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OAR Box 1142 

Prepped by Ollie Stewart 

Document Number: 

13) IV-F-11 

Docket Number: 

A-87-11 

Printed 4/23/2008 10:21:21 AM Sheet 13 of 30 
Statement of KeDy M. Blown, Executive Engineer 

..-••" Ford Fuel Economy and Emissions Control Planning Staff 

EPA PubUc Hearing - Onboard Vehicle Refuehng Controls 

'%> \ September 26, 1991 

-'Good afternoon, I am Kelly M. Brown, Executive Engineer of Fuel Economy and 

/Emissions Control Planning at Ford Motor Company. With me today are Robert 

Brown of the Automotive Emissions and Fuel Economy Office, Tim O'Brien of Ford's 

Office of the General Counsel, and Ted Rusinowski of Ford's Automotive Safety 

Office. Ford is pleased to have an opportunity to appear here today. We will present 

Ford's position regarding the safety issues associated with onboard refueling vapor 

recovery (OBVR) systems and the report by the National Highway. Traffic Safety 

Administration: "An Assessment of the Safety of Onboard Refueling Vapor Recovery 

Svstems." Ford participated in the preparation of and fully endorses the legal analysis, 

presented by MVMA. 

Ford believes that vehicle based refuehng controls ("onboard controls"), if 

required, will result in increased vehicle safety risk. We do not believe that onboard 

refueling vapor recovery systems are simple extensions of evaporative systems, 

especially when viewed from a safety context. In view of the fact that there is a safe 

alternative means of controlling refueling vapors (Stage II), we believe that the safety 

risk associated with onboard controls is unreasonable. Accordingly, we believe that 

EPA should publish its determination not to require onboard controls. 

Since EPA's August, 1987 Notice of Proposed Rulemaking proposing to require 

onboard controls, Ford has continued work to develop an acceptable onboard refueling 

system. We have evaluated several systems as well as component design concepts. As 

yet we have not developed and demonstrated a production feasible onboard refueling 

vapor recovery system, which includes meeting the refueling control requirements as 

well as more stringent exhaust emission standards, customer performance needs and 

safety requirements. 
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In evaluating experimental components and systems, we have experienced, in 

varying degrees, some of the specific failure modes discussed in the NHTSA report. 

With regard to several of the concerns discussed in the NHTSA report, the following 

comments are provided. 

• Failure modes during the refueling process: Ford has experienced fuel 

spitback and frequent fuel nozzle shut-offs during evaluation of 

experimental onboard refueling vapor control systems. 

• Failure modes while the vehicle is being driven: Ford has experienced 

stumbles and stalls. Additionally, as vehicles age without proper 

maintenance - including maintenance of the onboard refueling vapor 

recover system, we are concerned that any potential driveability issues 

associated with refueling vapor recovery systems could become more 

pronounced. 

• Failure modes due to crash involvement: We have not successfully 

demonstrated acceptable crash characteristics on vehicles equipped with 

experimental onboard refueling vapor recovery systems. 

Moreover, the potential for fire caused by component failure, improper repair, 

tampering or crash damage to the onboard system is a primary concern to Ford due to 

the potential for severe injury to vehicle occupants. 

Ford agrees with the methodology (logistic regression; the dependent variable was 

defined as a dichotomous outcome [0,1] indicating whether a fire was reported in the 

specific vehicle involved in the crash) used by the NHTSA in its analysis of fire 

accident data, and agrees that the findings are correct While recognizing the 

limitations (impossible to define the source of a fire in a motor vehicle crash) of the 

analysis due to the many changing factors (1968 implementation of a fuel system 

integrity safety standard, changing vehicle emission control svstems, i.e., 1971 

evaporative canisters implementation, etc.) as noted in the NHTSA report, Ford 
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believes that the fire accident data supports the findings stated in NHTSA's report. 

Also, from a logical standpoint, we believe that it is reasonable to conclude that the 

added components, connections, and lack of available space to properly package 

onboard refueling vapor controls , along with the added system complexity, supports 

the conclusion that an additional risk of fire can be expected. 

