EPA-AA-LDTP 78^-15

                             December 1978
                     Recommendation on Feasibility
                                  for
                     Onboard Refueling Loss Control
                                 NOTICE

Technical Reports do not  necessarily  represent  final EPA decisions
or positions.  They  are intended to present  technical  analysis of
issues using  data  which are  currently  available.    The  purpose in
the release of such reports  is  to  facilitate  the exchange of tech-
nical  information  and  to  inform  the  public  of  technical develop-
ments which may  form the  basis for a  final EPA decision, position
or regulatory action.
              Standards Development and Support Branch
                Emission Control Technology Division
            Office of Mobile Source Air Pollution Control
                 Office of Air, Noise and Radiation
                U.S. Environmental Protectioa Agency

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I.   Introduction

     Refueling loss hydrocarbon  emissions,  estimated  to be in the
range; of 4-5  g/gallon,  can  be  controlled  by use of control equip-
ment at the service station  (Stage  II  control) or by use of control
equipment  in  the vehicle (onboard  control).   As  required  by the
1977 amendments to the Clean Air Act, the Emission Control Techno-
logy Division (ECTD)  of  EPA has  reviewed  and  analyzed available
data on the feasibility and desirability of onboard refueling loss
control which will be discussed  in this report.   This  information
will be  combined  by  the Office  of Policy  Analysis with available
Stage II control  information to provide the basis  upon which the
Administrator may choose the best of the two strategies.

II.  Summary of Conclusions  and  Recommendations

     Several hardware demonstrations and paper studies, Ref. 1, 2,
have been conducted to determine  the technical feasibility and cost
effectiveness on  onboard refueling loss control.  Much  of the
current information is from the  American Petroleum Institute (API)
onboard demonstration program, Ref.  3.   Other current  information
was obtained from motor  vehicle manufacturers in response to a June
27, 1978 Federal Register (43FR  27892) request for relevant informa-
tion.   These  demonstrations and analyses deal with the state-of-
the-art emission control technology.

     Analysis of  this information  supports the  following conclu-
sions:

     1.   Onboard  refueling  loss  control  is  feasible  for light-
duty vehicles;

     2.   The most probable  control system uses hydrocarbon adsorp-
tion on  charcoal  (the same  strategy that is  used  for evaporative
emission control);

     3.   Control effectiveness   can be  as high at  97% but depends
especially upon the vehicle  fillpipe/service station nozzle inter-
face and upon control  technology  design;

     4.   An  analysis of  data  from three  fillpipe/nozzle concepts
(fillpipe  seals,   nozzle  seals,  and combination  fillpipe/nozzle
seals)  shows  that the  effectiveness  of  all three  concepts is
approximately equal.   Durability effects have  not been extensively
evaluated,  especially  for the nozzle seal concept;

     5.   A vapor/liquid pressure relief  valve  is  required to
protect the integrity  of the vehicle fuel tank during the refueling
process.  The pressure relief valve can be designed to  function on
the fuel nozzle, or it may be incorporated as  part of the fillpipe

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seal mechanism, which  would  be sealed-off by  the  fuel  cap during
vehicle operation.  Durability effects have not been evaluated for
either  the  fillpipe or  nozzle pressure relief.   ECTD  recommends
that the fillpipe/nozzle  sf:al and  pressure  relief be located on the
vehicle if onboard controls are required.

     6.   Cost to  the  consumer for  control of refueling losses on
light-duty vehicles will probably range around  $17/vehicle.   The
$17 estimate does not  include costs for a  seal or pressure relief.
Cost  for  a seal  and  pressure  relief,  if  used on  the  vehicle, is
estimated to  be  about $2.70.   The cost of  a seal on  the nozzle
should be the  same  as  the cost for a Stage II nozzle.   Except for
the as  yet  undefined  durability of the  interface  seal  no mainte-
nance costs are expected;

     7.   The  feasibility of controlling  refueling loss  emission
from gasoline fueled trucks and diesel  fueled vehicles has not been
evaluated to date.  Technical feasibility and cost effectiveness of
controlling these sources should be determined;

     8.   Minor increases in  CO exhaust emissions seen for some of
the vehicles can probably be  controlled by minor changes to either
the refueling loss control system or to the  exhaust  emission
control system.  The ability  to certify a vehicle to a 3.4 g/mi CO
standard to 50,000 miles  should not be  seriously  impaired;

     9.   The use  of  a  bladder in  the fuel tank appears  to  be  a
viable  alternative  control strategy,  but  some  problems  exist and
technical feasibility  is  yet  to be demonstrated.

    10.   Considering  the lead time needed for regulation develop-
ment  and review  within EPA and  the  lead time required by the
industry for development  and application  of technology, implemen-
tation of onboard controls cannot  occur  before  1983.

     ECTD recommends  that  the choice between  onboard control and
Stage  II  control of  refueling loss emissions  be  based  upon the
relative cost  effectiveness  of  the two  strategies  for  the  same
overall level of  control  and  air quality considerations.

     It is recommended that methods of reducing the cost of onboard
refueling  control  systems be  examined  by  considering  tradeoffs
between control system capacity and  cost.    It  may be possible to
sacrifice  some  capacity  that  is  only required under  infrequent
conditions and  achieve  proportionately  more  significant  cost
savings.

     The feasibility  and  desirability of  control  of refueling
losses  from  light and heavy-duty gasoline fueled  trucks  and  from
diesel  fueled  vehicles should be  considered.   EPA  should support
the development of  the bladder tank alternative for refueling loss

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control strategy.  If  regulations  are  to  be developed for onboard
refueling  loss  control,  a certification  test  procedure  must  be
developed.

III. Review of Available Information

     The data and information summarized in this section are based
on  material  submitted  to EPA by  the  American Petroleum Institute
and information received  in  response  to a request for information
(43FR 27892) published  on June 27,  1978.  The API material, Ref. 3,
is  the result of their most recent study to assess onboard techni-
cal feasibility and compare the  cost effectiveness of  onboard
refueling controls  and  Stage  II  controls.  This study was initiated
at  the urging of EPA.   Respondents to the Federal Register notice
include  General Motors, Ford, and  AMC.  The  API,  GM, and  Ford
information contain data  from tests with onboard control hardware.
All respondents, with  the exception  of AMC, submitted information
on  the cost  and the  desirability of onboard  control systems.

     1.   API Onboard Study

     The API Onboard  Control  Study  was  structured to  address
questions regarding onboard feasibility which  were posed to API in
a December 1977 meeting with  EPA.   The  API study consisted of three
tasks:  a vehicle concept demonstration, a fillpipe/nozzle concept
demonstration,  and  a  cost/benefit analysis.   Exxon  Research  and
Engineering  Company  and  Mobil  Research and  Development Corpora-
tion were  the API contractors  for the vehicle  concept demonstra-
tion.   Atlantic  Richfield Company was  the API  contractor  for the
fillpipe/ nozzle concept demonstration.  Exxon R & E completed the
cost/benefit analysis for API.

     The vehicle concept modification task Tiad the following design
objectives:

     1)   Minimum 90% overall refueling vapor recovery.

     2)   No significant effect  on  exhaust emissions.

     3)   No significant effect  on  evaporative emissions.

     4)   Design should be durable, practical, and safe.

     The  fillpipe/nozzle demonstration had  the  following objec-
tives:

     1)   90% overall vapor control.

     2)   Compatible with existing  vehicle population.

     3)   Compatible with existing  Stage II nozzles.

     4)   Design should be durable, practical, and safe.

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     A review of the three API contractor's  activities  is  presented
below.

     Test procedure guidelines for  the  API work were discussed at a
meeting with API  on March 15,  1978.   Important  procedural guide-
lines which  resulted  from that meeting are summarized as  follows:

     Fuel specification:   Indolene unleaded test fuel was  used  for
all exhaust,  evaporative,  and refueling loss measurements.

     Dispensed fuel quantity:  Test vehicles were refueled to 100%
of capacity from a condition  of 10% tank capacity.

     Fuel tank temperature/Dispensed fuel temperature:  The dispen-
sed  fuel  temperature  was selected  to  be representative  of summer
refueling conditions in Los Angeles during the month of August, or
about 85°F.  The fuel temperature  in the tank was also selected to
be 85°F.  Thus, the refueling was  isothermal.*

     Purge Cycle:    For the  purposes  of the  API study,  the only
driving cycle  which was  used  for  purging  the  refueling  loss can-
ister is the  LA-4 cycle.

     Individually,  these  test procedure guidelines  are considered
to  represent  real world situations  in a high oxidant.forming
location, e.g., Los Angeles  during the  month of August.   Collec-
tively, these  guidelines  imply that the API vehicles demonstrated
the  feasibility of onboard control systems in an approximate worst
case  condition.    This  reasoning  is  consistent with, earlier  EPA
recommendations  that API  err on the conservative side during
their study.    For  example, Exxon  used  the following test  sequence
to quantify the exhaust emissions  interaction between the  refueling
control system and the exhaust emission control system:

     1)   Load ECS (Evaporative Control  System) canister to break-
through .

     2)   Condition the vehicle by  driving 2 LA-4's.

     3)   Soak vehicle overnight.

     4)   Load  RCS  (Refueling Control   System)  canister  to break-
through.
*This represents  a  conservative  situation  as survey data, Ref. 4,
 show  that  nationwide  dispensed  fuel  temperatures  are  typically
 lower  than  tank fuel  temperatures,  thereby representing a vapor
 shrinkage situation during the refueling process.

