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OAR Box 1142 

Prepped by Ollie Stewart 

Document Number: 

7) IV-F-5 

Docket Number: 

A-87-11 

Printed 4/23/2008 10:21:21 AM Sheet 7 of 30 
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MV-F-5 

nPT - ? IS"' 

^ ^ CHRYSLER 

I V f MOTORS 

Chrysler Motors Corporation 

Statement by Gordon E. Allardyce, Manager of Environmental & Energy Regulatory 

Planning, Chrysler Corporation. EPA Hearing on Refueling Emission 

Regulations. 

Romulus, Michigan September 26. 1991 

Chrysler is pleased to have the opportunity to present its views at this EPA 

hearing concerning the safety issues associated with onboard refueling vapor 

recovery (ORVR) systems. Our comments today supplement those we submitted in 

response to the August 19, 1987 NPRM on the relative merits of vehicle onboard 

systems versus Stage II gasoline pump systems for controlling refueling 

emissions. 

At the 1987 hearing, Chrysler challenged EPA's analysis favoring onboard 

controls primarily because it erroneously excluded an analysis of the 

increased risk to fuel system integrity. We urged EPA to consider the entire 

matter again. It was our belief that further analysis would show onboard 

systems are not a reasonable or appropriate approach to controlling refueling 

emissions under any circumstances. 

Since that time, a number of important events relevant to this issue have 

occurred. Foremost was the Clean Air Act Amendments (CAAA) of 1990. We were 

pleased to see the entire matter of refueling emissions considered by the 

Congress in legislative debates, with EPA as a key participant. As a result, 

the Congress included in the Amendments a requirement that EPA consult with 

the DOT regarding the safety of onboard systems in light of provisions 

prohibiting use of devices that cause unreasonable risk to public safety. 

Highland Park Ml 48288-1118 
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Today, we have before us the results of the DOT (NHTSA) study on onboard 

refueling systems. It confirms Chrysler's continuing concern that these 

systems unreasonably increase safety risks to vehicle occupants. A growing 

body of studies and reports corroborates the NHTSA's findings. 

Fortunately, the Congress provided for alternatives by requiring that Stage II 

systems be used in many ozone noncompliance regions of the country. We 

recognize that refueling emissions, though small in relation to other sources 

of volatile organic compounds (VOCs), nevertheless contribute to the overall 

inventory, and that controls concentrated in problem regions can contribute 

toward achieving compliance. Stage II systems are ideal for that purpose. 

They can be installed in a short period of time and immediately control all 

refueling emissions at the source. In contrast, the introduction of ORVR 

through the sale of new vehicles and the turnover of the current fleet is a 

much slower process. We believe that if it is worthwhile to control these 

emissions at all, then it is clear that Stage II is a superior approach. 

In my following comments I will present a summary of Chrysler's position on 

this issue which is of vital importance to our company and, most importantly, 

to our customers and their families. Chrysler has a moral obligation to 

oppose any regulatory requirement that may compromise the integrity of our 

vehicles and, as indicated by NHTSA, will increase the safety risk to 

occupants. 
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I will explain our position as follows: 

o First, why Chrysler believes that onboard systems cause an unreasonable 

risk to public safety; 

o Second, why EPA must conclude that onboard vapor recovery controls cause 

an increased risk to public safety; 

o Third, why EPA must conclude that ORVR is an unreasonable risk to safety 

because a safe alternative is available; 

o Fourth, why Stage II systems are superior alternatives to onboard 

systems; 

o Fifth, Chrysler's recommendations for EPA's further actions on this 

important issue. 
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1. Chrysler believes that onboard systems cause an unreasonable risk to 

public safetv. 

Chrysler continues to believe that mandated onboard vapor recovery 

systems cause an unreasonable risk to the safety of our customers. This 

position is based on the fact that systems needed to meet the proposed 

standard are inherently less safe due to their complexity. 

Chrysler has been working on the development of onboard refueling 

emission control systems since 1984. Our eighth generation system as it 

stands today is greatly superior to our initial design. Though proud of 

their progress, our engineers concede that serious problems remain. 

The issue is the increased risk to safe operation of the vehicle, 

specifically, the increased risk of fires. However, problems with 

durability, driveability, and effects of proposed exhaust and 

evaporative requirements must also be addressed. 

Some critics of the auto industry claim that engineering an onboard 

system should be a simple task. Their basic description of an onboard 

system is that of an evaporative control system with a larger canister. 

That Is a misconception. 

We know from experience that an effective onboard system will be much 

more complex. The heart of our system is a new filler tube refueling 

module designed specifically to control the routing of the refueling 
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vapors to the canister. Incorporated in the refueling module is a 

nozzle sealing device, a refueling event device, a pressure relief 

device, provisions for nozzle shut off and liquid carryover protection, 

and a large vapor connection to the canister. Additional and larger 

lines, connections, valves, fittings and clamps are also required, as 

well as an additional opening in the fuel tank to accommodate the 

additional hardware. And, of course, a much larger charcoal canister 

will be required. 

