OAR Box 1142 

Prepped by Ollie Stewart 

Document Number: 

20)IV-F-18 

Docket Number: 

A-87-11 

Printed 4/23/2008 10:21:21 AM Sheet 20 of 30 

P.1 
P.2 

A-87-H 

W-F-18 

Environmental Activities Staff 

General Motors Corporation 

General Motors Technical Center 

30400 Mound Road 

Box 9015 

Warren, Michigan 48090-9015 

Fax: (313) 947-1797 

October 3, 1991 

FE-4766 

Mr. Don Kopinski 

Standards Development and Support Branch 

Emission Control Technology Division 

U.S. Environmental Protection Agency 

2565 Plymouth Road 

Ann Arbor, Michigan 48105 

RE: Onboard refueling vapor recovery Hearing 9/26-27/91 (Docket No. A-87-11) 

Dear Mr. Kopinski: 

GM's hearing statements from the EPA onboard refueling vapor recovery (ORVR) hearing which was 

held on September 26-27 are enclosed. All of the information that was available in specific text form 

or detailed overheads is enclosed. Harold Haskew's and Bill Wecker's presentations did not include a 

written text so I am unable to send you any details on their specific presentations. Details on each of 

the presentations will be included in our written comments. Please let me know if you have any 

questions. 

Sincerely, 

Lisa M. Fior 

cc: S. Beale, Court Reporter 

Printed On Recycled Paper 

Let's Get It Together 

SAFETY BELTS SAVE UVES * 
P.3 

Overview Testimony for ORVR Hearing September 26, 1991 

S.A. Leonard 

SLIDE 1: 

Good Afternoon. My name is Samuel A. Leonard, the Director of the 

Automotive Emission Control department of General Motors Environmental 

Activities Staff. With me today are Bob Sinke, Director of GM's Engineering 

Analysis Department, Harold Haskew of the GM Powertrain Division, Bob Lange 

of Failure Analysis Associates (FaAA), Bill Wecker of Wecker and Associates, 

Dick Kirkpatrick of GM's platform organization, Kevin Cullen of GM's Emission 

Lab, and Tim McCann of GM's Legal Staff. 

SLIDE 2: 

There are many facets to the onboard refueling vapor recovery (ORVR) issue, 

or I believe more correctly stated, to the public policy issue of what is the best 

way to control refueling emissions. Effectiveness, cost, timeliness of 

implementation, the synergy or lack there of between onboard refueling and 

vehicle evaporative emission controls, consideration of possible toxic emissions, 

and technology development of onboard and Stage II are subjects we will be 

addressing for the record, either in the remainder of my statement or in the 

testimony of others on our team. 

I think it is important to recognize at the outset that the issue today is not clean 

air or emissions control. Congress has established Stage II refueling emissions 

control requirements in Title I of the 1990 Clean Air Act Amendments. Stage 

II will control refueling emissions in the absence of ORVR rules. Congress 

thus assured that EPA can decide the merits of the ORVR safety issue, without 

any concern that a decision against ORVR will leave the need for refueling 

emissions control unaddressed. 
P.4 

As a result, the focal point of this hearing should be the safety implications of 

an ORVR rule. We will address the safety issue at some length. 

SLIDE 3: 

Perhaps the best way to place the many facets of refueling emissions control 

in proper context is to trace some of the history of the issues. Refueling 

emissions were first recognized as a volatile organic compound (VOC) source 

in the early 70's. In its 1987 Notice of Proposed Rulemaking (NPRM), EPA 

estimated refueling emissions to be less than 2% of the total VOC emissions 

inventory. Because refueling emissions are proportional to the Reid Vapor 

Pressure (Rvp) of the fuel, regulations reducing fuel volatility have, and will 

continue, to reduce the amount of refueling emissions. 

In the mid-1970's, EPA proposed Stage II for state implementation plans. Early 

Stage II systems were installed in California and in Washington, D.C. Since 

then, other areas have adopted Stage II systems and Stage II technology has 

evolved dramatically over the intervening years. Early systems had heavy 

nozzles with stiff sealing boots and twin hoses. The newest, most advanced 

systems have single hoses and light, bootless nozzles. 

In the 1977 Clean Air Act Amendments, EPA was directed to assess the viability 

of onboard refueling vapor recovery. Even then, Congress expressed concern 

for the safety of ORVR systems and specified that EPA should consult with the 

DOT. EPA studied the issue, but never determined that ORVR controls should 

be used. 

In 1981, a task force lead by then vice-president Bush concluded that ORVR 

should not be required. 
P.5 

SLIDE 4: 

In 1983, interest in refueling controls and ORVR systems was renewed when 

laboratory tests conducted for the American Petroleum Institute (API) reported 

that wholly volatilized gasoline caused an elevated incidence of kidney tumors 

in male rats and liver tumors in female mice. As a result of further work and 

understanding of the exposure criteria and tumor forming mechanisms involved, 

the implications of these API studies for human cancer risk have been 

dramatically reduced, if not eliminated. 

First, the animal studies dealt with high level exposures to volatilized whole 

gasoline for long and continuous periods whereas humans are exposed to low 

levels of refueling vapors and generally for only very short, intermittent periods. 

Second, the composition of refueling vapors is significantly different from whole 

gasoline and the heavier hydrocarbon compounds of whole gasoline which most 

directly affected the animals in the experiment, are almost totally absent from 

refueling vapors. 

Third, the male rat has a unique protein known as alpha 2u~globulin that is not 

in humans, but is integral to the development of kidney tumors in the male rat. 

Fourth, the applicability of female mouse liver tumors in association with human 

risk has been even more questionable than the male rat renal tumors because 

of the erratic nature of the findings. 

As a result, both the Health Effects Institute and the EPA Science Advisory 

Board have cautioned against the use of these animal studies in human risk 

assessment. The SAB has suggested that renal tumors produced by a 
P.6 

mechanism that is not operative in humans is not relevant for human risk 

assessment, and endorses the February 1991 document by the Risk 

Assessment Forum that if the rat specific mechanism is the sole explanation of 

tumors it should not be used for human cancer hazard identification. 

SLIDE 5: 

In addition, there has been debate over the human health concerns of benzene 

in gasoline refueling vapors. Benzene was classified as a human carcinogen 

based on occupational studies of workers exposed to very high concentrations 

of benzene over long periods. However, current evidence indicates that low 

level, short term, intermittent benzene exposure as experienced during normal 

refueling operations, is highly unlikely to have a significant effect on human 

health. 

Moreover, the use of reformulated gasoline will reduce the benzene content of 

gasoline vapors and the additional requirements for further reductions in exhaust 

emissions will continue to reduce ambient levels. Finally, if it is EPA's intent to 

further reduce benzene exposure from gasoline vapor beyond these limits, EPA 

has the authority to eliminate benzene from gasoline and also the authority 

under section 112 of the 1990 Clean Air Act Amendments to require Stage II 

technology in all areas of the country. This approach would be far preferable 

to requiring ORVR, with the added benefit of improved service station safety 

nationwide. 

SLIDE 6: 

In its 1987 NPRM on ORVR, EPA stated that "no increase in overall safety risk 

should be accepted because of the presence of onboard control systems." 

However, the Agency in its proposal tended to dismiss the safety concerns 

raised and failed to discuss or evaluate the safety advantages of Stage II control 
P.7 

systems. Because the safety issue had remained a serious problem, 

organizations such as the Insurance Institute for Highway Safety (IIHS), 

automobile manufacturers, and others raised their continued concerns at the 

public hearing and during the written comment period that followed the issuance 

of the NPRM. 

Also in 1987, California had discussions concerning ORVR and Stage II refueling 

controls and decided to retain use of existing Stage II control systems and not 

adopt ORVR controls. The CARB concluded that implementing ORVR controls 

in areas that have existing Stage II systems is redundant and actually increases 

emissions due to the "breathing loss emissions" from underground storage tanks. 

SLIDE 7: 

In 1989, H.R. 3030, the Administration's Clean Air Amendment proposal 

contained no provision for ORVR, because the Administration had determined 

that Stage II controls were a more cost-effective, quicker, and safer means of 

abating refueling emissions. In testimony to a Senate committee in 1989, EPA 

Administrator Reilly summarized the Administration's position as follows: 

"We looked carefully at both [Stage II and onboard control] options... There 

are concerns that the Transportation Department and others have raised 

about the safety of onboard systems. We had an election to make. We 

made it for Stage II refueling controls which, in fact, do target the 

reductions to the areas most in need of them and can be brought on and 

have a quicker impact on the problem - on reducing pollution - sooner." 

SLIDE 8: 

In the final 1990 Clean Air Act Amendments, Congress required the installation 

of Stage II controls in nonattainment areas. Attainment deadlines for moderate, 

serious, severe, and extreme areas are November 15, 1996, 1999, 2005, and 

2010 respectively. The 1990 Amendments to the Clean Air Act require states 
P.8 

to revise State Implementation Plans (SIP) by November 15, 1992 and that 

Stage II controls be required within 2 years of the state adoption date. 

