours, 

C <-i ^v :

 l-'-'*=• . •1-^''-:.7 -h> 

Charles L. Gray'JJf:) 

Director 

Emission Control Technology Division 

Enclosure 
P.2 

Suggested Questions from NHTSA to ask 

about the Safety of Onboard Systems. 

1. What safety concerns, if any, do you have regarding 

onboard controls? What is the basis of those concerns? 

2. if onboard controls are required, are you likely to make 

additional changes to the fuel system? If so, what are 

these changes? 

3. Will-- you provide an "integrated" system- if onboard 

controls are mandated? If not, why not? ••••*--••• 

4. What safety criteria do you use in designing onboard 

control systems? Do these extend to ease of repair and 

maintenance? 

5. Have you done research regarding fuel tank bladders? If 

so, what is the prognosis for this technology (i.e., 

feasible?, near-term?, etc.)? 

6. Where would the onboard cannisters be located? How do you 

assure that they do not pose any safety hazard? 

7. Do the crash test requirements of Federal Motor Vehicle 

Safety Standard (FMVSS) No. 301 represent a complete 

matrix of crash tests that you use for purposes of 

checking the crash safety/integrity of the fuel systems of 

your vehicles? If not, are there additional tests that 

you believe are needed? 

8. Does the pass/fail criteria of FMVSS 301, post-crash 

liquid fuel leakage, adequately assess the crash 

safety/integrity of the evaporative and/or onboard vappr 

control system? If not, what additional criteria do yoifc 

believe are needed? 

9. How do you test and evaluate your vehicle fuel systems for 

non-crash fire hazards? 

10. What sensitivity studies do you conduct for onboard 

systems? For example, what range of Reid Vapor Pressure 

(RVP) and ambient temperatures do you consider? 

11. How do you test and evaluate your vehicle fuel systems for 

durability? 

12. How many years or miles of maintenance-free life can be 

expected for the rubber, plastic, metal, charcoal, and 

other components of your onboard system? 
P.3 

13. What sorts of maintainance, if any, could be required for 

your onboard system over the life of the vehicle? if 

maintainance would be required, please submit details on 

expected cost and frequency. 

14. Is there any incentive for an. owner and/or mechanic to 

disconnect or tamper with your onboard system to improve 

performance or facilitate repairs to other vehicle systems? 

15. Is there any incentive to repair or replace damaged or 

disconnected portions of your onboard system?. Can the 

system be checked after repair, or periodicaii'y, as to its 

safety/integrity and function? 

16. Identify and describe all significant modifications to 

fuel and emission systems which will be required if 

onboard systems are to be installed? 

17. Explain why certain design alternatives may have been 

selected, e.g., liquid versus mechanical seal. 

18. How many prototypes have you developed? Describe each. 

Provide a summary of the results of testing conducted on 

these prototypes. 

19. Furnish your opinion of any additional safety risks 

involved with onboard systems. Include an assessment of 

the following: 

a) the causal or contributory factors which could 

increase the chances of a defect or 

non-compli ance, 

b) the failure mode, 

c) the risk to motor vehicle safety 

d) any forseeable warning to drivers of the problem.. 

20. Identify (by NHTSA recall number) all safety-related 

defect campaigns which have been conducted due to the 

design, construction and/or performance of systems and/or 

components which are similar in design or function as 

those which will be utilized in any onboard vapor recovery 

system. Provide a summary of the problem or failure 

involved and the number of known incidents, accidents and 

fatalities involved with each such recall campaign. 

21. Provide copies of all service bulletins and/or other 

communications to dealer/owners which were issued due to 

the design, construction and/or performance of systems 

and/or components which are similar in design or function 

as those which will be utilized in any onboard vapor 

recovery system. Provide a summary of the problem or 

failure involved and the number of known incidents, 

accidents and fatalities involved with each such bulletin 

or communication. 
P.4 

- *«i0 SUfi-

/ _f% \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

ANN ARBOR. MICHIGAN 48105 

OFFICE OF 

AIR AND RADIATION 

NOV I 0 i98T 

Mr. Gary L. Petersen 

c/o Newhall Refining Company, Incorporated 

P.O. Box 938 

Newhall, CA 91322 

Dear Mr. Petersen: 

I am writing in response to your testimony at the recent 

onboard/volatility hearing held October 27-29, 1987 in 

Washington, DC. Due to the large number of testifiers and the 

broad range of issues covered by the two proposals, the time 

limits of the hearing prevented us from exploring your 

testimony as fully as we would have liked. In particular, some 

questions were submitted from National Highway Traffic Safety 

Administration (NHTSA) which we did not have time to present. 

These questions are included in the enclosed list. We believe 

that some of these guestions are such that they will already be 

included in your written comments. However, we wish to insure 

that these areas, which are of specific concern to EPA, are 

covered. To the extent possible, based upon your knowledge in 

this area, please include responses to these questions in your 

written comments. \ 

We appreciate your responsiveness in this matter. 

Sincerely yours, 

Charles L. Grayg(Jr. 

Director 

Emission Control Technology Division 

Enclosure 
P.5 

Suggested Questions from NHTSA to ask 

about the Safety of Onboard Systems• 

1. What safety concerns, if any, do you have regarding 

onboard controls? What is the basis of those concerns? 

2. If onboard controls are required, are you likely to make 

additional changes to. the fuel system? If so, what are 

these changes? 

3. Will-- you provide an "integrated" system, if onboard 

controls are mandated? If not, why not? ' **"'"' 

4. What safety criteria do you use in designing onboard 

control systems? Do these extend to ease of repair and 

maintenance? 

5. Have you done research regarding fuel tank bladders? If 

so, what is the prognosis for this technology (i.e., 

feasible?, near-term?, etc.)? 

6. Where would the onboard cannistefs be located? How do you 

assure that they do not pose any safety hazard? 

7. Do the crash test requirements of Federal Motor Vehicle 

Safety Standard (FMVSS) No. 301 represent a complete 

matrix of crash tests that you use for purposes of 

checking the crash safety/integrity of the fuel systems of 

your vehicles? If not, are there additional tests that 

you believe are needed? 

8. Does the pass/fail criteria of FMVSS 301, post-crash 

liquid fuel leakage, adequately assess the crash 

safety/integrity of the evaporative and/or onboard vappr 

control system? If not, what additional criteria do you* 

believe are needed? 

9. How do you test and evaluate your vehicle fuel systems for 

non-crash fire hazards? 

10. What sensitivity studies do you conduct for onboard 

systems? For example, what range of Reid Vapor Pressure 

(RVP) and ambient temperatures do you consider? 

11. How do you test and evaluate your vehicle fuel systems for 

durability? 

12. How many years or miles of maintenance-free life can be 

expected for the rubber, plastic, metal, charcoal, and 

other components of your onboard system? 
P.6 

13. What sorts of maintainance, if any, could be required for 

your onboard system over the life of the vehicle? if 

maintainance would be required, please submit details on 

expected cost and frequency. 

14. Is there any incentive for an. owner and/or mechanic to 

disconnect or tamper with your onboard system to improve 

performance or facilitate repairs to other vehicle systems? 

15. Is there any incentive to repair or replace damaged or 

disconnected portions of your onboard system?. Can the 

system be checked after repair, or periodically, as to its 

safety/integrity and function? 

16. Identify and describe all significant modifications to 

fuel and emission systems which will be required if 

onboard systems are to be installed? 

17. Explain why certain design alternatives . may have been 

selected, e.g., liquid versus mechanical seal. 

18. How many prototypes have you developed? Describe each. 

Provide a summary of the results of testing conducted on 

these prototypes. 

19. Furnish your opinion of any additional safety risks 

involved with onboard systems. Include an assessment of 

the following: 

a) the causal or contributory factors which could 

increase the chances of a defect or 

non-compli ance, 

b) the failure mode, 

c) the risk to motor vehicle safety 

d) any forseeable warning to drivers of the problem,. 

-\ 

20. Identify (by NHTSA recall number) all safety-related 

defect campaigns which have been conducted due to the 

design, construction and/or performance of systems and/or 

components which are similar in design or function as 

those which will be utilized in any onboard vapor recovery 

system. Provide a summary of the problem or failure 

involved and the number of known incidents, accidents and 

fatalities involved with each such recall campaign. 

21. Provide copies of all service bulletins and/or other 

communications to dealer/owners which were issued due to 

the design, construction and/or performance of systems 

and/or components which are similar in design or function 

as those which will be utilized in any onboard vapor 

recovery system. Provide a summary of the problem or 

failure involved and the number of known incidents, 

accidents and fatalities involved with each such bulletin 

or communication. 
P.7 

USBJ 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

ANN ARBOR. MICHIGAN 48105 

OFFICE OF 

AIR AND RADIATION 

MOV I 0 1987 

Mr. Craig Moyer, Counsel for AIRA 

c/o Demettriou, Del Guercio and Lovejoy 

649 South Olive Street 

Suite 500 

Los Angeles, CA 90014 

Dear Mr. Moyer: 

I am writing in response to your testimony at the recent 

onboard/volatility hearing held October 27-29, 1987 in 

Washington, DC. Due to the large number of testifiers and the 

broad range of issues covered by the two proposals, the time 

limits of the hearing prevented us from exploring your 

testimony as fully as we would have liked. In particular, some 

questions were submitted from National Highway Traffic Safety 

Administration (NHTSA) which we did not have time to present. 

These questions are included in the enclosed list. We believe 

that some of these questions are such that they will already be 

included in your written comments. However, we wish to insure 

that these areas, which are of specific concern to EPA, are 

covered. To the extent possible, based upon your knowledge in 

this area, please include responses to .hese questions in your 

written comments. \ 

We appreciate your responsiveness in this matter. 

Sincerely yours, 

. '?' : - r -/ '-• 

C //Si. w V (. .Ji£.<i . ~)f^ 

Charles L. Gray/ tfi • 

Director 

Emission Control Technology Division 

Enclosure 
P.8 

Suggested Questions from NHTSA to ask 

about the Safety of Onboard Systems. 

1. What safety concerns, if any, do you have regarding 

onboard controls? What is the basis of those concerns? 

2. If onboard controls are required, are you likely to make 

additional changes to the fuel system? If so, what are 

these changes? 