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     5)   Condition  the vehicle by  driving  5 to 6  simulated  city
driving days (4.7 LA-4's with one hour hot  soaks  in between and  a
diurnal at  the  end  of  the  day)  to consume 90% of the fuel in the
tank.

     6)   Drain the  fuel tank.

     7)   Block RCS  canister line.

     8)   Fill  tank  to  40%, unblock RSC canister lines.

     9)   Conduct diurnal evaporative test in SHED.

     10)  Drain tank to 10%.

     11)  Bring fuel tank liquid and vapor to  equilibrium at  85°F
(shake the vehicle to accelerate the equilibrium process).

     12)   Refuel the  vehicle  to 100%  in  SHED with 85°F fuel.

     13)  FTP

     14)  Hot soak evaporative test in SHED.

     Obviously,  these test procedures do not lend themselves  to  a
routine laboratory certification test procedure.  They do, however,
permit  an  approximation of how an  onboard  control system would
function in a severe "real-world" situation.

Exxon

     Exxon  assumed  the responsibilty  for  modifying  four  test
vehicles.   Their vehicles included the following:

     1978 Chevrolet  Caprice

     1978 Ford  Pinto

     1978 Plymouth Volare*

     1978 Chevrolet  Chevette

     All vehicles are designed to  comply  with 1978 California
exhaust and evaporative  emission  standards  (.41 HC,  9.0  CO,
1.5 NOx, 6.0 Evap).
* Vehicle  subsequently  dropped  from test program because of high
baseline NOx levels.

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                            Table 1




      FTP Exhaust and Evaporative Emissions - Caprice

Baseline Configuration
Modified Configuration
Percent


n=4
Ave.
S.D.
n=4
Ave.
S.D.
Change

FTP Exhaust

Baseline Configuration
Modified Configuration

n=4
Ave.
S.D.
n=4
Ave.
S.D.
Exhaust (g/mi)
HC CO
0.345 6.48
0.033 0.56
0.338 7.10
0.010 0.59
-2 +10
Table
and Evaporative
Exhaust (g/mi)
HC CO
0.187 1.70
0.021 0.10
0.217 1.83
0.006 0.12
NOx
0.95
0.06
0.86
0.05
-10
2
Emissions
NOx
0.77
0.01
0.79
0.07
Diurnal
n*3
0.8
0.4
n=3
1.1
0.3


- Pinto
Diurnal
n*=3
1.0
0.2
n=3
0.9
0.3
Evap. (g)
Hot Soak
2.1
0.4
2.1
0.2



Evap. (g)
Hot Soak
2.5
0.3
2.4
0.5
Total
2.9
0.8
3.1
0.4
+7


Total
3.5
C.4
3.3
0.7
Percent Change
+16
+8
-6

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                                              Table 3
                            FTP Exhaust and Evaporative Emissions - Chevette
Exhaust g/mi)

Baseline Configuration


Modified Configuration


Percent

n=3
Ave.
S.D.
n=3
Ave.
S.D.
Change
HC

0.27
0.02

0.26
0.05
-4
CO

3.7
0.32

3.6
0.28
-3
NOx

1.09
0.04

1.13
—
+4
Evap. (g)
Diurnal
n = 4
0.8
0.36

0.3
0.08

Hot Soak

2.6
0.79

1.2
0.15

Total

3.4
1.03

1.5
0.15
-56
                                                                                                           00
*FTP + 3 Hot Start LA-4s

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           Table 4




 Engine-Out Emissions - Caprice
FTP (g/mi) City Driving
HC CO NOx HC CO
Baseline Configuration n=5
Ave. 1.28 26.42 1.17 41.86 733.86
S.D. 0.05 0.72 0.04 2.00 39.27
Modified Configuration n=5
Ave. 1.29 32.04 1.17 42.32 853.52
S.D. 0.09 2.4 0.04 1.90 61.51
Percent Change +1 +21 — +1 +16
*FTP + 3 Hot Start LA-4s
Table 5
Engine-Out Emissions - Pinto
FTP (g/mi)
HC CO NOx
Baseline Configuration n=4
Ave. 1.83 52.7 1.25
S.D. 0.06 1.2 0.08
Modified Configuration n=4
Ave. 1.77 60.1 1.12
S.D. 0.09 0.8 0.04
Day* (g)
NOx
38.68
1.17
41.34
3.17
+7

Percent Change
-3
+14
-10

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          Table 6




Refueling Loss Measurements

Potential HC (g)
SHED HC (g) Percent Control Effectiveness

Caprice


Ave.
Pinto



Ave.
Chevette




Ave.
93.4
91.0
89.3
91.2

51.0
59.3
53.1
54.5

62.5
65.5
60.1
64.6
63.2
0.4
0.4
0.3
0.4

1.0
1.3
1.1
1.1

0.5
1.5
1.1
1.6
1.2



99




98





98

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                                                  Table 7




                                             Benzene Emissions
          Potential Benzene Emissions*SHED Measurements (ppm)
                                  Measured Loss*SHED Measurements(ppm)
Caprice




Pinto
3.0




2.7
<0.05




<0.05
*A11 refueling at 85°F, RVP 9 Ibs., Benzene content 0.7%.

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                                 12

      The  Caprice  is  a  conventional  oxidation  catalyst  vehicle,
 while the Pinto is a three-way catalyst  vehicle with feedback
 carburetor  control.    Vehicle  descriptions  and complete  refueling
 loss  control system  descriptions  are presented  in  Table A-l  and
 Figure  A-l  of the Appendix.   The  refueling loss canisters  in  the
 Caprice, Pinto and Chevette are described as follows:

               RCS
 Vehicle   Carbon Volume   Carbon Mass   Carbon Type*    Location

 Caprice       5.0*           1800 g       BLP-F3       Underhood

 Pinto        3.0*           1100 g       BLP-F3       Underhood

 Chevette      3.0*           1100 g       BLP-F3         Trunk
 *  Same carbon currently used for controlling evaporative  emissions.

     The  Exxon  exhaust and evporative emission test^ results  which
 compare  baseline and  modified  versions  of  the Caprice,  Pinto  and
 Chevette  are summarized  in Tables  1,  2  and  3.   Engine-out  data  are
 summarized  in  Tables 4  and  5.   Refueling loss effectiveness test
 results  are summarized in Table  6.   All Exxon refueling  emission
 tests  assumed a  no-leak  seal  at the  fillpipe/nozzle  interface.   In
 laboratory  practice  this was  achieved  with leak free connections
 from the  fuel nozzle to the fillpipe.

     Benzene emissions were measured during  the refueling loss SHED
 tests  with  both  the  Caprice  and Pinto.   These  results are  summari-
 zed  in Table 7.   The  Exxon data  indicate that benzene  control  is
 directly  proportional  to  refueling loss  control   effectiveness,
 although  current  benzene levels in the SHED are at  the  detectable
 limit  of  the instrumentation.

     Table  8 presents Exxon's manufacturer  cost  estimates  for
 onboard  control  systems  for  the  1978  Caprice and  Pinto.    These
 estimates do not  include the costs for fillpipe sealing devices  and
 pressure  reliefs, and  this hardware  represents an additional cost
 of approximately  $1.50 (manufacturer's  cost) per vehicle.   Exxon's
 cost  estimates  assume  an estimated $.50 credit for  downsizing  the
,ECS canister,  which  in the  two canister  system,  controls only
 carburetor  losses.   Exxon  estimates  the incremental cost   of two-
 canister  refueling  control  systems to range from $8.25  to  $10.53.
 This estimate includes the above mentioned $.50 credit but  does  not
 include  the $1.50 cost for the  fillpipe seal  and pressure  relief.
 The  corresponding cost range  for single  canister refueling  control
 systems  is  $6.75  to  $9.00.   For light-duty  trucks, Exxon estimates
 a  cost range  of from $12 (large single  canister)  to $20 (two
 separate  refueling  loss  canisters  or  multistage  purge systems).

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                                  13


                               Table 8

                  COST ESTIMATES FOR ONBOARD SYSTEMS*1'
        (2)
Charcoal^ '
Canister and Valves

Tank Modifications

Hoses and Tubing

Assembling and Ins
      @ $20.00/hr.


Credit for Downsized

s(3)
(4)
)
talling(6)

ed ( }
>l System^ '
Caprice
$4.96
2.50
0.50
1.57

1.50
$11.03
$0.50
$10.53
Pinto
$3.03
2.00
0.50
1.72

1.50
$8.75
$0.50
$8.25
(1)  Estimates are made for cost to manufacturer for large volume
     production.

(2)  1800 g for the Caprice canister, 1100 g for the Pinto
     canister at $1.25/ibm (Calgon BPL-F3 carbon).

(3)  Plastic container and valves.

(4)  Larger size float/roll-over valve.

(5)  3/4" vapor line from fuel tank to canister, 3/8" purge line.
     EPDM tubing for vacuum control lines.

(6)  Additional 4.5 minutes labor at $20/hour.

(7)  Reduced size evaporative control canister.

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     Exxon estimates the  average  cost  for onboard control systems
to  be  $9/vehicle.    This  is  based  on the  following assumptions:

     1)   Onboard systems  are designed to control refueling emis-
sions from light duty vehicles with  an average fuel tank size of 17
gallons  refueled  to 100% capacity  from   a  condition of  10%  tank
capacity.  The onboard systems are designed to control hydrocarbon
emissions at  a level of  6  g/gal.

