p.1 

OAR Box 1830 

Prepped by Ollie Stewart 

Document Number: 

62) IV-C-28 

Docket Number: 

A-87-11 

Printed 11/13/2008 7:20:54 AM Sheet 62 of 232 
P.2 

DEC 30 

Kr. .lira Burnett, Chairman 

National Transportation Safety Board 

800 Independence Avenue SV 

Washington, DC 20594 

Dear Mr. Burnett» 

As you know, the Environmental Protection Agency recently 

publiehed a proposal to recuire new gasoline-powered vehicles 

to be equipped with onboard refueling emissions control 

hardware. In relation to this proposal, comments have been 

made indicating that onboard systems may pose eoane safety risk 

due to their increased complexity over current evaporative 

control systems. EPA is presently conducting an extensive 

safety analysis in an effort to address these concerns and we 

wish to solicit your input on a variety of specific issues 

related to the safety of onboard systems. 

The enclosed list represents eone of the eajor questions 

related to onboard safety which we are attempting to answer at 

this point In our analysis. However, we do not believe that 

any of these questions will be easy to resolve, and we are 

seeking input from you and others about how best to proceed. 

It is our desire to conduct a complete and thorough analysis, 

and to do that we desire suggestions from as broad a base of 

safety perspectives ae possible about how to approach these 

natters. We would value your giving serious thought to these 

issues and providing us with written suggestions. We woul^ 

especially appreciate such things as suggested methodologies we 

wight follow, sources of relevant data, or the identification 

of siwilar studies which have been done in the past. Any other 

input or suggestions you way have on how we might proceed with 

our safety analysis would also be appreciated. If you would 

find it useful, we would also be happy to rceet with you to 

discuss these issues in wore detail. 

SDSB;Mueller:DillinghaiB:2565PlyBiouth Rd:X275:12/14/87:ID|:0373w 

Last reviewed by Charles Gray:12A4/87 
P.3 

' • 

- 2 -

It is EPA's intent to address the onboard safety issue in 

as timely a manner as possible. Therefore, I woul<i apr-reciatryour prorept response to tnia letter. Pleaee seno *?ny comr-i^nts 

you have to Mr. P.ichard Wilson, Director of the Office of 

Mobile Sources, at the above address. 

Thank you very auch for your cooperation. 

Sincerely, 

j 

1 J. traig Potter 

| Assistant Administrator 

* for Air and Radiation 

i Enclosure 
P.4 

Questions Relate^ to Onboard Safety 

1. How do we assess the increase in safety risk (if any) that 

can be expected to result from the installation of onboard 

refueling control hardware? 

2. How do these risks compare in general with other safety 

risks and in particular with other fuel system changes 

(such as fuel injection)? 

3. What safety engineering solutions are available to 

eliminate or minimize these risks? 

4. How much leadtime is necessary to provide for necessary 

safety engineering? 

5. Row do we assess the benefit of eliminating existing 

safety risks which might occur in conjunction with onboard 

installation (e.g., excess canister capacity, changing 

from rear to side fill tanks, elimination of exposed vent 

lines)? 

6. How do we evaluate the benefits of the potential reduction 

in service stations safety risks (from reduced spillage 

and containment of vapors)? 

7. What safety benefits can we expect from the volatility 

rule? 
P.5 

DEC 3 0 1937 

Mr. Charles Hurley 

Vice President of Public Policy 

National Safety Council 

1050 17th Street, W.tf., Suite 770 

Washington, D.C. 20036 

Dear Mr. Hurley: 

As you know, the Environmental Protection Agency recently 

published a proposal to require new gasoline-powered vehicles 

to be equipped with onboard refueling emissions control 

hardware. In relation to this proposal, comments h*ve been 

made indicating that onboard systems nay pose some safety risk 

due to their increased complexity over current evaporative 

control systems. EPA is presently conducting an extensive 

safety analysis in an effort to address these concerns and we 

wish to solicit your input on a variety of specific issues 

related to the safety of onboard systems. 