3. Will- you provide an "integrated" system, if onboard 

controls are mandated? If not, why not? •;&••'-' 

4. What safety criteria do you use in designing onboard 

control systems? Do these extend to ease of repair and 

maintenance? 

5. Have you done research regarding fuel tank bladders? If 

so, what is the prognosis for this technology (i.e., 

feasible?, near-term?, etc.)? 

6. Where would the onboard cannisters be located? How do you 

assure that they do not pose any safety hazard? 

7. Do the crash test requirements of Federal Motor Vehicle 

Safety Standard (FMVSS) No. 301 represent a complete 

matrix of crash tests that you use for purposes of 

checking the crash safety/integrity of the fuel systems of 

your vehicles? If not, are there additional tests that 

you believe are needed? 

8. Does the pass/fail criteria of FMVSS 301, post-crash 

liquid fuel leakage, adequately assess the crash 

safety/integrity of the evaporative and/or onboard vapor 

control system? If not, what additional criteria do yov* 

believe are needed? 

9. How do you test and evaluate your vehicle fuel systems for 

non-crash fire hazards? 

10. What sensitivity studies do you conduct for onboard 

systems? For example, what range of Reid Vapor Pressure 

(RVP) and ambient temperatures do you consider? 

11. How do you test and evaluate your vehicle fuel systems for 

durability? 

12. How many years or miles of maintenance-free life can be 

expected for the rubber, plastic, metal, charcoal, and 

other components of your onboard system? 
P.9 

13. What sorts of maintainance, if any, could be required for 

your onboard system over the life of the vehicle? if 

maintainance would be required, please submit details on 

expected cost and frequency. 

14. Is there any incentive for an. owner and/or mechanic to 

disconnect or tamper with your onboard system to improve 

performance or facilitate repairs to other vehicle systems? 

15. Is there any incentive to repair or replace damaged or 

disconnected portions of your onboard system? Can the 

system be checked after repair, or periodically^ as to its 

safety/integrity and function? 

16. Identify and describe all significant modifications to 

fuel and emission systems which will be required if 

onboard systems are to be installed? 

17. Explain why certain design alternatives may have been 

selected, e.g., liquid versus mechanical seal 

18. How many prototypes have you developed? Describe each. 

Provide a summary of the results of testing conducted on 

these prototypes. 

19. Furnish your opinion of any additional safety risks 

involved with onboard systems. Include an assessment of 

the following: 

a) the causal or contributory factors which could 

increase the chances of a defect or 

non-compliance, 

b) the failure mode, 

c) the risk to motor vehicle safety 

d) any forseeable warning to drivers of the problem.. 

20. Identify (by NHTSA recall number) all safety-related 

defect campaigns which have been conducted due to the 

design, construction and/or performance of systems and/or 

components which are similar in design or function as 

those which will be utilized in any onboard vapor recovery 

system. Provide a summary of the problem or failure 

involved and the number of known incidents, accidents and 

fatalities involved with each such recall campaign. 

21. Provide copies of all service bulletins and/or other 

communications to dealer/owners which were issued due to 

the design, construction and/or performance of systems 

and/or components which are similar in design or function 

as those which will be utilized in any onboard vapor 

recovery system. Provide a summary of the problem or 

failure involved and the number of known incidents, 

accidents and fatalities involved with each such bulletin 

or communication. 
P.10 

#

i 

? A \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

1^_S-^/

 AN N

 ARBOR. MICHIGAN 48105 

NPRC* 0 

OFFICE OF 

AIR AND RADIATION 

NOV ! 0 :98T 

Mr. Linas Gobis 

c/o MVMA 

300 New Center Building 

Detroit, MI 48202 

Dear Mr. Gobis: 

I am writing in response to your testimony at the recent 

onboard/volatility hearing held October 27-29, 1987 in 

Washington, DC. Due to the large number of testifiers and the 

broad range of issues covered by the two proposals, the time 

limits of the hearing prevented us from exploring your 

testimony as fully as we would have liked. In particular, some 

guestions were submitted from National Highway Traffic Safety 

Administration (NHTSA) which we did not have time to present. 

These questions are included in the enclosed list. We believe 

that some of these questions are such that they will already be 

included in your written comments. However, we wish to insure 

that these areas, which are of specific concern to EPA, are 

covered. To the extent possible, based upon your knowledge in 

this area, please include responses to these questions in your 

written comments. 

We appreciate your responsiveness in this matter. 

Sincerely yours, 

•? 

Charles L. GrayV(_yr. 

Director 

Emission Control Technology Division 

Enclosure 
P.11 

Suggested Questions from NHTSA to ask 

about the Safety of Onboard Systems. 

1. What safety concerns, if any, do you have regarding 

onboard controls? What is the basis of those concerns? 

2. If onboard controls are required, are you likely to make 

additional changes to the fuel system? If so, what are 

these changes? 

3. Will-- you provide an "integrated" system , if onboard 

controls are mandated? If not, why not? ^: ' 

4. What safety criteria do you use in designing onboard 

control systems? Do these extend to ease of repair and 

maintenance? 

5. Have you done research regarding fuel tank bladders? if 

so, what is the prognosis for this technology (i.e., 

feasible?, near-term?, etc.)? 

6. Where would the onboard cannistefs be located? How do you 

assure that they do not pose any safety hazard? 

7. Do the crash test requirements of Federal Motor Vehicle 

Safety Standard (FMVSS) No. 301 represent a complete 

matrix of crash tests that you use for purposes of 

checking the crash safety/integrity of the fuel systems of 

your vehicles? If not, are there additional tests that 

you believe are needed? 

8. Does the pass/fail criteria of FMVSS 301, post-crash 

liquid fuel leakage, adequately assess the crash 

safety/integrity of the evaporative and/or onboard vappr 

control system? If not, what additional criteria do youbelieve are needed? 

9. How do you test and evaluate your vehicle fuel systems for 

non-crash fire hazards? 

10. What sensitivity studies do you conduct _ for onboard 

systems? For example, what range of Reid Vapor Pressure 

(RVP) and ambient temperatures do you consider? 

11. How do you test and evaluate your vehicle fuel systems for 

durability? 

12. How many years or miles of maintenance-free life can be 

expected for the rubber, plastic, metal, charcoal, and 

other components of your onboard system? 
P.12 

13. What sorts of maintainance, if any, could be required for 

/• your onboard system over the life of the vehicle? If 

maintainance would be required, please submit details on 

expected cost and frequency. 

14. Is there any incentive for an: owner and/or mechanic to 

disconnect or tamper with your onboard system to improve 

performance or facilitate repairs to other vehicle systems? 

15. Is there any incentive to repair or replace damaged or 

disconnected portions of your onboard system? Can the 

system be checked after repair, or periodically'^ as to its 

safety/integrity and function? 

16. Identify and describe all significant modifications to 

fuel and emission systems which will be required if 

onboard systems are to be installed? 

17. Explain why certain design alternatives may have been 

selected, e.g., liquid versus mechanical seal. 

18. How many prototypes have you developed? Describe each. 

Provide a summary of the results of testing conducted on 

these prototypes. 

19. Furnish your opinion of any additional safety risks 

involved with onboard systems. Include an assessment of 

the following: 

a) the causal or contributory factors which could 

increase the chances of a defect or 

non-compliance, 

b) the failure mode, 

c) the risk to motor vehicle safety 

d) any forseeable warning to drivers of the problem.. 

20. Identify (by NHTSA recall number) all safety-related 

defect campaigns which have been conducted due to the 

design, construction and/or performance of systems and/or 

components which are similar in design or function as 

those which will be utilized in any onboard vapor recovery 

system. Provide a summary of the problem- or failure 

involved and the number of known incidents, accidents and 

fatalities involved with each such recall campaign. 

21. Provide copies of all service bulletins and/or other 

communications to dealer/owners which were issued due to 

the design, construction and/or performance of systems 

and/or components which are similar in design or function 

as those which will be utilized in any onboard vapor 

recovery system. Provide a summary of the problem or 

failure involved and the number of known incidents, 

accidents and fatalities involved with each such bulletin 

or communication. 
P.13 

I > . 

• * _F_k % UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

ANN ARBOR. MICHIGAN 48105 

OFFICE OF 

AIR AND RADIATION 

NOV I 0 1987 

Mr. Gregory; J. Dana, Technical Director 

c/o Automobile Importers of America, Inc. 

Suite 1002 

1725 Jefferson Davis Highway 

Arlington, VA 22202 

Dear Mr. Dana: 

I am writing in response to your testimony at the recent 

onboard/volatility hearing held October 27-29, 1987 in 

Washington, DC. Due to the large number of testifiers and the 

broad range of issues covered by the two proposals, the time 

limits of the hearing prevented us from exploring your 

testimony as fully as we would have liked. In particular, some 

questions were submitted from National Highway Traffic Safety 

Administration (NHTSA) which we did not have time to present. 

These questions are included in the enclosed list. We believe 

that some of these questions are such that they will already be 

included in your written comments. However, we wish to insure 

that these areas, which are of specific concern to EPA, are 

covered. To the extent possible, based upon your knowledge in 

this area, please include responses to these questions in your 

written comments. -v 

We appreciate your responsiveness in this matter. 

Sincerely yours, 

/ / / • , . .• ' 

Charles L. Grayy Jjf". 

Director 

Emission Control Technology Division 

Enclosure 
P.14 

- * • > 

Suggested Questions from NHTSA to ask 

about the Safety of Onboard Systems. 

1. What safety concerns, if any, do you have regarding 

onboard controls? What is the basis of those concerns? 

2. If onboard controls are required, are you likely to make 

additional changes to the fuel system? If so, what are 

these changes? 

3. Will" you provide an "integrated" system.- if onboard 

controls are mandated? If not, why not? •-.••*--•' 

4. What safety criteria do you use in designing onboard 

control systems? Do these extend to ease of repair and 

maintenance? 

5. Have you done research regarding fuel tank bladders? If 

so, what is the prognosis for this technology (i.e., 

feasible?, near-term?, etc.)? 

6. Where would the onboard cannistefs be located? How do you 

assure that they do not pose any safety hazard? 