Implementation of Stage II controls as required by the CAA in non-attainment 

areas can achieve reductions from all refueling emissions by November 15, 

1994. Even if ORVR controls are promulgated, the benefit of ORVR controls 

would not be gained for many years due to the length of time required for fleet 

turnover. Therefore, ORVR controls could not assist moderate, serious, severe, 

or extreme areas in reaching attainment prior to their respective deadlines as 

easily, effectively, or safely as Stage II controls. This, in conjunction with the 

more important issue of the inherent safety risk of ORVR control systems, 

makes the continued pursuit of ORVR illogical and inappropriate, 

Congress also required EPA to promulgate ORVR rules after consulting with the 

DOT on the safety of vehicle-based systems and an EPA determination that 

such systems are safe. Thus, Congress specifically expressed its intent when 

it stated: "No one wants a rule that requires controls for the consumer that 

present safety problems." (H.R. Rep. No. 490 101st Cong. 2d. Sess. pt1 at 304 

(1990)). 

SLIDE 9: 

After the 1990 Amendments to the Clean Air Act were completed, the EPA and 

NHTSA continued to consult on the safety of ORVR control systems. Several 

correspondences were exchanged between the Agencies and culminated with 

the NHTSA Safety Assessment of ORVR systems dated July 1991. The 

NHTSA report clearly states that ORVR controls systems will increase safety 

risks. This is in comparison to the lack of increased motor vehicle safety risk 

with the Stage II control of refueling emissions. 
P.9 

SLIDE 10: 

We believe that the NHTSA safety report is comprehensive and definitive as to 

the increased safety risk of ORVR systems. The NHTSA evaluated all of the 

available data and information concerning ORVR safety, supplemented that 

information with tests to assess the fire risk inherent with ORVR systems, and 

then compared those risks to the situation of using Stage II. This process lead 

to their conclusion that:" Since ORVR systems increase safety risk and Stage 

II does not, ft seems reasonable for EPA to conclude that ORVR systems 

constitute an unreasonable safety risk." We agree with that assessment. 

In the Clean Air Act Amendments passed last year, Congress required the 

installation of Stage II equipment in nonattainment areas and promulgation of 

ORVR rules provided that ORVR systems were determined to be safe after 

consultation with the Department of Transportation (DOT). Thus, the decision 

as to which system to require was left to EPA, after consultation with DOT. 

The NHTSA report is very clear in its conclusions. We strongly believe that it 

would be bad public policy and inconsistent with the Clean Air Act Amendments 

and Congressional intent to subject the public to the vehicle safety risks of 

ORVR. This is especially true when refueling emissions can be controlled 

without risk by Stage II which has been shown to increase service station 

safety. 

To summarize: 

The debate over the control of refueling emissions has been going on for almost 

20 years. The record is established that ORVR control systems will increase 

the risks to motor vehicle safety. In the pursuit of emission reductions, it is bad 

public policy for EPA to subject the public to the vehicle safety risks of ORVR 
P.10 

when the emission reductions can be achieved and public safety enhanced by 

enforcing the Stage II requirements of the Clean Air Act Amendments. 

EPA has the opportunity to end the debate on this issue by not promulgating 

ORVR controls. 

We would like to continue our testimony and discuss in more detail our 

concerns regarding this rulemaking. 

o Bob Sinke of GM's Engineering Analysis organization will address fuel system 

safety, 

o Harold Haskew will talk about the differences between evaporative control 

systems and ORVR, 

o Bob Lange will discuss the NHTSA conclusions, 

o Bill Wecker will discuss the benefits of ORVR and Stage II controls, and 

o Dick Kirkpatrick and Kevin Cullen will discuss vehicle safety from a product 

development standpoint. 
P.11 

General Motors Testimony 

on 

Refueling Emission Regulations 

S. A. Leonard 

R. A. Sinke 

H. M. Haskew 

R. C. Lange 

W. E. Wecker 

R. L. Kirkpatrick 

K. Cullen 

T. C. McCann 

September 26-27, 1991 

Slide 1 
P.12 

• 

Slide 2 

0 

0 

0 

0 

0 

0 

Refueling Emission Controls 

Cost-effectiveness 

implementation timing 

Onboard refueling vapor recovery (ORVR) 

compared to evaporative emission controls 

Consideration of toxic emissions 

Technology Development 

Safety 

-
P.13 

History of Refueling Emissions 

o Recognized as a VOC Source in early 1970's 

Less than 2% of the total VOC emissions inventory 

o EPA proposed Stage II for state implementation plans in the 

mid-1970's 

Several areas have adopted Stage II controls and the 

technology has evolved dramatically 

1977 Clean Air Act Amendments introduced ORVR 

Safety concerns expressed by Congress 

EPA never concluded ORVR should be used 

o 1981 Task Force Lead by then Vice President Bush 

declared ORVR should not be required 

Slide 3 
P.14 

History of Refueling Emissions 

o Renewed EPA interest in 1983 due to API rat study 

o Animal studies not applicable to human health risk 

High exposure levels for long, continuous periods vs. 

low exposure levels for very short, intermittent periods 

Composition of volatilized whole gasoline vapors vs. 

refueling emission vapors 

Unique protein (alpha 2u-globulin) of male rat 

Erratic nature of female mouse findings 

SAB/HEI/EPA Risk Assessment Forum 

Caution use of studies for human risk assessment and 

Support statement that if male rat renal tumors are 

produced by a mechanism that is not operative in 

humans, it is not relevant for human risk assessment 

Slide 4 
P.15 

History of Refueling Emissions 

Benzene Concern 

Controversy of human health effect due to refueling 

vapor exposure 

High exposure levels for long, continuous periods 

vs. low exposure levels for very short, intermittent 

periods 

Benzene reductions will occur 

Introduction of reformulated gasoline 

Implementation of new exhaust emissions 

standards 

EPA authority to: 

Eliminate benzene from gasoline 

Require Stage II per Section 112 of 1990 Clean 

Air Act Amendments 

SlideS 
P.16 

History of Refueling Emissions 

o 1987 EPA NPRM on refueling emissions 

EPA stated that: 

"no increase in overall safety risk should be accepted 

because of the presence of onboard controls systems" 

EPA then dismissed safety concerns 

Safety remained a serious problem and several 

organizations voiced continued concern for safety of 

ORVR systems throughout comment period 

o In 1987, CARB rejected the adoption of ORVR controls 

Slide 6 
P-17 

History of Refueling Emissions 

o 1989 Administration Proposal for Clean Air Act Amendments 

Deleted ORVR requirement 

Required Stage II controls 

"We looked carefully at both [Stage II and onboard control] 

options... There are concerns that the Transportation 

Department and others have raised about the safety of 

onboard systems. We had an election to make. We made 

it for Stage II refueling controls which, in fact, do target the 

reductions to the areas most in need of them and can be 

brought on and have a quicker impact on the problem -- on 

reducing pollution - sooner." 

— EPA Administrator Reilly 

Slide 7 
P.18 

History of Refueling Emissions 

1990 Clean Air Act Amendments 

Required Stage II 

Required EPA to consult with DOT on ORVR safety 

Congressional intent: 

"No one wants a rule that requires controls for the 

consumer that present safety problems." 

Slides 
P.19 

History of Refueling Emissions 

o July 1991 NHTSA Safety Assessment 

ORVR control systems will increase safety risk 

Stage II controls have a lower risk of fire compared to 

non-Stage II stations 

"Since ORVR systems increase safety risk and Stage 

II does not, it seems reasonable for EPA to conclude 

that ORVR systems constitute an unreasonable safety 

risk." 

Slide 9 
P.20 

Conclusion 

NHTSA safety report is comprehensive and definitive as to 

the increased safety risk of ORVR 

The 1990 Clean Air Act Amendments (CAAA) state that it 

is EPA's decision after consultation with the Department of 

Transportation 

Bad public policy and inconsistent with the CAAA and 

Congressional intent to subject the public to the vehicle 

safety risks of ORVR when Stage II controls are required 

and can be used 

Slide 10 
P.21 

R. A. SINKE 

ORVR 

EPA HEARING 9/26/91 

SLIDE 1 

SLIDE 2 

GOOD MORNING. MY NAME IS BOB SINKE. I AM 

TESTIFYING TODAY ON BEHALF OF GENERAL MOTORS. I AM 

CURRENTLY DIRECTOR OF ENGINEERING ANALYSIS FOR CURRENT 

PRODUCT ENGINEERING OF GM. IN THIS POSITION, I AM 

RESPONSIBLE FOR PRODUCT DEFECT INVESTIGATION, RECALL 

CAMPAIGNS, AND FIELD SAFETY CLAIMS INVESTIGATIONS. I 

HAVE SPENT OVER THE PAST 23 YEARS OF MY ENGINEERING 

CAREER WITH GM IN VARIOUS ASSIGNMENTS DEALING WITH 

VEHICLE SAFETY DEVELOPMENT AND EVALUATION. I AM, 

THEREFORE, VERY FAMILIAR WITH THE EVOLUTION OF FUEL 

SYSTEM DEVELOPMENT AND THE PROCESSES FOR EVALUATING 

LABORATORY AND FIELD PERFORMANCE OF FUEL SYSTEMS. I WILL 

PROVIDE GM'S VIEWS IN SUPPORT OF THE NHTSA CONCLUSION 

THAT ORVR SYSTEMS WILL RESULT IN AN INCREASED SAFETY RISK 

AND THUS HAVE A NEGATIVE IMPACT ON SAFETY. MY TESTIMONY 

WILL FOCUS ON FUEL SYSTEM EVALUATION HISTORY, GM'S 

EXPERIENCE WITH FUEL SYSTEM SAFETY, AND OUR VIEWS ON THE 

JUNE 1991 GAO AND JULY 1991 NHTSA REPORTS ON ORVR AS THEY 
SLIDE 3 

RELATE TO FUEL SYSTEMS DEVELOPMENT IN GM. 

