Evaporative Emission Regulations for
Light Duty Vehicles and Trucks
(2 gram standard): Analysis of Comments
United States
Environmental Protection
'<10 L=il Agency
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Evaporative Emission Regulations for
Light Duty Vehicles and Trucks
(2 gram standard):
Analysis of Comments
Mobile Source Air Pollution Control
Office of Air and Waste Managment
U.S. Environmental Protection Agency
A United States
Environmental Protection
Agency
EPA-420-R-78-101
August 1978
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Introduction
The Notice of Proposed Rulemaking for Evaporative Emissions Regu-
lations was published on January 13, 1976. This rulemaking included a
proposal to implement a 2.0 g/test standard for the 1979 model year.
Eleven motor vehicle manufacturers, one environmental organization, the
research subsidiary of a petroleum company, and two governmental agencies
separate from EPA responded to the request for comments on a 2.0 g/test
standard. The respondents are listed in Table 1.
The responses were in general, directed toward the areas of concern
identified in the preamble to the NPRM. Only the topics specifically
pertaining to the proposed 2.0 g/test standard are addressed here.
These have been divided into two major issues, and these are "Technical
Feasibility and Lead Time .Requirements of a 2.0 g/test Standard" and
"Cost of a 2.0 g/test Standard". The issues that were generally appli-
cable to both the 6.0 g/test and the 2.0 g/test standards were addressed
in the 6.0 g/test regulatory package.
Most of the respondents argued that a two gram per test standard is
unattainable, or at least not attainable by 1979 - especially if vehicle
background hydrocarbon emissions are included in the measurement.
The analysis of comments consists of the following items:
1. A brief statement of each issue;
2. A description of each respondent's position regarding the
issue;
3. A discussion and analysis of the issue; and
4. Summary and Recommendations.
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Table 1
List of Respondents
1. American Motors Corporation (AMC)
2. Chrysler Corporation. (Chrysler)
3. Council on Wage and Price Stability
4. Department of Commerce.
5. Exxon Research and Engineering Co. (Exxon)*
6. Fiat
7. Ford Motor Company
8. General Motors Corporation (GM)
9. Honda Motor Company (Honda)
10. International Harvester (IH)
11. Natural Resources Defense Council (NRDC)
12. Nissan Motor Company (Nissan)
13. Toyo Kogyo, Co.
14. Toyota Motor Sales, U.S.A., Inc. (Toyota)
15. Volkswagen (VW)
* Although Exxon Research and Engineering Co., responded on behalf
of its corporation, it should be noted that Exxon Research and Engineering
was a contractor to EPA to explore evaporative emission control technology.
The subsequent discussions differentiate between the contract study
results and Exxon's corporate response to the NPRM.
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Issue - "Technical Feasibility and Lead Time Requirements of a 2.0
g/test Standard"
An evaporative emission standard of 2.0 g/test was proposed for the
1979 model year vehicles. This section deals with the technical feas-
ibility and lead-time requirements for meeting this regulation.
A. Summary of Comments
AMC - The question of inclusion or exclusion of the non-fuel
hydrocarbon background into the emission level must be adequately
answered before any consideration can be given to a 2.0 g/test standard.
Chrysler - Laboratory-to-laboratory test variability of 3.4 grams
per test and replicate test variability of 4.0 grams per test is not
uncommon. Tests on a six day old vehicle showed a hot background level
during a hot soak of 2.62 grams. Thus, the proposed regulatory level of
2 grams per test is unrealistic if the SHED technique•with its high
degree of test variability, and the inclusion of non-fuel background
emissions are utilized for certification purposes.
Chrysler also refers the EPA to Volume III of our "Progress Report
on Chrysler's Efforts to Meet the 1977 and 1978 Federal Emission Stan-
dards for HC, CO, and NOx" (December, 1975). In Section III-C of that
report, Chrysler itemized the thirty-six evaporative emission control
system development tests that it had conducted in the 1975 calendar year
through mid-November. From that program it is apparent that no evapora-
tive system technique tested to date on the 440 engine even approached
the 2 gram per test level* and that only limited success was obtained
with the 225 and 318 engines.
"It can only be concluded that our present state of evaporative
emission control cannot support a 2 gram per test control level and that
considerably more development is required... The amount of development
required to be conducted cannot feasibly be achieved before 1979 certi-
fication and most probably could not be effectively achieved even by the
start of the 1980 certification... The State of the Art of control of
evapor.ative emissions must be characterized as requiring the development
of new technology to provide more effective control systems rather than
application of existing technology."
Department of Commerce - Several major problems are posed by the
2 gram/test standard proposed for model year 1979 and later.
* Results varied between 9.03 and 2.73 grams per test.
