P.1 

OAR Box 1830 

Prepped by Ollie Stewart 

Document Number: 

171) IV-C-138 

Docket Number: 

A-87-11 

Printed 11/13/2008 7:21:00 AM Sheet 171 of 232 
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

>4, ,.<? WASHINGTON. D.C. 20460 

JUN 2 ! 1988 

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THE ADMINISTRATOR 

Honorable John D. Dingell 

Chairman, Subcommittee on 

Oversight and Investigations 

Committee on Energy and Commerce 

U.S. House of Representatives 

Washington, DC 20515 

Dear Mr. Chairman: 

This is in response to your April 14, 1988 letter to EPA 

concerning a variety of issues related to EPA's onboard 

refueling control proposal. 

Your first questions and comments concerned EPA's 

simplified onboard hardware design and the briefings we 

recently gave to the Automobile Importers of America (AIA) and 

the Motor Vehicle Manufacturers Association (MVMA) on this 

hardware. We agree with you that these briefings serve a 

useful purpose. We also feel that refocusing the safety debate 

around specific design considerations has stimulated a 

constructive dialogue on the safety of onboard systems. 

Concerning the involvement of NHTSA in these briefings, a 

representative of NHTSA was present at the MVMA meeting and we 

have since provided NHTSA a videotape of the meeting for review 

by other personnel. Of course, you are aware that we gave a 

separate briefing on this matter to NHTSA staff. 

The onboard system designed by EPA is intended to address 

the safety and complexity issues that were raised in the public 

comments. Our primary objective, therefore, was to develop a 

system that was no more complex than current evaporative 

control systems and utilized as many production components as 

possible. We believe we have accomplished these objectives. 

Due to the simple nature of the changes made to the 

production f,uel system, we have no plans to install this system 

on a vehicle for testing at this time. The complete fuel 

system along with all onboard hardware was bench tested in the 

Sealed Housing for Evaporative Determination (SHED) as it would 

be installed on a vehicle. The results of this testing, 
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, ,>,• " 

• 

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which were included in the briefings, show that our system met 

the proposed refueling emission standard by a substantial 

margin. In addition, we have initiated some follow-up bench 

testing in direct response to suggestions raised at the 

briefings for MVMA, AIA, and NHTSA. This testing will evaluate 

the effects of various fuel RVPs and temperatures and different 

tank angles on system performance. 

In response to your concerns about the availability of 

this system for public comment, the primary purpose of our 

briefings was to solicit comments on our recent hardware design 

and testing from both automotive and safety interests. We have 

also had follow-up contacts with several manufacturers 

concerning our hardware, during which we have solicited 

feedback. However, to date we have received very little direct 

response. It is EPA's intent to include documentation on the 

development and testing of this system in the onboard safety 

analysis accompanying our reproposal. NHTSA will have the 

opportunity to comment on that documentation both during the 

pre-publication review process and during the comment period 

following publication of the reproposal. All other interested 

parties wishing to express their views on our system will have 

a formal opportunity to do so during the comment period on the 

reproposal. 

In reference to the issue of integrated versus 

non-integrated onboard systems, you expressed concern that EPA 

may be setting a design standard rather than a performance 

standard in order to force the use of integrated systems. This 

is not our intent. We clearly contemplate a performance 

standard. However, it should be recognized that our test 

procedure will influence designs. In recognition of this, we 

have attempted to explain in our briefings that there are many 

reasons why integrated systems have an advantage from a 

performance perspective. For example, integrated systems 

should be less costly and less complex than non-integrated 

systems. Also, integrated systems are desirable from an 

environmental perspective because they have the potential to 

control "excess" evaporative emissions which are produced 

outside the, test conditions of the official Federal Test 

Procedure (FTP), but which contribute to ozone formation under 

ambient conditions. We plan to structure our test procedure so 

as to insure the realization of this control, with or without 

integrated systems. We have consistently asked for feedback on 

how we might modify the test procedure to provide the proper 

control of these emissions and are presently planning a public 

workshop for early this summer to discuss a number of topics 

related to this issue. 
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1 <• * 

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In response to your question as to whether the integrated 

system/liquid seal approach is workable for the wide variety of 

vehicles and trucks covered by the onboard proposal, this is an 

issue we have specifically asked manufacturers to address. 

Based upon our experience, we feel the concept is applicable to 

most vehicles. Some, such as certain heavy-duty trucks, may 

present unique challenges. However, these trucks represent a 

very small portion of the fleet and we feel that using another 

fillneck seal approach on these vehicles would be possible, 

should that be necessary. 

In your letter you requested information pertaining to 

EPA's estimates of Stage II in-use efficiency and commented 

that Stage II effectiveness is greatly dependent on the level 

of enforcement. EPA's estimates of 62 percent control 

efficiency in areas of minimal enforcement and 86 percent in 

areas of annual enforcement were based on an analysis of 

enforcement issues (including misinstallation, improper 

maintenance and tampering data) from existing Stage II programs 

in Washington, DC and California, respectively. These control 

efficiencies, combined with the Federally mandated 50,000 

gallon/month exemption limit for independents and a 10,000 

gallon/month exemption limit for non-independents, yields an 

average Stage II VOC reduction efficiency range of 48 to 66 

percent depending upon the level of enforcement and subsequent 

maintenance. Because enforcement is such a large factor in 

Stage II efficiency, a range of minimal to annual enforcement 

was used in our Stage II analysis, yielding a range of costs 

and benefits. The full analysis and the sensitivity to changes 

in the exemption levels are presented in the draft Regulatory 

Impact Analyses for our refueling NPRM. 

You also asked whether EPA presumed that states, like New 

York and New Jersey, which are committed to Stage II in their 

SIP's, would not conduct effective enforcement programs; and 

whether they were, in fact, legally required to effectively 

enforce their programs. The Act requires that States commit 

themselves to implement and enforce the measures contained in 

their SIP.'s and provides for certain sanctions when they fail 

to do so. EPA, through its audit system, attempts to assess 

the effectiveness of State regulations and to obtain correction 

of deficiencies in either implementation or enforcement. 

However, no enforcement system is flawless and for our analysis 

we have presumed that the effectiveness of state programs would 

fall in the range represented by the existing District of 

Columbia and California programs and have used that range in 

reaching all our results. 
P.5 

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You also requested details concerning EPA's contract to 

perform a fuel systems comparative risk assessment. As 

discussed in our April 5, 1988 letter, the comparative risk 

assessment we are having performed is a failure modes and 

effects analysis (FMEA) of current fuel/evaporative systems and 

several possible onboard systems. This effort will identify 

and attempt to quantify the alleged "unquantifiable risk" 

associated with onboard systems and compare it to current risks 

in fuel/evaporative systems. This work was initiated following 

discussions with NHTSA and other safety organizations 

(including the National Transportation Safety Board (NTSB) and 

the Insurance Institute for Highway Safety (IIHS)) who felt 

that it would be useful in addressing remaining questions and 

uncertainties concerning onboard safety. The scope of work 

(SOW) for this task was submitted to NHTSA for review and was 

revised in response to their suggestions. The revised SOW was 

then sent to NTSB, IIHS, the Center for Auto Safety (CAS) and 

the Office of Motor Carrier Safety (OMCS) for comment. A copy 

of the SOW is enclosed for your information. This same 

information has previously been placed in the public docket. 

As far as the selection of a contractor is concerned, we 

consulted with NHTSA, IIHS, CAS and others to obtain 

suggestions for suitable contractors. The details have just 

recently been worked out, and after a thorough and careful 

evaluation of the availability, expertise and impartiality of 

several contractors, Battelle Columbus Division was selected. 

Work is now underway. 

In your letter you requested that we comment on two 

studies, one performed by ICF Technology for the American 

Petroleum Institute and one by CAS, entitled "Fuel Volatility 

and Public Safety." The ICF study submitted with the API 

comments in early February is a brief conceptual FMEA which 

compares the safety of a "typical" current evaporative system 

to that of two different onboard systems, one of which was 

included in our onboard proposal and the other being a new 

"passive" system suggested by API. In general, the ICF study 

provided some helpful information. However, it is limited in 

scope and merely conceptual in nature. The results of the 

analysis are a qualitative rather than a quantitative 

comparison of onboard and evaporative systems. Nevertheless, 

the ICF study is useful and we will carefully consider its 

findings in our safety reanalysis, along with all other safety 

related comments received. 

The CAS study is a review of NHTSA's recall and owner 

complaint files for both past and current fuel systems. The 

findings of the study show that evaporative systems have 
P.6 

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resulted in very few recalls (21 out of 4276 total recalls -

0.5%) or owner complaints (27 out of 20,000 fuel system 

complaints - 0.1%). This conclusion is generally consistent 

with both NHTSA1s and EPA's findings in this area. CAS went on 

to assess fuel volatility related safety problems in its 

study. We are presently reviewing this aspect of the study. 

We have also asked NHTSA for its detailed comments on the 

entire study and we will consider the CAS report and NHTSA's 

comments on it in our refueling and volatility control 

deliberations. 

Concerning Mobil's letter to NHTSA criticizing the General 

Motors' video tape of a crash test of an onboard equipped 

vehicle, there are a number of points we would like to clarify 

concerning this testing. First, the onboard system in question 

was in fact a Mobil design. However, the onboard control 

hardware used in this testing was fabricated and installed in 

the vehicle by Failure Analysis Associates (FaAA) who performed 

this work for General Motors. While we understand that the 

vehicle/system constructed and tested earlier by Mobil did in 

fact meet the proposed refueling emission standard and the 

current exhaust and evaporative emission standards, we do not 

know if the FaAA vehicle met these standards or if either the 

Mobil or FaAA vehicle met any applicable NHTSA standards. As 

far as we know, Mobil did not expend any effort toward 

designing this system to meet FMVSS 301. Second, it is 

important to note that the Mobil system was essentially a 

conceptual demonstration and was not intended to be a 

production-ready design. Thus, it contained a number of 

components which would not be normally used in a production 

system, such as a liquid/vapor separator made from a one pint 

can and vapor lines constructed of copper tubing. It was 

precisely these components which were damaged in the crash 

testing. Therefore, we feel that the results of this testing 

say little about onboard safety for true production systems. 

I trust that this information has responded to all of the 

concerns you raised in your April 14, 1988 letter. I look 

forward to the full resolution of remaining refueling control 

issues in the months ahead. 

Sincerely, 

Lee M. Thomas 

Enclosure 

cc: The Honorable Diane K. Steed, Administrator 

National Highway Traffic Safety Administration 

Public Docket A-87-11 
P.7 

jfi--, 

ONE HUNDREDTH CONGRESS 

JOHN 0. OINGELL, MICHIGAN. CHAIRMAN 

RON WYDEN, OREGON 

DENNIS E. ECKART. OHIO 

JIM SLATTERY. KANSAS 

GERRY SIKORSKI. MINNESOTA 

RICK BOUCHER. VIRGINIA 

JIM COOPER. TENNESSEE 

THOMAS A LUKEN. OHIO 

DOUG WALGREN, PENNSYLVANIA 

THOMAS J. BLILEY, JR.. VtRGINIA 

NORMAN F. LENT. NEW YORK 

DAN COATS. INDIANA 

MICHAEL 0. OXLEY. OHIO 

MICHAEL BILIRAKIS. FLORIOA 

DAN SCHAEFER. COLORADO 

MICHAEL F. BARRETT. JR. 

CHIEF COUNSEL/STAFF DIRECTOR 

^-^y-Y k 

tt.fr ftouse of Itepresentattoes 

Subcommittee on Ootrsigte anil limestigatfons 

of the 

Committee on £nergg and Commerce 

I, B C 20515 

* • - • (•. , 

" ROOM 2323 

RAYBURN HOUSE OFFICE BUILDING 

PHONE (202) 225-4441 

W. 

The Honorable 

Administrator 

Environmental 

401 M Street, 

Lee M. Thomas 

Protection Agency 

S.w. 

Washington, D.C. 20460 

The Honorable Diane K. Steed 

Administrator 

National Highway Traffic Safety Administration 

Department of Transportation 

400 Seventh Street, S.W. 

Washington, D.C. 20590 

Dear Mr. Thomas and Ms. Steed: 

Since writing to you on March 3 

proposal of the Environmental Protec 

onboard system, I understand that ou 

in a briefing by the EPA staff of th 

Safety Administration (NHTSA) of thi 

that briefing was helpful. Clearly, 

about this safety issue and are work 

commend them. 

1, 1988 concerning the staff (jlt4/u^'' 

tion Agency for a simplified S^^jX 

r staff participated this week A 

e National Highway Traffic 

s proposal. The observance of 

both staffs are concerned 

ing diligently on it. I 

I understand that this week EPA has also briefed the 

Automobile Import Association and the Motor Vehicle Manufacturers 

Association about the system. That is a step in the right 

direction. I believe, however, that the briefings were quite late. 

