p.1 

OAR Box 1830 

Prepped by Ollie Stewart 

Document Number: 

6DIV-C-27 

Docket Number: 

A-87-11 

Printed 11/13/2008 7:20:54 AM Sheet 61 of 232 
; 4 . &-S7-J.1 

V-L'- * | , A \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY ~ 

P.2 

\. +> y 

ANN ARBOR. MICHIGAN 48105 

• DEC 2 ! 1987 •-"•'••• - o .- ••:-. OFFICEOF - ; 

";:, : .-,•'''•' AI R AN D RADIATIO N * 

'Mr. Paul- Yoshida,- Chief • E ,7 

Defects Investigation Branch (NEF-12). 

Office of Defects and Investigation 

National Highway Traffic Safety. Administration 

400 Seventh St. S.W. 

Washington, D.C. 20590 

Dear Mr. Yoshida: 

Thank you for meeting v/ith Paul Laing and I to discuss the 

details of NHTSA's recent recall analysis which examined past 

fuel and evaporative system defects in an attempt to identify 

potential future problems with onboard systems. We appreciate 

the time you spent with us on October 29, and November 5, 1987 

and your efforts in gathering the detailed recall reports we 

requested. 

As was agreed at our October 16, 1987 meeting in Ann 

Arbor, we plan to work closely with you in reviewing and 

analyzing the recall files with the goal of developing a list 

of past recall actions which both NHTSA and EPA agree may be 

pertinent to onboard/volatility controls. As a step toward 

that goal, we have prepared a summary and analysis of the 

discussions and views presented at our November 5, 1987 meeting 

(Enclosure 1). This summary and analysis is broken into five 

parts. 

Table 1, which is included for sake of reference and 

completeness, lists all 58 recalls we discussed. To the best 

of our knowledge this list represents all recalls considered in 

NHTSA's analysis to date. If any work you do in the future 

results in additions to this list, please inform us and provide 

the relevant recall summaries as soon as possible. Of course 

we would appreciate any corrections to the information listed 

for each recall. 

Table 2 lists seven recalls that we agreed are to be 

dropped from further consideration. We concur that these are 

not related to onboard or volatility and should be dropped from 

the list presented in Table 1. - '• • * 

Table 3 lists seven recalls which we beli.eve are clearly 

unrelated to evaporative/onboard systems' "'"'• or similar 

components. In each case the technical rationale supporting 

our view is summarized for your consideration. Adding onboard 
P.3 

\ 

controls would not increase the frequency of these problems or 

the severity of the consequences. Using these criteria we see 

no relationship with onboard control systems and suggest that 

these recalls be eliminated from further consideration. 

Table 4 lists eight recalls which we believe are best 

classified as being related to fuel volatility. These eight 

recalls involve fuel expulsion problems due to use of high RVP 

fuel. These problems did not occur because of defects in the 

evaporative control systems as evidenced by the fact most of 

the vehicles in Recall No. 85V106 and some in 87V113 were not 

even equipped with evaporative control systems. (A Federal 

evaporative emission standard for heavy-duty gas vehicles did 

not exist prior to 1985). Pressure buildup problems with high 

RVP fuel result because the fuel tanks are tightly sealed from 

the atmosphere. However, EPA's evaporative standard doesn't 

require that tanks be tightly sealed, rather only that 

evaporative emissions be controlled, using components such as a 

canister. Rather, we believe fuel tanks are sealed tightly to 

ensure compliance with rollover tests required by NHTSA and 

OMCS. 

Furthermore, in a September 17, 1987 response to 

Congressman Dingell, NHTSA has already characterized Recall 

No's 79V028, 81V058, 82V076, and 87V113 as fuel expulsion 

problems resulting from high RVP gasoline. We feel these 

problems should not be characterized as evaporative control 

defects but rather should be considered as a potential benefit 

of EPA's proposals since our combined onboard/volatility 

package will substantially reduce these problems in the 

future. Adding onboard will certainly have no adverse affect 

on these types of recalls. 