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"(1) Is technology currently available to permit meeting the standard
of 2 grams per test? It is by no means clear that this can be done. Tech-
nology is assumed to be available in the draft environmental impact state-
ment .
(2) Interference from non-fuel evaporative emissions... The issue
of certifying vehicles less than 60 to 90 days old, with high non-fuel
evaporative emissions, has a real bearing on the impact on the environment
and on the costs of compliance with the 2 gram standard. It must be granted
that a widely varying non-fuel evaporative emission level is difficult to
take into account. But, the very fact that it can be large in comparison
with the 2 g/test standard means that it must be taken into account if the
standard is to be realistically met. To age all test vehicles for 60-90
days is not a practical solution, since certification at present takes
five to six months."
Exxon - "We believe that the proposed standard of 2 grams per SHED
test, for the 1979 model year vehicle, is an over-restrictive standard.
While such a 2 grams standard might be technically feasible, it is
difficult to meet and might be economically unattractive. We would like
to refer EPA to the recent work conducted at Exxon Research and Engineer-
ing Company under EPA Contract 68-03-2172 entitled "Investigation and
Assessment of Light Duty Vehicle Evaporative Emissions." We believe
that Table II of a status report dated January 23, 1976 submitted to Mr.
Ron Kruse of EPA would be of special interest here. In our opinion, the
cost-effectiveness relationship between the 6 and 2 gram standards
should be better defined before adopting a specific standard for the
1979 model year vehicle."
Fiat - Assuming to have the 1979 models certified by the end of
September 1978, this means that Fiat has to make its 1979 model year
application for certification on November 1977. In the period of time
which remains to that date, Fiat deems that it is very hard to extend to
all its production for the U.S., especially to new models now under
definition, evaporative systems which meet the 2 g/test standard, and to
verify, that their compliance with the standard is assured for the
"useful life" of any model of the car product line.
Fiat's opinion is that the reduction from a 6 g/test standard to a 2
g/test standard is not achievable in the course of only one model year.
Fiat suggests to postpone to later model years the proposed 2 g/test
standard and to adopt the 6 g/test standard for 1979.
Ford - The technological feasibility of the 2 gram standard specified
in the proposal for 1979 has not been demonstrated. The few select
production vehicles that have given test results of 2 g/test does not
prove feasibility for every vehicle, engine and system combination. Nor
does it suggest that there is sufficient technology to manufacture
complying vehicles in 1979 in sufficient quantity to meet consumer demand.
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Ford has supplied multiple SHED test data on 20 vehicles equipped
with the system componentry necessary to meet the 6 g/test standard.
The average emission level was 3.23 g/test and the test-to-test pooled
standard deviation was 0.82g. Ford has no program in place to meet a 2
g/test standard and cannot get a program underway within the remaining
time period to give any chance of meeting this standard in 1979.
A factor that complicates system development at a 2 g/test standard
level is the vehicle background. A test involving 12, 1976 model vehicles
indicates that the mean background level for a 90 day old vehicle is
0.75 g/test. The standard deviation is estimated to be 0.54 g at a 2 g
standard, which produces a 1.79 g/test upper 95% confidence limit. This
means the manufacturer must develop a zero fuel system evaporative
level. This technology clearly is not available today, nor is it expected
to be available in 1979. Ford recommends that the proposed 2 g/test
standard be deleted until such time as a need for a 2 g/test SHED
standard is shown in combination with proven technology.
GM - "The Administrator further states in the preamble (to the
NPRM) that the technological feasibility of a 2 g/test standard for 1979
model year is supported by the California Waiver Hearing record...and by
data developed by EPA. This information, the NPRM states, includes test
results which show that the 1975 production Vega, a fuel injected
Volkswagen and a 1974 Plymouth Duster currently generate evaporative
emissions below 2 g/test when tested by the proposed method.
A note here on the definition of "technological feasibility is in
order. Technical feasibility is defined by a demonstration on one car
or one line of cars. Technological feasibility, on the other hand,
means ability to produce all cars with similar performance.
General Motors contends that the Administrator has considered only
limited and very selective data and that the technological feasibility
for a 2 g/test standard for the entire line of General Motors vehicles,
or for that matter all motor vehicles available for sale in the United
States, has not been demonstrated. The preamble states that technological
feasibility is established by "...data developed by EPA". We have
requested these data from the Agency, which apparently includes measure-
ments at or below 2 g/test only on the three cars cited above. It
appears that EPA has no other test data on real cars at the 2 g/test
level."