     2)   70% of  light-duty  vehicles  and single  tank  light-duty
trucks  are assumed to use single canister (evap  + refueling)
systems.

     3)   30% of  light-duty  vehicles  and single  tank  light-duty
trucks are assumed  to use  two  canister systems.

     4)   Light  duty trucks with  dual or  large  fuel  tanks consti-
tute approximately  10%  of the light-duty  vehicle light-duty truck
population.

     In  summary, Exxon  finds  that  onboard  refueling controls for
light-duty vehicles are  a  technically feasible, practical, and cost
effective alternative to Stage II vapor recovery.  They are of the
opinion that the  same  may also  be said for light-duty trucks.

Mobil       '

     Mobil R&D has modified a 1978  Pontiac  Sunbird for  control of
refueling  losses.   This vehicle  has  a  three-way  catalyst  with  a
feedback carburetor control  system,  and is certified  for complaince
with  California exhaust  and  evaporative  emission standards.
This modified vehicle  uses  a single canister which  contains  1550
grams of Calgo'n BLP-F3 carbon.  The complete vehicle and refueling
loss  control  system descriptions are  presented   in  the  Appendix.
Table 9  presents comparisons  of exhaust  and evaporative emissions
from  the Sunbird for the baseline  and modified  configurations;  a
summary  of the  refueling  emission data is presented  in  Table 10.

     Similar   to Exxon's  findings,  Mobil  states that their  test
results  have demonstrated  that onboard controls  are a feasible and
desirable  method  of controlling  refueling  losses from light-duty
vehicles and  light-duty  trucks.

Atlantic Richfield  Company

     One  of  the requirements for  the  operation of  an  effective
refueling loss control  system  is  the existence of  a no-leak seal at
the  fillpipe nozzle interface.  Atlantic Richfield (ARCO) has
developed working  prototypes  of  fillpipe  seals and nozzles.   ARCO
has  investigated three  types  of  sealing  systems.   They  included:

     1)   Modification  of the vehicle  fillpipe   to achieve  a  seal
when used with conventional  lead-free nozzles.

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                                               Table 9
                    FTP Exhaust and Evaporative Emission Comparisons ~ Sunbird
Exhaust (g/mi)

Baseline Configuration
Modified Configuration
Percent

n=9
Ave.
S.D.
n-6
Ave.
S.D.
Change
HC
0.39
0.03
0.40
0.03
+3
CO
6.41
0.91
6.35
0.74
-1
NOx
0.98
0.07
0.99
0.03
+1
Diurnal
n=2
0.87
030
n=4
0.72
0.23

Evap. (g)
Hot Soak
1.12
0.13
1.27
0.37

Total
2.00*
0.34
2.11
0.56
+6
* Includes five tests at low mileage where individual diurnal and hot soak results are not available.
                                               Table 10

                              Refueling Loss Measurements — Sunbird
Fuel Dispensed (gal)
16.4
15.3
16.9
17.1
HC Collected in Canister (g)*
85
73
113
109
Refueling Emissions
SHED Measurements (g/gal)
0.18
0.02
0.44
0.36
Control
Efficiency (%)
97
99
94
95
     * Canister purged from a nominal working capacity load of 210 g.
       Fuel of nominal 9 Ibs. RVP.
       8 gpm refueling rate, using modified Stage II nozzle.

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                                 16


     2)   Modifications  to both the fillpipe and lead-free nozzle.

     3)   Modification  of  a  Stage  II  vapor recovery  nozzle.

     A description  of  each  type of  seal and a  summary of the
durability data  collected with each  system are  presented below:

     Fillpipe seals:   Two types  of  fillpipe seals have  been ex-
amined.   They are a  rotary  grease seal  (similar  to  grease  seals
used  on  rotating machinery  shafts),  and  a  doughnut  shaped  seal.
The material types for these  two seals  are a  compounded nitrile and
thermosetting urethane,  respectively.   More complete  descriptions
of  these  seals,  including  durability  data,  are   found  in Figure
A—5 and Tables A—2 and A-3 of the Appendix.  Appproximately thirty
days of durability tests with  both types of seals have demonstrated
that  the rotary seal is more effective, basically due to the
absence of expansion  problems when exposed to  gasoline liquid and
vapor  atmospheres.   The seal  effectiveness of  the prototype  fill-
pipe and nozzle  hardware  are  determined by a bench test apparatus
which  pressurizes  a  particular system  and measures  the resulting
leak  rates.    Seal effectiveness  calculations  are determined  by
dividing the leak rate by  a nominal fueling rate (assumed to be 7.5
gallons/min.}.   Durability  tests  conducted  with   the  rotary  seal
have demonstrated that the rotary seal  is  effective after 700-1000
nozzle insertions, which  correspond  to the life  of  the vehicle.

     Combination fillpipe/nozzle seals:    These  systems  consist  of
connecting parts on both the  fillpipe  and nozzle.   Figure A-6 is an
example of a  prototype design  evaluated by ARCO.   Durability test
results with these systems are  similar  to results obtained with the
rotary seal.

     Nozzle Modification:    Working  prototypes  of vapor recovery
nozzles,  modified  for refueling  loss  control,  have been developed
by OPW and Emco Wheatpn and evaluated  by ARCO for effectiveness and
durability.    These nozzles  are  designed  to seal  on  standardized
fillpipes.   The modified vapor  recovery nozzles incorporate a
pressure relief valve, which  is  located at the vapor return exit or
cast  into  the nozzle body,  which  is  designed  to  open at approxi-
mately  14-17  in. water pressure*,  thereby  permitting  the nozzle
to  refuel  onboard control vehicles  and  in-use vehicles.   Nozzle
durability data  are very  limited  but  one nozzle has  been inserted
and  latched  7500 times,  representatitve of a year's  service  at a
high  volume  station,  and showed  a seal  effectiveness  of greater
than 99%.

     ARCO concludes  that  the  preferred seal techniques are either
the  fillpipe  seal  method  or  the combination fillpipe/nozzle  seal.
* Refueling  loss  control  systems designed by Exxon  and  Mobil are
  designed to operate at fill  pressures  of'less than 4 in. of water
  pressure.

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                                 17
No statements are made  as  to the desired location of  the  pressure
relief mechanism.

     2.   Vehicle  Manufacturer Comments

General Motors

     GM's March  1978 submission to EPA,  Ref.  5,   presents a summary
of their work on  the control of diurnal evaporative emissions  and
refueling losses  through the  use of  fuel  tank  bladders.    Their
information   represents   the  most complete  study of  bladder  tank
feasibility  known to EPA.   Regarding bladder tank feasibility,  GM
admits bladder tanks have the potential  for  a substantial amount of
emissions control, but  they  are  of the opinion that the technical
problems which must  be  solved before bladder tanks are capable of
demonstrating the same  degree of  control  effectiveness as  carbon
adsorption systems,  do not permit this  technology to be considered
applicable in the same  time  frame as  the  other candidate  control
technologies, including  Stage II  control  methods.    The  March  15
submission states that the major  problem with controlling  evapora-
tive and refueling emissions  with the bladder tank is  the formation
of gasoline  vapor mixtures  from  dissolved  air  in  gasoline.   The
temperature  at which the vapor pressure  of the dissolved air equals
the partial  pressure  of  air  in the vapor space  (bubble formation)
is known to  be  very sensitive to the quantity of dissolved  air in
gasoline.   Other  design problems  include  pressure relief  Valves,
and a puncture resistant fuel gaging  indicator.

     The March,  1978  submission  presents calculations  showing that
the additional weight  of the  components  of an onboard  control
system  would  cancel  out  any potential energy  saving which  would
result from the  combustion of the refueling  vapors.

     The June, 1978  submission, Ref.  6, is basically a cost  effec-
tiveness study  comparing onboard and Stage II cost effectiveness.

     GM's March,  1978  submission estimates  the cost of  typical
carbon  adsorption onboard control systems  to range  from  $11  for
single canister systems, to  $15  for  two-canister systems.    The GM
estimates represent  costs to  the consumer.   The June,  1978 submis-
sion  indicates  that  these  figures must be  increased  by $5-$9  per
vehicle  to  cover  the costs for an enlarged  vapor/liquid separator
and additional  carbon.   Thus, GM's  estimates are now $16-$24  per
vehicle.  These estimates  do not include  costs  for fillpipe seals
or pressure reliefs   as GM assumes that  this  hardware would be part
of the service station fuel dispensing equipment.

     GM has  stated  that  both onboard and service station  controls
are technically feasible methods  of  reducing refueling loss emis-
sions.   However, GM's cost effectiveness calculations  find onboard
controls to  be  much  less  cost effective than  Stage  II vapor  re-

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                                   18
covery.    Rather,  GM  emphasizes  certain  technical concerns  which
they say  are  not  fully addressed by the API  study.   According  to
GM,  these  include  API's unsubstantiated  support  for the  onboard
fillpipe  seal  and  pressure  relief  (lack  of adequate  durability
results),  an unknown CO penalty for light-duty vehicles  (no sensi-
tivity  data  relating  CO to  test procedure differences),  and  un-
proven feasibility  for trucks.  .

     GM is  of  the opinion that  accelerated  laboratory  durability
tests are  not sufficient  to prove  that  proposed elastomer  type
seals will  be effective  in  the  extreme  usage and  environmental
conditions of the real  world,  particularly when considering  a  ten
year average lifetime  for a light-duty vehicle.