The enclosed list represents some of the major Questions 

related to onboard safety which we are attempting to answer at 

this point in our analysis. However, we do not believe that 

any of these questions will be easy to resolve, and we are 

seeking input from you and others about how best to proceed. 

It is our desire to conduct a complete and thorough analysis, 

and to do that we desire suggestions from as broad a base of 

safety perspectives as possible about how to approach these 

matters. We would value your giving serious thought to these 

issues and providing us with written suggestions. We would 

especially appreciate such things as suggested methodologies we 

might follow, sources of relevant data, or the identification 

of similar studies which have been done in the past. Any other 

input or suggestions you »ay have on bow we eight proceed with 

our safety analysis would also be appreciated. If you would 

find lt useful, we would also be happy to meet with you to 

discuss these issues in more detail. 

SDSB:Mueller:Dillingham:2565Plymouth Rd.:X275:12/14/87:ID#5446W 

Last reviewed by Charles Gray:12/14/87 
P.6 

- 2 -

It is EPA's intent to address the onboard safety issue in 

as timely a manner as possible. Therefore, I would appreciate 

your prompt response to this letter. Please send any comments 

you have to Mr. Richard Wilson, Director of the Office of 

Mobile Sources, at the above address. In order for us to 

continue to keep you informed of developments in this area, it 

would be helpful to establish a primary contact in your 

organization. Please call Mr. Wilson's office (202-382-7645) 

with the name of a contact at your earliest convenience. 

Thank you very much for your cooperation. 

Sincerely, 

H 

J. Craig Potter 

Assistant Administrator 

for Air and Radiation 

Enclosure 
P.7 

Question**; R*»lste<- to Onboarr Safetv 

1. How do we assess the increase in safety ri?v* (if any) thp.t 

can be expected to result from th* Installation of onboard 

refueling control hardware? 

2. How do these risks compare in general with oth*r safety 

risks and in particular with other fuel system changes 

(such as fuel injection)? 

3. What safety engineering solutions are available to 

eliminate or minimise these ricks? 

4. How much leadtime is necessary to provide for necessary 

safety engineering? 

5. How do we assess the benefit of eliminating existir.esafety risks which might occur in conjunction with onboard 

installation (e.g., excess canister capacity, changing 

from rear to side fill tanks, elimination of exposed vent 

lines)? 

6. How do we evaluate the benefits of the potentlel reduction 

in service stations safety risks (from reduced soillege 

and containment of vapors)? 

7. What safety benefits can we expect fron the volatility 

rule? 
P.8 

DEC 3 0 

Mr. Brian O'Neill, President 

Insurance Institute for Highway Safety 

Watergate 600 

Washington, DC 20037 

Dear Mr. O'Heillt 

As you know, the Environmental Protection Agency recently 

published a proposal to recruire new gasoline-powered vehicles 

to be equipped with onboard refueling emissions control 

hardware. In relation to this proposal, comments have been 

made indicating that onboard systems may pose some safety risk 

due to their increased complexity over current evaporative 

control systems. EPA is presently conducting an extensive 

safety analysis in an effort to address these concerns and we 

wish to solicit your input on a variety of specific Issues 

related to the safety of onboard systems. 

The enclosed list represents some of the major questions 

related to onboard safety which we are attempting to answer at 

this point in our analysis. However, we do not believe that 

any of these questions will be easy to resolve, and we are 

seeking input from you and others about how best to proceed. 

It is our desire to conduct a complete and thorough analysis, 

and to do that we desire suggestions from as broad a base of 

safety perspectives as possible about how to approach these 

matters. We would value your giving serious thought to these 

issues and providing us with written suggestions. We would 

especially appreciate such things as suggested methodologies we 

might follow, sources of relevant data, or the identification 

of similar studies which have been done in the past. Any other 

input or suggestions you may have on how we might proceed with 

our safety analysis would also be appreciated. If you would 

find it useful, we would also be happy to meet with you to 

discuss these issues in more detail. 