They should have been initiated long ago, rather than after 

inquiries by this Subcommittee. 

I would appreciate knowing whether staff of both agencies 

participated-Ln the briefing of AIA and MVMA. I would also like to 

know more precisely v/hat tests have been made by EPA of the system 

beyond laboratory tests. Has it been tested in any current year 

vehicles with various RVP fuels? Is it akin to a production-design 

system? Please explain. 

I understand that EPA does not plan to reopen the rulemaking 

to provide an opportunity for public comment on this system. There 

is some suggestion that EPA will include it in the re-proposal 

1 

I'I'M: I// 
P.8 

The•Honorable Lee M. Thomas 

T^e Honorable Diane K. Steed 

Page 2 

after NHTSA comments on the present rule. Since this system is not 

part of the present record, how will NHTSA comment? When will 

NHTSA comment? How will EPA obtain public comment, including that 

of the manufacturers? 

During the NHTSA-EPA briefing, EPA staff indicated that EPA 

intended this to be an integrated system. The staff also gave a 

strong indication that the EPA's view of the combined volatility 

and onboard proposed rules would, in fact, require all 

manufacturers to use an integrated system once the rules are 

finalized. That seems to suggest that EPA has or will write the 

rules in such a way as to essentially establish a design standard, 

rather than a performance standard. Please explain the legal basis 

under the Clean Air Act for this approach and please explain why 

such an approach is needed and appropriate. Is it workable for the 

wide variety of foreign and domestic lines of passenger cars, 

multi-purpose vehicles, light duty trucks, and heavy duty trucks? 

Enclosed is a very helpful EPA letter of April 5, 1988 which, 

among other things, shows that volatility controls yield a 

significant reduction in "HC emissions" both nationwide and in the 

several metropolitan nonattainment areas mentioned where stage II 

is also required. Clearly, these reductions far exceed the 

reductions expected from any kind of refueling controls. It also 

shows the importance of RVP controls from a public health 

standpoint, as well as a safety standpoint. 

At the same time, the letter provides some new and surprising 

numbers about the efficiency of stage II and onboard controls. I 

do not recall seeing them before. However, in an October 23, 1987 

letter to the Office of Technology Assessment on Sierra Research's 

draft report, the Deputy Executive Officer of the California Air 

Resources Board, Mr. Tom Cackette, provides a different perspective 

about this efficiency issue. He said: 

A second assumption is that Stage II systems are 92 

percent efficient. As noted, efficiency of these systems 

depends on the frequency of maintenance, and maintenance 

depends on the frequency of enforcement by the responsible 

agency. We have found that semi-annual inspections yield 92 

percent efficiency, and annual inspections result in 86 

percent efficiency. EPA believes a 62 percent efficiency 

results from no enforcement. Iji our view it is presumptuous 

to assume what degree of enforcement a state wTll choose. 

Certainly not all states will perform semi-annual 

inspections as is done in the South Air Basin, nor will all 

states ignore enforcement. Thus we recommend that the 

effectiveness of Stage II be evaluated for several different 

assumed efficiencies, rather than the point estimate 

provided by Sierra. Depending on which assumptions are 

chosen, either control measure can be determined to be more 

effective than the other. This should be illustrated to the 

reader. (Underlining supplied.) 
P.9 

The ,Honorable Lee M. Thomas 

,The Honorable Diane K. Steed 

. Pci'ge; 3 

How did EPA conclude an in-use efficiency of less than 50%? 

What is the basis for that number? Does EPA presume no enforcement 

in States, like New York and New Jersey, where the court has 

declared that Stage II is an enforceable commitment? Does the 

State have a SIP obligation to enforce? Does EPA not intend to 

audit compliance with the enforceable commitment? 

While I do not favor nationwide stage II, I also do not want 

to see EPA possibly misleading the Subcommittee or the public about 

this enforcement issue as part of this rulemaking. 

In that same letter, EPA indicates it is "preparing to 

conduct, through a contractor, a 'Fuels System Comparable Risk 

Assessment'." The letter indicates that this is being done at 

NHTSA's suggestion. I note, however, at this late date that the 

contractor has not been chosen and the details of the contract have 

not been resolved. Please explain to what extent NHTSA has been a 

part of the development of this contract, including the selection 

of a reliable contractor. Also, I request that you both explain 

the need for, and purpose of, this contract and assessment. 

In this regard, enclosed are two documents that appear 

relevant. One, dated February 8, 1988, was prepared by ICF 

Technology for the American Petroleum Institute and the other, 

dated March 24, 1988, entitled "Fuel Volatility and Public Safety" 

was prepared by the Center for Auto Safety. Please provide your 

views on both. What does each show regarding the safety of onboard 

controls and the importance of fuel volatility controls? 

The Center's report states (p. ii) that the "improved onboard 

systems under EPA's proposed evaporative control rule are only 

marginally more complex than present onboard systems. Any 

increased crash safety risk from onboard systems would be a 

marginal increase of an already minimal safety risk and could 

easily be handled by improved technology." My examination of the 

body of the report indicates that it is more devoted to the 

legitimate volatility concerns of the Center and provides little 

support for these onboard conclusions. Moreover, I understood that 

NHTSA's concerns were not limited solely to crash-related fires, 

but that NHTSA also is concerned about non-crash fires. Further, 

the Subcommittee has consistently said, along with others, that 

even a "marginal increase" in safety risk resulting from a Federal 

rule would be inconsistent with the very intent and purpose of the 

motor vehicle safety laws administered by NHTSA, as well as the 

purpose of the Clean Air Act. The Congressional objective as 

expressed in.these laws is to improve safety, not risk safety even 

slightly. I request your comments. 

Finally, I understand that on March 10, 1988, the Mobil 

Corporation which opposes stage II controls and supports onboard 

controls reportedly wrote a rather critical letter of a video tape 

of a crash test of a vehicle equipped (possibly by Mobil) with an 

onboard control system. The test apparently was performed by 

Failure Analysis Associates. I would appreciate NHTSA providing a 
P.10 

The, Ilonorible 

The Honorable 

P^ge 4 

Lee M. Thomas 

Diane K. Steed 

copy of that letter to NHTSA and that NHTSA and EPA advise the 

Subcommittee whether the vehicle in question met all applicable 

requirements under the proposed rules as well as all applicable 

emission and safety requirements. I am not sure why Mobil wrote to 

NHTSA about this matter, but I request a copy of NHTSA's reply. As 

I recall from our hearing last October, NHTSA did examine one or 

more oil industry vehicles (possibly Mobil's) and found that the 

added onboard system posed safety risks. Is that correct? Is that 

relevant to the Mobil comments? 

I request a reply from both agencies within 30 days after 

receipt of this letter. 

With best wishes. 

D. DINGELL 

Chairman 

Subcommittee on 

Oversight and Investigations 

Enclosures 

cc: The Honorable Thomas J. Bliley, Ranking Minority Member 

Subcommittee on Oversight and Investigations 

The Honorable Charles A. Bowsher, Comptroller General 

General Accounting Office 

Ms. Erica Jones, General Counsel 

National Highway Traffic Safety Administration 

The Honorable Lawrence Jensen, Acting General Counsel 

Environmental Protection Agency 

Mr. Thomas Hanna, President 

Motor Vehicle Manufacturers Association 

Mr. George C. Nield, President 

Automobile Importers of America 

Mr. Charles J. DiBona, Chief Executive Officer 

American .Petroleum Institute 

Mr. Clarence M. Ditlow, President 

Center for Auto Safety 

Mr. Brian O'Neill, President 

Insurance Institute for Highway Safety 

Mr. J. V. D'Ambrisi 

Mobil Research and Development Corporation 
P.11 

Pallura Madaa and Bffacta analysis 

of t±m Currant Bvsporatl*a and Propoaad Onboard 

AutoatotlT* lafuallng Vapor Bacowary Syat 

A ftaport 

Praparad for tha 

Aaarlcan Patrolau* Iattltuta 

Praparad by 

ICF Taehaolofy 

Fabtutry 8, 1988 
P.12 

Introduction 

ICF Technology parformad a Failure Nodaa and Effacta Analysis(FMEA) of 

tha daaign of a typical currant automotive fuel system evaporative vapor 

recovery system and proposed designs of automotive refueling vapor recovery 

systems designed to meet the proposed requirements of the EPA on refueling 

emissions. A FMEA is a component level safety analysis technique for 

systematic review and analysis of mechanical systems, such aa the vapor 

recovery systems. Tha primary purpose of tha FMEA is hazard identification. 

Tha FMEA was performed on the systems to determine the potential causes 

of failures which could lead to fires or to fire exposure of tha evaporative 

and refueling vapor recovery systems. A comparative examination of the 

propoaad designs to those of present-day evaporative emission control aysteas 

waa performed to determine the relative difference in the likelihood and 

potential severity of hazards of the different designs. The comparison made 

on the relative difference in hazerda waa baaed on engineering judgement and 

fire protection engineering. More quantified analyses with more extensive 

information is poaaible. 

Three designs of refueling vapor recovery systems ware analyzed, as shown 

in Figures 1-3 of Appendix B, including the J-eube(liquid seal) fillpipe 

design, tha flowing liquid seal fillpipe daaign, and the mechanical seal 

fillpipe design. Theaa systems, and the components that comprise them, are 

daacribad in more detail in the Systems Analysed section. 

Study Methodology 

Referring to the FMEA data form included in Appendix A: 

The Coapoom&t Mumber/Iana column liats the component under study and its 

associated number(referred to on the system drawings in appendix B). 

Tha Function .column lists the normal operating function of the system 

component. 

Tha. failure) Mode column preaenta a deviation from tha normal operating 

condition which could lead to a fire or other system malfunctions. 

The Probable Causa column lists potential causae for tha failure mode 

condition. 

The Potential Cooaaquancaa column lists generalised potential 

consequences aa a result of the failure mode. 

For the Probability of Failure Mode Causa and the Severity of 

Coneoquancoe columns, a rating of Same, Greater or Lass probability of 

occurrence or consequence of the failure, baaed on engineering judgement, is 
P.13 

given in order to determine the relative difference in the hazards of the 

various designs. Tha rating is based on a comparison of the refueling systems 

to tha baseline evaporative system illustrated in Figure 1. A rating of 

"Same", for example, Infers that the likelihood of the failure and/or the 

consequence of tha event are, in general, nearly equivalent. Soma failure 

modes for the refueling systems may have a greater or lesser likelihood of 

occurrence or consequence than tha evaporative aystam, and they are identified 

by a •Greater" or "Lass" designation respectively. 

Tha FMEA was limited to failure modes and consequences which could 

produce potential fire and safety problems, and doea not completely include 

normal operablllty problems. 

Since tha FKEA ia only Intended to identify and saalyse hazards, the 

absolute risk of each of the failure modes or of tha overall system is not 

calculated. As applied here, the FMEA was meant only to compare hazards 

between current and proposed systems, where hazards are found there are 

opportunities to lower these risks through engineering changes; a complete 

listing of suggested changes to reduce risk is not a part of this analysis. 

Srataaa Analysed 

Tha systems analyzed repreeent a typical current automobile evaporative 

emission control system, shown in Figure 1, and two integrated 

evaporativa/refueling emission control systems, shown in Figures 2 and 3. The 

typical evaporative eontrol system is taken as the baseline against which any 

changes in the probability of failure or the severity of consequences due to 

tha difference in design of the evaporative and refueling systems is assessed. 

Tha two lntegrsted evaporativa/refueling control systems represent 

concepts demonstrated on cars equipped and tested by Mobil Research and 

Development Corporation and by Exxon Research and Engineering Company(1,2). 

Tha major difference between the two systerna is in the approach taken to 

prevent rollover leakage. A nozzle*actuated rollover/vent valve is used on 

tha system in Figure 2 to keep the refueling vapor vent line elosed exeept 

during refualiag; while a float/rollover valve ia uaed on the system in Figure 

I Chat closes tha vapor line only in the event of tank overfill or rollover. 

That nacassary functional components of each systea are illustrated 

schematically in the figures. Other components could conceivably be used in 

such systaae, but tha components shown have been demonstrated to be sufficient 

for a practical and effective systea. Each of tha components is described 

briefly below. 

1. Praaaura;/*fii7''sfl til1<tf ffig * The pressure/vacuum relief cap is used 

on most current evaporative systems to relieve any exeeaslve 

pressure or vacuum condition in the tank caused by any failure of 

tha tank to equilibrate *lth atmospheric pressure through the 

canister. The cap would be used for the same purpose on integrated 
P.14 

evaporativa/refueling systems, as shown in Figure 2, but a p/v type 

cap would not be needed on the systea in Figure 3 since this systea 

maintains tha tank at atmospheric pressure through the 

float/rollover valve with nonrestricting orifices. 