Ford

     Ford  has  submitted test  results  from  four  1978 model  year
vehicles  (three non-feedback systems  and one feedback control
system)  modified for  refueling loss control.   These  vehicles  are
described in detail  in Table A-4  in  the Appendix  and in  their
submission to EPA,  Ref. 7.   The purge control systems  for  these
vehicles are shown  in  Figures A-7 and A-8 in the Appendix.

     Ford  estimates  the cost to the consumer of onboard controls  to
range from $15-$20.   They note that  the  $15-$20 estimate does  not
include additional  expense  for  such items  as:    packaging  costs,
incremental labor  costs, or  the costs  for additional exhaust
emission control,  such  as  feedback control over  a wider air/fuel
ratio range.

     Recent  Ford  material,  Ref.  12,  suggest  that  the cost  of
onboard systems may  range from $30 to  $253.  The  $30 estimate
includes costs over the original $15-20  estimate,  including  costs
for such items as  vehicle modifications to package  onboard systems,
incremental assembly,  and material substitution.  The $253 estimate
includes the cost  for a feedback fuel  system and  electronic  con-
trols for  vehicles which are  not  planned  to be equipped  with  these
control devices.

     On the basis  of their in-house test  results,  Ford has conclu-
ded  that  onboard controls are  not  technically  feasible  for light-
duty vehicles.

American Motors

     AMC has submitted a letter to EPA,  Ref.  9,  which states  their
concerns with the  possible  use  of  onboard  controls.   They  state
that packaging concerns,  reduced  quantities of purge air  from
downsized engines,  and compliance with stringent  evaporative
emission standards are  unresolved  technical  issues which have  not
been addressed by  the  API work  to date.

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     AMC does not find that API has  demonstrated  light-duty vehicle
technical feasibility.

IV.  Analysis of Available  Information

     1.   API Work

Exxon

     Exxon R&E  appears  to  have done a  credible  job in character-
izing  the components of  a hydrocarbon adsorption system.   An
examination of  the results  from baseline  tests  and tests with the
modified Pinto  (3-way + feedback carburetor system) show small but
finite  increases  in  engine-out  (14%)  and tailpipe  (8%)  CO emis-
sions.   HC,  CO,  and  NOx emissions  are still well below statuatory
emission levels for low mileage vehicles.  Engine-out CO emissions
from the  Caprice  are approximately 20%  higher  than baseline test
results; tailpipe  CO  emissions are approximately  10% higher than
the  baseline  results.   No increase  in tailpipe CO  was observed
during tests  with the  Chevette.   Exxon suggests that differences in
CO emissions  for  the  Caprice  and the  Pinto can be  further reduced
by minor modifications to the refueling loss control system or the
exhaust emission control system, although this has not been demon-
strated.

     Figure  A-2  shows canister purge as  a function, of  time.
Although the  data are  bench  test  results,  the results  are also
representative of actual control system  purge  data.  It is signifi-
cant to note  that the  refueling loss canister  is essentially purged
to  its working capacity  after three  LA-4 driving days.   This
implies that  the  refueling  control/exhaust emission interaction is
likely to be  less in a typical  driving day than Exxon has measured
using  conservative  test methods,  which  required  running  a cold
start FTP immediately  after a  90% refueling.

     ECTD expects that  refueling  loss  control systems will result
in  slightly  higher  CO feedgas  levels.   Exxon estimates  that the
average increases in CO feedgas between refuelings will be approx-
imately 5% for  non-feedback control systems and  less  than  3% for
feedback control systems.   ECTD has  no other data concerning either
the magnitude of  the  average  CO feedgas  penalty  or the resulting
effect on catalyst durability.   It  is ECTD's opinion that the Exxon
estimates are  reasonable  and  that  these  additional  CO penalties
will make it  more difficult for vehicle manufacturer's to certify
some engine/families  to  the 3.4 g/mi CO  standard.   The higher CO
levels  somewhat  reduce  the margin  available  to  allow for exhaust
system deterioration  over 50,000 miles.

     ECTD  finds  that  light-duty vehicles  equipped  with  onboard
systems are   capable of meeting a 2  gram evaporative emission
standard.

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     An analysis of the control effectiveness of benzene emissions
during refueling,  Table  6,  indicates  that  charcoal canisters can
control  in  excess of  99% of  the  uncontrolled  benzene emissions.
Exxon  conducted  additional  tests with  the Caprice and Pinco using
indolene test fuel with a  high  benzene  content (4.2%).  The results
from  these  five tests with the  modified vehicles support  the
earlier findings — benzene  emissions  are controlled in excess of
99% during refueling.

     Packaging refueling loss  control  systems  is a difficult
problem,  but  definitely  not an insurmontable one.   The refueling
loss canister  is  located  behind  the rear  seat  and above  the rear
axle in the  Caprice,  and  in the engine compartment of the Pinto.
It  is  Exxon's opinion, and  ECTD  agrees,  that  it  is possible for
manufacturers  to  locate  a  refueling  loss canister  on downsized
vehicles without major engine  compartment or sheetmetal modifica-
tions.

     The  feasibility  of  refueling  loss  controls  for  light-duty
trucks has not been evaluated by Exxon,  but  they are  of the opinion
that refueling  loss  control is feasible  for  light-duty trucks by
using  larger  control  systems and  more  sophisticated purging con-
trols  (refueling  loss  control  canisters  for each  tank  and/or two
stage  purging systems).   It  is ECTD's  opinion  that the control of
refueling losses from  light-duty trucks needs  to be demonstrated,
especially the ability to comply with  a 2 g evap standard, before
onboard controls are judged  to be  effective for these vehicles at
the costs Exxon has estimated.

     Table 8  shox^s  Exxon's  detailed manufacturer's cost estimates
for refueling control  systems which have two canisters.  ECTD finds
these  cost estimates to be reasonable for onboard systems designed
to  control  100%  of refueling emissions from  90%  fill conditions.
Exxon  estimates the average manufacturer's cost for the light-duty
truck  and  light-duty  vehicle population  to be  about $9.   That
number is derived as follows:

                                 Assumed         % of
                               Average  Cost   Population

One-cansiter vehicles*           $7.88            70
Two-canister vehicles*           $9.38            20

6,000 to 8,500 Ibs. trucks**    $16.00            10
            Weighted average      $9.00
*   Includes light-duty vehicles and  light-duty  trucks  under 6000
   GVW - average fuel tank size  = 17 gal.
** Average fuel tank size  = 35 gal.

The charcoal cost per gallon of tank volume is assumed to be about
$0.20.

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                               21
     The $9  incremental  manufacturer cost may  be  translated to a
consumer cost estimate of $16.20 by multiplying the manufacturer's
cost estimate by  a  factor  of 1.8 (Ref.  10, EPA 'Report "Cost Esti-
mations  for  Emission Control Related Components/Systems  and Cost
Methodology Description"  by Rath and Strong,  March 1978).   The 1.8
factor is  in general  agreement  with  previous  EPA studies, such as
the EPA  Report,  Ref. 11, "Investigation  and  Assessment  of Light-
Duty Vehicle Evaporative Emission Sources and Control," June 1976,
which  used a manufacturer  to  consumer cost  factor  of 2.0.   The
$16.20 estimate is  in good  agreement with consumer cost  estimates
submitted  by GM  ($16-$24)  and  Ford  ($15-$20).   It is possible to
further reduce the  cost  of an  onboard  system by trading  off some
degree of refueling  loss  control effectiveness.

     Exxon has  designed  refueling  loss  control systems  based on
conservative criteria, and thus a different set of design criteria
will  afford  reductions  in  the  cost  of  onboard  control  systems.
Texaco has submitted data (Figure A-ll)  Ref.   12, which relates the
number of  light-duty vehicle  refuelings  and  the  percent of tank
fill.  A reasonable design criterion is to size the refueling
canisters  to  control  90%  of  nationwide refueling emissions.
Calculations (Figure A-12)  show that  90% control can be achieved by
designing systems  to control 100% of  refueling emissions from fills
to  63% of  fuel tank  volume.   If onboard  control  systems are de-
signed to  control emissions from refueling to 63% of tank capacity
rather than  90% of  tank capacity,   the  Exxon estimate of  $9 per
vehicle can be reduced by  $1.60 as  the  result of reduced charcoal
quantity.  This cost reduction is proportional to the reduction in
carbon bed volume.  The net effect of this design change  is a cost
reduction  to the consumer of  approximately $2.88.  Changes in
design specifications such  as  the  90% fill requirement may afford
additional cost reductions  for  other control  system components as
well  as  a  general  reduction in the problem  of packaging onboard
control systems.

     ECTD estimates  the consumer cost  of light-duty vehicle onboard
control  systems designed  for maximum control effectiveness  to be
about $17.   This estimate does  not include  an  estimate for the cost
of the fillpipe seal or pressure relief valve.   The $17 estimate is
based  on Exxon estimates, which when translated to consumer costs,
are in agreement  with consumer cost estimates  provided by  GM and
Ford.

     Exxon estimates  the  manufacturer's  cost  for  a  fillpipe seal
and onboard pressure relief valve to be approximately $1.50..  ECTD
estimates  the consumer cost  of  an  onboard fillpipe seal  and pres-
sure relief to  be  approximately  $2.70.

Mobil
     Comparisons  of  baseline  and modified  vehicle  test  results
indicate that Mobil  R&D  is able  to  add  refueling controls to the

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                               22
1978 Pontiac Sunbird  (3-way  + feedback carburetor system) without
adversely affecting exhaust  or  evaporative  emissions.   No changes
in engine-out or  tailpipe  CO emissions  are  observed.   Evaporative
emissions  are also unchanged, with  both baseline -and  modified
vehicle  test results near  the 2 g  evaportive  emission  level.