IN THE 1950'S AND 1960'S, THE SOCIETY OF AUTOMOTIVE 

ENGINEERS (SAE) WAS ACTIVE DEVELOPING CRASH TEST 

PROCEDURES TO EVALUATE FUEL SYSTEMS. THESE EARLY TEST 

PROCEDURES FOCUSED ON BROAD CRASH CONSIDERATIONS IN THAT 

THEY DEFINED THE FLAT FACE MOVING BARRIER AS A GENERIC 

TEST DEVICE. THE FEDERAL GOVERNMENT ADOPTED THE GENERAL 

SERVICES ADMINISTRATION (GSA) STANDARD FOR GOVERNMENT 

VEHICLES USING THE SAE PROCEDURES. THE NHTSA FOLLOWED 

WITH THE FMVSS 301 FOR FRONTAL IMPACTS IN 1967. THE 

NHTSA ADDED THE 30 MPH REAR AND 20 MPH SIDE MOVING 

BARRIER IMPACT REQUIREMENTS IN 1976. ALSO, A REQUIREMENT 

TO PERFORM A STATIC ROLL TEST AFTER ALL IMPACTS WAS ADDED 

IN 197S. THE JUSTIFICATION FOR THESE STANDARDS HAS BEEN 

TO REDUCE THE CHANCES OF INJURY AND FATALITY DUE TO FIRES 

WHICH RESULT FROM FUEL LEAKS IN MOTOR VEHICLE CRASHES. 

SLIDE 4 THE NHTSA HAS CONDUCTED PERIODIC REVIEWS OF FMVSS 

301 AS REQUIRED BY EXECUTIVE ORDER. THE MOST RECENT 

REVIEW OF FMVSS 301 WAS REPORTED BY THE NHTSA IN NOVEMBER 

1990. IN THEIR REPORT, THE NHTSA OBSERVED THAT MOTOR 

VEHICLE FIRES IN TRAFFIC CRASHES ARE RELATIVELY RARE, 
P.23 

OCCURRING AT THE RATE OF APPROXIMATELY THREE FIRES FOR 

EVERY 1000 VEHICLES INVOLVED IN CRASHES. HOWEVER, THEY 

OBSERVED THAT FOR ALL VEHICLES INVOLVED IN FATAL CRASHES, 

FIRES ARE CONSIDERABLY MORE FREQUENT, WITH ABOUT 26 FIRES 

PER 1000 VEHICLES IN CRASHES (NEARLY NINE TIMES THE RATE 

FOR ALL CRASHES). THEY ALSO OBSERVED THAT FIRE IS 

ASSOCIATED WITH SUBSTANTIALLY MORE SEVERE IMPACT CRASHES. 

SLIDE 5 GM'S OBSERVATIONS FROM FIELD ACCIDENT STUDIES ARE 

CONSISTENT WITH THE NHTSA'S. MOST FUEL FED FIRES AAE 

RELATED TO SEVERE CRASHES. IN ADDITION, GM HAS OBSERVED 

THAT MANY FUEL FED VEHICLE FIRES ARE RELATED TO SPECIFIC 

VEHICLE DESIGN CHARACTERISTICS. As A RESULT, GENERAL 

TEST PROTOCOLS ARE NOT SUFFICIENT TO ADDRESS FUEL SYSTEM 

SAFETY RISKS. SINCE MILLIONS OF CRASHES OF EVERY 

CONCEIVABLE KIND OCCUR ANNUALLY, IT IS LIKELY THAT EVERY 

FUEL SYSTEM IN PRODUCTION WILL SUFFER VIOLATION NO MATTER 

WHAT ITS DESIGN CHARACTERISTICS AND/OR EVALUATION 

PROTOCOL. NO FMVSS OR GENERAL TEST PROTOCOL CAN MINIMIZE 

THE VEHICLE SPECIFIC AND CRASH SPECIFIC FACTORS WHICH 

PRODUCE THE MAJORITY OF THE REMAINING CRASH RELATED 

FIRES. THE CHALLENGE FOR THE FUEL SYSTEM DESIGN ENGINEER 

IS TO MINIMIZE THESE OCCURRENCES BY OTHER MEANS SUCH AS 
REDUCED DESIGN COMPLEXITY. 

SLIDE 6 THOUGH CRASHES WITH FIRES ARE RELATIVELY RARE, FIRES 

IN MOTOR VEHICLE CRASHES HAVE LONG BEEN A TOPIC OF 

INTEREST AND CONCERN TO THE AUTOMOBILE MANUFACTURERS, THE 

NHTSA, AND THE PUBLIC. BY ITS VERY NATURE, THE 

OCCURRENCE OF FIRE CAN SIGNIFICANTLY INCREASE THE RISK OF 

INJURY, AND BURN INJURIES ARE DISFIGURING, PAINFUL, AND 

RECOVERY IS DIFFICULT. THE PUBLIC, IN GENERAL, BECOMES 

VERY UPSET WITH FIRE RELATED FATALITIES AND INJURIES 

BECAUSE THEY ABHOR THE THOUGHT OF BEING BURNED. SO, EVEN 

THOUGH VEHICLE FIRES ARE INFREQUENT, EXTRAORDINARY 

EFFORTS ARE NEEDED TO MINIMIZE THEM. 

SLIDE 7 

WITH THIS BACKGROUND, LET ME REFLECT ON THE RECENT 

GAO AND NHTSA RECOMMENDATIONS. I PARTICIPATED IN 

BRIEFING THE GAO FOR THEIR REPORT WHICH WAS ISSUED JUNE 

1991. I WANT TO MAKE IT CLEAR THAT THE GAO REPORT DOES 

NOT RECOGNIZE THE PRIMARY THRUST OF OUR CONCERNS WITH 

ORVR. 

FIRST, WE EMPHASIZED TO GAO THAT ORVR SYSTEMS POSE 

INHERENT SAFETY RISKS WHICH ARE SIGNIFICANTLY GREATER 
P.25 

THAN RISKS RELATED TO EVAPORATIVE EMISSION SYSTEMS. 

THESE RISKS RELATE TO THE INCREASED VOLUME OF COMBUSTIBLE 

FUEL VAPOR CARRIED BY ORVR SYSTEMS AND THE INCREASED 

VULNERABILITY TO COLLISION DAMAGE SUCH SYSTEMS PRESENT 

DUE TO LARGER COMPONENTS AND INCREASED COMPLEXITY. 

SECOND, GAO HAS NOT FULLY ACKNOWLEDGED OUR CONCERN 

THAT ORVR MAY RESULT IN AN INCREASE IN THE NUMBER OF 

MOTOR VEHICLE FIRES, THE SEVERITY OF SUCH FIRES, AND 

ASSOCIATED BURN INJURIES. THIS WILL BE SO EVEN AFTER 

MANUFACTURERS APPLY THEIR BEST EFFORTS TO LIMIT ORVR 

RISKS AND TO CORRECT ANY SPECIFIC PROBLEMS WHICH ARE 

BOUND TO BE ENCOUNTERED IN THE DEVELOPMENT PROCESS. 

STUDIES IN THE DOCKET SHOW THAT IMPLEMENTATION OF ORVR 

COULD INCREASE MOTOR VEHICLE FIRES BY SEVERAL HUNDRED TO 

SEVERAL THOUSAND ANNUALLY, AND THAT FATAL MOTOR VEHICLE 

FIRES COULD INCREASE BY AS MANY AS SEVERAL HUNDRED 

ANNUALLY. As I MENTIONED EARLIER, THESE TRAGIC ACCIDENTS 

EVOKE STRONG PUBLIC EMOTION. 