Table 5 lists the remaining 36 recall campaigns which 

NHTSA selected as relevant to onboard controls because they 

involve fuel tank/evaporative system hardware. Screening out 

these recalls on this basis serves as a reasonable starting 

point for the onboard analysis since it narrows the scope to a 

workable number of recalls. However, we believe that more 

evaluation is required. The real issue involved here is the 

extent to which onboard controls would be likely to 

incrementally affect recalls of this nature and more 

specifically the degree to which onboard will positively or 

negatively affect the frequency or severity of such recalls. 

Table 5 breaks down the fuel tank/evaporative system 

recalls into the following four categories: external vent tube, 

fillpipe, vapor line, and evaporative system/components. While 

we agree that recalls similar in nature to those in Table 5 are 

likely to continue to occur in the future, we see no technical 

basis for why onboard controls would or must adversely affect 

the frequency or severity of these problems. For example, 

recalls involving external vent tube connections (77V063 and 
P.4 

85V154), material (78V016), or placement (85V014, 78V208, and 

85V132) should not increase in frequency or severity as a 

result of onboard controls since most onboard designs will not 

increase the number of vent tube connections or change vent 

tube placement or material. In fact some onboard designs (such 

as the Toyota system presented at the onboard/volatility 

hearings; see Enclosure 2) are likely to eliminate the external 

vent tube thereby reducing these types of problems in the 

future. We see many other areas where the onboard/volatility 

proposals could actually improve safety through possible 

reductions in future recalls. Some of these areas are 

discussed in Table 5. 

Also, we fail to see how onboard controls will have any 

adverse effect on fillpipe problems. These problems happen 

without onboard systems, and there is no technical reason why 

onboard controls will affect the frequency or severity of FMVSS 

301 fillpipe failures, or fillpipe installation, fabrication, 

and placement problems. 

In addition, for integrated onboard refueling/evaporative 

systems, nearly identical valving and vapor line routing will 

be used as compared to current evaporative systems. Because 

very little (if any) additional vapor line is needed for an 

integrated system, the incremental impact of onboard controls 

on vapor line problems such as blockage (Recall No's 78V181 and 

79V032), kinking (79V019), misrouting (79V045), or assembly 

damage (83V115) should be negligible. Similarly, onboard 

controls will not affect the design or use of vent valves in 

the evaporative system, so there should be no effect on recalls 

related to these valves (78V106, and 79V048). Furthermore, 

with regard to vacuum valve recalls (84V116), these types of 

components are used on present vehicles and will be used on 

future vehicles (with or without onboard controls) so no 

incremental effect should occur. 

We are not suggesting that onboard related recalls will 

never occur. Design, manufacturing, and assembly errors happen 

now and are likely to occur in the future. However, it is 

incorrect to predict the frequency of additional onboard 

problems to be equivalent to the frequency of past evaporative 

recalls since onboard is not a completely new system being 

added to the vehicle as were evaporative systems. Evaporative 

system recalls provide a good indicator of the types of 

problems that could occur with onboard controls, and form the 

basis of what is probably the best source of information to 

predict how onboard could impact recalls. However, it is 

critical that this information be analyzed carefully. It is 

imperative that an additional level of screening take place 

which considers the incremental impact of onboard controls 

(both positive and negative) on fuel/evaporative system 

recalls. Such an analysis needs to carefully evaluate the 
P.5 

Enclosure 1 

Summary and Analysis of EPA/NHTSA Recall Data Discussions 

November 5, 1987 
P.6 

Table 1 

Recall Analysis Baseline 

NHTSA 

Campaign 

Number 

76V001 

76V007 

76V037 

Model 

Year(s) 

1975 

1976 

1976 

Vehicle 

Type 

Pass. Veh. 

Pass. Veh. 

Pass. Veh. 

Number of 

Affected 

Vehicles 

631 

911 

2,400 

Description of Problem 

76V069 1975-76 Pass. Veh. 67,633 

76V126 1976 Pass. Veh. 9,137 

76V151 1976 Motor Home 150 

77V063 1977 Motor Home 242 

77V214 1978 Pass. Veh. 3,000 

78V016 1973-74 Pass. Veh. 20,661 

78V036 1977-78 Lt. Truck 20,000 

78V106 1977-78 Pass. Veh. 10,500 

78V145 1973-77 Med. Truck 2,500 

78V181 1978-79 Lt. Truck 23,000 

Fuel filler neck hose clamp may have been 

insufficiently tightened. 