7. Do the crash test requirements of Federal Motor Vehicle 

Safety Standard (FMVSS) No. 301 represent a complete 

matrix of crash tests that you use for purposes of 

checking the crash safety/integrity of the fuel systems of 

your vehicles? If not, are there additional tests that 

you believe are needed? 

8. Does the pass/fail criteria of FMVSS 301, post-crash 

liquid fuel leakage, adequately assess the crash 

safety/integrity of the evaporative and/or onboard vapor 

control system? If not, what additional criteria do you: 

believe are needed? 

9. How do you test and evaluate your vehicle fuel systems for 

non-crash fire hazards? 

10. What sensitivity studies do you conduct for onboard 

systems? For example, what range of Reid Vapor Pressure 

(RVP) and ambient temperatures do you consider? 

11. How do you test and evaluate your vehicle fuel systems for 

durability? 

12. How many years or miles of maintenance-free life can be 

expected for the rubber, plastic, metal, charcoal, and 

other components of your onboard system? 
P.15 

13. What sorts of maintainance, if any, could be required for 

your onboard system over the life of the vehicle? if 

maintainance would be required, please submit details on 

expected cost and frequency. 

14. Is there any incentive for an. owner and/or mechanic to 

disconnect or tamper with your onboard system to improve 

performance or facilitate repairs to other vehicle systems? 

15. Is there any incentive to repair or replace damaged or 

disconnected portions of your onboard systemf Can the 

system be checked after repair, or periodically, as to its 

safety/integrity and function? 

16. Identify and describe all significant modifications to 

fuel and emission systems which will be required if 

onboard systems are to be installed? 

17. Explain why certain design alternatives may have been 

selected, e.g., liquid versus mechanical seal. 

18. How many prototypes have you developed? Describe each. 

Provide a summary of the results of testing conducted on 

these prototypes. 

19. Furnish your opinion of any additional safety risks 

involved with onboard systems. Include an assessment of 

the following: 

a) the causal or contributory factors which could 

increase the chances of a defect or 

non-compliance, 

b) the failure mode, 

c) the risk to motor vehicle safety 

d) any forseeable warning to drivers of the problem,. 

20. Identify (by NHTSA recall number) all safety-related 

defect campaigns which have been conducted due to the 

design, construction and/or performance of systems and/or 

components which are similar in design or function as 

those which will be utilized in any onboard vapor recovery 

system. Provide a summary of the problem or failure 

involved and the number of known incidents, accidents and 

fatalities involved with each such recall campaign. 

21. Provide copies of all service bulletins and/or other 

communications to dealer/owners which were issued due to 

the design, construction and/or performance of systems 

and/or components which are similar in design or function 

as those which will be utilized in any onboard vapor 

recovery system. Provide a summary of the problem or 

failure involved and the number of known incidents, 

accidents and fatalities involved with each such bulletin 

or communication. 
P.16 

\ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

3 ANN ARBOR. MICHIGAN 48105 

OFFICE OF 

AIR AND RADIATION 

NOV 1 0 1987 

Mr. Jerome C. Loftus 

c/o Recreational Vehicle Industry Association 

1896 Preston White Drive 

P.O. Box 2999 

Reston, VA 22090 

Dear Mr. Loftus: 

I am writing in response to your testimony at the recent 

onboard/volatility hearing held October 27-29, 1987 in 

Washington, DC. Due to the large number of testifiers and the 

broad range of issues covered by the two proposals, the time 

limits of the hearing prevented us from exploring your 

testimony as fully as we would have liked. In particular, some 

questions were submitted from National Highway Traffic Safety 

Administration (NHTSA) which we did not have time to present. 

These questions are included in the enclosed list. We believe 

that some of these questions are such that they will already be 

included in your written comments. However, we wish to insure 

that these areas, which are of specific concern to EPA, are 

covered. To the extent possible, based upon your knowledge in 

this area, please include responses to these questions in your 

written comments. ^ 

We appreciate your responsiveness in this matter. 

Sincerely yours, 

Charles L. GrayVJJr. 

Director 

Emission Control Technology Division 

Enclosure 
Suggested Questions from NHTSA to ask 

about the Safety of Onboard Systems. 

1. What safety concerns, if any, do you have regarding 

onboard controls? What is the basis of those concerns? 

2. If onboard controls are required, are you likely to make 

additional changes to the fuel system? If so, what are 

these changes? 

3. Will-- you provide an "integrated" system, if onboard 

controls are mandated? If not, why not? ••:•»•-••' 

4. What safety criteria do you use in designing onboard 

control systems? Do these extend to ease of repair and 

maintenance? 

5. Have you done research regarding fuel tank bladders? If 

so, what is the prognosis for this technology (i.e., 

feasible?, near-term?, etc.)? 

6. Where would the onboard cannisters be located? How do you 

assure that they do not pose any safety hazard? 

7. Do the crash test requirements of Federal Motor Vehicle 

Safety Standard (FMVSS) No. 301 represent a complete 

matrix of crash tests that you use for purposes of 

checking the crash safety/integrity of the fuel systems of 

your vehicles? If not, are there additional tests that 

you believe are needed? 

8. Does the pass/fail criteria of FMVSS 301, post-crash 

liquid fuel leakage, adequately assess the crash 

safety/integrity of the evaporative and/or onboard vapor 

control system? If not, what additional criteria do you; 

believe are needed? 

9. How do you test and evaluate your vehicle fuel systems for 

non-crash fire hazards? 

10. What sensitivity studies do you conduct for onboard 

systems? For example, what range of Reid Vapor Pressure 

(RVP) and ambient temperatures do you consider? 

11. How do you test and evaluate your vehicle fuel, systems for 

durability? 

12. How many years or miles of maintenance-free life can be 

expected for the rubber, plastic, metal, charcoal, and 

other components of your onboard system? 
P.18 

13. What sorts of maintainance, if any, could be required for 

your onboard system over the life of the vehicle? if 

maintainance would be required, please submit details on 

expected cost and frequency. 

14. Is there any incentive for an. owner and/or mechanic to 

disconnect or tamper with your onboard system to improve 

performance or facilitate repairs to other vehicle systems? 

15. Is there any incentive to repair or replace damaged or 

disconnected portions of your onboard system?; Can the 

system be checked after repair, or periodically, as to its 

safety/integrity and function? 

16. Identify and describe all significant modifications to 

fuel and emission systems which will be required if 

onboard systems are to be installed? 

17. Explain why certain design alternatives may have been 

selected, e.g., liquid versus mechanical seal. 

18. How many prototypes have you developed? Describe each. 

Provide a summary of the results of testing conducted on 

these prototypes. 

19. Furnish your opinion of any additional safety risks 

involved with onboard systems. Include an assessment of 

the following: 

a) the causal or contributory factors which could 

increase the chances of a defect or 

non-compli ance, 

b) the failure mode, 

c) the risk to motor vehicle safety 

d) any forseeable warning to drivers of the problem.. 

20. Identify (by NHTSA recall number) all safety-related 

defect campaigns which have been conducted due to the 

design, construction and/or performance of systems and/or 

components which are similar in design or function as 

those which will be utilized in any onboard vapor recovery 

system. Provide a summary of the problem or failure 

involved and the number of known incidents, accidents and 

fatalities involved with each such recall campaign. 

21. Provide copies of all service bulletins and/or other 

communications to dealer/owners which were issued due to 

the design, construction and/or performance of systems 

and/or components which are similar in design or function 

as those which will be utilized in any onboard vapor 

recovery system. Provide a summary of the problem or 

failure involved and the number of known incidents, 

accidents and fatalities involved with each such bulletin 

or communication. 
P.19 

yf°Srv*-

«. !> £ _fl_

 ri UNITED STATES ENVIRONMENTAL PROTECTJON AGENCY 

\5_J2^ i ANN ARBOR. MICHIGAN 48105 

OFFICE OF 

AIR AND RADIATION 

MOV I 0 1987 

Mr. Herbert Wortreich 

c/o New Jersey Department of Environmental Protection 

Division of Environmental Quality 

401 East State Street, 2nd Floor 

Trenton , NJ 08625 

Dear Mr. Wortreich: 

I am writing in response to your testimony at the recent 

onboard/volatility hearing held October 27-29, 1987 in 

Washington, DC. Due to the large number of testifiers and the 

broad range of issues covered by the two proposals, the time 

limits of the hearing prevented us from exploring your 

testimony as fully as we would have liked. In particular, some 

questions were submitted from National Highway Traffic Safety 

Administration (NHTSA) which we did not have time to present. 

These questions are included in the enclosed list. We believe 

that some of these questions are such that they will already be 

included in your written comments. However, we wish to insure 

that these areas, which are of specific concern to EPA, are 

covered. To the extent possible, based upon your knowledge in 

this area, please include responses to these guestions in your 

written comments. 

We appreciate your responsiveness in this matter. 

Sincerely yours, 

' " < * 

/ / : " ••• r ' \ 

C /^K.<-t~-«- '• VM^J ' •& • 

Charles L. Gray?''Jr. 

Director 

Emission Control Technology Division 

Enclosure 
P.20 

Suggested Questions from NHTSA-to ask 

about the Safety of Onboard Systems. 

1. What safety concerns, if any, do you have regarding 

onboard controls? What is the basis of those concerns? 

2. If onboard controls are required, are you likely to make 

additional changes to the fuel system? If so, what are 

these changes? 

3. Will-- you provide an "integrated" system- if onboard 

controls are mandated? If not, why not? •**••'-' 

4. What safety criteria do you use in designing onboard 

control systems? Do these extend to ease of repair and 

maintenance? 

5. Have you done research regarding fuel tank bladders? If 

so, what is the prognosis for this technology (i.e., 

feasible?, near-term?, etc.)? 

6. Where would the onboard cannisters be located? How do you 

assure that they do not pose any safety hazard? 

7. Do the crash test requirements of Federal Motor Vehicle 

Safety Standard (FMVSS) No. 301 represent a complete 

matrix of crash tests that you use for purposes of 

checking the crash safety/integrity of the fuel systems of 

your vehicles? If not, are there additional tests that 

you believe are needed? 