     It must  be  emphasized, however,  that Mobil and Exxon use
different  test  procedures  for  measuring  the   refueling  control/
exhaust emission  interaction.   Mobil's  test  procedure consists of
the following sequence of  events:

     1)   Load canister  to  approximately  one-half  of working
capacity.

     2)   Condition vehicle by  driving  two  simulated  city driving
days (4.7 LA-4's with  one  hour  hot  soaks  in between and a diurnal
at the end of the  day).

     3)   Drain  fuel tank  to  10% of volume.

     4)   Refuel to 90% of volume in SHED.

     5)   Conduct  hot  start emission test.

     6)   Soak vehicle for 11 hrs.

     7)   Conduct  diurnal  evaporative  test in SHED.

     8)   FTP

     9)   Hot soak evaporative test in SHED.

     Steps 1, 2,  and  5 are  the .important  differences  between the
test procedures  used  by Exxon and Mobil.   Mobil starts their test
sequence with a  canister  loaded to one—half of working capacity,
versus a saturated condition  for the Exxon procedure.'  Mobil purges
the refueling loss canister with two LA-4 driving days, versus the
Exxon method of purging by running a  series of LA-4  driving days
until  the  fuel  tank  reaches  10%  of  capacity.    Mobil runs  a hot
start emission test prior  to  the FTP;  no such additional condition-
ing is used in the Exxon test sequence.  It is ECTD's opinion that
the  the  Mobil  test sequence, particularly  the  addition  of  a hot
start exhaust emission test,  will result in a less severe refueling
control/exhaust  emission interaction.   This is  due to the smaller
quantity of hydrocarbon which is purged during  the cold start FTP
when using  the  Mobil   test  sequence.   The actual  emission  sensi-
tivity  to  various  test  procedure  arrangements  has not  yet  been
determined.

Atlantic Richfield Company

     ARCO  states  that the fillpipe modification  approach and the

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                                  23
combination  fillpipe/nozzle  seal  concept are  the  preferred  tech-
niques for  achieving  a no-leak seal.  This  recommendation  is  not
supported from an analysis  of leak  rate and durability data because
the  test results  show that seal  effectiveness  among all  three
concepts are equal.  Cost estimates for the three designs have not
been  submitted.    ARCO  is  continuing to  collect  field  durability
data on their prototypes, but the lack of  a more extensive durabil-
ity  demonstration  under  simulated  conditions  of  real world  usage
makes it questionable  to assume that  their  seals  will  function as
well in the field as they have  in the  laboratory.

     In particular, ARCO has not adequately addressed the issue of
onboard pressure relief valves  versus  liquid pressure relief valves
located on  the  fill nozzle.   Pressure relief valves are necessary
to prevent  over-pressurization of  the fuel tank  in  the  event of a
failure  of the  automatic  shutoff on the fill  nozzle.  For  the
purpose  of  fuel tank  integrity in the event  of  a  vehicle  crash,
NHTSA recommends  that  the  pressure relief not be  located on  the
fuel tank.   However,  a relief valve might be incorporated  safely
with a  fillpipe seal  mechanism,  which would  be  sealed-off by  the
fuel cap during vehicle operation.

     The achievement  of a safe and durable  seal  at the nozzle
fillpipe interface  is  critical to the  performance of  an  onboard
refueling  loss  control system.    ARCO  has  demonstrated that  the
effectiveness  of  fillpipe seals,  combination  seals and nozzle
seals are equal; but,  the design,  locations,  and durability  of  the
pressure relief valve have  not  been adequately  addressed.

     Conceptually,  a pressure  relief  may be  designed to function
properly when located on  the  vehicle or on the nozzle.  However, if
refueling losses are controlled on the vehicle,  it  is  recommended
that  the  fillpipe/nozzle  seal and  pressure  relief valve also be
located on the vehicle.   Locating all parts of  an onboard system on
the vehicle will prevent  the  potentially serious problem of  refuel-
ing a controlled vehicle without protection from overpressurization
(no relief valve).  Administrative and certification concerns also
suggest that onboard controls  are  practical  only if the seal  and
pressure relief are located onboard.

     An alternative technique of achieving a  seal at the fillpipe/
nozzle interface is the liquid trap or  submerged  fill.   This seal
concept  has not been  adequately  investigated.   Submerged fill
offers the potential for  significant advantages iii terms  of  simpli-
city of  operation  and  durability  (mechanical, magnetic, or  elas-
tomer type seals  are  avoided).   It  is ECTD's  opinion that  the
submerged fill concept  should be investigated.  Submerged fill (and
seal  techniques investigated by ARCO)  must  be  evaluated  in  the
context  of  a complete  refueling and  evaporative  emission  control
system.   This  includes  incorporating  features to  provide adequate
thermal   expansion  capability and  rollover protection while  still
permitting normal safe  refueling.

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                                24
     2.   Vehicle Manufacturer  Information

General Motors

     General Motors has several reservations concerning the appli-
cability of onboard  controls,  citing such things as:   the uncer-
tainty  of  the  effectiveness  of  fillpipe/nozzle  seals,  potential
cost  increases  associated with  exhaust emission  control  systems
which must be designed to control increased CO emissions, negative
fuel  penalties  which  are  the  result  of this  increased emission
control,  and the  long lead time which is required to obtain a
substantial reduction in  atmospheric hydrocarbon and  benzene
loading.  However,  with  the exception  of GM's  concern  with using
accelerated laboratory tests to  assess  fillpipe/nozzle  seal dura-
bility, these reservations  are  not  detailed in their submissions.
GM  has stated  that refueling losses  can be  controlled  on the
vehicle (feasibility  for  trucks has not been  demonstrated)  or at
the service station.   GM's  disagreements with controlling refueling
emissions  with onboard controls  are  primarily based on the issue of
cost/effectiveness.

     GM's  March, 1978 submission to  EPA  presents a summary of their
work on the control of diurnal evaporative emissions and refueling
losses using fuel tank bladders.

     It is EPA's opinion  that the  theoretical control effectiveness
of  evaporative  and  refueling  loss  emissions  using bladder  tank
technology is high and that these  problems can be  solved.   It is
recommended that bladder tank feasibility be researched by funding
a bladder  tank hardware demonstration contract.

     The March, 1978  submission presents calculations showing that
the  additional weight of the  components of  an  onboard  control
system  will  cancel out any potential energy  saving which results
from  the  combustion  of the refueling  vapors.     ECTD  agrees  with
this analysis.

     The June,  1978  submission is  basically  a cost effectiveness
analysis comparing onboard controls  with Stage II controls  (balance
displacement and vacuum assist  systems).  GM estimates that onboard
control systems,  effective with  the 1982 model year,  will range
from $16 to $24.   These figures are  about $5 to $9 higher than the
March,  1978 estimates due to higher  estimates for larger canisters
and a  new vapor/liquid separator.  GM assumes that the seal at the
fillpipe/nozzle  interface  will be  obtained using  modified vapor
recovery nozzles.  GM does hot include  seal costs in its estimate.
They  assume  these costs will  be  the same for  either Stage  II or
onboard controls and, hence, leave these costs out of their analy-
sis  of both  options.   General Motor's  onboard  cost  estimates are
costs  to  the consumer.   These  estimates  are  based on  costs for
hydrocarbon  adsorption  systems which control  evaporative and
refueling emissions with one canister (cheapest) and systems which

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                                25
 use two separate canisters for containing evaporative  (diurnal  and
 hot soak) and  refueling  emissions  (most  expensive).   The  GM  cost
 estimates  are consistent  with Exxon's manufacturers  cost  estimates
 for onboard  controls.   As  discussed earlier,  it  is  possible  to
 design  cheaper  refueling  loss control systems by not  providing  100%
 control of refueling emissions under worst case conditions.   If  the
 design  criterion of 100%  control  for  a 90% refueling is  changed to
 100% control for  a 63%  refueling,  it is  possible  to reduce  the
 required working capacity of the  charcoal  canister, thus  reducing
 the average  system  cost to the consumer by about $3.00.

      GM does not find  that  onboard  controls are feasible  for  the
 1982 model  year,   although  their cost effectiveness  analysis
 calculations are based on the assumption that onboard control could
 become  effective beginning with the  1982  model  year.   It  is ECTD's
 opinion that onboard refueling  loss  controls cannot  be implemented
 prior to 1983 model year.   GM did not comment on the feasiblity of
 refueling loss controls for  light-duty  trucks and heavy-duty
 gasoline powered vehicles.

 Ford

      Ford  emphasizes  that  the   refueling   loss/exhaust  emissions
 interaction is a  function of the  test  procedure and  that  the
 differences  between emissions interactions  measured by Exxon  and
 Mobil are due  to  test procedure  differences.   This  statement  is
 correct,  although the actual emission  sensitivity  to the test
 procedure  is unknown.