The location and space needed for a large canister presents a design 

challenge. In most vehicles, the underhood space used for the current 

evaporative canister would not be sufficient for the larger onboard 

canister. Rearward locations on the vehicle are the only alternatives, 

but fuel system vulnerability may be increased. This means trunk space 

or fuel tank capacity may be lost to provide space for the canister. 

While there is no indication that canisters have been the cause of fires 

in our vehicles, the canister can act as a secondary accelerant if a 

fire is present. 

The added complexity of the onboard system will cause compliance with 

MVSS 301 Fuel System Integrity requirements to be a major obstacle. 

Extensive changes in the fuel tank and filler tube connections and the 

number of added components also raise Chrysler's concern for potential 

fuel spillage in the event of an accident. The consequence of including 

the added complexity of this system in a vehicle is a greatly increased 

potential for fuel or vapor leakage in an accident. The filler tube 
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refueling module is needed to close off the vent line in such an event. 

If the module were to be sheared off in a side impact, a leak could 

occur. And leaks could also result from any of the connection points on 

the fuel tank needed for additional hardware. 

Onboard system durability remains a formidable obstacle. A useful-life 

requirement of 10 years and 100,000 miles for passenger cars, and longer 

for trucks, is required. This is a major undertaking for designers of 

this new complex system. We will have to conduct a lengthy test program 

on each of the different classes of our vehicles to assure that all 

components survive and continue to function properly. Even then, of 

course, all our best efforts may be defeated by tampering, a significant 

obstacle to ensuring proper safety and emission control. 

During our development of ORVR systems, we also studied EPA's "simple 

system" in hope of finding some innovative features to use in mitigating 

the problems with our systems. The results were disappointing. 

Although it performs the basic function of capturing refueling emissions 

under controlled laboratory conditions, our engineers concluded that it 

needs a lot of work to have any chance of being even marginally 

acceptable under real world conditions. 

Briefly, our concerns with the EPA simple system include an increased 

difficulty in refueling, spitback, and poor operation during high 

ambient conditions. Chrysler's testing revealed a high vapor generation 

problem. Although a few problems can be alleviated, this requires 
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additional hardware and cost. These same drawbacks were also noted by 

NHTSA in their test of a simple system. 

NHTSA also listed driveability as a safety issue. While testing a 

vehicle equipped with the API onboard system, NHTSA experienced 

driveability problems that they characterized as "a serious safety 

concern." Serious driveability problems will be further exacerbated as 

stricter evaporative controls and ever tighter exhaust emissions 

standards are implemented. Taking all of these concerns into 

consideration, NHTSA concluded that a simple system does not necessarily 

mean that it is a safer system. 

Chrysler engineers continue to search for a system that will minimize 

the increased safety risks of onboard systems. The risk to safe 

operation of the vehicle is threatened due to the increased size and 

complexity of the system. Chrysler believes this increased risk is 

unnecessary. 

2. The EPA must conclude that onboard vapor recovery controls cause an 

increased risk to public safetv. 

The Congress clearly expressed their concern about the safety of onboard 

refueling emission control systems as evidenced by the language of 

section 202(a)(6). The EPA Administrator was specifically directed to 

consult with the Secretary of Transportation regarding the safety of 

these systems. In response, NHTSA concluded that, 
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"ORVR systems would increase the risk of 

fire and hence result in increased safety 

risk compared to current vehicles." 

NHTSA evaluated the influence of increasing system complexity by 

comparing vehicles with early, simple vapor control systems with 

vehicles not having these systems. NHTSA found that vapor control 

systems have shown an increase in fire frequency over pre-vapor control 

vehicles. Despite years of production, vapor control systems as 

recently as 1991 model year have been the subject of recalls because of 

potential fire situations. NHTSA is concerned that onboard system fires 

will be more intense and self sustaining because of the presence of a 

greater quantity of highly flammable material available in larger 

canisters needed for the proposed ORVR systems. 

For 1975-1988, NHTSA reported the annual average number of injuries in 

motor vehicle crashes involving fires as numbering 13,000, with 10 

percent of them being fatal. Sixty-five percent of the injuries were 

incapacitating. As previously reasoned, these numbers can only increase 

with onboard systems. 

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In the words of NHTSA, 

"... fires are a major safety concern. Clearly, any 

action, such as the implementation of ORVR systems, 

that could increase the potential for fire risk would 

have an adverse effect on safety." 

The magnitude of the numbers in any of the studies is debatable. The 

direction, however, is clear. Onboard controls increase safety risks. 

NHTSA further stated, 

"The complexity of an ORVR system results in an 

increased risk of component failure with resultant 

fire risk." 