Improper functioning of fuel pump valves creates 

possible overflow condition from canister. 

Misrouted vapor return line which runs from the 

fuel filter/vapor separator assembly back to the 

fuel tank. 

Defective rivets used in fabrication of fuel 

filler inlet assembly. 

Erroneously installed piping for the "check and 

cut valve". 

Defective installation of filler hose leads to 

stresses under certain road vibration which can 

rupture hose. 

External vapor line not connected to fill spout. 

Improper installation of vacuum line connecting 

carburetor and thermo valve. 

Cracking of fuel tank vent hose allowing fumes 

to enter trunk area. 

Blockage of tank vent system can lead to 

pressure buildup and force fuel or vapor leakage 

through cracks in tank. 

Defective fuel tank vent valve. 

Liquid gasoline may discharge from bottom of 

canister because evap system may lack adequate 

capacity under certain fuel expansion conditions. 

Obstructed evap line causes pressure build up in 

tank. 
P.7 

Table 1 (cont.) 

NHTSA 

Campaign 

Number 

78V200 

78V208 

78V249 

79V016 

79V019 

79V028 

79V032 

79V045 

79V048 

79V139 

79V212 

79V242 

80V019 

81E001 

81V004 

81V047 

81V055 

81V058 

Model 

Year(s) 

1978 

Vehicle 

T Y Pe 

Number of 

Affected 

Vehicles 

Pass. Veh. 5,700 

1977-78 Pass. Veh. 16,238 

1978 Lt. Truck 5,317 

1977-79 Pass. Veh. 83,000 

1976-78 Pass. Veh. 17,800 

1975-76 Pass. Veh. 57,000 

1977-79 Pass. Veh. 83,000 

1979 Pass. Veh. 3,700 

1975-76 Pass. Veh. 61,000 

1979 Motor Home 46 

1973-78 School Bus 2,950 

1975-79 Pass. Veh. 295,710 

1978-80 Pas. Veh. 9,429 

1981 Med. Truck 20,156 

1981 

1982 

1981 

Pass.Veh. 14,000 

Pass. Veh. 5,200 

Description of Problem 

Assembly error of pressure relief valve in fuel 

pump which may cause valve spring seat to 

dislodge and fuel supply to carburetor to 

decrease. 

Insufficient clearance between floor pan and 

vent tube can damage vent tube. 

Fuel filler pipe can disconnect in 301 collision. 

Throttle valve sticking. 

Possibility of kinked evaporative system hose. 

Under adverse conditions of high ambient 

temperatures, pressures and fuel volatility, 

fuel may surge when fuel filler cap is removed. 

Obstructed evap line causes pressure build up in 

tank. 

Misrouted vapor line to canister. 

Defective pressure control valve. 

Fuel filler hose can come in contact with 

exhaust pipe. 

Defective liquid/vapor separators. 

Defective PCV valve system. 

Cut fuel filler tube in 301 crash. 

Defective crankcase regulator valve on diesel 

trucks. 

Improper design/installation of fuel system such 

that it restricts fuel supply. 

Poor design of fuel filler & vent pipe leads to 

301 failure. 

Pass. Veh. 30,000 Defective carburetor fuel bowl vent solenoid. 

1980-81 Pass. Veh. 133,000 Overpressurization in tank may cause fuel 

Lt. Truck to spurt from tank. 
P.8 

Table 1 (cont.) 

NHTSA 

Campaign 

Number 

81V120 

82V021 

82V041 

Model Vehicle 

Year(s) Type 

1981 Motor Home 

Number of 

Affected 

Vehicles 

78 

1982 Pass. Veh. 

1982 Pass. Veh. 

519,329 

15,988 

82V076 

82V088 

82V109 

83V085 

83V115 

83V138 

84V038 

84V041 

84V116 

85V014 

1982 

1983 

1983 

1982 

1984 

1983 

1984 

1984 

1985 

1984 

Pass.Veh. 