•ual Fillolaa and Saal - On the current evaporative system, 

refueling vapors are vented from the open fillpipe. These vapors 

often are routed from the tank to tha top portion of the fillpipe 

through external tubing, as shown in Figure 1. On the refueling 

system, tank vapors are vented through the canister, aa described 

later, and a aeal is provided to prevent venting through the 

fillpipe. 

Three types of seals have been demonstrated by tha American 

Petroleum Institute (API). The J-tube seal (also demonstrated by 

EPA) has a bant section, as shown by 2A in Figure 2, which becomes 

filled with liquid to block escape of vapors. Liquid flowing in the 

standard fillpipe has also been shown to be a very effective seal 

whan an alternative vent path of low back pressure is provided. 

This seal is the "flowing liquid" eeal shown aa 2B ia Figure 3. 

Tha third type of aeal is a mechanical seal designated 2C in this 

analysis. One type of mechanical seal is a rubber ring aounted in 

tha fillpipe so that the nozzle spout must be inserted through it. 

The ring fl u tightly between the nozzle spout and tha fillpipe 

wall. The mechanical seal ia regarded as less practical than the 

j.tube or flowing liquid seals because it requires a pressure relief 

aachanlaa to protect against overpreasuring tha tank in the event of 

a nozzle shut*off failure. 

ZMtii.AaftMfd lallawr/Vent vklv - This valve shown aounted on 

the fillpipe in Figure 2 is designed to provide positive closure of 

the tank vapor vent line at all times except during refueling. It 

is designed so that.insertion of the nozzle opens tha vapor flow 

path froa tha tank to the canister without admitting tank vapor to 

the fillpipe. Tha valve is kept closed at all other times to 

prevent fuel leakage through the refueling vapor Un a in the event 

of a rollover accident. Tank venting during normal operations is 

aaistainad through the rollover device of the current evaporative 

system (component 4 in Figures 1 and 2) which is daacrlbed below. 

Thia tank vent is not satisfactory for refueling vapors because it 

is not designed for low back pressure at the vapor flow rate 

generated during refueling. 

The nozzle-actuated valve is illustrated as being mounted external 

to the fillpipe. It could also be designed to be enclosed within 

tha fillpipe to provide additional protection against collision 

damage. Then the vapor line between the tank and tha valve could 

alao be enclosed in the fillpipe, eliminating any hazard associated 

with this external line en the current evaporative control system. 
P.15 

4 • 

A further alternative to the nozzle-actuated valve on the fillpipe 

ia a valve located at the tank. Such a valve could be operated by a 

solenoid which could be actuated by cap removal or nozzle insertion. 

The nozzle-actuated valve has a vapor-liquid separator associated 

with It to protect the canister from carry-over of entrained liquid 

during refueling. This separator is simply an expansion volume at a 

high point in the vapor line to allow liquid droplets to settle and 

flow back to the tank. It can be mounted with the valve at the 

fillpipe, or at the tank. 

4. lollafwr Price • Current evaporative systems are equipped with 

devices to prevent fuel leakage froa the vapor line to the canister 

in the event of a rollover accident, aa required by federal motor 

vehicle safety standards. Examples of current rollover devices are 

cheek valves actuated by flotation or by gravity aa the vehicle is 

rolled over, anti-siphoning "bow tie" arrangements of the vapor line 

tubing, flow-reatrieting orifices, or combinations of these. These 

devices would be retained in conjunction with the nozzle actuated 

rollover/vent valve described above. 

The cheek valve approach can be adapted for use in refueling control 

systems, aa shown by tha float/rollover device in Figure 3. Vapor 

passages in the device would be enlarged to provide low back 

pressure at the vapor flow races encountered during refueling. The 

tank would be vented freely through this device both during 

refueling and in normal vehicle operation; consequently, tha tank 

would remain at atmospheric pressure at all times. Use of this 

tank-mounted rollover device would also eliminate the external vent 

line on the fillpipe shown in Figures 1 and 2. 

This rollover device alao would have sufficient expansion volume to 

serve as a vapor-liquid separator to prevent carry-over of entrained 

liquid. A suitable peeking material could be used to improve 

separation efficiency. The device would be mounted at the tank. 

5. Irf^^Tlg QgiFloa • Many current evaporative systems contain a flow 

limiting orifice in the vapor line from the tank to tha canister. 

This orifice helps to control leakage in a rollover accident and 

sonatinas takes the place of tha check valve described above. This 

orifice alao helps to reduce vapor loading of the canister by 

allowing soma prassurization of the tank. The limiting orifice can 

be retained in a refueling control systea as shown in Figure 2, but 

it Is not used in the system of Figure 3. Eliminating the orifice 

eliminates any prassurization of tha tank; consequently, it 

eliminates any vapor release through tha preasure/vacuum relief cap 

or any vapor release on removing the cap. 

^mmmmm^^mMl • Both current evaporative systems and refueling systems 

have a vapor line from the tank to tha canister (possibly by way of 

a noszle-ectuated valve on the fillpipe). On evaporative systems 

this line is typically one-quarter inch tubing, but on refueling 
P.16 

systems this line must be large enough to accommodate the vapor flow 

rata during refueling (about 10 gal/min.) with minimal back 

pressure. The back pressure, hence the required line size, is 

dependent on the line length. For front aounted canisters, fiveeighths or three-quarter inch tubing has been used, but for a rear 

mounted canister close to the tank, one-quarter inch tubing has 

performed well. 

- Canisters filled with activated carbon are used in 

current evaporative systems to capture fuel vapors vented from the 

tank. Similar canisters would be used on refueling control systems, 

but they will require approximately three times greater vapor 

adsorption capacity to handle expected refueling vapor loadings. 

Canisters are vented to the atmosphere; they exhale air that is free 

from fuel vapor during adsorption eycles end inhale air during 

desorption or purge cycles. 

Because of the capacity required for refueling vapora, refueling 

canisters have a larger capacity available for evaporative 

emissions, and are less likely to become saturated and to allow 

vapor to breakthrough under extreme operating conditions. This is 

because tha refueling vapor capacity is used for only a small 

portion of tha canister'a duty cycle. The refueling vapor la purged 

quickly during driving after refueling, thus that capacity becomes 

available for evaporative emissions until the next refueling. 

Refueling canisters can be placed in forward locations on a vehicle 

as current evaporative control canisters generally are. These are 

located under the hood or in front wheel-well areas. Refueling 

control canisters can alao be located in the rear of the vehicle 

near the tank. Rear-mounted canisters offer potential advantages in 

that shorter, smaller diameter vapor lines can be used to connect 

them to the tank. Furthermore, any accidental discharge of fuel 

vapor from the canister vent or from a disconnected or broken vapor 

line will occur well away from any potential ignition sources under 

the hood. 

• The purge line connects the caniatar to the Intake 

systea of tha engine and provldee a vacuum to draw purge air through 

tha canister. This is generally one-quarter inch tubing. This 

tubing la common to both evaporative and refueling control systems. 

9. a» f central velv . This valve controla the flow of deaorbed vapor 

from the canister to the engine. It opens end eloses as appropriate 

to ainialze disturbances to engine performance and exhaust 

emissions. The valve ia actuated by engine vacuum or by the 

engine's electronic control systea. The valve may alao contain a 

flow control orifice. 

10. Pure* T«-*"fi*rtfln fBiat - This is the point at which purged vapor enters 

the intake systea. It is usually a fitting on tha intake manifold (or 

carburetor) to which the purge line is attached. 
P.17 

Diacusaloos and Conclusions 

The FMEA shows that most of the components of the systems have the same 

probability of failure and the same severity of consequence in the integrated 

evaporative/refeuling systems as in the current evaporative system. Where 

differences occur between evaporative and refeullng systems, there are design 

options available to eliminate any incremental hazard. For example, refueling 

systema require a fillpipe vapor saal, but tha flowing liquid seal is an 

unmodified current fillpipe with no different probability or consequence of 

failure. 

The nozzle•actuated rollover/vent valve is unique to refueling systems, 

but it could be incorporated inside a fillpipe so that it presents no 

different hazard froa a current fillpipe, or it could be aounted on the tank 

and actuated remotely by nozzle insertion. Both of these alternatives would 

alao eliminate the vapor line that runs outside the fillpipe on many current 

systems. 

The tank-mounted float/rollover device in Figure 3 would not only 

eliminate the vapor line at the fillpipe, but It would alao eliminate tank 

praasurizatlon by eliminating the limiting orifice found in many current 

evaporative systems. This device would also eliminate any hazard associated 

with the current pressure/vacuum relief cap. 

Any hazard associated with saturation or breakthrough of the carbon 

canister is similar for refueling and current evaporative systems. The 

quantity of vapor breaking through is potentially greater with the larger 

refueling canister, but the frequency of breakthrough is likely to be less 

because of the canister's larger capacity. In any caae, any potential fire 

hazard aasociatad with breekthrough can be reduced by locating the canlstsr in 

the rear of the vehicle away froa potential underhood ignition sources. 

Likewise, any potential fire hazard associated with a broken or disconnected 

vapor line between the tank and canister will be minimized with a rear mounted 

canister. 

In conclusion, the FMEA shows that there are design alternatives 

available to mitigate any incremental hazard projected for specific refueling 

control systems in- comparison with current evaporative systems and even to 

reduce potential hazards in the current evaporative systea. 
P.18 

la* 

7 -

(1) Koahl, ?. J., sc al, "Vehicle Onboard Control of Refueling Eaissions -

System Demonstration on a 1985 Vehicle", SAE Technical Paper Series 

#861551, October, 1986. 

(2) "Onboard Control of Refueling Emissions", a Report to the API, Exxon 

Research and Engineering Company, Linden, New Jersey, January, 1986. 

(3) Stateaeat of Diane X. Steed, Adminlatrator. National Highway Traffic 

Safety Administration Before the Subcommittee on Oversight and 

Investigations, House Committee on Energy and Commerce, October 2, 1987. 

(4) Statement of Brian O'Neill, Insurance Institute for Highway Safety, 

Before the House Subcommittee on Health and Environment Hearing on tha 

Glean Air Act Amendments of 1987, September 28, 1987. 

(5) "Safety Implications of Onboard Refueling Vapor Recovery Syatems", June, 

1987, Office of Mobile Sources, Office of Air and Radiation, U.S. 

Environmental Protection Agency. 
P.19 

APPENDIX A 

FAILURE MODES AMD EFFECT* AHA1TSIS 
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V

i0Sr<fc 

A 

1 SlSfe § UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

% .<? WASHINGTON. D.C. 20460 

APR 5 see 

THE ADMINISTRATOR 

Honorable John D. Dingell 

Chairman 

Subcommittee on Oversight and Investigations 

Committee on Energy and Commerce 

U.S. House of Representatives 

Washington, DC 20515 

Dear Mr. Chairman: 

This is in response to your January 20, 1988 letter 

concerning the onboard vapor recovery and gasoline volatility 

control proposed rulemakings. In your letter you asked what 

the expected reductions would be from onboard controls by the 

year 1995 and 2000 in each of the ozone nonattainment areas 

where Stage II controls have been or are being installed, or 

where a state has committed in its State Implementation Plan 

(SIP) to require such controls, assuming, at a minimum, a 

different leadtime than now proposed by EPA. You also 

requested the expected nationwide and Stage II nonattainment 

area benefits from volatility controls. In addition, you 

expressed some concerns regarding contract work EPA is planning 

in regard to the safety of onboard systems. 

As a point of reference, the areas which currently have 

Stage II installed or which are committed to it are California, 

New York City Metropolitan area (New York counties only), New 

Jersey, St. Louis (Missouri counties only) and Washington DC. 

EPA has excluded California in its emission projections, so 

only the four remaining areas will be discussed in this letter. 

With regard to your first question, EPA has not completed 

its investigation of the effects that varied amounts of 

leadtime - .f.or onboard controls will have on emissions 

inventories. The amount of the inventory reduction in 1995 and 

2000 will depend on both the year in which a final rule is 

promulgated and the amount of leadtime given to manufacturers. 

We intend to perform such detailed studies as we continue our 

analyses of the leadtime issue. These studies will be able to 

incorporate the results of our leadtime analysis plus other 

analyses of issues relating to the timing and efficiency of 

controls. 
P.25 

- 2 -

Based on our current analysis we are able to estimate the 

incremental refueling emissions which would be captured by 

onboard systems in areas with Stage II controls (due to the 

higher in-use efficiency of onboard systems). EPA estimates 

the overall in-use efficiency of onboard systems to be 83 

percent versus an overall in-use efficiency of 48 to 66 percent 

for Stage II equipment (depending upon the level of 

enforcement). Therefore, onboard technology would control an 

additional 17 to 35 percent of uncontrolled refueling emissions 

in areas where Stage II is being implemented once onboard is 

fully implemented and incorporated in the vehicle fleet. 