SLIDE 8 IN THEIR REPORT, THE GAO RECOMMENDED THAT THE EPA 

AND THE NHTSA DEVELOP A JOINT ACTION PLAN TO "PERFORM A 

SAFETY EVALUATION OF MANUFACTURERS' ONBOARD SYSTEMS TO 
P.26 

IDENTIFY AND CORRECT ANY SAFETY DEFECTS OR FLAWS WELL IN 

ADVANCE OF THE 1996 MODEL YEAR SO THAT AN ORDERLY PHASEIN OCCURS." 

SLIDE 9 FORTUNATELY, THE GAO REPORT APPEARS TO RECOGNIZE 

THAT THE PROPOSED "ACTION PLAN" DOES NOT APPLY IF ORVR 

SYSTEMS INHERENTLY INCREASE SAFETY RISK, AS THE GAO SAID 

THE FOLLOWING IN ITS COVER LETTER OF JULY 30, 1991: 

"OUR RECOMMENDATION FOR AN ACTION 

PLAN WAS NOT MADE TO PROVIDE A BASIS 

FOR CHANGING EPA'S RESPONSIBILITY FOR 

SAFETY RELATED DECISION-MAKING PRIOR 

TO PROMULGATING A REGULATION." 

SLIDE 10 

AS THE GAO RECOGNIZES, EPA CANNOT REQUIRE ORVR 

SYSTEMS IF IT DETERMINES THAT SUCH SYSTEMS CREATE AN 

INCREASED SAFETY RISK. IT IS REASONABLE TO CONCLUDE THAT 

SUCH A DETERMINATION WILL BE MADE IN LIGHT OF THE NHTSA'S 

DEFINITIVE REPORT REGARDING THE SAFETY OF SUCH SYSTEMS, 

AND THE NHTSA'S STATEMENT IN ITS JULY 1991 REPORT THAT: 

"SINCE ORVR SYSTEMS INCREASE SAFETY 
P.27 

SLIDE 11 

RISK AND STAGE II DOES NOT, IT SEEMS 

.. REASONABLE FOR EPA TO CONCLUDE THAT 

ORVR SYSTEMS CONSTITUTE AN 

UNREASONABLE SAFETY RISK." 

WHAT THE GAO PROPOSAL FOR AN "ACTION PLAN" 

OVERLOOKED IS THAT TESTING BY ITSELF IS NOT SUFFICIENT TO 

PRODUCE ACCEPTABLE NEW FUEL SYSTEMS. I AM UNABLE TO 

ACCEPT THE NOTION THAT THE RISKS OF ADDITIONAL FIRES FROM 

ONBOARD SYSTEMS COULD BE APPROPRIATELY HANDLED THROUGH 

PRE-SALE VEHICLE CERTIFICATION OR TEST PROGRAMS. NO TEST 

PROTOCOL OR CERTIFICATION PROGRAM COULD ELIMINATE THE 

ADDITIONAL ORVR PARTS AND CONNECTIONS THAT AN ORVR RULE 

WOULD REQUIRE, OR ELIMINATE THE INVENTORY OF FUEL VAPOR 

THAT CAN BE RELEASED AND CATCH FIRE. FURTHER, 

MANUFACTURERS CANNOT ACCEPT IN-USE VEHICLE SAFETY RECALL 

CAMPAIGNS AS A MEANS OF MANAGING FIRE RISKS. THE GAO 

RECOMMENDATION MAKES NO PROVISION FOR THE FACT THAT THE 

ORVR SAFETY CONCERNS ARE INCAPABLE OF RESOLUTION BECAUSE 

THEY ARE INHERENT TO AN ORVR CANISTER-BASED DESIGN. 

SLIDE 12 As THE NHTSA JULY 1991 REPORT FOUND: 
P.28 

"DURING THE REFUELING PROCESS, VAPOR 

FLOW FROM THE FUEL TANK TO AN ORVR - . 

CANISTER FOR VAPOR STORAGE CAN BE 45 

TO 65 GRAMS PER MINUTE. THIS IS MUCH 

GREATER THAN CURRENT EVAPORATIVE FLOW 

RATES, WHICH RARELY EXCEED 6 TO 8 

GRAMS PER MINUTE AND ARE GENERALLY 

LESS THAN 1 GRAM PER MINUTE. SHOULD 

THIS VAPOR ESCAPE, DUE TO A DESIGN OR 

MANUFACTURING ERROR, IMPROPER 

MAINTENANCE, OR TAMPERING, 

UNCONTROLLED VAPOR WOULD FLOW INTO 

THE ENGINE COMPARTMENT OR UNDER THE 

VEHICLE AND IGNITE, SHOULD AN 

IGNITION SOURCE BE PRESENT. THIS 

RESULTS IN AN INCREASED SAFETY RISK." 

8 

SLIDE 13 MOREOVER, THE GAO "ACTION PLAN" DOES NOT RECOGNIZE 

THE TECHNICAL COMPLEXITY OF THIS ISSUE. IT WOULD HAVE 

THE NHTSA AND EPA SOMEHOW TEST AND EVALUATE 600 MODELS 

PRODUCED BY 30 MANUFACTURERS EVERY YEAR "TO IDENTIFY AND 

CORRECT ANY SAFETY DEFECTS OR MANUFACTURING FLAWS." ORVR 
P.29 

SYSTEMS WOULD INVOLVE THE INTERACTION OF MANY VEHICLE 

SYSTEMS, INCLUDING CHASSIS/BODY DESIGN, THE. EXHAUST 

EMISSION CONTROL SYSTEM, AND THE FUEL SYSTEM ITSELF. NO 

PRACTICAL TEST PROTOCOL COULD AOORESS ALL THESE VEHICLE 

SPECIFICS AND THE CHANGES WHICH OCCUR FROM YEAR TO YEAR 

IN VEHICLE SYSTEMS. THIS APPROACH IS TOTALLY 

INCOMPATIBLE WITH THE PRACTICALITIES OF A NEW FUEL SYSTEM 

DESIGN SUCH AS ORVR. IT DOES NOT PROVIDE AN ADEQUATE 

MEANS TO DEAL WITH UNFORESEEN FIELD EVENTS WHICH WILL 

MOST ASSUREDLY OCCUR AS A RESULT OF INCREASED COMPLEXITY 

OF PROPOSED ORVR SYSTEMS. 

SLIDE 14 GAO's POSITION IS, IN MY VIEW, INCONSISTENT WITH 

NHTSA's JULY 1991 STUDY. THE GAO ANALYSIS WAS NOT BASED 

ON TECHNICAL EVALUATION OF THE SAFETY DATA, AND 

APPARENTLY WAS NOT WRITTEN OR REVIEWED BY FUEL SYSTEM OR 

VEHICLE SAFETY ENGINEERS. IN RECOGNITION OF THIS POINT, 

GAO PROPERLY ACKNOWLEDGED, AFTER RELEASE OF ITS 

MEMORANDUM, THAT ITS PROPOSED "ACTION PLAN" APPROACH 

WOULD NOT BE APPROPRIATE IF ORVR SYSTEMS WERE UNSAFE, 

GAO HAS ACKNOWLEDGED THAT EPA CANNOT REQUIRE ORVR SYSTEMS 

IF SUCH SYSTEMS CREATE AN INCREASED SAFETY RISK. GIVEN 
P.30 

10 

THE NHTSA FINDING REGARDING THE INHERENT SAFETY RISKS 

ASSOCIATED WITH ORVR SYSTEMS, THE GAO ANALYSIS IS 

OBSOLETE. 

SLIDE 15 IN CONCLUSION, THE PROPOSED ORVR SYSTEMS WILL 

CLEARLY INTRODUCE A STEP FUNCTION INCREASE IN FUEL SYSTEM 

COMPLEXITY AND SAFETY RISK. IN THIS REGARD, GM AGREES 

WITH THE NHTSA REPORT THAT "THE INCREASED DESIGN 

COMPLEXITY OF ORVR SYSTEMS WILL RESULT IN AN INCREASE IN 

SAFETY RISK." FURTHER, WE AGREE WITH THE NHTSA REPORT 

THAT "SINCE ORVR SYSTEMS INCREASE SAFETY RISK AND STAGE 

II DOES NOT, IT SEEMS REASONABLE FOR EPA TO CONCLUDE THAT 

ORVR SYSTEMS CONSTITUTE AN UNREASONABLE SAFETY RISK." 

GIVEN THESE FINDINGS AND CONCLUSIONS, GM STRONGLY 

BELIEVES THAT THE PROPOSED ORVR SYSTEMS ARE NOT 

ACCEPTABLE FROM THE STANDPOINT OF MOTOR VEHICLE SAFETY. 