Pass. Veh. 

Pass. Veh. 

Lt. Truck 

H. Truck 

Lt. Truck 

Van 

Motorcycle 

Motorcycle 

Pass. Veh. 

Motor Home 

24,455 

2,800 

1,849 

215 

1,548 

51 

295 

1,296 

2,385 

750 

85V106 1979-85 Motor Home 28,545 

85V132 1985 Pass. Veh. 11,000 

85V141 1984-85 Motor Home 285 

85V154 1982-85 Bus 1,520 

86V101 1986 . Pass. Veh. 27,000 

Description of Problem 

Filler hose made of incorrect material and 

deteriorates with gasoline contact. 

Fillpipe hose clamp can fracture. 

Inadequate seal between filler pipe housing 

assembly and fuel filler opening because of 

omitted screws during assembly. 

Pressure buildup in tank causes fuel spitback. 

Cut rubber filler pipe connecting hose in 301 

test. 

Fuel filler hose breaks during 301 crash. 

Hose type 3 piece pipe fails in 301 

test. 

Fuel or vapor line damaged due to assembly error. 

Diesel trucks do not comply with FMVSS 301 

because of valve line failure. 

L/V separator leak. 

L/V separator leak. 

Improper functioning of vacuum line valve. 

Auxiliary fuel tank is subject to overfill and 

pressure build up due to improper vent tube 

placement. 

Filler cap disengages suddenly when removed for 

refueling. May cause expulsion of vapor and 

gasoline. 

Bumper causes damage to air vent hose in 

accident. 

Electrical short circuit involving the fuel 

shut-off valve. 

Fuel pipe vapor line disconnects in accident. 

Pierced fuel filler pipe in rear collision. 
P.9 

Table 1 (cont.) 

NHTSA 

Campaign 

Number 

87V033 

87V051 

Model 

Year(s) 

Number of 

Vehicle Affected 

Type Vehicles Description of Problem 

1986-87 Motor Home 2,018 Threads in filler neck insert are not properly 

formed. 

1986 Lt. Truck 339 

87V052 

87V097 

1986-87 

1984-87 

Van 15,500 

Van 343 

(Ambulance) 

87V111 1984-87 Van 250 

(Ambulance) 

87V113 1983-87 Truck 16,000 

(Ambulance) 

87V144 1983-87 Vans 188,000 

87V155 1985-87 Motor Home 9,041 

87V157 1984-88 Pass. Veh. 25,000 

Fillneck not seated properly in tank - causes 

leaks. 

RVP problem - expulsion of gasoline. 

Holes in filler neck weld seam. 

Defective vapor valve grommet on fuel 

tank. (This component was installed as part of 

a preliminary attempt at correcting the fuel 

expulsion problem of Recall No. 87V113). 

RVP problem - expulsion of fuel. 

Expulsion of fuel due to use of high RVP fuel. 

Expulsion of fuel due to use of high RVP fuel. 

Overfilling of the fuel tank can increase fuel 

system pressure to the point where fuel vapors 

escape from the charcoal filter and cause an 

engine compartment fire. 

Total: 58 recalls involving 1,900,000 vehicles, 
P.10 

NHTSA 

Campaign 

Number 

76V007 

77V214 

79V016 

79V242 

81E001 

81V055 

85V141 

Table 2 

Recalls Agreed to be Dropped From Further Consideration 

Model 

Year(s) 

1976 

1978 

Number of 

Vehicle Affected 

Type Vehicles 

Pass. Veh. 

Pass. Veh. 

Description of Problem 

911 Improper functioning of fuel pump valves creates 

possible overflow condition from canister. 

3,000 Improper installation of vacuum line connecting 

carburetor and thermo valve. 

1977-79 Pass. Veh. 83,000 Throttle valve sticking. 

1975-79 Pass. Veh. 295,710 Defective PCV valve system. 

1981 Med. Truck 20,156 Defective crankcase regulator valve on diesel 

trucks. 