8. Does the pass/fail criteria of FMVSS 301, post-crash 

liquid fuel leakage, adequately assess the crash 

safety/integrity of the evaporative and/or onboard vapor 

control system? If not, what additional criteria do you> 

believe are needed? 

9. How do you test and evaluate your vehicle fuel systems for 

non-crash fire hazards? 

10. What sensitivity studies do you conduct for onboard 

systems? For example, what range of Reid Vapor Pressure 

(RVP) and ambient temperatures do you consider? 

11. How do you test and evaluate your vehicle fuel systems for 

durability? 

12. How many years or miles of maintenance-free life can be 

expected for the rubber, plastic, metal, charcoal, and 

other components of your onboard system? 
P.21 

13. What sorts of maintainance, if any, could be required for 

your onboard system over the life of the vehicle? If 

maintainance would be required, please submit details on 

expected cost and frequency. 

14. Is there any incentive for an. owner and/or mechanic to 

disconnect or tamper with your onboard system to improve 

performance or facilitate repairs to other vehicle systems? 

15. Is there any incentive to repair or replace damaged or 

disconnected portions of your onboard system?. Can the 

system be checked after repair, or periodically, as to its 

safety/integrity and function? 

16. Identify and describe all significant modifications to 

fuel and emission systems which will be required if 

onboard systems are to be installed? 

17. Explain why certain design alternatives may have been 

selected, e.g., liquid versus mechanical seal. 

18. How many prototypes have you developed? Describe each. 

Provide a summary of the results of testing conducted on 

these prototypes. 

19. Furnish your opinion of any additional safety risks 

involved with onboard systems. Include an assessment of 

the following: 

a) the causal or contributory factors which could 

increase the chances of a defect or 

non-compliance, 

b) the failure mode, 

c) the risk to motor vehicle safety 

d) any forseeable warning to drivers of the problem,. 

20. Identify (by NHTSA recall number) all safety-related 

defect campaigns which have been conducted due to the 

design, construction and/or performance of systems and/or 

components which are similar in design or function as 

those which will be utilized in any onboard vapor recovery 

system. Provide a summary of the problem or failure 

involved and the number of known incidents, accidents and 

fatalities involved with each such recall campaign. 

21. Provide copies of all service bulletins and/or other 

communications to dealer/owners which were issued due to 

the design, construction and/or performance of systems 

and/or components which are similar in design or function 

as those which will be utilized in any onboard vapor 

recovery system. Provide a summary of the problem or 

failure involved and the number of known incidents, 

accidents and fatalities involved with each such bulletin 

or communication. 
f P.22 

& Af% \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

I -^gp^Zj* ANN ARBOR. MICHIGAN 48105 

%«* / 

OFFICE OF 

AIR AND RADIATION 

NOV I 0 I98T 

Mr. Daniel H. Moenter, Director -*• 

Industry & Corporate Affairs 

c/o Marathon Petroleum Company 

539 South Main Street 

Findlay, OH 45840 

Dear Mr. Moenter: 

I am writing in response to your testimony at the recent 

onboard/volatility hearing held October 27-29, 1987 in 

Washington, DC. Due to the large number of testifiers and the 

broad range of issues covered by the two proposals, the time 

limits of the hearing prevented us from exploring your 

testimony as fully as we would have liked. In particular, some 

questions were submitted from National Highway Traffic Safety 

Administration (NHTSA) which we did not have time to present. 

These questions are included in the enclosed list. We believe 

that some of these questions are such that they will already be 

included in your written comments. However, we wish to insure 

that these areas, which are of specific concern to EPA, are 

covered. To the extent possible, based upon your knowledge in 

this area, please include responses to these questions in your 

written comments. '\ 

We appreciate your responsiveness in this matter. 

Sincerely yours, 

(.. /?._*t(.o Cv^^ | >? 

Charles L. GraypJrJ. 

Director 

Emission Control Technology Division 

Enclosure 
P.23 

Suggested Questions from NHTSA to ask 

about the Safety of Onboard Systems. 

1. What safety concerns, if any, do you have regarding 

onboard controls? What is the basis of those concerns? 

2. If onboard controls are required, are you likely to make 

additional changes to the fuel system? If so, what are 

these changes? 

3. Will-- you provide an "integrated" system. , if onboard 

controls are mandated? If not, why not? ••-

:-#--' 

4. What safety criteria do you use in designing onboard 

control systems? Do these extend to ease of repair and 

maintenance? 

5. Have you done research regarding fuel tank bladders? If 

so, what is the prognosis for this technology (i.e., 

feasible?, near-term?, etc.)? 

6. Where would the onboard cannisters be located? How do you 

assure that they do not pose any safety hazard? 

7. Do the crash test requirements of Federal Motor Vehicle 

Safety Standard (FMVSS) No. 301 represent a complete 

matrix of crash tests that you use for purposes of 

checking the crash safety/integrity of the fuel systems of 

your vehicles? If not, are there additional tests that 

you believe are needed? 

8. Does the pass/fail criteria of FMVSS 301, post-crash 

liquid fuel leakage, adequately assess the crash 

safety/integrity of the evaporative and/or onboard vapor 

control system? If not, what additional criteria do yoi* 

believe are needed? 

9. How do you test and evaluate your vehicle fuel systems for 

non-crash fire hazards? 

10. What sensitivity studies do you conduct for onboard 

systems? For example, what range of Reid Vapor Pressure 

(RVP) and ambient temperatures do you consider? 

11. How do you test and evaluate your vehicle fuel systems for 

durability? 

12. How many years or miles of maintenance-free life can be 

expected for the rubber, plastic, metal, charcoal, and 

other components of your onboard system? 
P.24 

13. What sorts of maintainance, if any, could be required for 

your onboard system over the life of the vehicle? If 

maintainance would be required, please submit details on 

expected cost and frequency. 

14. Is there any incentive for an. owner and/or mechanic to 

disconnect or tamper with your onboard system to improve 

performance or facilitate repairs to other vehicle systems? 

15. Is there any incentive to repair or replace damaged or 

disconnected portions of your onboard system? Can the 

system be checked after repair, or periodically, as to its 

safety/integrity and function? 

16. Identify and describe all significant modifications to 

fuel and emission systems which will be required if 

onboard systems are to be installed? 

17. Explain why certain design alternatives may have been 

selected, e.g., liquid versus mechanical seal. 

18. How many prototypes have you developed? Describe each. 

Provide a summary of the results of testing conducted on 

these prototypes. 

19. Furnish your opinion of any additional safety risks 

involved with onboard systems. Include an assessment of 

the following: 

a) the causal or contributory factors which could 

increase the chances of a defect or 

non-compliance, 

b) the failure mode, 

c) the risk to motor vehicle safety 

d) any forseeable warning to drivers of the problem.. 

20. Identify (by NHTSA recall number) all safety-related 

defect campaigns which have been conducted due to the 

design, construction and/or performance of systems and/or 

components which are similar in design or function as 

those which will be utilized in any onboard vapor recovery 

system. Provide a summary of the problem or failure 

involved and the number of known incidents, accidents and 

fatalities involved with each such recall campaign. 

21. Provide copies of all service bulletins and/or other 

communications to dealer/owners which were issued due to 

the design, construction and/or performance of systems 

and/or components which are similar in design or function 

as those which will be utilized in any onboard vapor 

recovery system. Provide a summary of the problem or 

failure involved and the number of known incidents, 

accidents and fatalities involved with each such bulletin 

or communication. 
P.25 

- » 

\ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

ANN ARBOR. MICHIGAN 48105 

OFFICE OF 

AIR AND RADIATION 

NOV i o m< 

r\ :QC7 

Mr. Wellman E. Branstrom, Vice President ;-*- • 

Planning and Administration, Refining and Marketing Division 

UNOCAL Corporation 

911 Wilshire Boulevard 

Room 1240 

Los Angeles, CA 90017 

Dear Mr. Branstrom: 

I am writing in response to your testimony at the recent 

onboard/volatility hearing held October 27-29, 1987 in 

Washington, DC. Due to the large number of testifiers and the 

broad range of issues covered by the two proposals, the time 

limits of the hearing prevented us from exploring your 

testimony as fully as we would have liked. In particular, some 

questions were submitted from National Highway Traffic Safety 

Administration (NHTSA) which we did not have time to present. 

These questions are included in the enclosed list. We believe 

that some of these questions are such that they will already be 

included in your written comments. However, we wish to insure 

that these areas, which are of specific concern to EPA, are 

covered. To the extent possible, based upon your knowledge in 

this area, please include responses to these questions in 'your 

written comments. 

We appreciate your responsiveness in this matter. 

Sincerely yours, 

Charles L. Gray, Jr". 

Director 

Emission Control Technology Division 

Enclosure 
Suggested Questions from NHTSA to ask 

about the Safety of Onboard Systems. 

1. What safety concerns, if any, do you have regarding 

onboard controls? What is the basis of those concerns? 

2. If onboard controls are required, are you likely to make 

additional changes to the fuel system? If so, what are 

these changes? 

3. Will-- you provide an "integrated" system, if onboard 

controls are mandated? If not, why not? ••';-#--' 

4. What safety criteria do you use in designing onboard 

control systems? Do these extend to ease of repair and 

maintenance? 

5. Have you done research regarding fuel tank bladders? If 

so, what is the prognosis for this technology (i.e., 

feasible?, near-term?, etc.)? 

6. Where would the onboard cannistefs be located? How do you 

assure that they do not pose any safety hazard? 

7. Do the crash test requirements of Federal Motor Vehicle 

Safety Standard (FMVSS) No. 301 represent a complete 

matrix of crash tests that you use for purposes of 

checking the crash safety/integrity of the fuel systems of 

your vehicles? If not, are there additional tests that 

you believe are needed? 

8. Does the pass/fail criteria of FMVSS 301, post-crash 

liquid fuel leakage, adequately assess the crash 

safety/integrity of the evaporative and/or onboard vapor 

control system? If not, what additional criteria do you^ 

believe are needed? 

9. How do you test and evaluate your vehicle fuel systems for 

non-crash fire hazards? 

10. What sensitivity studies do you conduct ..for onboard 

systems? For example, what range of Reid Vapor Pressure 

(RVP) and ambient temperatures do you consider? 

