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OAR Box 1818 

Prepped by Ollie Stewart 

Document Number: 

28) ll-D-1 

Docket Number: 

A-87-11 

Printed 11/6/2008 3:12:44 PM Sheet 28 of 79 
A-mi Jf-0 -o\ 

#'Olo23 

Environmental and Safety The American Road 

Engineering Staff Dearborn, Michigan 48121 

Ford Motor Company 

June 17, 1986 

Mr. R. Fred Holbert 

U.S. Environmental Protection Agency 

2565 Plymouth Road 

Ann Arbor, MI 48105 

Dear Mr. Holbert: 

As I indicated in our telephone conversation of May 23, 1986, 

Ford has begun meeting with various suppliers in an attempt to pull 

together more detailed specifications for what it would take to do the 

onboard control of refueling vapors properly. Based on our initial 

contacts with fuel pump nozzle manufacturers, we are becoming more 

concerned by the multitude of fuel filler nozzles that are being used 

commercially and that without uniform standards trechanical fillpipe seals 

may not be feasible. These nozzles configurations have an effect on the 

amount of vapors generated, the efficiency of the seal mechanism and the 

fuel flow and shutoff characteristics. In order to help insure that the 

field efficiency of an onboard control system will approach the 

theoretical design efficiencies calculated by EPA and others, it appears 

now that some type of design standards will be required for nozzle 

configurations and that service stations would in all likelihood be 

required to install new nozzle spouts that conform to these uniform 

standards. 

These design standards should Include at a minimum a limit on 

fuel flow rate at the pump (as was discussed briefly at the April 10, 1986 

meeting in Ann Arbor), as well as specifications on length, diameter, 

position and angle of bends, position of latching mechanisms and controls 

on burrs and protrusions that could potentially damage the seal mechanism. 

The latter control is necessary because it appears now that the less 

efficient liquid seals may not be feasible for all vehicle configurations. 

Enclosed are scale drawings illustrating the nozzle end point 

and shutoff port positions for various nozzles placed in the fully 

inserted and latched position In a typical Ford filler pipe. The degree 

of variability is obvious and does contribute to difficulty in producing a 

fill pipe design which will flow fuel at a wide range of flow rates and 

shutoff automatically with no spitback. For example, it is not unusual 

for filler pipes to be capable of over 12 gallons per minute with one 

manufacturer's nozzle but just barely capable of meeting the CARB 

requirements at 8 gallons per minute with another design. There is no 
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point to optimizing the filling characteristics by modifying filler pipe 

designs to suit the "worst case" nozzle since this would inevitably lead 

to making another nozzle the worst case. The only rational approach is to 

tightly specify the nozzle configuration. 

It is hoped that this insight into some of the technical 

concerns surrounding our development efforts will result in better 

regulations. We would envision that EPA would also specify a particular 

nozzle for the certification test to insure consistency in measuring 

compliance. 

On a separate but somewhat related issue, we welcome your 

solicitation for details concerning bench aging techniques for stabilizing 

canisters for the test sequence. As indicated during our meeting, we 

believe that the repeatability of the test can be greatly improved by 

adopting these types of procedures. Our test laboratory is currently 

developing data to resolve some of the issues brought up at our meeting 

June 10, and we look forward to working with you to generate a more 

repeatable and streamlined test procedure. 

We will continue to keep you apprised of our findings and 

concerns and would appreciate it very much if you do the same. We are 

particularly interested in how EPA proposes to solve the safety concerns 

raised by NHTSA. 

WMK.10 
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PROPOSED ISO NOZZLE SmNDhRD 

ALLOWED NOYZLE POSITIONS 

( I50/TCZ2 ( SCI 6 / W&3/ Nil) 

1. LONG 5POUT SHORT LATCH SPRING 

2 LONG SPOl/T LONG LATCH SPRING 

3. SHORT SPOUT SHORT LATCH SPRIN& 

4 . SHORT SPOUT LONG LATCH SPRIWk 

NOTE: O DEMOTES SMUrOFF PORf POSIT/ON 
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FUELINL NOZZLE PD51TIDN 

1. E/WCO-WHEATOM 49/23 / 

2. OPW DC MAP 

3. C.A.R.B. 

NOTE! O DENOFE5 POSITION OF SHUT OFE PORT