1981 Pass. Veh. 30,000 Defective carburetor fuel bowl vent solenoid. 

1984-85 Motor Home 285 Electrical short circuit involving the fuel 

shut-off valve. 
P.11 

Table 3 

Recalls Unrelated to Evaporative/Onboard Systems 

Recall No: 76V037 

Affected Vehicles: 2,400 '76 passenger vehicles 

Problem: Misrouted "fuel vapor return line" which runs from the fuel filter/vapor 

separator assembly back to the fuel tank. 

Comments: We believe, that this defect is more of a fuel system problem than an 

evaporative system problem. We agree that it could possibly be related to 

evaporative emissions from the carburetor, but as such, this problem would 

have no bearing on onboard controls since onboard would affect only the fuel 

tank portion of the evaporative system. NHTSA agreed that it did not appear 

to be related to the fuel tank evaporative control system. 

Recall No. 78V200 

Affected Vehicles: 5,700 '78 passenger vehicles 

Problem: Defective pressure relief valve in the fuel pump. 

Comments: This is not an evaporative system problem since the defective component is 

part' of the fuel pump. This problem would have occurred regardless of whether 

or not the vehicle was equipped with evaporative or onboard controls. 

Recall No. 81V004 

Affected Vehicles: 14,700 '81 passenger vehicles 

Problem: Restricted fuel supply system which may have resulted from an obstructed vent 

tube (presumably in the evap system) among many other possibilities. 

Comments: This particular recall was one of the most difficult to make a judgment on 

because no single defect was identified as causing the fuel supply to become 

restricted. The basic approach used to remedy this situation was to inspect 

the entire fuel system and replace anything which seemed necessary. It 

appears as though the tubing for the evaporative system was inspected along 

with all other fuel system tubing simply because it was part of the overall 

fuel system. It would seem that a fuel supply problem could only result from 

an obstructed fuel supply or return line, and that the evaporative tubing has 

no direct bearing on the problem. We believe this should be viewed as 

unrelated to onboard unless further information is provided which indicates 

otherwise. 
P.12 

Table 3 (cont.) 

Recall No. 83V138 

Affected Vehicles: 51 '83 diesel trucks 

Problem: Defective vent valve hose. 

Comments: This recall should not be characterized as related to evaporative control 

systems since the vehicles involved are not even equipped with evaporative 

control systems. NHTSA seemed to feel that this recall concerned a defective 

vent valve similar to the type which might be used on onboard controls. 

However, upon closer examination of this problem, it becomes .clear that this 

recall involved a hose (not a valve). Hoses designed for this purpose would 

not be used on today's gasoline vehicles or future onboard equipped vehicles. 

Therefore, we feel this problem has no bearing on onboard controls. 

Recall No.'s: 84V038 and 84V041 

Affected Vehicles: 1,591 '84 motorcycles 

Problem: Fuel leaks from liquid/vapor separator. 

Comments: We feel that this problem cannot be classified as an evaporative system recall 

since motorcycles do not use evaporative systems. We also believe that 

onboard will have no incremental impact on this problem since onboard will not 

be reguired on these vehicles. NHTSA believes these recalls should be 

considered relevant to onboard since onboard systems might utilize 

liquid/vapor separators. We question the similarity between the design of 

these liquid/vapor separators and those which might be used on some onboard 

systems. NHTSA.'s own recall file summary sheets categorize this problem as a 

fuel tank assembly problem, and we feel this characterization is most 

appropriate. 

Recall No. 87V111 

Affected Vehicles: 250 '84-87 Ambulances 

Problem: This recall involved a defective vapor valve grommet that was used in 

connection with an initial attempt at fixing the volatility problem of Recall 

No. 87V113. 

Comments: We maintain that a manufacturer's unsuccessful attempt at eliminating an RVP 

problem through a defective modification to the evaporative control system 

cannot be characterized as an evaporative system problem. We especially feel 

this is true since these vehicles were later recalled as part of Recall No. 