Regarding . your second question, Table 1 contains the 

effects of the proposed volatility controls on HC emission 

inventories for Stage II nonattainment areas as well as the 

entire nation. The inventories presented assume onboard 

controls are implemented beginning in 1990 and Stage II is in 

place only in Washington, DC. (If neither onboard nor Stage II 

controls were assumed, the inventories would be slightly higher 

but the percent reductions due to volatility controls would be 

essentially the same.) Volatility controls yield an 8.1 to 8.6 

percent reduction in the total nationwide HC emissions 

inventory, compared to an 8.1 to 9.7 percent reduction in each 

of the Stage II areas. It should be noted that for the four 

Stage II areas presented, EPA's areas do not precisely match 

the areas where Stage II is being implemented. For example, 

EPA's analysis for St. Louis includes several surrounding 

counties in Illinois where Stage II is not required. This 

difference should not affect the percentage reduction 

calculations, however." 

Finally, you had several concerns regarding an EPA task 

order to conduct onboard safety related work through a 

contractor. EPA is preparing to conduct, through a contractor, 

a "Fuel System Comparative Risk Assessment". 

In brief, the contract will be a comparative risk 

assessment of vehicle fuel/vapor control systems. It is 

intended to assess and compare the potential risks from the 

addition of onboard controls to those risks which may have 

arisen as a result of other recent changes in fuel systems. 

These represent some of the areas that the National Highway 

Traffic -Safety Administration has suggested would be 

appropriate for EPA to investigate in addressing the concerns 

about onboard safety. A failure modes and effects analysis 

will be conducted for nine slightly different fuel systems 

configurations, including three fuel systems with onboard 

control approaches incorporated. Each fuel system will be 

assessed in terms of three phases with potential for safety 

problems (design, manufacture, and service) and under different 

accident scenarios. 
P.26 

- 3 -

At this time we have not decided who will be performing 

this work. As soon as the contractual details have been 

resolved, we will provide you with further information. 

Thank you for your continued interest in the onboard vapor 

recovery and gasoline volatility control proposed rulemakings. 

P Sincerely, 

C^\A _ .IJ^AVH^^-^ 

Lee M. Thomas 
2000 

Table 1 

Nationwide and Stage II Area HC Emissions Inventories^-

(1000 tons/year) 

1995 

Area 

Nationwide 

New York City Met 

New Jersey-* 

Vineland-Mi11vi 

Atlantic City 

St. Louis6 

Washington DC^ 

ro4 

lie 

No 

Control 

of RVP 

19504 

720.0 

12.2 

21.6 

207.2 

138.0 

EPA Gasoline 

Volatility 

Proposal^ 

17825 

652.7 

11.1 

19.5 

188.1 

126.4 

Reduction Due 

to EBA 

Propos 

1679 

67.3 

l.l 

2.1 

19.1 

11.6 

sal3 

(8.6) 

(9.3) 

(9.0) 

(9.7) 

(9.2) 

(8.4) 

Nationwide 

New York City Metro4 

New Jersey^ 

Vineland-Mi11vilie 

Atlantic City 

St. Louis6 

Washington DC'7 

19947 

732.2 

12.1 

21.8 

213.1 

137.8 

18324 

666.8 

11.0 

19.8 

194.7 

126.7 

1623 (8.1) 

65.4 (8.9) 

1.1 (9.1) 

2.0 (9.2) 

18.4 (8.6) 

11.1 (8.1) 

1. The nationwide and city-specific inventories listed are taken from 

the data used to support the gasoline volatility control proposed 

rulemaking. 

2. EPA proposal limits summer gasoline volatility to 10.5 psi in 1989 

and 9.0 psi in 1992 in ASTM Class C areas and proportional 

reductions from ASTM limits in other ASTM class areas. 

3. Numbers in parentheses are percent reduction in HC inventory from 

the "No Control of RVP" case. 

4. EPA's analysis of the New York City Metropolitan area contains parts 

of Connecticut and New Jersey. 

5. The remaining parts of New Jersey are included in the New York City 

Metro area. 

6. EPA's analysis of St. Louis contains several counties in Illinois. 

7. EPA's analysis of Washington DC contains parts of Virginia and 

Maryland. 
P.28 

CENTER FOR AUTO SAFETY STUDY & COMMENTS ON 

ENVIRONMENTAL PROTECTION AGENCY RULEMAKINGS ON 

GASOLINE AND ALCOHOL BLEND VOLATILITY 

AND 

REFUELING EMISSIONS FROM GASOLINE VEHICLES 

Washington DC 

March 24, 1988 
TABLE OF CONTENTS 

P.29 

I. INTRODUCTION 1 

A. SAFETY .' 1 

B. ENVIROMENTAL IMPACT OF FUEL SPURTING 

AND OVERPRESSURIZATION 2 

C. ALCOHOL FUELS 2 

II. SAFETY . 4 

A. SAFETY RECALLS 6 

C. SAFETY COMPLAINTS 12 

1. Fires 12 

2. Fuel Volatility, Stalling and Degradation .. . 15 

a. Fuel Spurting 21 

b. Fuel Overpressurization 23 

c. Vapor Lock and Fuel Foaming 25 

d. Degradation of Fuel System Components .. . 26 

III. ENVIRONMENTAL IMPACT OF FUEL SPURTING 

AND OVERPRESSURIZATION 28 

IV. ALCOHOL FUELS 30 

A. SAFETY HAZARDS 31 

B. STRINGENT ENFORCEMENT OF VOLATILITY STANDARDS .. . 34 

V. NO FEDERAL PRE-EMPTION OF STATE VOLATILITY STANDARDS . 37 

APPENDIX A — Vehicle Recall Analysis 

APPENDIX B ~ NHTSA Defect Complaint Fault Codes 

APPENDIX C — NHTSA Component System Classifications 

APPENDIX D — NHTSA Evaporative Emission System Complaints 

APPENDIX E — CAS Analysis of Fuel Safety Complaints 

APPENDIX F — Fire Incidence Versus RVP Standard 

APPENDIX G — Guide to Chrysler Vapor Lock Kits 

APPENDIX H — General Motors Vapor Lock & Volatility Memoranda 
P.30 

SUMMARY AND FINDINGS 

When the Environmental Protection Agency (EPA) proposed 

gasoline volatility standards and vehicle onboard control systems 

to reduce evaporative hydrocarbon emissions during refueling, 

major concern was raised about whether the proposed evaporative 

control -systems would cause more vehicle fires and explosions. 

To help resolve this issue, the Center for Auto Safety undertook 

a six month study of all 4,276 safety recalls of 130.8 million 

vehicle since 1966 and all 146,000 vehicle safety reports since 

1977 in the National Highway Traffic Safety Administration's 

computer data base to determine the relation between vehicle 

fires, gasoline volatility and evaporative emission control 

systems which have been on vehicles since 1971. The Center's 

study found: 

Recalls 

* Evaporative systems generated only two post-crash fire 

recalls of 11,911 out of 130,800,000 vehicles (0.01%) in 18 

years. Neither of these recalls was linked with any fires, 

deaths or injuries. 

* High gasoline volatility and excess fuel system pressure 

caused 12 recalls of 564,071 vehicles that were linked to 71 

fires, 25 injuries and 2 deaths. These recalls occurred since 

1979 as gasoline volatility levels increased. 

Safety Complaints 

* Of the 146,000 safety complaints since 1977, 20,000 are on 

fuel systems but only 27 (0.1%) of the fuel system complaints are 

on evaporative emission control systems. 

* There were 1,501 fires in the 20,000 fuel system complaints, 

but only 6 involved an evaporative system. 

* The 20,000 fuel system complaints included 1,551 reports of 

fuel spurting, fuel pressurization, vapor lock and fuel foaming 

associated with higher gasoline volatility. The vast majority 

(84%) occurred during the summer. 

* For 1978-80, NHTSA received less than 10 gasoline volatility 

related complaints per year; thereafter, complaints rose steadily 

as volatility rose with over 100 complaints/year for 1983 on. 

* States with lower ASTM volatility standards had fewer fuel 

safety complaints. The 2 6 states with an ASTM summer volatility 

standard of no higher than 10.0 psi RVP for at least one month 

had 48% of the total vehicle fleet but only 34% of the fuel 

safety reports. The other 24 states with ASTM levels higher than 

10.0 psi during the summer were 80% more likely to have fuel 

safety complaints. 
P.31 

* Of the 1,501 fires in the data base, 68 directly related to 

fuel safety problems. Only 2 of the 68 fires occurred when the 

ASTM standard was 9.0 psi RVP. 

* Gasoline leaks from fuel spurting and fuel overpressurrzatioiv average over 2 gallons per incident and increase 

total gasoline evaporative emissions by 10-20%. 

* Fuel safety reports and fires were 50% more likely to occur 

in states with high gasohol (10% ethanol-90% gasoline blends) 

sales unless the state required gasohol to meet a volatility 

standards no higher than 10.5 psi RVP. 

* High volatility gasohol states with just 32% of the national 

vehicle fleet have 50% of the fuel safety complaints and 56% of 

the fuel safety fires. 

CONCLUSIONS AND RECOMMENDATIONS 

The Environmental Protection Agency should move ahead as 

soon as possible with both gasoline volatility and onboard 

systems to control refueling emissions. The potential crash fire 

risk from onboard systems is small. The improved onboard systems 

under EPA's proposed evaporative control rule are only marginally 

more complex than present onboard systems. Any increased crash 

safety risk from onboard systems would be a marginal increase of 

an already minimal safety risk and could easily be handled by 

improved technology. 

Unlike onboard control systems which present minimal risk, 

increasing gasoline volatility poses a clear and present danger 

of vehicle fires. As gasoline volatility has increased, the 

incidence of gasoline spurting and leaking from overpressurized 

tanks has increased dramatically as has vehicle fires. States 

such as Colorado with high sales of alcohol blends with even 

higher volatility levels than gasoline are even more likely to 

have fuel safety incidents and fires. Only those states which 

have enforced more stringent volatility standards for both 

gasoline and alcohol blends have avoided the worst of this fire 

hazard. The Agency should move ahead to impose a national 9.0 

psi RVP standard with no exemption for alcohol blends. 

ii 
P.32 

I. INTRODUCTION 

The Center for Auto Safety is a consumer group concerned with 

auto safety, fuel quality and auto emissions. These comments focus 

on the safety issues involved in both proceedings, the environmental 

impact of fuel spurting and overpressurization, and the inadequacy 

of EPA's proposed regulation of alcohol fuels. 

A. SAFETY 

While a great deal of attention has focused on the safety of 

requiring onboard controls to control refueling emissions, the far 

greater and more real safety risk is the high volatility of present 

fuels, particularly ethanol blends. Evaporative emission controls 

including charcoal canisters and vent lines have been on cars since 

1971 so that there is a large data base of both recalls and reports 

of fires to assess their impact. As shown below, evaporative 

emission controls have not resulted in any significant incidence in 

vehicle fires or recalls. In sharp contrast, excess fuel volatility 

has led to many documented burn deaths and injuries as well as 

recalls. 

As fuel volatility and ethanol blend use have increased in 

recent years, the reported incidence of fuel spurting from overpressurized gas tanks and stalling due to vapor lock have increased 

significantly. Only in those few states which have more stringent 

volatility standards has the incidence of such fuel volatility 

problems been diminished. By increasing the capacity of the onboard system to capture refueling losses as well as imposing tighter 

fuel volatility controls, EPA will find that there is a major safety 
P.33 

benefit as well as an environmental benefit from going ahead with 

both onboard and fuel volatility controls. 

B. ENVIROMENTAL IMPACT OF FUEL SPURTING AND OVERPRESSURIZATION 

The Centers analysis of all 20,000 fuel systems complaints 

reported to the. National Highway Traffic Safety Administration 

(NHTSA) since 1977 shows major adverse impacts on hydrocarbon (HC) 

emissions that EPA has not considered to date in this rulemaking— 

(1) the massive release of hydrocarbons from widely occuring fuel 

spurting and pressurized leak incidents, and (2) tampering with fuel 

system components to compensate for adverse performance problems 

associated with high fuel volatility and fuel system pressure. The 

average release of gasoline in a fuel spurting incident or leak from 

an overpressurized fuel tank is over 5100 grams or the equivalent of 

the evaporative emissions from 300 vehicles at present 1988 fleet 

levels or more than 600 vehicles when the proposed volatility and 

evaporative emission controls take effect. In an effort to improve 

performance of vehicles with excessive fuel pressure, many consumers 

are drilling out, removing or loosening the gas cap, or even 

disabling the charcoal canister; all of which lead to increased HC 

emissions. 