11. How do you test and evaluate your vehicle fuel systems for 

durability? 

12. How many years or miles of maintenance-free life can be 

expected for the rubber, plastic metal, charcoal, and 

other components of your onboard system? 
P.27 

13. What sorts of maintainance, if any, could be. required for 

your onboard system over the life of the vehicle? if 

maintainance would be required, please submit details on 

expected cost and frequency. 

14. Is there any incentive for an. owner and/or mechanic to 

disconnect or tamper with your onboard system to improve 

performance or facilitate repairs to other vehicle systems? 

15. Is there any incentive to repair or replace damaged or 

disconnected portions of your onboard system?. Can the 

system be checked after repair, or periodically, as to its 

safety/integrity and function? 

16. Identify and describe all significant modifications to 

fuel and emission systems which will be required if 

onboard systems are to be installed? 

17. Explain why certain design alternatives may have been 

selected, e.g., liquid versus mechanical seal. 

18. How many prototypes have you developed? Describe each. 

Provide a summary of the results of testing conducted on 

these prototypes. 

19. Furnish your opinion of any additional safety risks 

involved with onboard systems. Include an assessment of 

the following: 

a) the causal or contributory factors which could 

increase the chances of a defect or 

non-compli ance, 

b) the failure mode, 

c) the risk to motor vehicle safety 

d) any forseeable warning to drivers of the problem,. 

• \ 

20. Identify (by NHTSA recall number) all safety-related 

defect campaigns which have been conducted due to the 

design, construction and/or performance of systems and/or 

components which are similar in design or function as 

those which will be utilized in any onboard vapor recovery 

system. Provide a summary of the problem- or failure 

involved and the number of known incidents, accidents and 

fatalities involved with each such recall campaign. 

21. Provide copies of all service bulletins and/or other 

communications to dealer/owners which were issued due to 

the design, construction and/or performance of systems 

and/or components which are similar in design or function 

as those which will be utilized in any onboard vapor 

recovery system. Provide a summary of the problem or 

failure involved and the number of known incidents, 

accidents and fatalities involved with each such bulletin 

or communication. 
P.28 

* t 

$ _f_l \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

I _ff|%Z * ANN ARBOR. MICHIGAN 48105 

OFFICE OF 

AIR AND RADIATION 

»\\®wi( 

Mr. Frank Bedell, Vice President 

c/o Virginia Petroleum Jobbers Association 

P.O. Box 6344 

Richmond, VA 23230 

Dear Mr. Bedell: 

I am writing in response to your testimony at the recent 

onboard/volatility hearing held October 27-29, 1987 in 

Washington, DC. Due to the large number of testifiers and the 

broad range of issues covered by the two proposals, the time 

limits of the hearing prevented us from exploring your 

testimony as fully as we would have liked. In particular, some 

questions were submitted from National Highway Traffic Safety 

Administration (NHTSA) which we did not have time to present. 

These questions are included in the enclosed list. We believe 

that some of these questions are such that they will already be 

included in your written comments. However, we wish to insure 

that these areas, which are of specific concern to EPA, are 

covered. To the extent possible, based upon your knowledge in 

this area, please include responses to these questions in your 

written comments. \ 

We appreciate your responsiveness in this matter. 

Sincerely yours, 

/?/. • ^. . f/ 

Charles L. Gray7 Jx. 

Director 

Emission Control Technology Division 

Enclosure 
P.29 

Suggested Questions from NHTSA to ask 

about the Safety of Onboard Systems• 

1. What safety concerns, if any, do you have regarding 

onboard controls? What is the basis of those concerns? 

2. If onboard controls are required, are you likely to make 

additional changes to the fuel system? If so, what are 

these changes? 

3. Will-- you provide an "integrated" system, if onboard 

controls are mandated? If not, why not? •-

:-»••-••' 

4. What safety criteria do you use in designing onboard 

control systems? Do these extend to ease of repair and 

maintenance? 

5. Have you done research regarding fuel tank bladders? If 

so, what is the prognosis for this technology (i.e., 

feasible?, near-term?, etc.)? 

6. Where would the onboard cannistefs be located? How do you 

assure that they do not pose any safety hazard? 

7. Do the crash test requirements of Federal Motor Vehicle 

Safety Standard (FMVSS) No. 301 represent a complete 

matrix of crash tests that you use for purposes of 

checking the crash safety/integrity of the fuel systems of 

your vehicles? If not, are there additional tests that 

you believe are needed? 

8. Does the pass/fail criteria of FMVSS 301, post-crash 

liquid fuel leakage, adequately assess the crash 

safety/integrity of the evaporative and/or onboard vapor 

control system? If not, what additional criteria do you: 

believe are needed? 

9. How do you test and evaluate your vehicle fuel systems for 

non-crash fire hazards? 

10. What sensitivity studies do you conduct for onboard 

systems? For example, what range of Reid Vapor Pressure 

(RVP) and ambient temperatures do you consider? 

11. How do you test and evaluate your vehicle fuel systems for 

durability? 

12. How many years or miles of maintenance-free life can be 

expected for the rubber, plastic, metal, charcoal, and 

other components of your onboard system? 
P.30 

13. What sorts of maintainance, if any, could be required for 

your onboard system over the life of the vehicle? if 

maintainance would be required, please submit details on 

expected cost and frequency. 

14. Is there any incentive for an: owner and/or mechanic to 

disconnect or tamper with your onboard system to improve 

performance or facilitate repairs to other vehicle systems? 

15. Is there any incentive to repair or replace damaged or 

disconnected portions of your onboard system? Can the 

system be checked after repair, or periodically, as to its 

safety/integrity and function? 

16. Identify and describe all significant modifications to 

fuel and emission systems which will be required if 

onboard systems are to be installed? 

17. Explain why certain design alternatives may have been 

selected, e.g., liquid versus mechanical seal. 

18. How many prototypes have you developed? Describe each. 

Provide a summary of the results of testing conducted on 

these prototypes. 

19. Furnish your opinion of any additional safety risks 

involved with onboard systems. Include an assessment of 

the following: 

a) the causal or contributory factors which could 

increase the chances of a defect or 

non-compliance, 

b) the failure mode, 

c) the risk to motor vehicle safety 

d) any forseeable warning to drivers of the problem.. 

20. Identify (by NHTSA recall number) all safety-related 

defect campaigns which have been conducted due to the 

design, construction and/or performance of systems and/or 

components which are similar in design or function as 

those which will be utilized in any onboard vapor recovery 

system. Provide a summary of the problem or failure 

involved and the number of known incidents, accidents and 

fatalities involved with each such recall campaign. 

21. Provide copies of all service bulletins and/or other 

communications to dealer/owners which were issued due to 

the design, construction and/or performance of systems 

and/or components which are similar in design or function 

as those which will be utilized in any onboard vapor 

recovery system. Provide a summary of the problem or 

failure involved and the number of known incidents, 

accidents and fatalities involved with each such bulletin 

or communication. 
P.31 

* _f-k \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

ANN ARBOR. MICHIGAN 48105 

.~, , n >nQ7 OFFICE OF 

NQV \ U WOl AIR AND RADIATION 

Ms. Teri Richman, Vice President Government Relaticfh" 

c/o National Association of Convenience Stores 

1605 King Street 

Alexandria, VA 22314-2792 

Dear Ms. Richman: 

I am writing in response to your -estimony at the recent 

onboard/volatility hearing held October 27-29, 1987 in 

Washington, DC. Due to the large number of testifiers and the 

broad range of issues covered by the two proposals, the time 

limits of the hearing prevented us from exploring your 

testimony as fully as we would have liked. In particular, some 

guestions were submitted from National Highway Traffic Safety 

Administration (NHTSA) which we did not have rime to present. 

These questions are included in the enclosed list. We believe 

that some of these questions are such that they will already be 

included in your written comments. However, we wish to insure 

that these areas, which are of specific concern to EPA, are 

covered. To the extent possible, based upon your knowledge in 

this area, please include responses to *:hese questions in your 

written comments. 

We appreciate your responsiveness ir. this matter. 

Sincerely yours, 

Charles L. Gray,(J.:. 

Director 

Emission Control Technology Division 

Enclosure 
Suggested Questions from NHTSA to ask 

about the Safety of Onboard Systems. 

1. What safety concerns, if any, do you have regarding 

onboard controls? What is the basis of those concerns? 

2. If onboard controls are required, are you likely to make 

additional changes to the fuel system? If so, what are 

these changes? 

3. Will-- you provide an "integrated" system, .if onboard 

controls are mandated? If not, why not? -^';: 

4. What safety criteria do you use in designing onboard 

control systems? Do these extend to ease of repair and 

maintenance? 

5. Have you done research regarding fuel tank bladders? If 

so, what is the prognosis for this technology (i.e., 

feasible?, near-term?, etc.)? 

6. Where would the onboard cannistefs be located? How do you 

assure that they do not pose any safety hazard? 

7. Do the crash test requirements of Federal Motor Vehicle 

Safety Standard (FMVSS) No. 301 represent a complete 

matrix of crash tests that you use for purposes of 

checking the crash safety/integrity of the fuel systems of 

your vehicles? If not, are there additional tests that 

you believe are needed? 

8. Does the pass/fail criteria of FMVSS 301, post-crash 

liquid fuel leakage, adequately assess the crash 

safety/integrity of the evaporative and/or onboard vapor 

control system? If not, what additional criteria do you: 

believe are needed? 

9. How do you test and evaluate your vehicle fuel systems for 

non-crash fire hazards? 

10. What sensitivity studies do you conduct for onboard 

systems? For example, what range of Reid Vapor Pressure 

(RVP) and ambient temperatures do you consider? 

11. How do you test and evaluate your vehicle fuel systems for 

durability? 

12. How many years or miles of maintenance-free life can be 

expected for the rubber, plastic, metal, charcoal, and 

other components of your onboard system? 
P.33 

13. What sorts of maintainance, if any, could be required for 

your onboard system over the life of the vehicle? If 

maintainance would be required, please submit details on 

expected cost and frequency. 

14. Is there any incentive for an. owner and/or mechanic to 

disconnect or tamper with your onboard system to improve 

performance or facilitate repairs to other vehicle systems? 