87V113. If the vehicles in this recall were to be counted separately from 

Recall No. 87V113, it would amount to the double counting of the vehicles in 

this recall for basically the same problem. 
P.13 

NHTSA 

Campaign 

Number 

79V028 

81V058 

82V076 

85V106 

87V052 

87V113 

87V144 

87V155 

Table 4 

Recalls Related To' Fuel Volatility 

Model 

Year(s) 

Number of 

Vehicle Affected 

Type Vehicles Description of Problem 

1975-76 Pass. Veh. 57,000 Under adverse conditions of high ambient 

temperatures, pressures and fuel volatility, 

fuel may surge when fuel filler cap is removed. 

1980-81 Pass. Veh. 133,000 Overpressurization in tank may cause fuel 

1982 

1979-85 

1986-87 

1983-87 

1983-87 

1985-87 

Lt. Truck 

Pass.Veh. 24,455 

Motor Home 28,545 

Van 

Truck 

(Ambulance) 

Vans 

15,500 

16,000 

to spurt from tank. 

Pressure buildup in tank causes fuel spitback. 

Filler cap disengages suddenly when removed for 

refueling. May cause expulsion of vapor and 

gasoline. 

RVP problem - expulsion of gasoline. 

RVP problem - expulsion of fuel. 

188,000 Expulsion of fuel due to use of high RVP fuel. 

Motor Home 9,041 Expulsion of fuel due to use of high RVP fuel. 
P.14 

Table 5 

Fuel Tank/Evaporative System Related Recalls 

EXTERNAL VENT TUBE RELATED RECALLS: 

The six recalls in this category involve problems that affect the external vent tube. 

These problems include poor placement (78V208, 85V014, and 85V132), defective material 

(78V016), and improper connections (77V063 and 85V154). Since onboard will not increase 

vent tube connections or change vent tube placement/material selection, recalls of this 

nature should neither increase in frequency or severity as a result of onboard. In fact, 

some onboard designs (such as the Toyota system presented at the onboard/volatility 

hearings; see Enclosure 2) are likely to eliminate the vent tube thereby reducing these 

types of problems in the future. 

NHTSA 

Campaign 

Number 

77V063 

78V016 

Model 

Year(s) 

1977 

1973-74 

Number of 

Vehicle Affected 

Type Vehicles 

Motor Home 242 

Pass. Veh. 20,661 

Description of Problem 

242 External vapor line not connected to fill spout. 

to enter trunk area. 

78V208 

85V014 

85V132 

1977-78 Pas. Veh. 16,238 

1984 Motor Home 750 

1985 Pass. Veh. 11,000 

Insufficient clearance between floor pan and 

vent tube can damage vent tube. 

Auxiliary fuel tank is subject to overfill and 

pressure build up due to improper vent tube 

placement. 

Bumper causes damage to air vent hose 

accident. 

in 

85V154 1982-85 Bus 1,520 Fuel pipe vapor line disconnects in accident. 
P.15 

Table 5 (cont.) 

FILLPIPE RELATED RECALLS: 

The 17 recalls in this category involve problems that affect the fuel tank fillpipe. 

These problems include FMVSS 301 failures (78V249, 80V019, 81V047, 82V109, 83V085, and 

86V101), defective material (81V120), - poor installation (76V151 and 87V051), fabrication 

defects (76V069, 87V033, and 87V097), poor placement (79V139), and connection problems 

(76V001, 82V021, and 82V041). We agree that all 17 of. these problems are fillpipe 

problems. However, we fail to see how onboard systems will have any adverse incremental 

impact on these types of problems. These problems happen without onboard, and there is 

no reason why onboard controls will affect the frequency or severity of fillpipe problems 

such as these in the future. 

We wish to stress that depending on the onboard system design, many of the FMVSS 301 

fillpipe failures could even be reduced in the future. NHTSA seems to agree that the 

impact of onboard on these problems is design dependent. However, NHTSA chooses to 

consider these recalls as relevant to onboard since preliminary onboard designs shown to 

them have contained rollover valves in the filler pipe location and therefore may be 

susceptible to crash damage. We agree that these valves could be susceptible to damage 

in a crash if located in the filler pipe area. However, we question whether or not this 

would incrementally worsen the risk of fuel leakage over that which now exists. We also 

want to point out that with enough leadtime, manufacturers have indicated they are less 

likely to locate these valves in the filler pipe area. 