C. ALCOHOL FUELS 

With their higher volatility, alcohol blends have worse safety 

and emission problems than straight gasoline. Analysis of NHTSA 

fuel system complaints show that states with more than 7% gasohol 

penetration (the national average) have 50% more fuel safety 

complaints than states with less than 7% gasohol sales. Indeed, 
P.34 

these states have just 37% of the vehicle population but 52% of the 

fuel safety reports. Recalls, NHTSA investigations, and 

manufacturer bulletins and internal documents all show alcohol fuels 

as one of the primary causes of vapor lock, fuel spurting and 

overpressurization, and fuel system component degradation. Of all 

the states with high gasohol sales, those few which enforce the same 

summer RVP standards no higher than 10.5 psi for both gasoline and 

gasohol have reduced fuel safety complaints. The remaining gasohol 

states with just 32% of the vehicle population have 50% of the fuel 

safety complaints and 56% of the vehicle fuel volatility fires. 

Higher volatility standards for alcohol fuels are worsened by 

weakened enforcement levels. Without stringent enforcement, alcohol 

blends are likely to exceed any tolerance, 0.5 to 1.0 psi, set by 

EPA. The proposed EPA paper certification where a gasohol blender 

can demonstrate compliance by showing a document indicating the base 

gasoline met RVP standards is fraught with problems. EPA's own 

experience with the lead trading and credits program clearly 

demonstrates that widespread violation of regulations would occur. 

The Federal Highway Administration (FHWA) has estimated that up to a 

billion dollars per year in highway taxes are evaded through a 

"daisy chain" of paper transactions within the gasoline industry. 

The available evidence does not demonstrate a volatility 

exemption is necessary for the marketing of ethanol fuel. At least 

seven states have regulations requiring ethanol blends to meet the 

same volatility standards as gasoline. Yet significant quantities 

of gasohol are sold in those states indicating sufficient quantities 
P.35 

of sub-RVP gasoline are available for blending with ethanol. Given 

the increased VOC emissions from the use of alcohol blends as well 

as the demonstrated safety hazards of higher volatility fuels, EPA 

should require 'all alcohol blends to meet the same volatility 

standards as other gasolines. This is particularly true of methanol 

blends which are now required to meet ASTM volatility limits and 

which have been successfully marketed in the past while meeting 

these limits. 

Whatever action EPA takes in this rulemaking, the agency should 

make it clear states are free to mandate stricter gasoline 

volatility standards to protect vehicle driveability and safety. 

The purpose behind ASTM volatility standards and state adoption 

thereof is not emission control but public safety and consumer 

protection. If EPA were to exempt alcohol blends from volatility 

standards, clearly a hot weather or high altitude state could set 

volatility standards for alcohol blends to prevent vapor lock and 

fuel spurting. Whatever else safety means in this proceeding, it 

means states are free to protect consumers from vehicle safety and 

driveability problems. 

II. SAFETY 

Throughout EPA's rulemaking process, much attention has been 

focused on the safety of requiring onboard systems to control 

refueling emissions. At the October 27, 1987 public hearing on this 

notice, the Insurance Institute for Highway Safety stated "about 

1,200 fatal passenger vehicle crashes — plus about 16,000 nonfatal 

ones — already involve fire every year. More than 1,500 occupants 
P.36 

sustain at least one burn injury each year." The National Highway 

Traffic Safety Administration (NHTSA) has told EPA that "there will 

be some unquantifiable, increased risks of crash and non-crash fire 

associated with onboard controls." Despite these concerns, little 

effort has been made thus far to quantify the increased risk that 

has been supposed and to separate out the fires from evaporative 

emission systems from other fires which compromise the vast majority 

of vehicle fires. 

The Center for Auto Safety (CAS) would be the first to agree 

that any significant increase in the risk of fire and burn injuries 

caused by onboard controls is unjustified. Since 1970, CAS has. been 

an outspoken advocate of safer vehicles and critic of designs that 

compromise safety. Over the years, CAS has urged adoption of tough 

federal safety standards to reduce the risk of burn related injuries 

and submitted comments on NHTSA rulemaking actions establishing 

important standards such as Federal Motor Vehicle safety Standard 

(FMVSS) 3 01, concerning post-crash fuel system integrity. CAS has 

also played a leading role in securing the recall of vehicles with 

defects which cause fires such as the 1971-76 Ford Pinto with 

exploding gas tanks, the 1984 Pontiac Fiero with engine compartment 

fires, and the 1983-86 Ford ambulances and vans that spurt fuel. 

FMVSS 301 has reduced the risk of post-crash fires in vehicles 

made since its September 1, 1976, effective date and will continue 

to assure an adequate level of safety after onboard controls are 

required. In a March 27, 1986, letter to Congressman John Dingell, 

NHTSA Administrator Diane Steed pointed out that FMVSS 301 is: 
P.37 

a performance standard, and assuming current crash 

test compliance can be met by the particular onboard 

system a manufacturer may choose, may simply mean that 

the costs and benefits of the vapor controls can be 

assumed at a constant level of crash safety. 

Apart from ;the overall level of safety provided by FMVSS 301, a 

June 11, 1987, letter from NHTSA to EPA noted that "the National 

Traffic and Motor Vehicle Safety Act requires manufacturers to be 

responsible for the recall and remedy of any of their vehicles found 

to contain any safety-related defect, including any defect not 

related to aspects of performance covered by our safety standards." 

This recall authority enables NHTSA to obtain a level of fire safety 

above that required by FMVSS 301. 

In determining whether the proposed onboard controls pose any 

significant safety problem, CAS used the two largest available data 

bases to quantify the risk associated with the potential fuel system 

hazards identified in this rulemaking. These data bases are (1) all 

safety recalls since 1966 and (2) all safety complaints since 1977. 

Each of these data bases is quite large so that valid conclusions 

can be drawn therefrom. Review of these data bases is an effective 

method of quantifying the risk associated with onboard controls and 

fuel volatility since the proposed emission controls are quite 

similar to those used on vehicles since 1971. 

A. SAFETY RECALLS 

Since 1966 thru February 1988, motor vehicle manufacturers have 

recalled 130.8 million vehicles in 4,276 recalls. CAS analyzed each 

one of these recalls and identified 291 recalls manufacturers have 

conducted for gasoline fuel system problems on vehicles subject to 
P.38 

* 

EPA' s proposed onboard rule. (A comprehensive list and 

contained in Appendix A.) In reviewing the condition 

recall, CAS identified 10 distinct 

problems that led to the 291 recalls 

numb 

categories of 

for fuel system 

j 

i 

1 

analysis is 

prompting each 

sa: fety-related 

defects. The 

er and percent of total recalls associated with each category is 

shown in Table 1 below and in the graphs on the following page. 

1. 

2. 

3. 

4. 

5. 

6. 

7. 

8. 

9. 

10. 

TABLE 1 — NHTSA FUEL 

CATEGORY 

Fuel tank ruptures; 

all FMVSS 301 failures 

Fuel leaks from chemically 

caused component degradation 

Fuel leaks from mechanically 

caused component failures 

Fuel system pressurization, 

fuel spurting 

Evaporative emission system 

failures 

Miscellaneous 

Stalling 

Manufacturing problems 

Structural failures 

Fuel lines loosen or 

disconnect 

TOTAL 

7 

SYSTEM RECALLS 

NUMBER 

44 

27 

46 

12 

21 

14 

13 

63 

25 

26 

291 

PERCENT 

15 

9 

16 

4 

7 

5 

4 

22 

9 

9 

100 
MOTOR VEHICLE RECALLS SINCE 1966 

All Recalls 

(4,276) 

Fuel System Recalls 

(291) 

Fuel System 

Fuel Leaks (Chemical) 

9% 

Fuel Pressure 

4% 

Miscellaneous 

5% Stalling 

4% 

Evaporative 

7% 
P.4Q 

Analysis of these recalls shows that many different fuel system 

conditions can cause fires and prompt safety recalls. These 

conditions range from gasoline leaks caused by carpet fasteners 

penetrating the 'fuel tank during manufacture, to misrouted fuel 

lines, to defective fuel filler caps, and tanks that rupture in 

crashes. The largest single category of fuel safety recalls with 

22% is errors in manufacturing and installation such as misrouting 

the fuel line, puncturing the fuel tank, and omitting components. 

Indeed, carpet tacks, screws and drill holes alone accounted for 10 

of the 291 recalls. 

The recall category which received the most emphasis in this 

rulemaking is fuel system failures which are associated with burn 

injuries in post-crash fires. Post-crash fires are particularly 

dangerous because occupants trapped in wreckage from a collision may 

be unable to extricate themselves in time to avoid burn injuries. 

Further, post-crash fires and FMVSS 301 failures are more likely to 

involve fuel tank ruptures causing explosions and rapidly spreading 

fires. Because of the danger of post-crash fires, the likelihood of 

evaporative systems to cause them is given particular attention. 

Review of manufacturer recalls shows that conditions involving 

crash related fuel tank ruptures, filler neck breaks and primary 

fuel line failures account for 15.1% of all fuel system recalls. 

These crash related failures are caused by factors including pinched 

fuel lines, missing fuel tank shields, faulty gas caps and mispositioned fuel hoses — conditions likely to produce fires 

immediately fed by a large quantity of fuel. 
P.41 

In contrast, evaporative emission systems account for only 7.2% 

of all fuel system recalls. Virtually all of these conditions cause 

fuel leaks rather than post-crash fires. Out of the 291 fuel system 

recalls, 20 involved the evaporative system. Only 2 of the 291 fuel 

system and 4,276 total recalls pertain to gasoline vapor line or 

valve malfunctions that can cause post-crash fuel leakage. In 

October 1985, Subaru recalled 11,000 XT models because the bumper 

could damage the air vent hose and cause a fuel leak during a 

collision. In January 1976, Jaguar recalled 911 XJ6 models because 

the fuel pump non-return valve could cause fuel to syphon from one 

tank to the other, and cause the carbon canister to overflow.1 

Recall data showing only two defects associated with postcollision failure of current evaporative systems indicates the 

potential crash fire risk from onboard systems is small. The 

improved onboard systems under EPA's proposed evaporative control 

rule are only marginally more complex than the present systems which 

have generated two post-crash fire recalls of 11,911 out of 

130,800,000 vehicles (0.01%) in 18 years. Neither of these recalls 

was linked with any fires, deaths or injuries. Any increased crash 

safety risk from onboard systems would be a marginal increase of a 

present small safety risk and could easily be handled by improved 

technology. 

1In December 1983, Grumman Olson recalled 51 diesel trucks 

because "the location and length of the vent valve hose" could result 

in fuel spillage during an accident. This recall and fuel system is 

not affected by EPA's gasoline evaporative emission controls. 

10 
P.42 

Recall data clearly demonstrate that the safety risk from high 

fuel volatility and excessive fuel pressure is far greater than from 

evaporative control systems. Excess fuel pressure causes large 

amounts of gasoline spurting out of the filler neck after the gas 

cap is removed as. well as large fuel leaks from the fuel system even 

with the filler cap in place. Automakers have conducted 12 recalls 

of 654,071 vehicles to alleviate fuel pressure and spurting problems. These recalls have been associated with at least 71 fires, 25 

injuries and 2 deaths. 

TABLE 2 — NHTSA FUEL PRESSURE RECALLS 

Recall 

Number 

79V-028 

79V-048 

79V-132 

80V-083 

81V-058 

82V-076 

85V-014 

85V-106 

87V-113 

87V-144 

87V-155 

88V-013 

TOr 

Manufacturer 

Volvo 

Volvo 

Volvo 

Fiat 

Volkswagen 

General Motors 

Heritage 

Fleetwood 

Ford 

Ford 

Winnebago 

Georgie Boy 

fAL 

Type & Year 

1975-76 Cars 

1975-77 Cars 

1974-75 Cars 

1979 Cars 

1980-81 Cars 

1982 Cars 

1984 Motorhomes 

1979-85 Motorhomes 

1983-87 E350 

1983-87 E250, 

Ambulances 

E350 Vans 

1985-87 Motorhomes 

1984-85 Motorhomes 

Number of 

Vehicles 

57,000 

61,000 

121,000 

13,280 

133,000 

24,455 

750 

28,545 

16,000 

188,000 

9,041 

2,000 

654,071 

11 
P.43 

The NHTSA fuel pressure recalls closely track the increase in 

gasoline fuel volatility with no fuel pressure recall before 1979 

when the national average summer RVP was less than 10 psi.2 In 

addition to these* recalls, NHTSA has active investigations into fuel 

pressure problems on 1983-85 Renault Fuego's (EA 88-020) and General 

Motors 20 and 30 chassis (EA 88-016) so the fuel pressure recall 

trend will continue up in the future unless fuel volatility controls 

are imposed. 