      Ford  attributes  the  high  CO  effects,  which they have  observed
 with both  conventional  oxidation catalyst  systems  and  three-way
"plus feedback carburetor systems,  to the presence of  refueling  loss
 controls.   However, the reason for their high  CO  emissions is  due
 to a non-optimally  designed  system for controlling the hydrocarbon
 purge rate.   Ford  uses a manifold vacuum controlled purge  system,
 which results  in cold  start  hydrocarbon  loadings  that are  two  to
 three  times higher  than results obtained with venturi vacuum
 controlled systems  (Exxon system).   This  is  the  reason the Ford
 results are  so high,  particularly engine-out CO emissions.  Ford
 maintains  that  refueling  loss  control systems produce  peak  enrich-
 ment effects equal to two  air/fuel  ratios, which  is beyond  the
 capability  of  their  current  feedback carburetor  control  system.
 Exxon has demonstrated,  however,  that venturi vacuum maintains  the
 air/fuel ratio  within  the  control limits of the  feedback  control
 system.   Problems  with  the  existing Ford  feedback  control system
 are likely to be the result  of response time problems, not  control
 range problems.

      Some  of Ford's  concerns  with onboard  refueling  control  sys-
 tems, such as packaging,  weight of onboard  systems,  and  the design
 of vapor/liquid separators have been  examined during the API study
 and shown  not to be significant problem areas.  Other concerns with

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                               26
onboard controls,  including  system  durability,  onboard  feasiblity
for  light  and heavy  duty  trucks,  and high  altitude  feasibility,
have  not  been  adequately addressed in  any of the  information
submitted  to  ECTD.   It  remains ECTD's judgment that  these  issues
need further examination,  particularly before onboard  controls  are
determined to be  feasible  for light  and  heavy-duty  trucks.   Al-
though onboard durability data are not available, ECTD  finds  that
onboard control  systems  should  be as durable as current evaporative
emissions  control systems,  which  last  for the lifetime of  the
vehicle.

     Ford estimates the consumer cost  of onboard controls  for
light-duty vehicles to range  from $30  to  $253.   EPA  estimates  that
the  consumer  cost of onboard  control systems  will be about  $20
(includes  $2.70  for the cost of an onboard seal and pressure
relief).

American Motors

     AMC's concerns with the  use  of onboard controls are addressed
to  the  issues of exhaust and  evaporative  emissions interactions,
feasiblity of vehicles  using  small  engines,  costs, and  light-duty
truck feasibility.   With  the exception of  feasibility  for  light-
duty trucks,  AMC's concerns have been examined in detail by the  API
study.  EPA's analysis of that  data is that refueling loss  controls
are feasible  for light-duty vehicles at a consumer cost of approxi-
mately $17.

V.   Conclusions

Feasibility

     An Analysis of  the  available information has  shown that
onboard  refueling loss controls  are feasible for  light-duty
vehicles  designed  to meet  low  exhaust  and evaporative  emission
standards  (0.41  HC, 3.4 CO,  1.0  NOx and  2.0 Evap.).   However,  the
feasibility for light-duty  trucks,  particularly the assurance  that
onboard control  systems  are  compatible  with a  2 gram evaporative
emission  standard,  has not  been established.  Feasibility  for
heavy-duty gasoline vehicles  has not been established.

     An analysis  of   information  and  test  data presented to  EPA
regarding  the  control  of  light-duty  vehicle  refueling  emissions
offers the following  conclusions:

     1.    Onboard control  systems in laboratory use situations  can
control in excess of 97% of the uncontrolled hydrocarbon refueling
losses.

     2.    The same systems in laboratory use situations can control
in  excess  of 97% of the  uncontrolled  benzene refueling  losses.

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                                  27
     3.   Test results  from  two light-duty vehicles equipped with
three-way catalysts,  feedback  carburetors,  and  prototype  refueling
loss systems shew  that  tailpipe CO emissions range from  a 0 to  8%
increase.

     Test results  from  the  same vehicles  show that engine-out  CO
emissions range from a 0 to 14% increase.

     4.   Emission  data  from  two  conventional oxidation  catalyst
equipped light-duty vehicles show  that  tailpipe CO  emissions
range from a 0 to 10% increase.

     Data from one  of the  conventional oxidation  catalyst vehicles
show that engine-out CO  emissions  increase  by 10 to 20%.

     5.   The  addition  of refueling  loss  controls to  light-duty
vehicles does not significantly affect evaporative emission losses.

     6.   Minor  increases  in  CO  exhaust  emissions seen for some
vehicles can probably be  controlled by minor change to either the
refueling loss  control  system or  to  the  exhaust   emission control
system.   However,  the  addition  of  refueling  loss controls will
likely make  it more difficult  to  certify  some vehicles to the 3.4
g/mi standard at 50,000  miles.

     7.   Onboard  controls  do not affect  vehicle  fuel  economy.

     8.   Onboard  controls  do not  affect  vehicle driveability.

     9.   Refueling  loss  control  systems   for light-duty  vehicles
are estimated  to add $17  to the vehicle  sticker price.   The $17
estimate does  not  include  the  costs  associated with the  fillpipe/
nozzle seal or pressure relief valve.   The  consumer cost  of a seal
and pressure relief in the fillpipe is estimated to be  about $2.70.
The cost of a  seal  on the  nozzle should be  roughly the same as the
cost for  a  Stage II nozzle.   However,  it  is recommended that all
components of an onboard control system be  located  on  the vehicle.

Lead time

     Onboard refueling  loss  control  can  be  implemented  for 1983
model  year  light-duty  vehicles,  provided  that  potential problem
areas  such  as  the  design and  development  of effective  fillpipe/
nozzle seals and pressure  relief  valves do not require  additional
hardware demonstration programs.   It  is  anticipated  that  the
fillpipe/nozzle  seal and  the   control  feasibility for  light  and
heavy-duty trucks are issues which can be  resolved  during the NPRM
process.

     ECTD estimates  that a minimum of two  years  lead  time will  be
required by  manufacturers  for  development  (purge   system  optimiza-

-------
                                      28
             Quarter;

Develop Certification
Test Procedure

Continued Study of
Fillpipe/Nozzle Seal
Concepts

Decision on Seal
Concepts

EIS, EIA, NPRM
Preparation

Publish NPRM

Final Rule

Manufacturers
Lead Time
        Figure  1

       Lead Time

                     Calendar Year
        1979       1980       1981
I34.I1234J1234J1234
 1982
1234
   1983
11234
          (Decision  to publish service station nozzle
          requirements or put seal on vehicle)
                                                1983 MY

-------
                                   29
tion,  design  and  verification  of  fillpipe  seal mechanisms)  and
production tooling changes  (tooling  associated with fabrication and
relocation of  new evaporative  control components).  These estimates
are based  in  part  upon  data  provided  by manufacturers  relating to
carburetor tooling changes, and  in  part upon data supplied  by GM
relating  to  retooling  changes  for body  panel modifications.
Additional time  will  be  required  for EPA to develop a certification
type test  procedure and issue regulations,  however,  the certifica-
tion procedure development can overlap the  production tooling lead
time.  Therefore,  the projection  is  that an  NPRM can be published
late in 1979 with final  rules  promulgated by 1980 with the earliest;
possible  implementation date  being 1983.   (See lead  time  chart,
Figure 1).

Compliance Costs

     ECTD estimates that certifying  light-duty vehicles for compli-
ance with a refueling  loss standard  will require  an additonal
one-half person-year  at  the EPA-MVEL.  This is based on an estimate
of 100-150 refueling  loss tests per year.   Facility modifications/
equipment procurements will cost  from $30K to $80K.

     A potentially significant impact on refueling  loss compliance
costs  is  Inspection/Maintenance   testing  of  light-duty  vehicles.
EPA has  not developed,  and  is not aware of, a  valid  I/M  test  for
determining the  performance  of evaporative emission  control  sys-
tems.  Monitoring the performance of in-use refueling loss control
systems will be  difficult  and cumbersome.   At this  time,  it  may be
assumed  that  the onboard  compliance costs  associated with  an  I/M
test will be equal to the cost of  Stage  II enforcement.

VI.  Recommendations  for Future Work

     •1.   ECTD  recommends that  additional  hardware  testing be
conducted to determine the optimal fillpipe-nozzle seal.  Addition-
ally, the operation and durability of a  fillpipe or  nozzle pressure
relief must be  demonstrated.   The  use  of  an onboard  liquid  trap
seal (submerged  fill)  as an  alternative  to elastomer type  seals
should be investigated.

     2.   ECTD  recommends that  additional  hardware  testing be
conducted to assess the  feasibility of controlling refueling  losses
on  light-duty  trucks  and heavy-duty  gasoline powered trucks.

     3.   ECTD recommends  that the  need for  controlling  refueling
losses from diesel powered vehicles  be investigated since  these
vehicles are  predicted to represent a  substantial fraction  of  the
entire motor vehicle  population in the 1980's..

     4.   ECTD recommends  that the  bladder fuel tank  be  investi-
gated  as  an  alternative to  carbon adsorption technology.   It
is ECTD's  opinion  that  the  theoretical  control  of evaporative  and

-------
                                  30
refueling  loss emissions  with bladder  tanks is high  and that
technical  problems  can  be  solved.   It  is  recommended that bladder
tanks feasibility be researched  by  funding a hardware  demonstration
contract.

     5.    Finally,  ECTD recommends  that  methods  of  reducing the
cost of  onboard refueling control systems  ba examined.   Such
studies  should be directed toward tradeoffs between  level of
control  effectiveness and  cost.   It may be possible to  sacrifice
control  capacity  that is required under only infrequent conditions
to  achieve  a  proportionally  more  significant  cost  savings.

-------
                                .  31
                            Bibliography
 1.  "Control of Refueling Emissions," Statement by General Motors
     Corporation,  June  11,  1973.

