p.1 

OAR Box 1147 

Prepped by Ollie Stewart 

Document Number: 

165) IV-E-38 

Docket Number: 

A-87-11 

Printed 4/22/2008 2:42:56 PM Sheet 165 of 242 
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2 A \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

ANN ARBOR. MICHIGAN 48105 

MAY 51988 

OFFICE OF 

AIR ANO RADIATION 

MEMORANDUM 

SUBJECT: 

FROM: 

TO: 

THRU: 

Meeting With NHTSA Staff Regarding Onboard Vapor 

Recovery 

Glenn W. Passavant, Senior Project Manager 

Standards Development and Support Branch 

The Record 

Chester J. France, Chief 

Standards Development a 

On January 12, 1988 EPA and NHTSA staff held two meetings 

regarding the onboard vapor recovery project. The purpose of 

the first meeting was to discuss the technical rationale 

supporting NHTSA's analysis of past recall actions which they 

believe may be relevant to onboard safety. The second meeting 

was set up to discuss and coordinate on technical aspects of 

EPA and NHTSA responses to an October 30, 1987 letter from the 

House Committee on Energy and Commerce regarding onboard vapor 

recovery. (A list of attendees for the second meeting is 

attached.) 

With regard to the first meeting, between Friday January 

8, 1988 when the meeting was confirmed and Tuesday January 12, 

1988 when the meeting was held, NHTSA reassigned the recall 

analysis project from one Office of Defects Investigation (ODD 

engineer to another. The newly assigned engineer had not had 

time to review NHTSA's background files on the onboard project 

or their detailed files on the recalls which NHTSA claimed were 

relevant to onboard vapor recovery systems. The previously 

assigned engineer was not available for the meeting, but joined 

us during lunch. 

Nevertheless, we reviewed both NHTSA and EPA's philosophy 

and approach to the recall issue. During the course of the 

conversation the NHTSA engineer stated that it is hard to tie 
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past system performance directly to future recalls and that 

even NHTSA regulations lead to recalls. Since NHTSA was not 

prepared to discuss the technical rationale behind each of the 

recalls in their analysis, we asked to meet again at a later 

date to continue the discussion. We invited the NHTSA/ODI 

engineer attend a January 25, 1988 meeting between EPA and API, 

and to hold our discussions on the recalls afterward. The 

NHTSA engineer later elected not to attend the meeting. 

During our lunch discussions, the previously assigned 

engineer commented that the NHTSA recall analysis doesn't imply 

anything definite with respect to the future impact of adding 

onboard, and that NHTSA has no opinion about safety of 

evaporative control systems compared to pre-evaporative 

vehicles. 

Most of the pertinent details of the second meeting 

involved discussions of technical aspects of the questions 

raised in the letter mentioned above and how those technical 

details should be considered in the responses. Most of these 

points were ultimately reflected in the responses provided by 

EPA and NHTSA. 

Two other noteworthy discussions occurred. The first 

focused on the value of EPA or some other interested party 

crash testing an onboard-equipped vehicle. NHTSA stated that 

whether a given onboard-equipped vehicle passed or failed FMVSS 

301 would do little to address safety issues regarding onboard, 

because the outcome of any such testing would be largely 

dependent on the design tested. As measured by FMVSS 301, both 

safe and unsafe systems could be built for testing. Second, 

NHTSA agreed that due to the publicity given to the onboard 

safety question manufacturers would undoubtedly be very careful 

about safety if we proceed with onboard. 

Attachments 
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Attendees EPA-NHTSA Meeting 

Scott %, York 

Paul Yoshida 

Ralph Hitchcock 

Mike Brownlee 

John Anderson 

Chet France 

Glenn Passavant 

Don Zinger 

Jeff Quandt 

Art Neill 

Barry Felrice 

Erica Jones 

John Womack 

George Parker 

1/12/88 

NHTSA/ODI 

NHTSA/ODI 

NHTSA 

NHTSA 

EPA 

EPA 

EPA . 

EPA-DC 

ODI 

ODI 

NHTSA 

NHTSA 

NHTSA 

NHTSA