C. SAFETY COMPLAINTS 

NHTSA maintains a computer data base of 146,000 safety 

complaints received by the agency since 1977. CAS requested a 

computer search of the entire data base to identify and segregate 

all fuel system complaints within this data base. CAS received a 

computer printout of 20,000 complaints which covered all fuel system 

safety reports ranging from fuel tank explosions in crashes to fuel 

leaks of all types, to defective carburetors, and even sudden 

acceleration. CAS staff analyzed every single abstract to identify 

all reports of fires, fuel pressure and spurting, vapor lock and 

fuel foaming, carbon canisters, and degradation of fuel system 

components by the fuel (excluding contaminated fuel). Copies of 

each identified complaint were obtained from NHTSA to verify them. 

1. Fires 

The fuel system data base contain 1,501 reports of fires which 

were identified by examining the "fault code" and abstract sections 

2"Study of Gasoline Volatility and Hydrocarbon Emissions from 

Motor Vehicles," Environmental Protection Agency, Table 2-6 (November 

1985). 

12 
P.44 

of the computer printout of NHTSA's 20,000 fuel system complaints.3 

Identification of a complaint containing one of these fault codes 

was followed by examination of the abstract describing the reported 

problem. Review of the abstract verified that a fuel fire was 

involved and provided a method for determining whether or not the 

fire resulted from a crash. 

The vast majority of the 1,501 fuel related fires identified by 

this process were non-crash engine compartment fires which comprised 

60% of the complaints in the data base. The most frequently cited 

known causes of engine compartment fires were fuel leaks from fuel 

injectors, carburetors, and fuel lines.4 The next most common fire 

causes were catalytic converters overheating with 10%- and fuel 

leaking or spraying out from the filler neck with 5%. Crash fires 

totaled 24 or 2% of the data base. Of these 24 crash fires, none 

were caused by failure of the evaporative emission control system. 

3The complaint summaries of all fire reports are identified by 

one of the following 8 fault codes. [A complete list of NHTSA fault 

codes is included as Appendix B.] 

Code Fire Type/Cause 

22 Fluid Fire (transmission, etc.) 

23 Liquid Propane Gase Fire 

24 Gasoline Fire 

25 Unknown Fire 

16 Fluid Explosion 

17 Liquid Propane Gas Explosion 

18 Gasoline Explosion 

74 Electrical 

4A good example of this is Ford's recall (87V-139) of 3.6 

million 1986-88 vehicles for defective fuel line couplers that 

uncoupled and sprayed gasoline under high pressure in the engine 

compartment. At the time the recall was announced, Ford reported 225 

fires and 8 injuries due to the defect. 

13 
P.45 

Nor did the CAS analysis find any significant number of reports 

of crash or non-crash explosions. Reports describing explosions 

either alone or in crashes accounted for less than 1% of all fire 

reports identified by CAS. Since NHTSA's vehicle system categories 

are each distinct (as shown by the list in Appendix C) , reports of 

explosions and/or crash related fires would almost certainly have 

been coded as fuel system problems. 

The low involvement of evaporative emission components in 

vehicle fires in the NHTSA data base was cross checked by analysis 

of those safety reports that specifically referenced evaporative 

components. This search turned up only 27 complaints which are 

listed in Appendix D. Only 6 of these involve a vehicle fire (0.4% 

of all fire reports in the data base), none in a crash or causing an 

injury. Not all 6 fire complaints point to the evaporative system 

as causing the fire. For example, complaint H60877 indicates the 

fire was caused by a catalytic converter malfunction although the 

canister purge valve was repaired earlier. Where the evaporative 

emission system caused the fire, the mechanism varied from contact 

of a canister with the exhaust manifold to gasoline backing up 

through the vent lines due to overfilling. 

Review of existing highway safety literature confirms crashrelated fires account for a small fraction of all vehicle fires and 

resulting injuries. A 1981 Society of Automotive Engineers Technical Paper, for example, highlighted Michigan State Police fire 

data that showed "accident, overturn and knockdown" related events 

accounted for only 5.3% of all passenger car fires.5 In contrast, 

5"Motor Vehicle Non-Crash Fires," Peter Cooley (Highway Safety 

Research Institute, University of Michigan) SAE No. 810012, p.3 (1981). 

14 
P.46 

the most common cause, "part failure" accounted for 38.7% of all 

passenger car fires. According to this SAE paper, only "one in 

every 15 reported burn injuries associated with motor vehicles 

results from a crash."6 

2. Fuel Volatility, Stalling and Degradation 

NHTSA safety report data confirm that the largest safety hazard 

involved in this rulemaking is from higher fuel volatility and resulting fuel system overpressurization which cause fuel leaks, fuel 

spurting and fires as well as fuel foaming, vapor lock and stalling. 

In sharp contrast to the 27 safety complaints on evaporative emission systems, CAS identified 1,163 vehicle safety complaints with 

1,661 reports of fuel overpressurization, vapor lock/fuel foaming, 

fuel spurting and fuel degradation of vehicle components and performance as shown in the following graph. Appendix E is an explanation of this analysis with coding sheets listing every report by 

category along with the date, location and vehicle model and year.7 

CAS found the safety hazards of higher fuel volatility are (1) 

concentrated during May through October, (2) in states with higher 

fuel volatility levels, and (3) increasing as fuel volatility levels 

increase. Table 3 on page 17 compares the occurrence of fuel safety 

complaints versus vehicle registrations, ASTM low summer month Reid 

vapor pressure (RVP) volatility standard, and state RVP volatility 

standard. The 26 states for which ASTM set a voluntary RVP standard 

for one summer month of no higher than 10.0 psi had only 34% of the 

6Id. at 5. 

Attachment A includes the 1,133 complaints for 1,163 vehicles. 

15 
EVAPORATIVE AND FUEL SAFETY COMPLAINTS 

Number 

en 

Fuel System 

Pressure 

Vapor Lock Fuel Spurting Component 

Degradation 

Evaporative 

^i 
CO 

d) 

B 

3 

i 

o 

•H 

ii 

lO J. 

&<*. 

-H 

-H -H 

il B. 

o in 

* * 

I 

in 

s g s g 

o o o o 

& a 5s 55 

a 

i J. n 

55 55 21 55 55 < 55 < 55 55 

oinooooinmininoinoioioinoinoinmininmoooooininoinooinooininoooooininoinin o 

o n 

rH t-l 

OnO^OCnOHHHHOHOHHr-!OrHOf-li-trH*HHOOOOOHHCnrHOOiHOOHHOOOONOHt-HOHH O ^ cHrHrHiHt-li-tHHHHHi-trHt-li-lrHiHHrHfHrHHHHiHr- l rHHHr-i«-4fHiHHHH H rH H H H r-t H H 

TrN^]'OcoHl^ln^olcoolOln^^o^o(nNHOln^oon't^TrHn<J , N^^D^co^lOH^N'trl^oo^^Ntol n 

OOWOlOTTrHOO^OOrHHCNlOfH^OOrirH^OHOlOOOOMiHintHOr^OMinOOOfHfnOO^Hnr-i d 

a 

<H> 

rgHOWcooia)HHr^oooa)t^u>Nr^riOiHOooooo^o^o^<^oocnorHt^nu>iHOOvDoifovo\oO'^chOco H 

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m 

£- " » 

^oo^nH^o^on^m^OlnalcooH^)N(^(^JcoOH^O(^lnlnH(^^{^lOO^lOHlnlnln^eocoHTrN^^Nr10lne o (nHntOHln^NH»wn^^^lnN<J ,

^'^'O^HOOOOn^rlln^li)^lnn^«J( ,lH^M^(^lrl^OMln^l^(O N 

rH O H O HHHddlnrldd«NHHHHdHN«MH^IOOOONOlnPl01fHH'tOHO^^^OOM^JOH d 

nJ 

5 

*SSH5" H O e ' dt i h S s 

V< 

-9 g 3 S 3 8 gfe'ld u 0 * jjf 

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3 

w w 
P.49 

fuel safety reports but 48% of the national vehicle fleet. With 66% 

of the fuel safety reports and 52% of the vehicle fleet, those 24 

states with ASTM summer levels higher than 10.0 psi were 80% more 

likely to have fuel safety problems. 

As shown below in Table 4 and in the bar graph on the following 

page, the incidence of fuel problems has increased as fuel volatility levels have increased. From 1978 thru 1980, NHTSA received only 

8 fuel safety complaints. Thereafter, the complaints climbed to the 

level of over 100 per year. (CAS eliminated all 1983-86 Ford 

ambulances which were recalled for fuel spurting from this table to 

exclude the effect of this batch of late model vehicles.) Since the 

table is based only on the year of first incidence, the greater 

number of complaints in later years is not due to new vehicles 

continuing to have fuel volatility problems in later years. 

TABLE 4 ~ FUEL COMPLAINTS BY YEAR OF INITIAL INCIDENCE 

1978 1979 1980 1981 1982 1983 1984 1985 1986 1987 

2 0 6 11 41 150 167 199 193 348 

To confirm that the increase in fuel safety complaints is 

related to fuel volatility, CAS examined the records for the 1980 to 

1983 model years in depth. First, CAS eliminated all degradation 

complaints which are more likely to be time related and less likely 

to be volatility related. Then CAS plotted the year of first 

incidence verus model year for fuel overpressurization, fuel spurts 

ing and vapor lock/fuel foaming reports which are volatility 

related. (Table 5.) Only 15% of the vehicles had a volatility 

18 
P.50 

DISTRIBUTION OF FUEL SPURTING, PRESSURIZATION, AND VAPOR LOCK REPORTS BY 

SEASON 

(1,551 TOTAL) 

Fall/Spring 

12%" 

Winter 

4-% 

FUEL SAFETY COMPLAINTS BY YEAR OF INITIAL INCIDENCE 

(Excluding 1983-1986 Ford Ambulances) 

number 360 

340 

320 

300 

280 

260 

240 

220 

200 

180 

160 

140 

120 

100 

80 

60 

40 

20 

0 

11 

150 

235? 

167. 

•is? 

199 196 

.j.>.t --

••*;*;•• . 

:;yi'J 

348: 

J&'s 

Calendar year 

National Average 

Summer Gasoline RVP 

(Excluding California)* 

1978 1979 1980 1981 1982 1983 1984 1985 1986 1987 

9.9 9.2 10.0 10.1 10.5 10.6 10.4 10.8 10.4 

Prom Table 2 

Evaporative Hyd 

-5» Draft Regulatory Impact Analysis, "Control of Gasoline RVP Volatilit y and 

Hydrocarbon Emissions from New Motor Vehicles,* U.S. BPA, July 1987. 

19 
P.51 

9 

3 

-

— 

3 

16 

17 

-

28 

25 

29 

52 

19 

15 

13 

38 

7 

17 

8 

38 

7 

10 

26 

84 

6 

11 

11 

21 

related complaint in the first year they were sold with 85% having 

their first volatility complaint in later years when volatility 

levels were higher. If CAS had plotted additional volatility 

complaints for the same vehicle in later years, the number of 

complaints in later years would have been far higher. 

TABLE 5 — VOLATILITY COMPLAINTS BY MODEL YEAR AND FIRST INCIDENCE 

1980 1981 1982 1983 1984 1985 1986 1987 

Model 

Year 

1980 3 

1981 

1982 

1983 

Analysis of the fuel safety complaints by time of year confirms 

that controlling fuel volatility in the summer will advance both 

environmental and safety goals as the greatest incidence (84%) of 

fuel safety complaints occurs during this time period as shown in 

the pie chart on the previous page. Between 82 to 87% of all fuel 

spurting, overpressurization and vapor lock/fuel foaming reports 

occurred in the summer (May thru September) . Only 2 to 6% occur 

during the cold weather winter months (December thru February). 

During the spring and fall months (March to April and October to 

November) when there are occasional warm days, volatility related 

safety complaints range from 9 to 14%. Degradation of vehicle 

performance due to fuel problems is not strongly correlated with 

season with 53% occuring during the 5 summer months, 28% during the 

4 spring/fall months and 19% during the winter months. 

20 
P.52 

TABLE 6 ~ SEASONAL INCIDENCE OF FUEL SAFETY REPORTS 

Spurting Pressure Vapor Lock Degradation 

Season 

Summer 

Spring/Fall 

Winter 

85% 

9% 

6% 

82% 

14% 

4% 

87% 

11% 

2% 

53% 

28% 

19% 

Examination of the 68 reported fires due to fuel safety 

problems confirms this seasonal distribution with 81% occurring in 

the summer as shown in Table 7. Since the date and location for 

each fire was known as shown in Appendix F, CAS was able to deterine the applicable voluntary ASTM RVP standard for the time of the 

fire as well as whether ASTM standard D 439 was adopted by the 

state. As shown in the chart on the next page, only 2 fires occurred when the ASTM RVP standard for the area of the fire was 9.0 psi. 