Additionally, 

"Under ... conditions ... of ... motor vehicle crash, 

... ORVR refueling vapor recovery systems would result 

in a substantial Increase in fire potential. These 

occurrences result in an increased safety risk..." 

Chrysler believes the available evidence is irrefutable. ORVR systems 

cause an Increased risk to public safety. And the overwhelming weight 

of evidence must lead EPA to the same conclusion. 
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The EPA must conclude that ORVR is an unreasonable risk to safety 

because a safe alternative is available. 

Congress had great foresight in providing alternatives for protecting 

against refueling emissions by mandating Stage II systems in ozone 

noncompliance regions. We believe EPA should recognize that the public 

health is appropriately protected by this requirement. An added 

requirement along with its associated risks is not necessary. Further, 

Chrysler believes that EPA would be barred from requiring use of ORVR by 

provisions of Section 202(a)(4)(A) that states, 

"... no emission control device ... shall be used in a new motor 

vehicle ... if such device ... will cause or contribute to an 

unreasonable risk to public ... safety in its operation or 

function." 

Stage II control is an available and proven technology. Agencies, 

including the EPA, have concluded that "Stage II systems are safer than 

non-Stage II gasoline dispensing pumps." From its review of the 

literature, NHTSA cited "[a] unanimous conclusion that Stage II has a 

lower risk of service station fires than existing gasoline pumps." 

The technology for Stage II has evolved significantly since being 

introduced in San Diego in 1974. Washington D.C. implemented a Stage II 

program in the 1980s and many other local and state agencies have 

adopted Stage II regulations. What began as a somewhat clumsy, 

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difficult to use system, has evolved into a fifth generation device that 

is nearly transparent to the consumer. 

The technology is also durable and very effective in reducing refueling 

emissions. Third generation systems in California have been shown to 

have an actual in-use effectiveness of 90-95 percent. While EPA 

estimates in-use effectiveness of onboard to be 94 percent, 

Multinational Business Services projected only an 83 percent in-use 

effectiveness of ORVR when malmaintenance and tampering are considered. 

We believe EPA must take note of the effectiveness, durability and 

availability of Stage II when considering the overall strategy for 

refueling controls. 

Commenting on system effectiveness, NHTSA notes, 

"Implementation of Stage II would negate the need for 

ORVR systems, since the objective of capturing 

refueling vapors would be accomplished." 

NHTSA concluded that, 

"[their] finding of increased safety risk associated 

with ORVR systems, coupled with the lack of increased 

safety risk with Stage II, should be used by EPA in 

their regulation concerning ORVR installation." 

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The Agency must look to Section 202(a)(4)(B) and see that Stage II 

systems offer, 

"availability of other devices ... which may be used 

to conform to requirements ... without causing or 

contributing to ... unreasonable risk." 

With a safer, equally effective system available, we believe ORVR 

systems are by definition an unreasonable risk to public safety. 

Chrysler's conclusion in this regard is consistent with the MVMA's 

comments presented earlier today. We support the MVMA's position and 

contributed to its preparation. 

Stage II systems are superior alternatives to onboard svstems. 

Everyone agrees that there are only two potential means for controlling 

refueling emissions: Stage II systems and onboard systems. After 

several years of study and debate on the merits of each, an objective 

assessment will show Stage II systems to be clearly the superior 

approach. 

o Stage II systems cause no unreasonable risk to public health, 

welfare or safety. Onboard systems increase the safety risk. 

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P.M 

o Stage II is proven technology that is available and currently in 

service. Onboard has yet to be proven reliable. 

o Stage II systems are needed only in regions with ozone air quality 

problems. Onboard systems would be used on all vehicles 

everywhere. 

o Stage II systems can be installed quickly, within a few years. 

Onboard systems cannot be installed on all cars and light trucks 

until well into the next century. 

o Stage II controls will be required in many nonattainment areas 

where refueling control is needed. To require the redundant 

onboard systems will cost the nation billions of dollars. 

Stage II systems are available, technically proven, and inexpensive. 

The use of such systems has been supported broadly by consumer groups, 

environmental activists, and representatives of state and local 

governments (not to mention endorsement by the CAAA). With this set of 

facts in favor of Stage II systems, we do not see how the EPA can 

require onboard systems, either under any terms of the amended Act or on 

the basis of any other imperative or logic. 

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5. Chrysler's recommendations for the EPA's actions on this issue. 

In conclusion, Chrysler urges EPA to carefully consider the DOT 

findings, our comments, and those of the MVMA and its member companies. 

We believe the Agency must conclude from the overwhelming weight of 

evidence presented today, and under applicable provisions of the amended 

Act, that onboard systems cause an unreasonable risk to safety and, 

therefore, should not be mandated. 

Any decision to the contrary will increase the safety risk to vehicle 

occupants, especially since Congress has provided effective alternatives 

that give ample protection from the effects of refueling emissions. 

D0C19-GEA13 

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