 2.  "Control  of  Refueling Emissions  with an  Activated Carbon
     Canister on the Vehicle  - Performance  and.Cost Effectiveness
     Analysis," Interim  Report  Project  EF-14,  prepared   for  the
     American Petroleum Institute,  Washington,  D.C., October 1973.

 3.  "On-Board  Control  of Vehicle Refueling Emissions - Demonstra-
     tion of Feasibility," API Publication No.  4306, October 1978.

 4.  "Summary and  Analysis  of Data from Gasoline Temperature Survey
     Conducted  at  Service  Stations," Radian Corporation,  Austin,
     Texas.   Prepared  for  the  American  Petroleum Institute,  Wash-
     ington,  D.C.,  November 1976.

 5.  "General Motors  Commentary to  the  Environmental  Protection
     Agency  Relative  to  On-Board Control of Vehicle Refueling
     Emissions," March  1978.

 6.  "Suppplement  to  General Motors Commentary to the Environmental
     Protection Agency Relative to  On-Board  Control  of  Vehicle
     Refueling  Emissions,"  June  1978.

 7.  "Ford Motor Company Response to EPA Concerning Feasibility and
     Desirability  of a Vehicle  On-Board  Gasoline  Vapor  Recovery
     System."

 8.  "Ford Motor  Company Position Concerning Feasibility  and
     Desirability of  Vehicle On-board  Refueling Vapor  Control
     Systems,"  November 6,  1978.

 9.  AMC letter to Paul Stolpman, August 3, 1978.

10.  "Cost Estimations  for  Emission Control Related Components/Sys-
     tems and  Cost  Methodology Descriptions,"  Rath and  Strong,
     Inc., Lexington,  Massachusetts.   Prepared  for the  Environ-
     mental   Protection Agency,  Ann  Arbor,  Michigan, March  1978.

11.  "Investigation and Assessment of Light-Duty Vehicle  Evapora-
     tive Emission  Sources  and Control," Exxon  Research  and
     Engineering Company,   Linden,  New Jersey.    Prepared  for  the
     Environmental  Protection Agency, June 1976.

12.  Texaco   statement  submitted  to  Paul  Stolpman,   July  18,  1978.

-------
                                     32
                              APPENDIX
     The Appendix contains detailed descriptions and data from  the
test vehicles and fillpipe/nozzle seals  which were  used  in the most
recent  testing  and  evaluation of  refueling  loss control systems.

Exxon

     Table A-l  presents  a  description of all Exxon test vehicles.
Figure A-l is a  schematic of  the basic  control  system designed  for
the Chevrolet Caprice and the Ford Pinto.  The  refueling emissions
(RCS)  canister  controls  both  refueling emissions and  diurnal
evaporative  emissions;  the  evaporative emissions  (ECS)  canister
controls carburetor  hot  soak losses.   Exxon investigated several
different  purge  mechanisms,  including  combinations of  manifold
vacuum and venturi  vacuum,  and two stage  purge control  valves
controlled by  fuel  volume,  but  venturi vacuum,  which  is propor-
tional  to  engine air flow, is the most effective purging method.
Exxon's control  system is designed to maintain  the total purge  air
volume  (RSC  +  ECS)  equal  to  the purge  air  volume  of the unmodi-
fied vehicle's  evaporative  control  system.

     The air bleed control  valve, shown  in Figure A-l, is necessary
because the RCS  canitser is purged more  efficiently (higher hydro-
carbon purge per unit volume of air) than the unmodified ESC
system, thereby  resulting in  richer A/F mixtures.   This air bleed
may not  be necessary for  other  vehicles with   feedback carburetor
controls.

     Figure A-2 is a  plot of  the  RCS  canister purging as a function
of  time.   These data are based  on consecutive  LA-4 driving days.
As  noted,  the  RCS system is  purged  at  a rate  of  about 4 litres/
rain., which corresponds to a  total canister  purge volume of about
40 litres during an LA-4  driving  cycle.

Mobil                  .                                    .

     Specifications  for the vehicle Mobil has modified for refuel-
ing loss control are  summarized as  follows:

     Vehicle:  1978 California Pontiac Sunbird

     Engine Size:  151 cu.  in. L-4

     Interia Weight:   3000  Ibs.

     Emission Control System:
          Exhaust:      3-way  catalyst  with  feedback  carburetor,
                        EGR
          Evaporative:  Carbon canister

-------
                              33  A_
                                 A-2
     Fuel Tank Capacity:   18.5  gallons

     The production vehicle  is  modified  for controlling refueling
emissions by enlarging the existing carbon canister, (one canister
controls  refueling,  diurnal,  and  hot  soak loss),  enlarging  the
vapor line  between  fuel  tank and canister,  redesigning the vapor/
liquid  separator,  and  installing a purge  control  orifice between
the  canister  and intake  manifold.   A schematic of  the Sunbird's
control system  is shown  in Figure A-3.   Various flow  control
orifices were inserted in the canister purge line but best results
are  obtained  with  an orifice  of 0.100 in. diameter.   Mobil uses
1550 grams of Calgon BPL-F3 carbon for their control system, which
assumes a 20% safety factor.  This quantity  of carbon is based on a
90% fill of the 18.5 gallon tank,  and assumes a hydrocarbon loading
of six grams per gallon of  dispensed fuel.   The working capacity of
the.canister is  approximately  240 grams.   The  basic components of
the canister  control  system  are shown in Figure A-4.   The ported
vacuum purge control valve  is from a 1978 Chevrolet Impaia evapora-
tive  canister,  while the  two fuel tank  vapor valves  (two  are
used  to reduce  the pressure drop during  the  refueling operation)
are carburetor bowl valves  from a 1978  Impaia.  Using two fuel tank
vapor valves results in fillpipe pressures  as  low as two. inches of
water pressure during refueling.   The fuel tank vapor valves  are
also  controlled by manifold vacuum  such  that  the vapor  valves
are  closed  when  manifold vacuum  is  present at  the  control port.

Atlantic Richfield  Company

     Figure A-5  shows  the  fillpipe seal which  ARCO has developed
and tested  for durability.   Tables. A-2 and A-3 are typical of the
durability results  obtained with  this seal.   Figure A-6 is an
example of  a  prototype  combination  fillpipe/nozzle seal which  has
been developed and  evaluated  by ARCO.

Ford

     The vehicles  which  Ford has used  for  refueling loss testing
are  shown  in  Table A-4.   A  single 4.35 1  canister is  used in the
Mustang, while a duel canister  system,  829  ml  and  3.4 1,  are used
for  controlling  carburetor  vapors  and  diurnal/refueling losses,
respectively,  in the Pinto.  The purge systems for the Mustang and
the Pinto are shown in figures  A-7 and  A-8.

     Figures A-9 and A-10 are plots of  canister loading versus test
procedure  sequence.   These  plots  indicate that Ford's refueling
loss  control system is  quite  sensitive to the particular test
procedure which  is  used  to quantify the refueling control/exhaust
emission interaction.

-------
                                        34
                                      A-3
                                    Table A-l

                              Vehicle Descriptions
Make
Engine Displacement/
Model Configuration
Control Systems
Fuel Tank
Capacity
(gallons)
Chevrolet   Caprice    5.0 litre (305 CID)/V-8

Ford        Pinto      2.3 litre (140 CID)/L-4


Plymouth    Volare     3.7 litre (225 CID)/L-6

Chevrolet   Chevette   1.6 litre (98  CID)/L-4
Ox. Cat., AIR, EGR

3-Way, Ox. Cat.,
   AIR, EGR

Ox. Cat., AIR, EGR

Ox. Cat., AIR, EGR
21.0

13.0.


18.0

12.5

-------
                               35
                             Table A-2


                        FILLPIPE  MODIFICATION

                         ROTARY SEAL-CR 7538


                       LEAK  RATE  A3  AFFECTED BY

                      FILLNECK  PRESSURE AND WEAR
NO. OF SPOUT
INSERTIONS
0
100
100
• 100
100
100
100
100
100
100
100
TYPE
SPOUT

Smooth
Rough
Smooth
Rough
Smooth
Rough
Smooth
Rough
Smooth
Rough
CUMULATIVE
INSERTIONS
0
100
200
300
400
500
600
700**
800
900
1000
FT3/MIN
@ 5" W.C.
0
0
0
0
0
0
0
0
0
0
0
LEAK *
(§ 15" '
0.001
0.001
0.001
0.001
0.001
0.001
0.001
0.001
0.002
0.002
0.002
*  Leak rate average of six nozzle insertions.

** Expected number of insertions during vehicle life.
RGJ:ip
7/13/78

-------
                            36
                         Table  A-3


                   FILLPIPE  MODIFICATION

                     ROTARY SEAL-CR 7538
             EFFECT OF LIQUID  AND VAPOR GASOLINE
               SOAK ON SEAL  ID AND  LEAK  RATE*
HOURS OF
LIQUID
SOAK

    0

   16

   35
TOTAL WEEKS
OF VAPOR
SOAK










0
0
0
2
3
4
5
6
7
8
SEAL
ID, IN.
.712
.712
.711
.705
.699
.701
.703
.698
.693
.691
FT3/MIN
@ 5" WC
0
0
0
0
0
0
.001
0
0
.001
LEAK**
@ 15" W<
0
0
0
0
.001
.001
.001
0
.001
.002
*  Vapor and liquid soak at  72°F.