Finally, NHTSA believes that fillpipe connection problems are relevant to onboard 

controls since these systems are likely to utilize components like hose clamps, and 

similar problems may occur. We agree that to the extent that onboard controls use more 

hose clamps, a greater opportunity may exist for similar problems to occur. However, it 

is equally valid to consider that depending on the onboard design selected by 

manufacturers, fewer hose clamps may be used, and therefore these problems may be less 

likely to occur in the future. Manufacturers have many hose connection options to choose 

from including adhesives and improved fitting techniques which may even be less likely to 

fail than currently used clamps or could mitigate against any real problems. 
P.16 

Table 5 (cont.) 

FILLPIPE RELATED RECALLS (cont.) 

NHTSA 

Campaign 

Number 

76V001 

76V069 

76V126 

76V151 

78V249 

79V139 

80V019 

81V047 

81V120 

82V021 

82V041 

82V088 

82V109 

83V085 

87V051 

Model Vehicle 

Year(s) Type 

1975 Pass. Veh. 

Number of 

Affected 

Vehicles 

631 

1975-76 Pass. Veh. 67,633 

1976 Pass. Veh. 9,137 

1976 Motor Home 150 

1978 Lt. Truck 5,317 

1979 Motor.Home 46 

1978-80 Pas. Veh. 9,429 

1982 Pass. Veh. 5,200 

1981 Motor Home 78 

1982 Pass. Veh. 519,329 

1982 Pass. Veh. 15,988 

1983 Pass. Veh. 2,800 

1983 Pass. Veh. 1,849 

1982 Lt. Truck 215 

H. Truck 

86V101 1986 Pass. Veh. 27,000 

87V033 1986-87 Motor Home 2,018 

1986 Lt. Truck 

Description of Problem 

Fuel .filler neck hose clamp may have been 

insufficiently tightened. 

Defective rivets used in fabrication of fuel 

filler inlet assembly. 

Erroneously installed piping for the "check and 

cut valve". 

Defective installation of filler hose leads to 

stresses under certain road vibration which can 

rupture hose. 

Fuel filler pipe can disconnect in 301 collision. 

Fuel filler hose can come in contact with 

exhaust pipe. 

Cut fuel filler tube in 301 crash. 

Poor design of fuel filler & vent pipe leads to 

301 failure. 

Filler hose made of incorrect material and 

deteriorates with gasoline contact. 

Fillpipe hose clamp can fracture. 

Inadequate seal between filler pipe housing 

assembly and fuel filler opening because of 

omitted screws during assembly. 

Cut rubber filler pipe connecting hose in 301 

test. 

Fuel filler hose breaks during 301 crash. 

Hose type 3 piece pipe fails in 301 

test. 

Pierced fuel filler pipe in rear collision. 

Threads in filler neck insert are not properly 

formed. 

339 Fillneck not seated properly in tank 

leaks. 

- causes 

87V097 1984-87 Van 343 

(Ambulance) 

Holes in filler neck weld seam. 
P.17 

Table 5 (cont.) 

VAPOR LINE RELATED RECALLS: 

The seven recalls in this category involve problems that affect the evaporative system 

vapor line. These problems include blockage (78V036, 78V181, and 79V032), erroneous 

installation (76V126), misrouting (79V045), kinking (79V019), and assembly damage 

(83V115). However, integrated onboard refueling/evaporative systems utilize nearly 

identical vapor line routing as compared to current evaporative systems. Since very 

little (if any) additional vapor line is needed for an integrated system, and we believe 

most onboard systems will be integrated, the incremental impact of onboard on these types 

of vapor line problems should be negligible. On a final note, we would also like to 

reiterate our concern about the potential "overlap" of Recall No.'s 78V181 and 79V032. 

We would appreciate it if you could provide clarification on this question. 

NHTSA 

Campaign 

Number 

76V126 

Number of 

Model Vehicle Affected 

Year(s) Type Vehicles 

1976 Pass. Veh. 9,137 

Description of Problem 

Erroneously installed piping for the "check and 

cut valve". 