Some believe that onboard refueling controls will be simple extensions of 

enhanced evaporative emission control systems. Ford disagrees. While the technology 

may be similar, certain operational parameters, which could have important safety 

implications, will be very different For instance we have found that vapor flow rates 

during the refueling event can range from 18 to 56 grams per minute, from 3.2 to 10.8 

grams per minute during hot weather driving, and from 0.3 to 0.6 grams per minute 

during typical diurnal events (vapor flow rates vary depending on fuel RVP, 

temperature, tank size, and additionally for refueling, fuel fill rate). The higher 

refueling vapor flow rate greatly increases the consequences of a system leak in terms 

of the resulting concentration of combustible vapors at the site of the leak. 

Vehicle-based refueling controls will significantly increase system complexity by 

increasing the required vapor storage volume (as much as doubling the volume 

compared to enhanced evaporative systems), increasing the number of vapor hose 

connections, requiring larger hoses, and increasing the potential for collision damage to 

system components. In addition, Ford believes that developing onboard systems will 

require the invention of new vapor valves and associated strategies to port vapors to 

storage canisters during refueling events. These requirements represent a significant 

technological challenge above that required for enhanced evaporative systems. Since 

there will be a substantial increase in the amount of vapor present on the vehicle, 

combined with the added complexity of onboard systems, it is difficult not to conclude 

that an increased potential for fire exists. 

Furthermore, heavy duty vehicles (HDVs) would present unique refueling control 

challenges. A significant volume of HDVs over 10,000 pound GVWR and the majority 

of 8,500-10,000 pound GVWR applications are completed by second stage vehicle 
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manufacturers. Second stage manufacturers would face an almost overwhelming 

challenge to properly assemble onboard vapor controls, were they to be mandated. In 

addition, the average gasoline fuel tank for these heavy duty applications is 

approximately 38 gallons and could range as high as 100 gallons for vehicles equipped 

with dual tanks. This would result, on average, in eight liters of carbon and could 

potentially require as much as twelve liters of carbon, for onboard controls. 

Moreover, heavy duty applications over 10,000 pound GVWR encounter a wide 

range of operating conditions and usage patterns. Significant portions of time are 

spent under high load, wide open throttle cycles, such as occurs on hilly terrain and in 

high altitude locations. This operation makes purging more difficult and in conjunction 

with the relatively large refueling canisters, which are up to four times the capacity of 

current evaporative control systems, could result in canisters being fully saturated 

essentially all the time. 

Ford supports NHTSA's conclusion that Stage II systems are the preferable 

method of controlling refueling vapors: 

• The technology exists and state-of-the-art Stage II nozzle systems are 

both very effective and user friendly. 

• Stage II systems have been proven safe. In fact, studies show that 

service stations equipped with Stage II systems have improved safety 

records compared to stations without Stage II controls. 

• Emission reductions from Stage II systems are more timely, because 

upon installation, they will collect vapors from all vehicles, not just the 

new vehicles that would be equipped with onboard controls. 

• Stage II systems are gaining widespread acceptance in many areas of 

the country (outside of California) including, The District of Columbia, 
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St Louis, Missouri, New Jersey, the New York metropolitan area, 

Massachusetts, Philadelphia, and Dade County, Florida. 

• Studies suggest that current technology Stage II svstems used in 

conjunction with onboard controls will result in lower vapor capture 

rates; refueling vapors would be captured by the onboard system thus 

sacrificing underground storage tank losses "Breathing Losses" normally 

captured by Stage II systems. 

If the earliest practical air quality improvement consistent with safety is important 

to the public, Ford believes that it does not make sense to force a yet-to-be-proven 

technology upon society that, even if successful, will take 20 years to implement and 

that involves serious safety uncertainties, when a much safer alternative with more 

immediate air quality benefit is available. 

In summary, Ford has not developed and demonstrated a production feasible 

onboard system, which includes meeting the refueling control requirements as well as 

more stringent exhaust emission standards, customer performance needs and safety 

requirements. We, therefore, concur in NHTSA's primary conclusion that "because 

OBVR systems increase safety risk and Stage II does not, it seems reasonable for EPA 

to conclude that OBVR systems constitute an unreasonable safety risk". 

Thank you. We will be glad to answer any questions you may have.