** Leak rate average of nine nozzle  insertions,
RGJ:ip
7/13/78

-------
                              Figure  A-l


EVAPORATIVE AND  REFUELING EMISSIONS COF^TROL SYSTEMS
      REFUELING AND
      DIURNAL VAPORS
                         PURGE
                         CONTROL
                        ii VALVE
                                           CONTROL VACUUM
                                   AIR BLEED
                                   CONTROL
                      RESTRICTION la r VALVE
                      CARBURETOR VACUUM PURGE


                  RESTRICTION


                  VENT
CARBURETOR BOW
                                         CARBURETOR
                                                     MANFOLD VACUUM.
                                                         PURGE
                                                                 ECS CANISTER
          REFUELING EMISSIONS
           CONTROL CANISTER

-------
                                                  PURGE <§ A LITRE/MIN. WITH DIURNAL ADDITIONS
                                                     ADSORPTION TO 35 g. FROM BREAKTHROUGH
                                                      "'  3.5 litre Canister (BPL-F3)
320
300 -
1 LA-4 = 40  litres  =10 min.
5 LA-4's = 1DD=  50 min.
                                                                                                   240
                                                                                                     270

-------
                                          Figure A-3

                    ONBOARD  SYSTEM TO  CONTROL  REFUELING EMISSIONS
    Control
    Vacuunr
     Lines
Flow Control
  Valves
                                       Carburetor
                                                     Intake Manifold
   Carburetor  Bowl Vent
Engine
                                       Canister Purge Line
                                    .With Flow Control Orifice
                                       Fuel Tank Vapor Line
                                                                     Vapor-Liquid
                                                                       Separator
                                         (5/8" I.D.)
             Carbon Canister (4.4 L)
                                    Seaiing
                                    Nozzle
                        Fuel Tank

-------
                                                Figure  A-4

                                   Refueling System  Carbon  Canister
  Sunbird
Carb.  Bowl
  Fitting
 Chevy Purge
 Valve,  Drilled
   To 0.180"
                  Chevy Carb.
                  Bowl Valves

                  0,047"  Bleed
                  To Fuel Tank
Side View Of Top Disc
                                                              Carbon-


1 Na 1=3 1 =
1
//// // //// /i ////"/ y/
iJ
X
fj//ff //////// ///////////I
=mrtT<'n'rmTprrrt'ff tr m-

<: —
^r—-1
,. \

                                                                                                        •Foam
                                                                        •Foam
                                                                        -Wire Mesh        *
                                                                        Fiberglass Air Filterc
                                                                        Canister Dimensions
                                                                              6" High
                                                                             8"  Diameter
                                                                   Carbon:  BPL-F3
                                                                            1550 grams
                                                                            4350 ML
1	L

                                  Wire Mesh Glued To
                                     Bottom of Tube
     ~l/8" Plexiglass
.l"dia. x 13/4" long
    Plexiglass Tube

-------
               41
              Figure A-5
  FILL PIPE MODIFICATIONS
  ROTARY SEAL.
                    ROTARY SEAL
  TRAP DOOR
                                          SPOUT
           LEAD RESTRICTOR
FILL PIPE  MODIFICATIONS
ROTARY SEAL
                  ROTARY SEAL
TRAP DOOR
                                           SPOUT
         LEAD RESTRICTOR

-------
                 42
            Figure A-6
 NOZZLE / FiLLPIPE MODIFICATION

 CONE SEAL

 LEAD RESTRICTOR
 TRAP DOOR
 SPOUT
                           DISK
                                     LATCH COLLAR
         CONICAL SEAL
NOZZLE / FILLPIPE MODIFICATION

CONE SEAL

 LEAD RESTRICTOR
 TRAP DOOR
SPOUT
                                    LATCH COLLAR
        CONICAL SEAL

-------
VACUUM ACTUATED PURGE
VALVE AND TANK VAPOR  '
liiLST VALVES ARE SIMILAR
TO CURRENT PURGE VALVES
                                       ON BOARD VAPOlfRECOVERY SYSTEM

                                          Mustang  8Z18  &  8Z19
                                                System A
TANK.-VAPOR INLET VALVES
VACUUM CLOSED       "~"~
                                      PURGE VALVE WITH
                                      0.180 IN ORIFICE  .
                                      VACUUM OPEN
                                                                                                 SERVICE STATION
                                                                                                   NOZZLE
                                                                        FILL PIPE OPENING
                                              THIS VALVE CONTAINS
                                              A  .0^1 IN. BY-PASS
                                              .ORIFICE FOR TANK RUNNING
                                              LOSES
                                          GARB BOWL
                                          VENT CONNECTION
   PURGE LINE TO
   PCV HOSE
GARB EOWL
VENT LINE
                                             PURGE SIGNAL
                                                       ~X_3/8"DIA
                                                                   TUBING
                                                  (REPLACES CONVENTIONAL
                                                   TUBING)
                                         ^"-4350 ML CARBON VOLUME
                                                OPEN CELL FOAM
                                                WIRE SCREEN
                                                FIBERGLASS
                             8 IN.
                             DIA"
                           CANISTER (REPLACES CONVENTIONAL CANISTER)
                       H«P o(-,vo fiPTMTVT1
                                                                            TANK VAPOR
                                                                            LINE
                                                                                       7
                                                                               •  FUEL TANK
                                                                                                               H-
                                                                                                               OQ
                                                                                                               C
                                                                                                               >

-------
                           ON BOARD V/"""Q:ECOVERY SYSTEM
                               PINTO 8E?9
                                  System B
                            ~3	*- PURGE LINE TO PCV HOSE

                             GARB BOWL VENT LINE
               i i ________ .
            PURGE
        TO PCV LINE
   '^_t.j THRU BOTH .090"
   '
     ,'vi—;-..i iriiio ijuin .uyu"
    //'   I & .085" ORIFICES
   //    V	
//
  _x
-^EF^C ")\	**
\ ^7^:~==
                                   -"•- PURGE SIGNAL

                                       -1-'PURGE LINE
            PURGE
           'SIGNAL
\  |  C_J   (PROD. VLV.)
T"!.'. r.i--,     '  •
                         \090" REMOTE PURGE VLV.
                                31+00 ML CARBON VOL.
         925 ML CARBON VOL.

                                               I/
                                             ATMOS.
                                                                   "
                                                                    TANK VAPOR
                                                                   FILL PIPS
                                                                        . .
                                                           FUEL TANK
                                                                                  H-
                                                                                  OQ
                                                                                  oo

-------
                     45
                    Procedure #2 Sc* 2.
                  Mustang 5«OL (J5Z18) 197d 49 States
                      Date. 7-17-78 Test 29
              tsl Caaieter, TcmK % Garb. Bowl w/.lSO" Purge
              I    Grows cr Vapor Purged (.-)> Absorbed CT;
                                                                  Figure A 9
           I +55  I -93  I +27  ! -50  1  +35 I  -38 1+39  1+3   1.495  '  -7^ l  +1
                                                                       Produetic
                                                                      Sys. Parzs
                                                                    NN  23 G-s7
                                                                      s
§
I
;P
^
•P
c.
o
                                              .Fscdas
                                        Mi CO
                     Qli BOARD SIS.  Bag 1,25:3 CO Cms.
                     	Bag 1 CO Gas.
                                        1 CO. Gas.
                     BASELir-S SI'S.  B»g I,2i3 CO G=s.
                                    Gcs/Mi CO
                                                                  15.9
                                                                   205
                                                                   118
         f-{
          a
C
M
              o
                   6-1 sO
                                 r-
                                      o t
                                      ac 3
                                               0 »•
                                                               o*
                                                            Q       ^

                                                            S?   I10
CVS
                                       Sequence

-------
                                      Procedure #3  Set 2
                                Mustang 5.0L (8Z19)  1978 ty States
                                     Date 7-8 & 9-78 Tost //Ht, 15
                                  Jr350 ml Canlatsr,  Tank & Garb. Bowl Vapors w/.l80" Purge Orifice
                                 I Grains of vapor,  Purged (-), Absorbed (+)
                +30  I -33  I  +77 I ~^5  I +22  I +3   I  -17 I
X
 g
•S«*6
i
I
 tf»
•8
o
fc
                                                       66
                                                                                        Foedsas CO Grama Bag
              t      t     t     f     t    t
              a]
              •H
              -P
              •H
              CJ
              M
                                      a
 in

^ 2!
•Ou
o +>
vl O
w W
w
•H CO
B t:"
cu b
                                                    O
                                                    •P
O
CO
                           t
                   o
                  to
a:
                                                               H-
                                                               OQ


                                                               fC

                                                               >

-------
                                             Figure A-11


                                DISTRIBUTION  OP GASOLINE PURCHASES
   too
  80
<
I
o
cc.
u.
O

h-
2
UJ
O
CC
UJ
Q-

LU
Z)
2

3  20
             10
._»-.

 20
                                                                            »*•
                                                                              »*««••*»»»
                                                                        •«*
                            **•»
30      40      50      60      70      60

    PERCENT OF TANK CAPACITY
90
100

-------
                                             Figure  A-12
                                  REFUELING EMISSIONS CONTROLLED
    too
 Q  ao
 LU
 oc
 H
 2

 O  60

 (/)
 Z
 o

 CO
 CO


 ui  «°
 a:
 O
    20
tu
'ac
«*
                                                           »»*
                                                              **«»
                                                                 #»»»«
                                                                     «*»»***«»»««»««*•«*»»»
                                                                                oo
              10      20      30      <10      80      60      70      00       90

              REFUELING TEST REQUIREMENT'FOR  NO EMISSIONS, % of TANK CAPACITY
                                                                       too

-------