ACCORDINGLY, THEY SHOULD BE REJECTED BY EPA AS AN 

UNREASONABLE SAFETY RISK, AND STAGE II SYSTEMS, REQUIRED 

BY CONGRESS IN OTHER PROVISIONS OF THE CAA, SHOULD BE 

INSTALLED AS PROMPTLY AS POSSIBLE. 
P.31 

EPA HEARING, SEPTEMBER 26. 1991 

ONBOARD REFUELING VAPOR RECOVERY (ORVR) 

TESTIMONY BY: 

ROBERT A. SINKE 

FOR: 

GENERAL MOTORS 

SHOE 1 
P.32 

TESTIMONY FOCUS: 

a FUEL SYSTEM EVALUATION HISTORY 

a FUEL SYSTEM SAFETY 

a GAO AND NHTSA REPORTS 

SLIDE 2 
VEHICLE FUEL SYSTEM HISTORY 

SAE CRASH TEST PROCEDURES 

GENERAL SERVICES ADMINISTRATION 

(GSA) STANDARDS 

NHTSA STANDARD 301 

SLIDE 3 
P.34 

NHTSA REVIEWS OF FMVSS 301 

Q FIRES ARE RELATIVELY RARE 

FOR FATAL CRASHES FIRE MORE 

FREQUENT 

n FIRE ASSOCIATED WITH MORE 

SEVERE CRASHES 

SLIDE 4 
P.35 

GM OBSERVATIONS FROM ACCIDENT STUDIES 

a CONSISTENT WITH NHTSA 

D FIRES RELATED TO SEVERE CRASHES 

a FIRES RELATED TO SPECIFIC DESIGN 

a GENERAL TEST PROTOCOL NOT 

SUFFICIENT TO ADDRESS RISKS 

SLIDE S 
P.36 

FIRES ARE A CONCERN 

D INCREASE RISK OF INJURY 

a PUBLIC BECOMES UPSET WITH FIRES 

D EXTRAORDINARY EFFORTS NEEDED 

SLIOE. 6 
P.37 

RRTFFTNG THE GAO 

a EMPHASIZED ORVR SYSTEMS POSE 

INHERENT SAFETY RISKS 

a ORVR SYSTEMS WILL INCREASE 

VEHICLE FIRES EVEN AFTER 

MANUFACTURERS BEST EFFORTS 

SLIDE 7 
GAO RECOMMENDATIONS 

EPA/NHTSA JOINT "ACTION PLAN" TO: 

"PERFORM A SAFETY EVALUATION OF MANUFACTURERS' 

ONBOARD SYSTEMS TO IDENTIFY AND CORRECT ANY SAFETY 

DEFECTS OR FLAWS AS WELL IN ADVANCE OF THE 1996 

MODEL YEAR SO THAT AN ORDERLY PHASE-IN OCCURS." 

SLIDE 8 
P.39 

GAO REPORT APPEARS TO RECOGNIZE 

PROPOSED "ACTION PLAN" DOES NOT APPLY 

IF ORVR INHERENTLY INCREASES SAFETY RISK 

GAO COVER LETTER: 

"OUR RECOMMENDATION FOR AN ACTION PLAN WAS NOT 

MADE TO PROVIDE A BASIS FOR CHANGING EPA'S 

RESPONSIBILITY FOR SAFETY RELATED DECISION-MAKING 

PRIOR TO PROMULGATING A REGULATION." 

SLIOE 9 
P.40 

NHTSA's STATEMENT THAT: 

"SINCE ORVR SYSTEMS INCREASE SAFETY 

RISK AND STAGE II DOES NOT, IT 

SEEMS REASONABLE FOR EPA TO 

CONCLUDE THAT ORVR SYSTEMS 

CONSTITUTE AN UNREASONABLE SAFETY 

RISK. 

it 

SLIDE 10 
P.41 

GAO "ACTION PLAN" 

OVERLOOKED: 

D TESTING NOT SUFFICIENT 

MANUFACTURERS CANNOT ACCEPT 

RECALL CAMPAIGNS 

SLIDE 11 
P.42 

INHERENT TO ORVR CANISTER DESIGN 

NHTSA JULY, 1991 

"DURING THE REFUELING PROCESS, VAPOR FLOW FORM THE FUEL 

TANK TO AN ORVR CANISTER FOR VAPOR STORAGE CAN BE 45 TO 

65 GRAMS PER MINUTE. THIS IS MUCH GREATER THAN CURRENT 

EVAPORATIVE FLOW RATES, WHICH RARELY EXCEED 6 TO 8 

GRAMS PER MINUTE AND ARE GENERALLY LESS THAN 1 GRAM PER 

MINUTE. SHOULD THIS VAPOR ESCAPE, DUE TO A DESIGN OR 

MANUFACTURING ERROR, IMPROPER MAINTENANCE, OR 

TAMPERING, UNCONTROLLED VAPOR WOULD FLOW INTO THE 

ENGINE COMPARTMENT OR UNDER THE VEHICLE AND IGNITE, 

SHOULD AN IGNITION SOURCE BE PRESENT. THIS RESULTS IN 

AN INCREASED SAFETY RISK." 

SLIDE 12 
P.43 

GAO "ACTION PLAN" 

DOES NOT RECOGNIZE COMPLEXITY 

OF THIS ISSUE 

D NHTSA AND EPA TEST ANNUALLY 

a INVOLVES MANY VEHICLE SYSTEMS 

a YEAR-TO-YEAR CHANGES 

a INCOMPATIBLE WITH NEW FUEL 

SYSTEMS 

SLIDE 13 
GAO INCONSISTENT WITH NHTSA 

D NOT BASED ON SAFETY DATA 

D NOT WRITTEN BY SAFETY ENGINEERS 

RECOGNIZED "ACTION PLAN" WOULD 

BE INAPPROPRIATE IF ORVR UNSAFE 

o ACKNOWLEDGED EPA CANNOT REQUIRE 

ORVR IF THEY INCREASE SAFETY 

RISK 

GIVEN NHTSA FINDING, GAO 

ANALYSIS OBSOLETE 

SLIOE 14 
P.45 

GM CONCLUSIONS 

D HORVR SYSTEMS CLEARLY INCREASE SAFETY 

RISK 

a GM AGREES WITH THE NHTSA REPORT THAT: 

"THE INCREASED DESIGN COMPLEXITY OF ORVR SYSTEMS WILL RESULT 

IN AN INCREASE IN SAFETY RISK." 

"SINCE ORVR SYSTEMS INCREASE SAFETY RISK AND STAGE II DOES 

NOT, IT SEEMS REASONABLE FOR EPA TO CONCLUDE THAT ORVR 

SYSTEMS CONSTITUTE AN UNREASONABLE SAFETY RISK." 

GM STRONGLY BELIEVES ORVR SYSTEM NOT 

ACCEPTABLE 

a ORVR SYSTEMS SHOULD BE REJECTED IN 

FAVOR OF STAGE II 

SLIDE 15 
COMMENTS ON "DEPARTMENT OF 

TRANSPORTATION SAFETY STUDY"0 

"AN ASSESSMENT OF THE SAFETY OF ONBOARD 

REFUELING VAPOR RECOVERY SYSTEMS" 

ENFORCEMENT - NATIONAL HIGHWAY TRAFFIC 

SAFETY ADMINISTRATION, JULY 1991 

<D Federal Register, Tuesday September 3,1991 
INTRODUCTION 

NHTSA'S Assessment is well reasoned 

NHTSA'S Assessment is based partially on original 

research and new data 

NHTSA'S Assessment is well supported by data and 

information in the public record regarding ORVR 

safety 
CONCLUSIONS - ORVR SAFETY 

ORVR systems are more complex and require larger components 

than do evaporative emission systems 

ORVR system complexity and component size would increase the 

risk of motor vehicle collision fire 

ORVR systems regularly are required to handle greater inventories 

of hazardous material (gasoline vapor) at greater flow rates than 

are evaporative emission systems 

Unscheduled release of a gasoline refueling vapor charge from an 

ORVR system would increase non-collision fire risk 
CONCLUSIONS - ORVR SAFETY 

ORVR collision and non-collision fire risks are incremental 

and would have an adverse impact on motor vehicle safety 

Stage II does not adversely affect motor vehicle safety but 

does favorably impact gas station safety 

As ORVR increases risk and Stage II does not, it is 

reasonable that EPA conclude ORVR safety risks are 

unreasonable 

CO 
CONCLUSION 

ORVR systems are more complex and require larger components than 

do evaporative emission systems 

BASIS 

NHTSA evaluations of ORVR "Simple System" 

Manufacturers' evaluation of ORVR "Simple System" 

Manufacturers' descriptions of prototype ORVR systems 

bt 
TYPICAL = omm SYsn 

Filter Neck 

00159.x 
ONBOARD REFUELING VAPOR RECOVERY 

"SIMPLE SYSTEM" 

3/8" dia. purge line 

vapor line 

Purge 

valve 

Anti-spitback 

valve 

Rollover 

valve 

Carbon 

canister 
NHTSA EVALUATIONS OF ORVR SYSTEMS 

• 1987 Buick Le Sabre— "Simple System" 

+ experienced refueling difficulties 

+ driveability after refueling unacceptable 

+ liquid fuel spit back at nozzle shutoff 

+ gasoline odor after hot soak, and during high 

temperature operation 

+ driveability at moderate ambients acceptable 

• 1988 Ford Taurus — EPA "Vehicle Based (i.e., modified) 

Simple System" 

+ driveability at moderate ambients acceptable 
MANUFACTURER'S EVALUATIONS OF EPA 

"SIMPLE SYSTEM'® 

EMISSION 

MA NUFA CTURER CONTROL 

FILL 

QUALITY SAFETY DRIVEABILITY 

General Motors Corp. Unacceptable Unacceptable test Unacceptable test Unacceptable test 

test results results results results 

Ford Motor Co. Unacceptable Unacceptable test Unacceptable test Unacceptable test 

test results results results results 

Toyota Unacceptable Unacceptable Unacceptable 

Mitsubishi 

BMW 

Unacceptable Requires testing Increased risk 

Volvo 

Jaguar 

Adverse 

impact on 

exhaust 

emissions 

Requires 

additional new 

technology 

Requires 

additional new 

technology 

Potential problem 

Requires additional 

new technology 

Potential problem 

Requires additional 

new technology 

Requires additional 

new technology 

(D SeeFaAA-PA-R-88-11-16 
MANUFACTURER'S DESCRIPTIONS OF PROTOTYPE 

ORVR SYSTEMS 

MANUFACTURER 

General Motors 

Ford Motor Co. 