SDSB:Mueller:Dillingham:2565Plymouth Rd.:X275:12/14/87:ID#5446W 

Last reviewed by Charles Gray:12/14/87 
P.9 

- 2 -

Tt is EPA's intent to addresr* the onboard safety if*5iK? in 

as timely a manner as possible. Therefore, I would aporeciste 

your prompt response to this letter. Please sen**! any comrrents 

you have to Mr. Richard Wilson, Director of the Office of 

Mobile Sources, at the above address. 

Thank you very much for your cooperation. 

Sincerely, 

H 

J. Craig Potter 

Assistant Administrator 

for Air and Radiation 

Enclosure 
P.10 

Questions Related to Onboard Safety 

1. How do we assess the increase in safety risk (if any) that 

can be expected to result from the installation of onboard 

refueling control hardware? 

2. How do these risks compare in general with other safety 

risks and in particular with other fuel system changes 

(such as fuel injection)? 

3. What safety engineering solutions are available to 

eliminate or minimize these risks? 

4. How much leadtime is necessary to provide for necessary 

safety engineering? 

5. How do we assess the benefit of eliminating existing 

safety risks which might occur in conjunction with onboard 

installation (e.g., excess canister capacity, changing 

from rear to side fill tanks, elimination of exposed vent 

lines)? 

6. How do we evaluate the benefits of the potential reduction 

in service stations safety risks (from reduced spillage 

and containment of vapors)? 

7. What safety benefits can we expect from the volatility 

rule? 

-
P.11 

SDSB:Mueller:Dillingham:2565Plvmouth Rd.:X275:I2/14/87:ID**446VT 

Last reviewed by Charles Gray:12/14/87 

DEC 3 0 

Mr. Clarence Ditlow 

Center for Auto Safety 

2001 S. Street WW, Suite 410 

Washington, DC 20009 

Dear Mr. Ditlowi 

As you know, the Environmental Protection Agency recently 

published a proposal to reouire new gasoline-powered vehicles 

to be equipped with onboard refueling emissions control 

hardware. In relation to this proposal, comments have been 

made indicating that onboard systems may po3e some safety risk 

due to their increased complexity over current evaporative 

control systems. EPA is presently conducting an extensive 

safety analysis in an effort to address these concerns and we 

wish to solicit your input on a variety of specific issues 

related to the safety of onboard systems. 

The enclosed list represents some of the major questions 

related to onboard safety which we are attempting to answer at 

this point in our analysis. However, we do not beliove that 

any of tnese questions will be easy to resolve, and we are 

seeking input from you and others about how best to proceed. 

It is our desire to conduct a complete and thorough analysis, 

and to do that we desire suggestions from as broad a base of 

safety perspectives as possible about how to approach thpse 

matters. We would value your giving serious thought to these 

issues and providing us with written suggestions. We would 

especially appreciate such things as suggested methodologies we 

might follow, sources of relevant data, or the identification 

of similar studies which have been done in the past. Any other 

input or suggestions you may have on how we might proceed with 

our safety analysis would also be appreciated. If you would 

find it useful, we would also be happy to meet with you to 

discuss these issues in more detail. 
P.12 

- 2 -

It is EPA's intent to addrsss the onboard safety issue in 

as timely a. manner as possible. Therefore, I woulc. aporeci:*5t.e 

your pror.pt response to this letter. Please sen'* snv comments 

you have to Mr. Richard Wilson, Director of the Office of 

Mobile Sources, at the above address. In order for us to 

continue to keep you informed of developments in this area, it 

would be helpful to establish a primary staff contact in your 

organization. Please call Mr. Wilson's office (202-382-7645) 

with the name of a contact at your earliest convenience. 

Thank you very much for your cooperation. 