78V036 1977-78 Lt. Truck 20,000 Blockage of tank vent system can lead to 

pressure buildup and force fuel or vapor leakage 

through cracks in tank. 

78V181 1978-79 Lt. Truck 23,000 Obstructed evap line causes pressure build up in 

tank. 

79V019 1976-78 Pass. .Veh. 17,800 Possibility of kinked evaporative system hose. 

79V032 1977-79 Pass. Veh. 83,000 Obstructed evap line causes pressure build up in 

tank. 

79V045 1979 Pass. Veh. 3,700 Misrouted vapor line to canister. 

83V115 1984 Lt. Truck 1,548 Fuel or vapor line damaged due to assembly error. 
P.18 

Table 5 (cont.) 

EVAPORATIVE SYSTEM/HARDWARE RELATED RECALLS: 

The six recalls in this category involve problems that affect the functioning of the 

evaporative control system. These problems include defective valves (78V106, 79V048, and 

84V116), insufficient capacity (78V145 and 87V157), and defective liquid vapor separators 

(79V212). We agree that these evaporative system problems could also happen on vehicles 

equipped with onboard refueling systems. However, since most onboard refueling systems 

will be integrated with the current evaporative system, we question the degree to which 

onboard will increase the likelihood or severity of these types of problems. For 

example, since onboard controls will not affect the design or use of vent valves in the 

evaporative system, there should be no net effect on recalls related to these valves. 

Furthermore, as long as the onboard system is integrated, problems like Recall No. 87V157 

would likely be eliminated because of the excess capacity of the integrated system. 

NHTSA 

Campaign 

Number 

78V106 

78V145 

79V048 

79V212 

84V116 

87V157 

Numbe r o f 

Model Vehicle Affected 

Year(s) Type Vehicles 

1977-78 Pass. Veh. 10,500 

1973-77 Med. Truck 2,500 

1975-76 Pass. Veh. 61,000 

1973-78 School Bus 2,950 

1985 Pass. Veh. 2,385 

1984-88 Pass. Veh. 25,000 

Description of Problem 

Defective fuel tank vent valve. 

Liquid gasoline may discharge from bottom of 

canister because evap system may lack adequate 

capacity under certain fuel expansion conditions. 

Defective pressure control valve. 

Defective liquid/vapor separators. 

Improper functioning of vacuum line valve. 

Overfilling of fuel tank can increase fuel 

system pressure to the point where fuel vapors 

escape from the charcoal filter and cause an 

engine compartment fire. 
P.19 

Enclosure 2 

Onboard Design Presented by Toyota 

at the Onboard/Volatility Hearings 
CURRENT EVAP. SYSTE ••* -

ENGINE PURGE CONTROL VALVE 

EVAP. 

CANISTER 

VALVE 

o 
J 

ONBOARD VAPOR RECOVERY SYSTEM 

PURGE CONTROL VALVE REFUELING CANISTER 6-8L 

ENGINE 

VAPOR VENT VALVE 

W/VAPOR LIQUID SEPARATER 

WATER SEPARATER 

LIQUID SEAL 

EVAP. CANISTER 1-1.8L VALVE OVERFILL LIMITER 

ho 
P.22 

incremental impact of adding onboard controls to 

evaporative-equipped vehicles *-nd to fully consider the fact 

that potential problems depend on the design of the onboard 

system. We hope to work with you more on this type of analysis. 

As you review the information presented in the enclosures, 

I would appreciate your comments on our technical and 

analytical rationale. Also, it would be especially helpful if 

you could respond to our comments on the individual recalls. 

Once again thanks for the time and effort spent 

coordinating with us on the recall analysis. Please contact me 

if you have any questions or comments on the enclosed summary 

and analysis of the discussions at our meeting. I would 

suggest that planning on getting together in the near future 

(possibly January 8 or 1.1 if that is agreeable to you) so that 

we can continue our dialogue on the recall analysis. Please 

call me at FTS:374-8408 to finalize a meeting time. 

Sincerely, 

Glenn W. Passavant, Senior Project Manager 

Standards Development and Support Branch 

Enclosures