Honda 

Toyota 

Saab 

Nissan 

Chrysler 

Subaru 

Mitsubishi 

LARGE OR 

MULTIPLE 

CARBON 

CANISTER 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

LIQ/VAP 

SEPARATOR 

OR EQUIVALENT 

Yes 

Yes 

— 

Yes 

— 

Yes 

No 

Yes 

Yes 

LARGE 

VAPOR 

LINES 

Yes 

Yes 

— 

Yes 

Yes 

Yes 

Yes 

— 

Yes 

ADDITIONAL 

VENT VALVE • 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Ul 

Ul 
CONCLUSION 

ORVR system complexity and component size would increase 

collision fire risk 

BASIS 

NHTSA canister ignition testing 

Collision testing with prototype ORVR systems 

Functional/Package requirements which govern ORVR component 

location 

Previous experience with a revolutionary fuel system change which 

increased system complexity —1971 evaporative systems 
SUMMARY— NHTSA CANISTER IGNITION TESTING 

GASOLINE 

VAPOR CHARGE NUMBER OF UNITS 

IN CANISTER TESTED 

NUMBER OF GAS 

VAPOR FIRES 

FREQUENCY OF 

IGNITION 

100% 

(saturated) 

11 11 100% 

75% — 99% 8 62% 

50% — 74% 10 90% 

0 — 49% 0% 

Data from "Fuel Vapor Canister Fire Simulation Tests", 

VRTC-71-0211, July, 1991 

OI806.q 

Ul 
ORVR COLLISION TESTING ® 

STRIKING VEHICLE 

1978 Chevrolet Mallbu 

Impact Speed: 29.4 mph 

Test Weight: 3866 lb 

Impact location at C 

of fuel door 

h=£Zz 

Front 

Front ~f~ 

Striking vehicle

 1 ft 

STRUCK VEHICLE 

1985 Buick Century 

with Mobil Oil 

ORVR System 

Test Weight: 3040 lb 

— (^crashrail 

Crash Test Configuration 

68.5% 

<27,000 

31.5% 

>27,000 

13.4% 

>SO,000 

0.64% 

Fire 

Collisions 

3.5% 

>100,000 

,07% 

Fire 

Collisions 

1.75% 

Fire 

Collisions 

1982-1984 NASS 

Energy Absorbed During Impact (ft-lbs) 

Results: Fuel leak at liquid-vapor separator and vapor delivery tube 

Conclusion: ORVR could result in additional collisions with fire 

<D See FaAA-AZ-R-87-10-6 

Ul 

oo 
ONBOARD REFUELING VAPOR RECOVERY SYSTEM 

(SEALED FILLER NECK) GENERAL MOTORS 

Large 

Canister 

Large 

Vapor Line 

Liquid/Vapor 

Separator Tank Vent 

Valve Assembly 

(TVVA) 

Mechanical 

Seal 
ONBOARD REFUELING VAPOR RECOVERY SYSTEM 

(LIQUID SEAL) GENERAL MOTORS 

DETAIL B 

DETAIL A 

01B17.g 
ONBOARD REFUELING VAPOR RECOVERY SYSTEM 

FORD 

Emergency 

Relief Valve 

Vapor/Liquid 

Discriminator 

Gas Nozzle 

Vapor 

To 

Canisters 

Carryover 

Evap. System 

Nozzle Seal 

Trap Door W/Seal 

Vapor/Liquid 

Discriminator 

Vent Tube 

DETAIL A 

Modular 

Carbon 

Canisters 

b> 
ONBOARD REFUELING VAPOR RECOVERY SYSTEM 

NISSAN 

Water Separator-. 

~5 

Air 

Refueling Canister—1 

•«— Control Unit 

Variable Orifice Control 

Rollover Valve -i 

(with fuel 

check valve) Vent Cut Valvea 

^Mechanical 

Nozzle Seal 

Over Fill Limiter 

Vapor/Liquid Separator 

01617.J 
ONBOARD VAPOR RECOVERY SYSTEM 

MITSUBISHI 

Purge 

Control 

Valve 

Control Unit 

Vent Line 

Vapor Liquid Separator n 

Overfill Limiter -i r-Vapor 

Line 

Purge Line Rollover Valve 

Nozzle Actuated 

Vent Valve 

Water Separator 

Filler Cap 

-Nozzle Seal 

Filler Pipe 

Fuel Tank -* L Overfill Limiter Valve 
ONBOARD REFUELING VAPOR RECOVERY SYSTEM 

TOYOTA 

TM Purge Control Valve 

\ 

Refueling Canister 6-8L 

Engine (f=z 

(f JJ 

Vapor Vent Valve 

W/Vapor Liquid Separator 

Water Separator 

Liquid Seal 

Evap. Canister 1 -1.8L Valve Overfill Limiter 
EVAPORA TIVE EMISSION SYSTEM RISK ANAL YSIS 

NCSA - July 8, 1991 

VEHICLE SELECTION 

Fleet with evaporative systems: 1971-1973 passenger cars 

Fleet without evaporative systems: 1968-1970 passenger cars 

DATA BASE SELECTION 

Illinois 1982-1983 Ohio 1982-1983 

Michigan 1980-1982 Pennsylvania 1977-1980 

METHOD 

Logistic regression for accident outcome, evaporative emission system, 

vehicle age, vehicle model year weighted for the four states. 

RESULTS 

Evaporative emission-equipped vehicles experienced a collision fire rate 

27% greater than vehicles not so equipped. 
EVAPORATIVE EMISSION SYSTEM RISK ANAL YSIS 

FaAA 1988, 1989 

ELEVEN STATES COMBINED ANALYSIS* 1975-1986 FARS 

COLUSION 

FIRES 

PER 1,000 

COLUSIONS 

1968-1970 1971-1973 

MY MY 

COLLISION 

FIRES 

PER 1,000 

COLLISIONS 

26.31 

1968-1970 1971-1973 

MY MY 

Conclusions: 

1. Evaporative emissions systems are associated with an 

increase of 12% in all collision fires and 18% in fatal 

collision fires 

2. If ORVR performance is similar, we could experience 

600-5,500 additional collision fires and 130-240 additional 

collision fire fatalities 

'1975-82 Alabama, 1976-86 Idaho, 1981-86 Illinois, 1977-85 Maryland, 1981-S5 Michigan, 1976-85 New York, 1982-85 

Ohio, 1977-85 Pennsylvania, 1971-85 S. Carolina, 1978-81, '84, '85 Texas, 1970-85 Washington 
CONCLUSION 

ORVR systems regularly are required to handle greater inventories 

of hazardous material (gasoline vapors) at greater flow rates than are 

evaporative emission systems 

BASIS ___ _ 

• NHTSA data from manufacturers 

• Refueling test data 
NHTSA DATA FROM MANUFACTURERS 

MANUFACTURER 

EVAP. 9.0 RVP @ 

72°F-96°F 

DIURNAL SOAK 

9.0 RVP 

REFUELING 

Nissan 

Chrysler 

Rate 

0.2 g/min.® 

Total 

21 g® 

51 g® 

120 g 

Rate 

43 g/min.® 

46 g/min.® 

64 g/min.® 

Total 

54.2 g®® 

58.0 g®® 

236.5 g®® 

Ford 0.3-0.6 g/min.® 35-50 g® 18-56 g/min.® 72.0 g @® 

General 

Motors 

0.055 g/min.® 32.9 g® 45 g/min.® 

to 0.117 g/min. to 70.3 g 

67.5 g ©(3) 

<D Test result @ Estimated @ 15 gal. fill ® 10 gal. fill <S) 33.4 gal. fill © 12.5 gal. fill 

01}16.. 
REFUELING TEST DA TA 

PROCEDURE 

• Fill tank with 14 gal. 8.9 RVP gasol 

delivered at 8.5 gal./min. 