Sincerely, 

J. Crai tt. g Potter 

Assistant Administrator 

for Air and Radiation 

Enclosure 
P.13 

Questions Related to Onboard Safetv 

1. How do we assess the increase in safety risk (if any) that 

can be expected to result from the installation of onboard 

refueling control hardware? 

2. How do theee risks compare in general with other safety 

risks and in particular with other fuel system changes 

(such as fuel injection)? 

3. What safety engineering solutions are available to 

eliminate or minimize these risks? 

4. How much leadtime is necessary to provide for necessary 

safety engineering? 

5. How do we assess the benefit of eliminating existing 

safety risks which might occur in conjunction with onboard 

installation (e.g., excess canister capacity, changing 

from rear to side fill tanks, elimination of exposed vent 

lines)? 

6. How do we evaluate the benefits of the potential reduction 

in service stations safety risks (from reduced spillage 

and containment of vapors)? 

7. What safety benefits can we expect from the volatility 

rule? 
P.14 

DEC 3 0 £ 

Mr. Eugene Schmidt 

National Fire Protection Association 

Batterymerch Park 

Oulncy, MA 02269 

Dear Mr. Schmidtt 

As you know, the Environmental Protection Agency recently 

published a proposal to reaulre new gasoline-powered vehicles 

to be equipped with onboard refueling emissions control 

hardware. In relation to this proposal, comments have been 

made indicating that onboard systems may pose some safety risk 

due to their increased complexity over current evaporative 

control systems. EPA is presently conducting an extensive 

safety analysis ln an effort to address these concerns and we 

wish to solicit your input on a variety of specific issues 

related to the safety of onboard systems. 

The enclosed list represents some of the major questions 

related to onboard safety which we are attempting to answer at 

this point in our analysis. However, we do not believe that 

any of these questions will be easy to resolve, and we are 

seeking Input from you and others about how best to proceed. 

It is our desire to conduct a complete and thorough analysis, 

and to do that we desire suggestions from as broad a base of 

safety perspectives as possible about how to approach these 

matters. We would value your giving serious thought to these 

issues and providing us with written suggestions. We would 

especially appreciate such things as suggested methodologies we 

might follow, sources of relevant data, or the identification 

of similar studies which have been done in the past. Any other 

input or suggestions you aay have on how we might proceed with 

our safety analysis would also be appreciated. If you would 

find it useful, we would also be happy to ceet with you to 

discuss these issues in more detail. 

SDSB:Mueller:Dillingham:2565Plymouth Rd.:X275:12/14/87:ID*5446W 

Last reviewed by Charles Gray:12/14/87 
P.15 

- 2 -

It is EPA's intent to adciress the onboard safety issue in 

as timely a manner as possible. Therefore, I vou3c appreciate 

your prompt response to this letter. Please send any corar.ents 

you have to Mr. Richard Wilson, Director of the Office of 

Mobile Sources, at the above address. 

Thank you very much for your cooperation, 

Sincerely, 

J. Craig Potter 

Assistant Administrator 

for Air and Radiation 

\ Enclosure 

1 

i 

i 

4 

I 
P.16 

Questions Related to Onboard Pefety 

1. How do we assess the increase in safety risk (if any) that 

can be expected to result froa the installation of onboard 

refueling control hardware? 

2. How do these risks compare in general with other safety 

risks and in particular with other fuel system changes 

(such as fuel injection)? 

3. What safety engineering solutions are available to 

eliminate or minimise these risks? 

4. How much leadtime is necessary to provide for necessary 

safety engineering? 

5. How do we assess the benefit of eliminating existing 

safety risks which might occur in conjunction with onboard 

installation (e.g., excess canister capacity, changing 

from rear to side fill tanks, elimination of exposed vent 

lines)? 

6. How do we evaluate the benefits of the potential reduction 

in service stations safety risks (from reduced spillage 

and containment of vapors)? 

7. What safety benefits can we expect from the volatility 

rule?