15. Is there any incentive to repair or replace damaged or 

disconnected portions of your onboard system! Can the 

system be checked after repair, or periodically) as to its 

safety/integrity and function? 

16. Identify and describe all significant modifications to 

fuel and emission systems which will be required if 

onboard systems are to be installed? 

17. Explain why certain design alternatives may have been 

selected, e.g., liquid versus mechanical seal. 

18. How many prototypes have you developed? Describe each. 

Provide a summary of the results of testing conducted on 

these prototypes. 

19. Furnish your opinion of any additional safety risks 

involved with onboard systems. Include an assessment of 

the following: 

a) the causal or contributory factors which could 

increase the chances of a defect or 

non-compliance, 

b) the failure mode, 

c) the risk to motor vehicle safety 

d) any forseeable warning to drivers of the problem,. 

20. Identify (by NHTSA recall number) all safety-related 

defect campaigns which have been conducted due to the 

design, construction and/or performance of systems and/or 

components which are similar in design or function as 

those which will be utilized in any onboard vapor recovery 

system. Provide a summary of the problem or failure 

involved and the number of known incidents, accidents and 

fatalities involved with each such recall campaign. 

21. Provide copies of all service bulletins and/or other 

communications to dealer/owners which were issued due to 

the design, construction and/or performance of systems 

and/or components which are similar in design or function 

as those which will be utilized in any onboard vapor 

recovery system. Provide a summary of the problem or 

failure involved and the number of known incidents, 

accidents and fatalities involved with each such bulletin 

or communication. 
P.34 

f 

* \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

uss.1 

«r \JVVr-J' ANN ARBOR. MICHIGAN 48105 

\ , -_* ^ 

OFFICE OF 

AIR AND RADIATION 

;-&'-• 

NW<liOPI9GEff 

Mr. Jeffrey L. Leiter, Counsel for SIGMA 

c/o Collier, Shannon, Rill _ Scott 

1055 Thomas Jefferson Street NW 

Washington, DC 20007 

Dear Mr. Leiter: 

I am writing in response to your -testimony a~ the recent 

onboard/volatility hearing held Octcber 27-29, 1987 in 

Washington, DC. Due to the large numbe- of testifiers and the 

broad range of issues covered by the two proposals, the time 

limits of the hearing prevented us from exploring your 

testimony as fully as we would have liked. In particular, some 

questions were submitted from National Highway Traffic Safety 

Administration (NHTSA) which we did not have time to present. 

These questions are included in the enclosed list. We believe 

that some of these questions are such thit they will already be 

included in your written comments. However, we wish to insure 

that these areas, which are of specific concern to EPA, are 

covered. To the extent possible, based upon your knowledge in 

this area, please include responses to *:hese questions in your 

written comments. 

We appreciate your responsiveness in this matter. 

Sincerely yours, 

,-' • /\ ' 

Charles L. Gray,^-. 

Director 

Emission Control Technology Division 

Enclosure 
Suggested Questions from NHTSA to ask 

about the Safety of Onboard Systems. 

1. What safety concerns, if any, do you have regarding 

onboard controls? What is the basis of those concerns? 

2. If onboard controls are required, are you likely to make 

additional changes to the fuel system? If so, what are 

these changes? 

3. Will- you provide an "integrated" system.;if onboard 

controls are mandated? If not, why not? ^-;' 

4. What safety criteria do you use in designing onboard 

control systems? Do these extend to ease of repair and 

maintenance? 

5. Have you done research regarding fuel tank bladders? If 

so, what is the prognosis for this technology (i.e., 

feasible?, near-term?, etc.)? 

6. Where would the onboard cannistefs be located? How do you 

assure that they do not pose any safety hazard? 

7. Do the crash test requirements of Federal Motor Vehicle 

Safety Standard (FMVSS) No. 301 represent a complete 

matrix of crash tests that you use for purposes of 

checking the crash safety/integrity of the fuel systems of 

your vehicles? If not, are there additional tests that 

you believe are needed? 

8. Does the pass/fail criteria of FMVSS 301, post-crash 

liquid fuel leakage, adequately assess the crash 

safety/integrity of the evaporative and/or onboard vapor 

control system? If not, what additional criteria do you>. 

believe are needed? 

9. How do you test and evaluate your vehicle fuel systems for 

non-crash fire hazards? 

10. What sensitivity studies do you conduct for onboard 

systems? For example, what range of Reid Vapor Pressure 

(RVP) and ambient temperatures do you consider? 

11. How do you test and evaluate your vehicle fuel systems for 

durability? 

12. How many years or miles of maintenance-free life can be 

expected for the rubber, plastic, metal, charcoal, and 

other components of your onboard system? 
P.36 

13. What sorts of maintainance, if any, could be required for 

your onboard system over the life of the vehicle? if 

maintainance would be required, please submit details on 

expected cost and frequency. 

14. Is there any incentive for an. owner and/or mechanic to 

disconnect or tamper with your onboard system to improve 

performance or facilitate repairs to other vehicle systems? 

15. Is there any incentive to repair or replace damaged or 

disconnected portions of your onboard system? Can the 

system be checked after repair, or periodically) as to its 

safety/integrity and function? 

16. Identify and describe all significant modifications to 

fuel and emission systems which will be required if 

onboard systems are to be installed? 

17. Explain why certain design alternatives may have been 

selected, e.g., liquid versus mechanical seal. 

18. How many prototypes have you developed? Describe each. 

Provide a summary of the results of testing conducted on 

these prototypes. 

19. Furnish your opinion of any additional safety risks 

involved with onboard systems. Include an assessment of 

the following: 

a) the causal or contributory factors which could 

increase the chances of a defect or 

non-compli ance, 

b) the failure mode, 

c) the risk to motor vehicle safety 

d) any forseeable warning to drivers of the problem.. 

20. Identify (by NHTSA recall number) all safety-related 

defect campaigns which have been conducted due to the 

design, construction and/or performance of systems and/or 

components which are similar in design or function as 

those which will be utilized in any onboard vapor recovery 

system. Provide a summary of the problem or failure 

involved and the number of known incidents, accidents and 

fatalities involved with each such recall campaign. 

21. Provide copies of all service bulletins and/or other 

communications to dealer/owners which were issued due to 

the design, construction and/or performance of systems 

and/or components which are similar in design or function 

as those which will be utilized in any onboard vapor 

recovery system. Provide a summary of the problem or 

failure involved and the number of known incidents, 

accidents and fatalities involved with each such bulletin 

or communication. 
P.37 

. V _ - *r -^/^f. 

/ *_f_k

 ri UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

\52I2£ / ANN ARBOR. MICHIGAN 48105 

%** / 

OFFICE OF 

AIR AND RADIATION 

NOV I 0 l§8T 

Mr . Ron E. Cannon .-ic/o Gas Processors Association 

6526 East 60th Street 

Tulsa, OK 74145 

Dear Mr. Cannon: 

I am writing in response to your testimony at the recent 

onboard/volatility hearing held October 27-29, 1987 in 

Washington, DC. Due to the large number of testifiers and the 

broad range of issues covered by the two proposals, the time 

limits of the hearing prevented us from exploring your 

testimony as fully as we would have liked. In particular, some 

questions were submitted from National Highway Traffic Safety 

Administration (NHTSA) which we did not have time to present. 

These questions are included in the enclosed list. We believe 

that some of these questions are such that they will already be 

included in your written comments. However, we wish to insure 

that these areas, which are of specific concern to EPA, are 

covered. To the extent possible, based upon your knowledge in 

this area, please include responses to these questions in your 

written comments. 

• \ 

We appreciate your responsiveness in this matter. 

Sincerely yours, 

Charles L. Grayv qjc. 

Director 

Emission Control Technology Division 

Enclosure 
P.38 

Suggested Questions from NHTSA to ask 

about the Safety of Onboard Systems. 

1. What safety concerns, if any, do you have regarding 

onboard controls? What is the basis of those concerns? 

2. If onboard controls are required, are you likely to make 

additional changes to the fuel system? If so, what are 

these changes? 

3. Will" you provide an "integrated" system., if onboard 

controls are mandated? If not, why not? -^-' 

4. What safety criteria do you use in designing onboard 

control systems? Do these extend to ease of repair and 

maintenance? 

5. Have you done research regarding fuel tank bladders? If 

so, what is the prognosis for this technology (i.e., 

feasible?, near-term?, etc.)? 

6. Where would the onboard cannisters be located? How do you 

assure that they do not pose any safety hazard? 

7. Do the crash test requirements of Federal Motor Vehicle 

Safety Standard (FMVSS) No. 301 represent a complete 

matrix of crash tests that you use for purposes of 

checking the crash safety/integrity of the fuel systems of 

your vehicles? If not, are there additional tests that 

you believe are needed? 

8. Does the pass/fail criteria of FMVSS 301, post-crash 

liquid fuel leakage, adequately assess the crash 

safety/integrity of the evaporative and/or onboard vapor 

control system? If not, what additional criteria do you-, 

believe are needed? 

9. How do you test and evaluate your vehicle fuel systems for 

non-crash fire hazards? 

10. What sensitivity studies do you conduct for onboard 

systems? For example, what range of Reid Vapor Pressure 

(RVP) and ambient temperatures do you consider? 

11. How do you test and evaluate your vehicle fuel systems for 

durability? 

12. How many years or miles of maintenance-free life can be 

expected for the rubber, plastic, metal, charcoal, and 

other components of your onboard system? 
13. What sorts of maintainance, if any, could be required for 

your onboard system over the life of the vehicle? if 

maintainance would be required, please submit details on 

expected cost and frequency. 

14. Is there any incentive for an. owner and/or mechanic to 

disconnect or tamper with your onboard system to improve 

performance or facilitate repairs to other vehicle systems? 

15. Is there any incentive to repair or replace damaged or 

disconnected portions of your onboard system? can the 

system be checked after repair, or periodically) as to its 

safety/integrity and function? 

16. Identify and describe all significant modifications to 

fuel and emission systems which will be required if 

onboard systems are to be installed? 

17. Explain why certain design alternatives may have been 

selected, e.g., liquid versus mechanical seal. 