Moreover, one of the fires occurred in Texas which has not adopted 

ASTM or any other volatility standards. The other fire occurred in 

New Mexico which has adopted ASTM D 439 but which has granted 

ethanol blends a volatility exemption. Colorado led all states in 

fires caused by fuel volatility problems with 12 of the 68 or 18%. 

TABLE 7 ~ SEASONAL FIRE DISTRIBUTION 

Summer Soring/Fall Winter 

56 (81%) 11 (16%) 2 (3%) 

a. Fuel Spurting 

The most serious safety hazard identified in the NHTSA safety 

complaint data base is fuel spurting — where the gasoline spurts or 

sprays from the fuel tank upon removal of the filler cap. In most 

cases, the fuel release is due to excess pressure in the fuel tank. 

21 
FUEL SAFETY REPORTS AND ETHANOL SALES 

100 

Percent 

Share 

Colorado Ethanol States* All Other States 

States with ethanol sales greater than 7.0 percent and ethanol volatility 

standard higher than 10.5 psi RVP. 01 

to 
P.54 

In some cases, the fuel boils and pours out of the tank. Fuel 

spurting occurred in 37% of the vehicle fuel safety complaints with 

the amount of fuel ranging from a pint to many gallons. 

The -safety.hazards of fuel spurting are readily apparent — if 

there•s an ignition source, there's a fire. This is best shown by 

some of the fuel spurting reports CAS analyzed as summarized below. 

July 9, 1985. Don Palanuk removed the gas cap of his 

Fleetwood Southwind motorhome to investigate a noise 

coming from the gas tank. Gasoline sprayed out of the 

filler neck onto Palanuk, another motorhome and a car. 

When a pilot light in the other motorhome ignited the 

gasoline, everything went up in flames. The car and both 

motorhomes were destroyed. Don Palanuk died 31 hours 

later in a burn center in Salt Lake City. 

August 17, 1986. Ansel Massey of Amarillo TX was vacationing in New Mexico in his 1986 Winnebago Chieftain when 

he saw fuel spilling from his gas cap. When he stopped 

and took off the cap, gasoline sprayed on him and ignited. 

Although a passerby smothered the flames with a blanket, 

Mr. Massey died the following day of burns suffered over 

63% of his body. 

May 9, 1986. Thomas Clough of Seminole FL pulled into a 

gas station in Acworth GA in his 1985 Ford E250 van. When 

he removed the filler cap, gasoline sprayed out and 

ignited, destroying the van and gas station and causing 

first, second and third degree burns to Mr. Clough. 

b. Fuel Overpressurization 

The most common safety hazard identified in the safety 

complaint data base is fuel overpressurization where the gasoline in 

the fuel tank builds up dangerously high levels of pressure that 

manifests itself in fuel leaks from the tank and vent lines, poor 

vehicle performance, excessive gasoline odors, constant whistling 

from the tank, and a rush of pressure upon removal of the filler 

cap. In some cases, the excess pressure can blow vent lines and gas 

tank seams. Too much excess pressure can also cause vehicle stalling which the driver often, and dangerously, alleviates by removing 

23 
P.55 

or loosening the gas cap. Excess fuel pressure occurred in 58% of 

the vehicle fuel safety complaints. 

The amount of gasoline that can be lost to a leak from excess 

pressure is staggering — up to 20 gallons in a motorhome and 

several gallons in a car. Although fires do not occur as frequently 

as in the case in of fuel spurting, pressure leaks ofter result in 

fires. Some owners who have experienced the excess pressure in the 

gas tank even stop driving the vehicles. The following are typical 

examples of the safety problems experienced by consumers with excess 

pressure in their vehicles. 

Christian Speaker of Graterford PA wrote about his 1986 

Tioga motorhome with "a lot of problems with it overpressurizing. Once, the motor just stopped and left me 

sitting in the middle of the road. I had to remove the 

fill cap and relieve the pressure before it would start. 

Every time I remove the filler cap I get a 'whooshing1 

sound of all the pressure being released. . . . Even 

during the day when the motorhome is just sitting, I have 

a pressure buildup. 

Helen M. Fipps of Hyattsville MD complained that "the fuel 

tank was leaking [on her 1983 Ford Thunderbird] because of 

excessive pressure. I had to call the fire department to 

hose down the parking lot. . . . Ford representative 

[said] that this is normal. .. . We do not like putting 

our lives or our children's lives in danger by driving 

this car. 

Ethel V. Vann of Ownings MD had an excess fuel tank 

pressure with her 1983 Renault Alliance such that "when 

the tank is filled over 1/2, the gasoline is expelled from 

the tank and runs down the side ... . I began to keep 

less and less gas in the tank . . . approximately three to 

four gallons. 

When there is an ignition source, gasoline leaks from fuel 

tanks with excess pressure can turn into fires as is clearly pointed 

out by Assistant Fire Chief Marc Crain for Hoodland Fire District 

#74 in Rhododendron OR in reporting on two Ford F250 pickup fires: 

24 
P.56 

Both vehicle drivers experienced a minor backfire and lost 

power, fire appeared at the fuel filler spouts, drivers 

pulled the vehicles to the side of the highway and fire 

rapidly involved the camp vehicles attached. [The 

ingnition factor identified was "fuel from overpressured 

tank spilled-onto side & rear of vehicle."] 

c. Vapor Lock and Fuel Foaming 

Another common safety hazard associated with high fuel 

volatility is vapor lock and fuel foaming which cause stalling and 

other performance problems in motor vehicles. Vapor lock and fuel 

foaming occurred in 39% of the fuel safety complaints. As with fuel 

spurting and overpressurization, vapor lock and fuel foaming are 

warm weather problems with 87% of the reports occurring from May 

through October with 11% occurring in March to April and October to 

November. 

Vapor lock and fuel foaming have become such common problems as 

fuel volatility has increased since 1980 that most manufacturers 

have devised special repair procedures for vehicles in use and have 

made production changes for new vehicles in efforts to alleviate the 

problem. For example, Chrysler has issued special driveability kits 

for most of its 1981-87 vehicle production as shown in Appendix G. 

As part of an overall effort to resolve fuel problems in 1982-83, 

General Motors (GM) noted that 100% of all class A motorhomes could 

have vapor lock as fuel volatility increased. GM was so concerned 

about vapor lock in these vehicles that it held a meeting at its 

Phoenix Proving Grounds in October 1983 of 34 of the 36 Class A 

motorhome manufacturers to discuss how to reduce vapor lock. (See 

Appendix H.) At the meeting, GM pointed out: 

25 
P.57 

The higher the Reid vapor pressure the more vapor lock can 

be expected. The average Reid vapor pressure of regular 

unleaded gasoline was 9.3 in 1980, 9.8 in 1981 and 10.3 in 

1982 with individual locations showing 12 and 13 and it 

appears the trend will continue upward. This really converts -to explain why some motorhomes that have never had 

any problems could, with fuel changes toward the higher 

Reid vapor pressure fuels, find problems of vapor lock 

that did not exist a year or so ago. 

Examination of the many individual consumer vapor lock and fuel 

foaming reports in the data base confirm the safety hazards of 

higher volatility fuels. 

In September 1985, Richard Antolovich of Denver wrote the 

NHTSA that his 1983 Chevrolet S-10 Blazer "vapor locks at 

the most dangerous times, e.g., pulling out onto a busy 

road . . . ascending a mountain interstate highway grade 

in the middle of a lot of traffic . . . attempting to pass 

another vehicle on a 2-lane highway. . . . This condition 

has become very common in my area of the country. It is 

also so dangerous that I no longer trust allowing my wife 

& children in the vehicle under the stated conditions." 

In June 1983, Christine Sedlmayr of Arvada CO wrote NHTSA 

that her 1981 Plymouth Reliant "vapor locks and stalls. I 

consider this problem to be a life-threatening hazard, as 

there is no telling who may be behind me when the car 

stops. So far I have been fortunate. Next time I may be 

dead. 

In June 1986, Barton Sadowsky of New York NY wrote NHTSA 

that his 1985 Mercury Merkur "has developed a progressively worsening case of vapor lock. [On a trip] the car 

backfired and stalled out approximately 15 times. Each 

time I was surrounded by heavy Saturday mid-day traffic. 

I had to get out of the car each time, lift the hood to 

cool the engine and the trunk lid to warn motorists behind 

me and stand in the road until the engine was cool enough 

to restart ... . 

d. Degradation of Fuel System Components 

In 10% of the fuel safety complaints, degradation of fuel 

system components by the fuel itself caused fuel leaks or poor 

performance such as stalling. This analysis excluded problems 

26 
P.58 

caused by fuel contaminated with water or impurities such as rust or 

debris. Thus it was limited to degradation caused by a fuel meeting 

specifications set by the marketer. Unlike the other fuel safety 

reports, degradation was not concentrated in any season. 

The fuel system components most likely to be degraded were 

carburetor floats and j ets, gaskets and seals, hoses, fuel 

injectors, filters, fuel pump diaphragms, and terne plate. Most 

frequently consumers would specify only that the components 

deteriorated such as Joanne Chris of Monrovia CA who reported the 

carburetor in her 1980 Honda flooded because "the floats were 

plastic & holes got eaten through them." Phillip Lewis of Memphis 

TN reported his 1984 Peugeot 505 leaked gas from the filler neck 

because "the rubber gasket on the gas cap reacts with gasoline, expands & no longer seals." 

The fuels most commonly identified as degrading fuel system 

components and causing safety problems were alcohol fuels. In fact, 

they are the only uncontaminated fuels that were identified as 

degrading vehicle components. This is supported by the fact that 

those states with gasohol sales greater than the national 7% average 

have more fuel degradation complaints. These states have just 35% 

of the vehicle market share but 51% of the fuel degradation 

complaints. 

The following are typical examples of fuel degradation reports 

about alcohol fuels. 

Kathie Rogers of Pretty Prairie KS experienced chronic 

stalling in her 1984 Honda CRX that the dealer advised 

"was caused by carburetor flaking away due to ethanol." 

27 
P.59 

William Lorenzen of Vallejo CA had the fuel line deteriorate on his new 1982 Ford Mustang after driving for 7,000 

miles on 10% ethanol blends despite the owner's manual 

saying they were acceptable. 

Harold. Dillenbeck of Johnson City TN paid a $100+ to 

replace the fuel pump on his 1981 Plymouth Reliant after 

using AP gasoline containing 10% ethanol that caused it to 

fail. 

Don Young of Garland TX had to replace the fuel injectors 

in his 1983 Nissan 280ZX at a cost of $600 after using 

Vickers gasoline containing ethanol. Although Vickers 

assured him its gasoline did not contain ethanol, he had a 

sample of the gas from his tank analyzed and found it 

contained 8% ethanol. 

II. ENVIRONMENTAL IMPACT OF FUEL SPURTING AND OVERPRESSURIZATION 

Higher fuel volatility has a major adverse impact on ozone 

levels that EPA has not considered to date in this rulemaking — (1) 

the massive release of hydrocarbons (HC) from widely occuring fuel 

spurting and pressurized leak incidents, and (2) tampering with fuel 

system components to compensate for adverse performance problems 

associated with high fuel volatility and fuel system pressure. Out 

of the 1163 vehicle safety complaints, 41% reported major gasoline 

losses to the environment due to fuel spurting or leaks from gas 

tanks with excess pressure. 

The average release of gasoline in a fuel spurting incident or 

leak from an overpressurized fuel tank in the safety complaint data 

base is over 2 gallons or 5100 grams. This is the equivalent of the 

evaporative emissions from 300 vehicles at present 1988 fleet levels 

of 16.93 grams/day or more than 600 vehicles at the projected levels 

of 7.23 grams/day when the proposed gasoline volatility standards 

take effect. The following examples from the complaint data base 

28 
P.60 

show the magnitude of the gasoline loss to the environment. 

Thomas Mark of Evergreen CO had 5 gallons of gas blow out 

of the filler neck of his 1979 Nissan 200ZX when he took 

off the cap on a day when the temperature was 90° and he 

was at a 7500 foot altitude. (H61017) 

The Iredell County NC EMS reported their 1981 Ford Econoline has leaked over 5 gallons of gas several times with 

and without the engine running. (141415) 

John Matras of Granite City IL reported a fuel spurting 

case on his 1985 Holiday Rambler motorhome, "On taking the 

cap off, the gas spewed out about 4 or 5 feet in the air 

and . . . several gallons ejected from the tank." (147907) 

When Karyn Litaker-Parker of Mesa AZ removed the filler 

cap from her 1983 Renault Fuego on August 17, 1985, she 

"was drenched by a flood of gasoline shooting from the 

filler area .. . at least a gallon of gasoline was thrown 

on me from head to toe." (136510) 

In order to determine the additional HC emissions due to fuel 

spurting and excess pressure leaks, one must estimate the percentage 

of vehicles affected and the frequency of fuel expulsion incidents. 