(tank initial fill = 1 gal., 89°F fuel) 

• Collect 

RESULTS 

Total fuel 

vapor 

Rate 

ine dispensed at 91 °F, 

vapors from disconnected tank vent 

1985 Buick Century 

production evaporative 

emission system 

0.73 g 

0.05 g/gal 

1985 Buick Century 

with mechanical seal 

5/8" dia. refuel vent 

93.05 g 

6.67 g/gal 

! 

01816.1 
CONCLUSION 

Unscheduled release of a refueling gasoline vapor charge from 

an ORVR system would increase non-collision fire risk 

BASIS 

NHTSA refueling vapor ignition testing 

FaAA refueling vapor ignition testing 

^1 
NHTSA REFUELING VAPOR IGNITION TESTING 

EQUIPMENT 

• Modified 13.7 gal. Dodge pickup fuel tank 

• 5/8" and 3/8" refueling vent 

• Closed system fill at bottom of tank 

• Spark ignition at end of refueling vent 

• Fill rate 8 gal./min. 

RESULTS 

• Vapor flow rate = 49 g/min. 

• Expansive flame front 2-3 feet in length 
FaAA REFUELING VAPOR IGNITION TESTING® 

PROCEDURE 

• Drive car to stabilized 

• Fill tank 

"warm" 

• Replace dispensing nozzle 

• Start car 

RESULTS 

ORVR 

Self-sustaining fire 

on engine start 

(D See FaAA AZ-R-87-10-6 

EVAP 

No self 

fire 

temperature 

-sustaining 

018I6.I 
CONCLUSION 

ORVR collision and non-collision fire risks are incremental and 

would have an adverse impact on motor vehicle safety 

BASIS 

Collision risks associated with ORVR: 

- Component size 

- Additional system complexity 

- Additional connections 

- Larger inventory of hazardous materials 

Non-collision risks are associated with unscheduled discharge 

of an ORVR vapor cloud due to: 

- Improper assembly or manufacturing 

- Improper service 

- Tampering and deliberate disconnect 

- Component deterioration 

- Component damage 
CONCLUSION 

Stage II does not adversely affect motor vehicle safety and reduces 

the frequency of gas station gasoline fire 

BASIS 

Stage II is entirely contained at fuel dispensing stations 

Study of Stage II safety effects at dispensing stations 
MOTOR VEHICLE FLEET STAGE II 

Fuel tank Muffler 

Engine 

Evap. emiss 

control 

Catalytic 

converter 

Electronic 

engine control 

Pressure 

sensitive 

cut-off 

Accordian seal 

(optional) 

Underground 

gasoline storage 

Vapor recovery 

system with line 

to underground 

storage 
STAGE II SAFETY EFFECTS? 

Gasoline gas station fire rates in 

installations 

Fire Rate 

(Fire per 

1010gal.) 

Casualty Rate 

(Casualties per 

1010gal.) 

Stage II 

(California) 

84.1 

4.0 

Stage II and non-Stage II 

Non-Stage II 

(18 Statef 

169.5 

10.3 

<J> Alaska, Connecticut, Delaware, Hawaii, Illinois, Louisiana, Maryland, Massachusetts, Michigan, 

Montana, Nebraska, Ohio, Oregon, Rhode Island, South Dakota, Vermont, West Virginia, Wisconsin 

a See FaAA AZ-R-87-tO-6 

01816.fTi 
SAFETY EFFECTS OF RVP CONTROLS 

BACKGROUND 

California limits gasoline RVP during the 7 month 

summer period. 

Texas, a state with the same ASTM gasoline class as 

California, had no RVP controls in the study period. 

1982-1985 NFIRS RESULTS 

California Texas 

(Stage II) (Non-Stage II) 

Summer Winter Summer Winter 

Fire Rate0 B5J 76^0 167.7 143.0 

Seasonal 62% 38% 63% 37% 

Distribution 

Conclusion: RVP controls do not affect gas 

station gasoline fire rates. 

tfl) Fires per 10 gallons 
CONCLUSION 

As ORVR increases risk and Stage II does not, it is reasonable 

that EPA conclude ORVR safety risks are unreasonable 

BASIS 

NHTSA has analyzed the record, conducted testing 

and concluded ORVR would present incremental safety risks 

Stage II has no incremental risk for motor vehicle safety 

and reduces gas station gasoline fire risk 

Desired VOC reductions can be achieved by 

implementation of Stage II controls 

Thus, the desired VOC reductions can be achieved with 

no incremental risk to motor vehicle safety 

Incremental risk to motor vehicle safety is unnecessary, 

therefore any incremental risk is also by definition unreasonable 

oo 
ONBOARD REFUELING VAPOR RECOVERY 

SAFETY RESEARCH PROJECTS 

Automobile 

Industry NHTSA OMS 

Manufacturers' Comments 

FaAA Studies 

ORVR Fill Tests 

ORVR Driveability Tests 

ORVR Function Tests 

ORVR Crash Tests 

ORVR Ignition Test 

Evap. System and 

Component Tests 

Canister Ignition Tests 

FARS Risk Analysis 

11 States Risk Analysis 

NASS Review 

Stage II Risk Analysis 

ORVR Safety Assessment 

ADL Study 

ORVR Fill Tests 

ORVR Driveability Tests 

ORVR Ignition Tests 

Canister Ignition Tests 

4 State Risk Analysis 

ORVR Safety Reports 

Batelle Study 

ORVR Fill Tests 

ORVR Function Tests 

FARS Assessment* 

3 States Data Review* 

Derivative of Data Link Report 

CO 
CONCLUSIONS 

OMS REPORTED AUGUST, 1988 

• ORVR systems are simple and are 

similar to evaporative emission 

systems 

• ORVR related fire risks can be 

overcome by manufacturerss 

• Stage II does not adversely effect 

motor vehicle safety 

NHTSA REPORTED JULY, 1991 

• ORVR systems are more complex and 

require larger components than do evaporative 

emission systems 

• ORVR system complexity and component size 

increase collision fire risk 

• ORVR systems regularly handle greater 

inventories of hazardous material at greater 

flow rates than do evaporative emission 

systems 

• Release of a gasoline vapor refueling charge 

from an ORVR system increases non-collision 

fire risk 

• ORVR related fire risks are incremental and 

will have an adverse impact on motor vehicle 

safety 

• Stage II does not adversely effect motor 

vehicle safety and improves gas station safety 

• As ORVR increases risk, and Stage II does not, 

it is reasonable for EPA to find ORVR safety 

risks unreasonable 

OI806.d 

XI 

co 

_ o 
P.81 

R. L. Kirkpatrick Testimony for ORVR September 26. 1991 Hearing 

Good afternoon. I am Richard L. Kirkpatrick. I am a Staff Project Engineer in 

Vehicle Development at General Motors. I have 33 years of experience in the 

design and testing of automotive components and systems, and since 1979 have 

been primarily involved in fuel systems development. 

My purpose today is to offer comments on the prototype onboard vapor recovery 

design described in an early 1990 paper by three Exxon Research and 

Development personnel. With me tb respond to emission questions concerning 

the Exxon paper and the Exxon design is Kevin Cullen, of the GM Vehicle 

Emission Laboratory at the Milford Proving Grounds. 

In the EPA document of August 1991 entitled, "Summary of Changed 

Circumstances" under the heading of "Technology Improvements" it is stated that 

even further design simplification is possible. The only documented design 

since the EPA "simple" system design that I'm aware of is a Society of 

Automotive Engineering paper 900155 by Exxon entitled, "Improved Design of 

Onboard Control of Refueling Emissions" published over a year and a half ago. 

The Exxon paper only describes the concepts of such a system and does not 

provide any details of how the system was specifically designed or the key 

testing parameters and vehicle conditions encountered during the authors' 

experimental work. 

Contrary to the OMS conclusion that its previous "simple" system met the 

proposed refueling standard and performed satisfactorily in in-use testing, 

General Motors testing found the "simple" system unacceptable for refueling 

emission recovery, evaporative emissions, and vehicle safety, and only further 

complexity could begin to address the unacceptable aspects of the system. 
P.82 

Exxon's so-called improved design purports to not only have improved refueling 

emissions and evaporative emissions, but, at the same time addressed the 

safety issues. 

Slide 1: 

The basic premise of the Exxon design is that the safety concerns presented by 

Onboard Refueling Vapor Recovery (ORVR) systems on passenger cars can be 

addressed by locating the vapor storage canister near, or inside, the fuel tank. 

That premise is incorrect. The location of the canister has never been the 

primary - or even a dominant - issue regarding ORVR safety. 