18. How many prototypes have you developed? Describe each. 

Provide a summary of the results of testing conducted on 

these prototypes. 

19. Furnish your opinion of any additional safety risks 

involved with onboard systems. Include an assessment of 

the following: 

a) the causal or contributory factors which could 

increase the chances of a defect or 

non-compli ance, 

b) the failure mode, 

c) the risk to motor vehicle safety 

d) any forseeable warning to drivers of the problem,. 

20. Identify (by NHTSA recall number) all safety-related 

defect campaigns which have been conducted due to the 

design, construction and/or performance of systems and/or 

components which are similar in design or function as 

those which will be utilized in any onboard vapor recovery 

system. Provide a summary of the problem or failure 

involved and the number of known incidents, accidents and 

fatalities involved with each such recall campaign. 

21. Provide copies of all service bulletins and/or other 

communications to dealer/owners which were issued due to 

the design, construction and/or performance of systems 

and/or components which are similar in design or function 

as those which will be utilized in any onboard vapor 

recovery system. Provide a summary of the problem or 

failure involved and the number of known incidents, 

accidents and fatalities involved with each such bulletin 

or communication. 
P.40 

/ -A ' \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

V^__t_£/ ANN ARBOR. MICHIGAN 48105 

OFFICE OF 

AIR AND RADIATION 

NuV'\019o7 

Mr. G. G. Sutclisfe, President 

Husky Corporation 

P.O. Box 67 

Pacific, MO 63069 

Dear Mr. Sutclisfe: 

I am writing in response to your testimony at the recent 

onboard/volatility hearing held October 27-29, 1987 in 

Washington, DC. Due to the large number of testifiers and the 

broad range of issues covered by the two proposals, the time 

limits of the hearing prevented us from exploring your 

testimony as fully as we would have liked. In particular, some 

questions were submitted from National Highway Traffic Safety 

Administration (NHTSA) which we did not have time to present. 

These questions are included in the enclosed list. We believe 

that some of these questions are such that they will already be 

included in your written comments. However, we wish to insure 

that these areas, which are of specific concern to EPA, are 

covered. To the extent possible, based upon your knowledge in 

this area, please include responses to these questions in your 

written comments. ^ 

We appreciate your responsiveness in this matter. 

Sincerely yours, 

/ . ... • / 

Charles L. Gray/, yr. 

Director 

Emission Control Technology Division 

Enclosure 
P.41 

Suggested Questions from NHTSA to ask 

about the Safety of Onboard Systems. 

1. What safety concerns, if any, do you have regarding 

onboard controls? What is the basis of those concerns? 

2. If onboard controls are required, are you likely to make 

additional changes to the fuel system? If so, what are 

these changes? 

3. Will" you provide an "integrated" system.- if onboard 

controls are mandated? If not, why not? v*-' 

4. What safety criteria do you use in designing onboard 

control systems? Do these extend to ease of repair and 

maintenance? 

5. Have you done research regarding fuel tank bladders? If 

so, what is the prognosis for this technology (i.e., 

feasible?, near-term?, etc.)? 

6. Where would the onboard cannistefs be located? How do you 

assure that they do not pose any safety hazard? •r 

7. Do the crash test requirements of Federal Motor Vehicle 

Safety Standard (FMVSS) No. 301 represent a complete 

matrix of crash tests that you use for purposes of 

checking the crash safety/integrity of the fuel systems of 

your vehicles? If not, are there additional tests that 

you believe are needed? 

8. Does the pass/fail criteria of FMVSS 301, post-crash 

liquid fuel leakage, adequately assess the crash 

safety/integrity of the evaporative and/or onboard vappr 

control system? If not, what additional criteria do you: 

believe are needed? 

9. How do you test and evaluate your vehicle fuel systems for 

non-crash fire hazards? 

10. What sensitivity studies do you conduct for onboard 

systems? For example, what range of Reid Vapor Pressure 

(RVP) and ambient temperatures do you consider? 

11. How do you test and evaluate your vehicle fuel systems for 

durability? 

12. How many years or miles of maintenance-free life can be 

expected for the rubber, plastic, metal, charcoal, and 

other components of your onboard system? 
P.42 

A3. What sorts of maintainance, if any, could be required for 

your onboard system over the life of the vehicle? if 

. . maintainance would be required, please submit details on 

expected cost and frequency. 

14. Is there any incentive for an. owner and/or mechanic to 

disconnect or tamper with your onboard system to improve 

performance or facilitate repairs to other vehicle systems? 

15. Is there any incentive to repair or replace damaged or 

disconnected portions of your onboard system?. Can the 

system be checked after repair, or periodically) as to its 

safety/integrity and function? 

16. Identify and describe all significant modifications to 

fuel and emission systems which will be required if 

onboard systems are to be installed? 

17. Explain why certain design alternatives may have been 

selected, e.g., liquid versus mechanical seal. 

18. How many prototypes have you developed? Describe each. 

Provide a summary of the results of testing conducted on 

these prototypes. 

19. Furnish your opinion of any additional safety risks 

involved with onboard systems. Include an assessment of 

the following: 

a) the causal or contributory factors which could 

increase the chances of a defect or 

non-compliance, 

b) the failure mode, 

c) the risk to motor vehicle safety 

d) any forseeable warning to drivers of the problem.. 

20. Identify (by NHTSA recall number) all safety-related 

defect campaigns which have been conducted due to the 

design, construction and/or performance of systems and/or 

components which are similar in design or function as 

those which will be utilized in any onboard vapor recovery 

system. Provide a summary of the problem- or failure 

involved and the number of known incidents, accidents and 

fatalities involved with each such recall campaign. 

21. Provide copies of all service bulletins and/or other 

communications to dealer/owners which were issued due to 

the design, construction and/or performance of systems 

and/or components which are similar in design or function 

as those which will be utilized in any onboard vapor 

recovery system. Provide a summary of the problem or 

failure involved and the number of known incidents, 

accidents and fatalities involved with each such bulletin 

or communication. 
P.43 

^2>, 

Uffiz 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

ANN ARBOR. MICHIGAN 48105 

OFFICE OF 

AIR AND RADIATION 

Ms. Nancy Seidman 

c/o NESCAUM 

85 Merrimac Street 

Boston, MA 02114 

Dear Ms. Seidman: 

I am writing in response to your testimony at the recent 

onboard/volatility hearing held October 27-29, 1987 in 

Washington, DC. Due to the large number of testifiers and the 

broad range of issues covered by the two proposals, the time 

limits of the hearing prevented us from exploring your 

testimony as fully as we would have liked. In particular, some 

questions were submitted from National Highway Traffic Safety 

Administration (NHTSA) which we did not have time to present. 

These questions are included in the enclosed list. We believe 

that some of these questions are such that they will already be 

included in your written comments. However, we wish to insure 

which are of specific concern to EPA, are 

extent possible, based upon your knowledge in 

include responses to these questions in your 

that these areas, 

covered. To the 

this area, please 

written comments. 

We appreciate your responsiveness in this matter. 

Sincerely yours, 

Charles L. GrayA'-Jr. 

Director 

Emission Control Technology Division 

Enclosure 
P.44 

Suggested Questions from NHTSA to ask 

about the Safety of Onboard Systems. 

1. What safety concerns, if any, do you have regarding 

onboard controls? What is the basis of those concerns? 

2. If onboard controls are required, are you likely to make 

additional changes to the fuel system? If so, what are 

these changes? 

3. Will-- you .provide an "integrated" system. , if onboard 

controls are mandated? If not, why not? -^;; 

4. What safety criteria do you use in designing onboard 

control systems? Do these extend to ease of repair and 

maintenance? 

5. Have you done research regarding fuel tank bladders? If 

so, what is the prognosis for this technology (i.e., 

feasible?, near-term?, etc.)? 

6. Where would the onboard cannisters be located? How do you 

assure that they do not pose any safety hazard? 

7. Do the crash test requirements of Federal Motor Vehicle 

Safety Standard (FMVSS) No. 301 represent a complete 

matrix of crash tests that you use for purposes of 

checking the crash safety/integrity of the fuel systems of 

your vehicles? If not, are there additional tests that 

you believe are needed? 

8. Does the pass/fail criteria of FMVSS 301, post-crash 

liquid fuel leakage, adequately assess the crash 

safety/integrity of the evaporative and/or onboard vapor 

control system? If not, what additional criteria do yoifc 

believe are needed? 

9. How do you test and evaluate your vehicle fuel systems for 

non-crash fire hazards? 

10. What sensitivity studies do you conduct- for onboard 

systems? For example, what range of Reid Vapor Pressure 

(RVP) and ambient temperatures do you consider? 

11. How do you test and evaluate your vehicle fuel systems for 

durability? 

12. How many years or miles of maintenance-free life can be 

expected for the rubber, plastic, metal, charcoal, and 

other components of your onboard system? 
'13. What sorts of maintainance, if any, could be required for 

your onboard system over the life of the vehicle? if 

maintainance would be required, please submit details on 

expected cost and frequency. 

14. Is there any incentive for an. owner and/or mechanic to 

disconnect or tamper with your onboard system to improve 

performance or facilitate repairs to other vehicle systems? 

15. Is there any incentive to repair or replace damaged or 

disconnected portions of your onboard system?: Can the 

system be checked after repair, or periodically) as to its 

safety/integrity and function? 

16. Identify and describe all significant modifications to 

fuel and emission systems which will be required if 

onboard systems are to be installed? 

17. Explain why certain design alternatives may have been 

selected, e.g., liquid versus mechanical seal. 

18. How many prototypes have you developed? Describe each. 

Provide a summary of the results of testing conducted on 

these prototypes. 

19. Furnish your opinion of any additional safety risks 

involved with onboard systems. Include an assessment of 

the following: 

a) the causal or contributory factors which could 

increase the chances of a defect or 

non-compliance, 

b) the failure mode, 

c) the risk to motor vehicle safety 

d) any forseeable warning to drivers of the problem,. 

20. Identify (by NHTSA recall number) all safety-related 

defect campaigns which have been conducted due to the 

design, construction and/or performance of systems and/or 

components which are similar in design or function as 

those which will be utilized in any onboard vapor recovery 

system. Provide a summary of the problem or failure 

involved and the number of known incidents, accidents and 

fatalities involved with each such recall campaign. 