Based on the total number of 146,000 vehicle reports in the consumer 

complaint data base, the frequency of fuel spurting or leaks from 

overpressurized gas tanks is at least 0.4%. If these vehicles have 

one fuel loss incident every 30 days during May thru October, this 

suggests that fuel spurting and overpressurization increases evaporative HC emissions by 40% over the base 1988 level. Even eliminating vehicles recalled for fuel spurting such as the 1983-86 Ford 

ambulances from the data bases suggests the present incidence rate 

is at least 0.1-0.2% which increases evaporative HC emissions by 10 

to 20% over the base 1988 level. 

By lowering the gasoline volatility standard, EPA will not only 

reduce normal evaporative emissions but also fuel spurting and leaks 

29 
P.61 

from excess gas tank pressure. However, significant reductions in 

fuel spurting and leaks will not occur unless the RVP volatility 

standard is set at 9.0 psi. The best indicator of this in the data 

base is the incidence of fire by RVP standard as shown in Appendix 

F. The primary difference between a fuel spurt with and without a 

fire is the presence of an ignition source. Only two of 68 fires 

occurred when the ASTM standard was 9.0 and one of these occurred in 

Texas which does not enforce ASTM standards. (See p. 22 supra.) 

The state by state examination of all fuel safety reports also 

shows a reduction in fuel spurting and pressure leaks as volatility 

levels are reduced. Those 26 states where the ASTM RVP standard was 

10.0 psi had only 34% of the fuel safety complaints even though they 

had 48% of the vehicle fleet. For the 24 states where the ASTM RVP 

standard was higher, they had 66% of the fuel safety reports but 

only 52% of the vehicle fleet. 

In an effort to improve performance of vehicles with excessive 

fuel pressure, many consumers are drilling out, removing or 

loosening the gas cap, and disabling vent lines to the charcoal 

canister; all of which lead to increased HC emissions. While the 

Center has not quantified the amount of additional HC emissions that 

are released, on an individual vehicle basis this can eliminate most 

of the reduction in HC emissions from evaporative controls. 

IV. ALCOHOL FUELS 

Since alcohol fuels have higher volatility and more materials 

incompatability than straight gasoline, they will cause more 

performance problems, particularly in older vehicles and vehicles 

30 
P.62 

with heavier driving cycles such as motorhomes, trucks and vans, and 

those operating at high altitude. These performances problems lead 

to greater safety hazards and higher emissions. Controlling the 

volatility of ethanol blends to the same level as straight gasoline 

is an important means of both reducing safety hazards and HC 

emissions. 

A. SAFETY HAZARDS 

With their higher volatility, alcohol blends have worse safety 

emission problems than straight gasoline. Analysis of NHTSA fuel 

system complaints shows that states with more than 7% gasohol 

penetration (the national average) have 50% more fuel safety 

complaints than states with less than 7% gasohol sales. Indeed, 

these states have just 35% of the vehicle population but 52% of the 

fuel safety reports. Recalls, NHTSA investigations, and manuacturer bulletins and internal documents all show alcohol fuels as 

one of the primary causes of vapor lock, fuel spurting and overressurization, and fuel system component degradation. 

Of all the states with high gasohol sales, those few (Alabama, 

South Dakota and Tennessee) which enforce summer RVP standards no 

higher than 10.5 psi and no ethanol exemption have reduced fuel 

safety complaints. The remaining gasohol states with just 32% of 

the vehicle population have 50% of the fuel safety complaints and 

56% of the vehicle fuel volatility fires as is shown in the graph on 

the following page. 

Colorado is a worst case example of providing a volatility 

exemption for ethanol blends. Much of the state is at high altitude 

31 
P.63 

FUEL SAFETY FIRE REPORTS AND RVP LEVELS 

(68 TOTAL) 

ASTM standard for 

location and date of fire 

9.0 psi fW 

3% 

32 
P.64 

which increases the adverse effects of higher fuel volatility 

including fuel spurting, vapor lock and fires. At present Colorado 

provide a volatility exemption for gasoline blended with ethanol 

while requiring straight gasoline to meet ASTM D 439 RVP standards 

of 10.0 psi from June thru September and 11.5 psi for May and 

October. Prior to July 1986, Colorado did not enforce any volatility standards for gasoline or ethanol blends. As the bar graph on 

the previous page shows, Colorado has only 1.56% of the U.S. vehicle 

fleet but has 4.1% of the fuel safety complaints and 17.6% of the 

fuel related fires in the complaint data base. Colorado should have 

a 9.0 psi RVP volatility standard for all gasoline and no ethanol 

exemption for May thru October in order to reduce its fuel safety 

problem. 

Many owners who have fuel safety problems on 10% ethanol blends 

find the problems disappear when they change to straight gasoline. 

The following are some typical examples: 

The Cerro Gordo Community Ambulance Service in Cerro Gordo 

IL had vapor lock caused by using gasoline with ethanol. 

"When fuel not containing ethanol is used, vehicle seems 

to run normally." 

When Gordon McGrew of Evanston IL had his 1980 Honda 

Accord "started running awful within 500 feet of the 

station", he had the Road Pilot gasoline tested on a gas 

chromatograph and found that it contained 10% ethanol and 

no water. He refueled with non-ethanol gasoline and had 

no problems. 

Debbie Carroll of Reston VA had $200 to $300 of engine 

repairs after using Digas containing 10% ethanol that 

resulted in her 1984 Chrysler E Class having "very little 

power when accelerating and a lot of stalling." She 

changed to non-ethanol blended gasoline and had no 

problems thereafter. 

33 
P.65 

B. STRINGENT ENFORCEMENT OF VOLATILITY STANDARDS 

The ethanol industry has proposed that whatever volatility 

standard EPA sets for ethanol blends should be enforced by "paper 

certification" — i.e., where the ethanol blender/retailer shows 

compliance by providing paper records that the base gasoline met 

EPA's RVP standard and that only ethanol was added to produce the 

finished 10% ethanol-gasoline blend. Even if EPA testing showed the 

ethanol blend to have a 14 psi RVP, the blender could avoid all 

liability for the violation. As experience with other gasoline 

regulatory programs has shown, paper certification is an invitation 

to disaster. 

Experience with gasoline regulatory programs shows significant 

fraudulent and evasive practices. While the majority of gasoline 

marketing practices are in accordance with applicable laws and 

regulations, the incidence of unlawful practice undermines the 

regulatory programs and puts those who obey the law at a competitive 

disadvantage. Such unlawful practices have been particularly widespread where the regulations rely upon paper records to demonstrate 

compliance as the fuel ethanol industry has proposed. 

Examples of such unlawful gasoline marketing practices in the 

past include cheating on generation and sale of lead rights under 

EPA's lead phasedown program. Based on a sample of refiners, EPA's 

Office of the Inspector General found widespread noncompliance with 

EPA's lead content and reporting regulations including: 

[EPA] refiners reports did not support the sale and purchase of 137 million grams of lead usage rights during 

1984 and 64 million during 1985 .. . 

34 
P.66 

Refiners in our sample did not report purchasing 763 

million grams of lead additive that lead manufacturers 

reported selling to them; and 

Ten refiners reported substantial decreases in lead use 

between 1984 and 1985, without having to provide detailed 

explanations of their actions.8 

EPA audits confirmed the widespread noncomplaince with the lead 

phasedown program with EPA announcing on December 2, 1986, that 

based on just . one audit, it was seeking $40 million dollars in 

penalties for violation of the lead content regulations. This audit 

found that certain refiners did not report the use of over 2 billion 

grams of lead. 

The General Account Office (GAO) has issued two reports since 

1986 which also show the gasoline industry failing to comply with 

regulatory requirements. In August 1987, GAO found widespread 

octane mislabeling in New York City that resulted in consumers being 

sold low octane gasoline as high octane at a price 12 to 25 cents 

per gallon higher than what low octane sold for.9 The GAO also 

found widespread noncompliance with EPA's lead phasedown program and 

found cases of lead use as much as 300 million grams in excess of 

the standard.10 According to GAO, EPA itself recognized "the 

increasingly restrictive lead standard has increased the incentives 

to cheat on the rules." 

8"Significant Control Weaknesses Identified In Program to 

Reduce Lead Emissions," February 1987, a copy of which is provided 

as Attachment B. 

^"Gasoline Marketing: Octane Mislabeling in New York City," 

August 1987. 

10"Vehicle Emissions: EPA Program To Assist Leaded-Gasoline 

Producers Needs Prompt Improvement," August 1986. 

35 
P.67 

In July 15, 1986, testimony before the House Ways and Means 

Committee, Federal Highway Administration Chief Counsel Anthony J. 

McMahon testified, "evasion of gasoline taxes has reached a 

staggering level." According to the Committee: 

Informal estimates of annual Federal revenue losses range 

from $100 million to over $1 billion. .. . In a typical 

evasion scheme, an individual or business may purchase 

gasoline through a "daisy-chain" series of tax-free paper 

transactions, the gasoline may be sold .. . to a nonexempt producer or retailer. The seller then 

misrepresents that the . . . gasoline excise taxes have 

been paid. Thus, the last producer in the chain receives 

a tax-included purchase price from the buyer, but the tax 

is never paid to the Federal government.11 

In implementing a volatility standard for 10% ethanol blends, 

EPA must adopt a rigorous enforcement program including sampling at 

all levels of the gasoline refining, distribution and marketing 

system to ensure that full compliance occurs and that no fraud such 

as misrepresenting the volatility of the base gasoline occurs. The 

potential for abuse by paper certification exists whether EPA sets 

the same standard for ethanol blends as for straight gasoline or 

gives a 1.0 psi tolerance for such blends. In either case, paper 

certification creates an economic incentive to misrepresent the base 

gasoline as either being (1) a sub-RVP gasoline (where ethanol 

blends have the same standard) or (2) a base gasoline meeting the 

RVP standard (where ethanol blends have a set psi tolerance). 

The regulatory option of giving ethanol blends a 1.0 psi 

tolerance is particularly bad since the average volatility increase 

from the addition of 10% ethanol to a certified base gasoline may be 

11Hearing on Compliance With Federal Gasoline Excise Tax 

Provisions Before the Oversight Subcomm. of the House Comm. on Ways 

and Means, 99th Cong., 2d Sess. (July 15, 1986). 

36 
P.68 

as low as 0.3-0.7 psi. Unless EPA adopts a strict enforcement mechansim, high volatility components such as butane can be added to the 

gasoline blend to further raise its volatility up to the allowed 

ceiling of- 1.0 psi where addition of ethanol raises the volatility 

by a lesser amount. 

V. NO FEDERAL PRE-EMPTION OF STATE VOLATILITY STANDARDS 

The ASTM- has issued voluntary standards for motor gasoline 

since 1937 to help ensure fuels that perform well in motor vehicles. 

Many states have adopted the ASTM gasol ine standard, D 4 39, to 

protect consumers and ensure the safe operation of motor vehicle. 

Other states have set their own motor gasoline quality laws and 

regulations, some at an earlier date than ASTM. At the heart of the 

ASTM D 439 standard and many of the individual state standards are 

volatility requirements for motor gasoline. 

Yet the purpose of all these early motor fuel quality standards 

was consumer protection, not control of motor vehicle emissions. As 

shown by the above analysis of the vehicle complaint data base, 

states that have more stringent gasoline volatility standards have 

reduced fuel safety problems including vapor lock, fuel spurting and 

overpressuization, and fires. Only 3% of all fuel related vehicle 

fires in this data base were in states that enforced a 9.0 psi RVP 

standard at the time and place of the fire. States which enforced 

an RVP standard of 10.5 psi or less during the summer had reduced 

fuel safety complaints (19%) compared to vehicle market share (32%). 

States such as Alabama, South Dakota and Tennessee with significant 

gasohol sales have lower fuel safety complaints than other states 

37 
P.69 

with significant gasohol sales that provide a volatility exemption 

for ethanol blends. 

EPA cannot and should not attempt to preempt states which have 

chosen to protect the health and welfare of their motorists by 

setting stringent volatility standards for gasoline and alcohol 

blends. EPA may set more stringent national volatility standards to 

reduce evaporative HC emissions. But it is within the police power 

of the states to set volatility standards if they find it necessary 

to protect the safety and welfare of their citizens. Both state and 

federal regulations can exist together. 

38