The 1989 Arthur D. Little study for NHTSA, for example, identified several safety 

concerns more serious than canister location, including: 

o The risk of combustible vapor releases during refueling, due to tampering 

or system malfunction; 

o Increased exhaust and underbody temperatures due to higher purge 

requirements; 

o Greater risk of post-crash fires due to enlargement of vapor-handling 

components; and, 

o Poor vehicle performance during acceleration due to inadequate controlled 

canister purge or other onboard-related factors. 

The July 1991 NHTSA safety evaluation prepared by the NHTSA gave special 

emphasis to non-crash failure modes. As the report stated and I quote: 

"ORVR systems will not merely be a simple extension of 

evaporative systems where vehicle operation and safety are 

concerned. While the two systems are structurally similar, functional 

differences exist. ORVR systems will have additional components, 

valves, more canisters and larger vapor hoses compared to 
P.83 

evaporative systems. The increase in the number of connections 

and number of components and valves, increased canisters, and the 

presence of more and larger hoses, will increase the likelihood of 

system failure. Failure could be due to design, manufacturing, or 

assembly errors, as well as damage, improper servicing, or 

deliberate disconnection through tampering..." 

"During the refueling process, vapor flow from the fuel tank to the 

ORVR canister can be 45 to 65 grams per minute. This is much 

higher than evaporative flow rates, which rarely exceed 6 to 8 

grams per minute and are generally less than 1 gram per minute. 

Should this vapor escape, due to a design or manufacturing error, 

improper maintenance or tampering, uncontrolled vapor would flow 

into the engine compartment or under the vehicle and create a fire, 

should an ignition source be present." 

Slide 2: 

Locating the canister inside or near the fuel tank does not address those 

significant concems expressed by the NHTSA or by the Arthur D. Little Report. 

Indeed, it can create additional problems. Having a canister inside a fuel tank 

subjects the canister to a very hostile environment. There is an increased risk 

of liquid intrusion into the canister through permeation or internal leaks that 

would contaminate the system and render it inoperative. In addition, any liquid 

leaks within the hose connections would cause the canister to be continuously 

saturated, thus making the system inoperative. 

In addition, the sudden rush of refueling vapors into a canister located inside the 

tank during refueling will heat the canister. Consequently, the fuel in the tank 

will be heated due to the increased canister temperature and will increase the 
P.84 

amount of vapors generated within the tank. Also, a canister inside the tank 

displaces fuel volume and vapor space which reduces driving range and 

therefore will increase the number of refueling events. 

Equally important, in a crash, the fuel tank can be more vulnerable to rupture 

during a crash due to the interaction between the canister, its attachments, and 

the fuel tank whether mounted inside or outside of the tank. A plastic or metal 

canister full of charcoal can present a significant hazard to a fuel tank during 

the unpredictable events of a crash. 

Slide 3: 

Although I have not examined the Exxon hardware or design first hand, there 

are a number of fundamental problems that are important to examine. First, it 

is important to inquire about Exxon's so called "simulated" rollover tests. The 

FMVSS 301 static rollover evaluation is intended to check for fuel system leaks 

due to a crash. The static rollover test must follow the prescribed FMVSS 301 

crash test. The 1990 Exxon paper states, however, that the barrier crash 

portion of the test was not performed." Consequently, the "rollover testsdescribed in the paper are trivial, and provide no meaningful indication of the 

crashworthiness of these reportedly "improved designs." 

In addition, there apparently was no extensive testing to evaluate: 

o Hot-weather fuel handling during vehicle maneuvering on steep grades; 

o Fuel tank fill quality testing under hot-weather conditions; nor 

o Hot-weather city traffic operation. 

The elimination of the liquid-vapor separator makes those tests particularly 

important. The conclusions drawn by Exxon from its refueling test results are 

also subject to question, given the real-world extremes in ambient temperatures 
P.85 

and fill rates, and the variations in nozzle geometry, that were apparently not 

fully included in Exxon's evaluation. 

It is critical that EPA recognize that unresolved functional issues are, in the case 

of ORVR, not just customer satisfaction issues for the manufacturers or the 

dealers; they are potential causes for vehicle tampering that create both safety 

and emissions problems. That is one reason why we are so concerned about 

the serious functional problems presented by systems like the latest Exxon 

design. 

Additional functional testing .would not make the Exxon system safe. The key 

point is that appropriate functional testing would have demonstrated that the 

radical simplifications in the ORVR design described in the 1990 Exxon paper 

would not be workable. By the time the functional problems were addressed, 

the system would cease to be either "simple" in its operation or less complex 

in its design than the other types of systems the NHTSA has already found to 

increase safety risks. 

Since a detailed description of this specific design has never been disclosed, 

there are probably other problems with the Exxon design that I have not been 

able to identify. 

Slide 4: 

Turning now to the emission tests reported for this system, most of the refueling 

and evaporative emission results reported in the paper were from tests 

conducted using an obsolete test procedure. This fact further undercuts any 

claim that the Exxon system is a viable design for ORVR control. 

The point can be illustrated by examining the running loss tests reported in the 
paper. The running loss tests reported in the paper were conducted using 12 

Rvp fuel at laboratory ambient temperatures between 95° and 105°F. In light of 

the existing volatility control regulations, this combination of fuel volatility and 

ambient temperature is inappropriate. The results presented in this paper of 

running loss tests at 100°F on 12 Rvp fuel obscure the fact that many current 

production vehicles perform quite well in controlling running losses during 

realistic conditions of 9 Rvp at 95°F, as shown by EPA's running loss testing. 

The authors acknowledge in the paper the importance of matching the fuel tank 

temperatures in the laboratory during running loss tests to those measured on 

the road. But the fuel tank temperature rise-over-ambient values reported in the 

paper and used by the authors during the running loss tests are unrealistically 

low compared to those used by EPA in their running loss testing. EPA's tank 

temperature data were collected at similar ambient temperatures to those used 

during their running loss tests: the ambient temperatures encountered by the 

authors during their on-the-road measurements of fuel tank temperatures were 

not reported in the paper. 

Considering the unrealistic combinations of temperature and fuel volatility used 

in the running loss tests reported in the paper, the authors' conclusions 

regarding running loss control of the ORVR system compared to current 

production vehicles is irrelevant. 

Having a low pressure drop design as described in the paper will actually 

contribute to increased running losses due to increased vapor generation under 

hot urban conditions because unpressurized fuel boils at lower temperatures. 

In addition, the possibility of fuel tank overfills also exists because of the 

unrestricted vent orifice and the ball check valve which creates a hard shutoff 

and the possibility of fuel spillage. Moreover, having a low pressure design will 
P.87 

require an enlarged canister to handle the increase in vapors. The larger the 

canister the less efficient the evaporative emission control system. 

In sum, the Exxon design does riot resolve the main safety-related problems 

with ORVR controls identified by independent researchers and engineers. 

Moreover, the emission testing work described appears to have followed 

obsolete or unrepresentative procedures which shed little light on the real-world 

emissions of the test vehicles. 
P.88 

Exxon ORVR Design 

Premise regarding reduction of the safety risks through 

"relocation of the canister is incorrect. 

NHTSA found: 

"ORVR systems will not merely be a simple extension of 

evaporative systems where vehicle operation and safety are 

concerned. While the two systems are structurally similar, 

functional differences exist. ORVR systems will have 

additional components, valves, more canisters and larger 

vapor hoses compared to evaporative systems. The 

increase in the number of connections and number of 

components and valves, increased canisters, and the 

presence of more and larger hoses, will increase the 

likelihood of system failure. Failure could be due to design, 

manufacturing, or assembly errors, as well as damage, 

improper servicing, or deliberate disconnection through 

tampering..." 

"During the refueling process, vapor flow from the fuel 

tank to the ORVR canister can be 45 to 65 grams per 

minute. ( This is much higher than evaporative flow 

rates, which rarely exceed 6 to 8 grams per minute 

and are generally less than 1 gram per minute. 

Should this vapor escape, due to a design or 

manufacturing error, improper maintenance or 

tampering, uncontrolled vapor would flow into the 

engine compartment or under the vehicle and create a 

fire, should an ignition source be present." 

Slide 1 
P.89 

Additional Problems 

o "In-tank" Design: 

Liquid intrusion 

Crash risks - tank rupture 

Exotherm during refueling 

o "Near-tank" Design: 

Canister as a hazard to the fuel tank 

No reduction in connections that create crash risks 

Slide 2 
Some Unanswered Questions about the Exxon Design 

Slide 3 

o FMVSS 301 "simulated" rollover tests 

o Hot-weather functional evaluations 

o Steep-grade/extreme maneuvering 

o Fill rate/operator/nozzle variations 
P.91 

Emissions Tests 

o Exxon's February 1990 Results: 

Unrealistic running loss tests 

Obsolete evaporative emission test procedures 

Reasons for Concern: 

Low-pressure drop design is inferior for real-time 

evaporative control 

Low-pressure design and tank-integral location will 

require enlarged canister 

Larger canisters are much less efficient in 

evaporative emission control 

Slide 4