21. Provide copies of all service bulletins and/or other 

communications to dealer/owners which were issued due to 

the design, construction and/or performance of systems 

and/or components which are similar in design or function 

as those which will be utilized in any onboard vapor 

recovery system. Provide a summary of the problem or 

failure involved and the number of known incidents, 

accidents and fatalities involved with each such bulletin 

or communication. 
P.46 

$ A \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

I S\ji%Z« ANN ARBOR. MICHIGAN 48105 

OFFICE OF 

AIR AND RADIATION 

NOV I Q 1987 

Mr. Bruce K:. Mail let, Director 

Division of Air Quality Control 

Massachussetts DEQE 

1 Winter Street 

Boston, MA 02108 

Dear Mr. Maillet: 

I am writing in response to your testimony at the recent 

onboard/volatility hearing held October 27-29, 1987 in 

Washington, DC. Due to the large number of testifiers and the 

broad range of issues covered by the two proposals, the time 

limits of the hearing prevented us from exploring your 

testimony as fully as we would have liked. In particular, some 

questions were submitted from National Highway Traffic Safety 

Administration (NHTSA) which we did not have time to present. 

These questions are included in the enclosed list. We believe 

that some of these questions are such that they will already be 

included in your written comments. However, we wish to insure 

that these areas, which are of specific concern to EPA, are 

covered. To the extent possible, based upon your knowledge in 

this area, please include responses to chese questions in your 

written comments. 

We appreciate your responsiveness ir. this matter. 

Sincerely yours, 

• > • 

,,- • .- .. , 1/ ' \ 

Charles L. Gray^Jf::. 

Director 

Emission Control Technology Division 

Enclosure 
P.47 

Suggested Questions from NHTSA to ask 

about the Safety of Onboard Systems• 

1. What safety concerns, if any, do you have regarding 

onboard controls? What is the basis of those concerns? 

2. If onboard controls are required, are you likely to make 

additional changes to the fuel system? If so, what are 

these changes? 

3. Will-- you provide an "integrated" system, if onboard 

controls are mandated? If not, why not? •-•-*•••-••' 

4. What safety criteria do you use in designing onboard 

control systems? Do these extend to ease of repair and 

maintenance? 

5. Have you done research regarding fuel tank bladders? If 

so, what is the prognosis for this technology (i.e., 

feasible?, near-term?, etc.)? 

6. Where would the onboard cannistefs be located? How do you 

assure that they do not pose any safety hazard? 

7. Do the crash test requirements of Federal Motor Vehicle 

Safety Standard (FMVSS) No. 301 represent a complete 

matrix of crash tests that you use for purposes of 

checking the crash safety/integrity of the fuel systems of 

your vehicles? If not, are there additional tests that 

you believe are needed? 

8. Does the pass/fail criteria of FMVSS 301, post-crash 

liquid fuel leakage, adequately assess the crash 

safety/integrity of the evaporative and/or onboard vapor 

control system? If not, what additional criteria do you: 

believe are needed? 

9. How do you test and evaluate your vehicle fuel systems for 

non-crash fire hazards? 

10. What sensitivity studies do you conduct for onboard 

systems? For example, what range of Reid Vapor Pressure 

(RVP) and ambient temperatures do you consider? 

11. How do you test and evaluate your vehicle fuel systems for 

durability? 

12. How many years or miles of maintenance-free life can be 

expected for the rubber, plastic, metal, charcoal, and 

other components of your onboard system? 
P.48 

13. What sorts of maintainance, if any, could be required for 

your onboard system over the life of the vehicle? If 

' maintainance would be required, please submit details on 

expected cost and frequency. 

14. Is there any incentive for an: owner and/or mechanic to 

disconnect or tamper with your onboard system to improve 

performance or facilitate repairs to other vehicle systems? 

15. Is there any incentive to repair or replace damaged or 

disconnected portions of your onboard system! Can the 

system be checked after repair, or periodically, as to its 

safety/integrity and function? 

16. Identify and describe all significant modifications to 

fuel and emission systems which will be required if 

onboard systems are to be installed? 

17. Explain why certain design alternatives may have been 

selected, e.g., liquid versus mechanical seal. 

18 How many prototypes have you developed? Describe each. 

Provide a summary of the results of testing conducted on 

these r>rototv_es prototypes . 

19. Furnish your opinion of any additional safety risks 

involved with onboard systems. Include an assessment of 

the following: 

a) the causal or contributory factors which could 

increase the chances of a defect or 

non-compliance, 

b) the failure mode, 

c) the risk to motor vehicle safety 

d) any forseeable warning to drivers of the problem,. 

20. Identify (by NHTSA recall number) all safety-related 

defect campaigns which have been conducted due to the 

design, construction and/or performance of systems and/or 

components which are similar in design or function as 

those which will be utilized in any onboard vapor recovery 

system. Provide a summary of the problem or failure 

involved and the number of known incidents, accidents and 

fatalities involved with each such recall campaign. 

21. Provide copies of all service bulletins and/or other 

communications to dealer/owners which were issued due to 

the design, construction and/or performance of systems 

and/or components which are similar in design or function 

as those which will be utilized in any onboard vapor 

recovery system. Provide a summary of the problem or 

failure involved and the number of known incidents, 

accidents and fatalities involved with each such bulletin 

or communication. 
P 4 9 

./'«".'% 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

ANN ARBOR. MICHIGAN 48105 

OFFICE OF 

AIR AND RADIATION 

NOV vo w 

Mr. Jan Lundberg 

General Washington Executive Center 

2217 Princess Anne Street 

Fredericksburg, VA 22401 

Dear Mr. Lundberg: 

I am writing in response to your testimony at the recent 

onboard/volatility hearing held October 27-29, 1987 in 

Washington, DC. Due to the large number of testifiers, and the 

broad range of issues covered by the two proposals, the time 

limits of the hearing prevented us from exploring your 

testimony as fully as we would have liked. In particular, some 

questions were submitted from National Highway Traffic Safety 

Administration (NHTSA) which we did not have time to present. 

These questions are included in the enclosed list. We believe 

that some of these questions are such that they will already be 

included in your written comments. However, we wish to insure 

which are of specific concern to EPA, are 

extent possible, based upon your knowledge in 

include responses to these questions in your 

that these areas, 

covered. To the 

this area, please 

written comments. 

We appreciate your responsiveness in this matter. 

Sincerely yours, 

/i* ,\^ (. •'2-<c V 

Charles L. Gray/, • .Jt. 

Director 

Emission Control Technology Division 

Enclosure 
P.50 

,1 

Suggested Questions from NHTSA to ask 

about the Safety of Onboard Systems. 

1. „ What safety concerns, if any, do you have regarding 

onboard controls? What is the basis of those concerns? 

2. If onboard controls are required, are you likely to make 

additional changes to. the fuel system? If so, what are 

these changes? 

3. Will" you provide an "integrated" system, if onboard 

controls are mandated? If not, why not? '•'*"''' 

4. What safety criteria do you use in designing onboard 

control systems? Do these extend to ease of repair and 

maintenance? 

5. Have you done research regarding fuel tank bladders? If 

so, what is the prognosis for this technology (i.e., 

feasible?, near-term?, etc.)? 

6. Where would the onboard cannisters be located? How do you 

assure that they do not pose any safety hazard? 

7. Do the crash test requirements of Federal Motor Vehicle 

Safety Standard (FMVSS) No. 301 represent a complete 

matrix of crash tests that you use for purposes of 

checking the crash safety/integrity of the fuel systems of 

your vehicles? If not, are there additional tests that 

you believe are needed? 

8. Does the pass/fail criteria of FMVSS 301, post-crash 

liquid fuel leakage, adequately assess the crash 

safety/integrity of the evaporative and/or onboard vapor 

control system? If not, what additional criteria do you: 

believe are needed? 

9. How do you test and evaluate your vehicle fuel systems for 

non-crash fire hazards? 

10. What sensitivity studies do you conduct for onboard 

systems? For example, what range of Reid Vapor Pressure 

(RVP) and ambient temperatures do you consider? 

11. How do you test and evaluate your vehicle fuel systems for 

durability? 

12. How many years or miles of maintenance-free life can be 

expected for the rubber, plastic, metal, charcoal, and 

other components of your onboard system? 
P.51 

i 

13. What sorts of maintainance, if any, could be required for 

your onboard system over the life of the vehicle? if 

maintainance would be required, please submit details on 

•'• expected cost and frequency. 

24. Is there any incentive for an; owner and/or mechanic to 

disconnect or tamper with your onboard system to improve 

performance or facilitate repairs to other vehicle systems? 

15. 

16. 

17, 

18 

19 

20 

21. 

Is there any incentive to repair or replace damaged or 

disconnected portions of your onboard system! Can the 

system be checked after repair, or periodically, as to its 

safety/integrity and function? 

Identify and describe all significant 

fuel and emission systems which will 

onboard systems are to be installed? 

modifications to 

be required if 

Explain why certain design alternatives may have been 

selected, e.g., liquid versus mechanical seal. 

How many prototypes have you developed? Describe each. 

Provide a summary of the results of testing conducted on 

these prototypes. 

additional 

Include an 

safety risks 

assessment of 

Furnish your opinion of any 

involved with onboard systems, 

the following: 

a) the causal or contributory factors which could 

increase the chances of a defect or 

non-compliance, 

b) the failure mode, 

c) the risk to motor vehicle safety 

d) any forseeable warning to drivers of the problem.. 

Identify (by NHTSA recall number) all safety-related 

defect campaigns which have been conducted due to the 

design, construction and/or performance of systems and/or 

components which are similar in design or function as 

those which will be utilized in any onboard vapor recovery 

system. Provide a summary of the problem or failure 

involved and the number of known incidents, accidents and 

fatalities involved with each such recall campaign. 

Provide copies of all service bulletins and/or other 

communications to dealer/owners which were issued due to 

the design, construction and/or performance of systems 

and/or components which are similar in design or function 

as those which will be utilized in any onboard vapor 

recovery system. Provide a summary of the problem or 

failure involved and the number of known incidents, 

accidents and fatalities involved with each such bulletin 

or communication.