GM supplied test data on several vehicles. Included were results
of 34 Vega 2 bbl tests covering nine vehicles. The average of these
tests was 2.53 g/test. Further testing was done on the Vega vehicle
with a 1 bbl carburetor. This 1975 regular production model exhibited
evaporative emissions averaging 7.73 g/test. The 2 bbl carburetor
vacuum operated bowl vent feature was added experimentally to the 1 bbl
carburetor and resulted in an average of 2.28 g/test for five tests and
other engines, with similar bowl vent equipment applied, do not even
approach the 2 g/test level.
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"The ability of General Motors to produce and market automobiles
that will meet the 2 g/test Evaporative Emission Control Standard requires
that we establish an engineering target level for the amount of evaporative
emissions that our design and development vehicles must achieve to be
considered candidates for certification...
Based on...car-to-car, test-to-test, and lab-to-lab variability, we
conclude that 50% of our...Chevrolet Vegas with 2 bbl carburetor, would
fail the proposed 2 g/test standard...
Further examination and analysis of these (Vega) data indicate that
General Motor's engineering design target would have to be about 1.0
g/test (90% confidence) to meet the proposed 2 g/test standard... The
technology to meet this standard has not been developed... It is
important to note that this analysis assumes that background emissions
would not be counted as evaporative emissions...If such a correction is
not allowed, the engineering design target would necessarily be even
lower.
...control to some level below 6 g may be achievable in the fore-
seeable future. However, no control system has yet been certified to a
SHED standard, produced and made available in the marketplace for field
experience. Until that experience is gained, we believe it is inappro-
priate to predict even the approximate level of a feasible standard
below 6 g."
Honda - Honda requests the EPA to keep the 6 g/test standard for at
least 2 years for the following reasons:
A. It is important to gain the experience of quality control of
the production vehicles with the new evaporative emission
control system incorporated including possible field problems.
B. Presently Honda does not have the technological feasibility to
achieve the proposed 2.0 gr/test standard. The following will
have to be solved in order to achieve the proposed standard.
.1. At the level of the 2.0 gr/test standard, hydrocarbons in
background will probably occupy more than half of total
hydrocarbons; therefore:
a. It is necessary to research and develop an evaporative
emission control system with which emits almost "0"
evaporative emissions and
b. It is necessary to research and develop technologies
to reduce car background hydrocarbons.
2. The research as to compatibility of the 2 gr/test evaporative
emission standard with the more stringent exhaust emission
standards to be regulated in the future.
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3. Development of an evaporative emission control system
compatible with the high altitude emission standards.
IH - IH believes that the 1979 standard of 2 g/test with the present
State of the Art is virtually unattainable on IH vehicles with no back-
ground allowance. The 2 g/test standard should be delayed until a precise
method of determining vehicle background emissions is available.
Natural Resources Defense Council - "We feel it is appropriate that
the reasons for the Administrator's judgment that this 2 gram per test
standard could not be applied to model year 1978 vehicles be articulated
in greater detail in the materials supporting this rulemaking. The
record indicates that some current production vehicles already apply
technology capable of achieving the 2 gram per test standard and that if
purged canisters were employed a test standard substantially lower than
the 2 gram per test standard could be met."
Nissan - Tests indicate that production vehicles equipped with
electronic fuel injection have emission levels which will probably meet
a 2 g/test standard. Tests on three such vehicles ranged from 1.2 to
1.5 g/test. In the case of carbureted vehicles, Nissan is unable to
estimate necessary lead time because it is not known yet what kind of
measures should be taken to reduce emission down to the 2 g/test level.
Nissan believes it will be able to have a better picture of this sometime
around the fall of this year. Baseline tests on six production carbureted
vehicles gave results of between 1.93 and 8.28 g/test. Tests on two
modified carbureted vehicles yielded minimum emission levels of 1.73 and
2.70 g/test.
A 6 g/ test standard in 1978 followed by a 2 g/test standard in
1979 would be a heavy burden to the manufacturer. Nissan therefore requests
that the 2 g/test standard be relaxed and also the enforcement of the
relaxed standard be postponed at least one year.
"It is our thought that 3 gr/test will be the lowest one we can
manage to comply with in 1980 model year, judging from the current
status of our development activity."
Toyo Kogyo - "We would like the EPA to investigate the technical
feasibility of a 2 g/test standard in 1979 before such a decision is
made. The currently available data on our production vehicles show that
the evaporative emissions resulting from something other than the
carburetor and tank would amount to 1-6 g/test, the causes of which we
do not yet know."
Toyota - "Our new evaporative emission control system progressed to
such a level that we may be able to satisfy the proposed 6 g/test standard
for the 1978 model year. However, we have the following problems when
attempting to meet the proposed 2 g/test standard for the 1979 model year:
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1. Hot Soak Loss
Our models generate 1 to 1.5 g/test of evaporative emission during
the hot soak loss test when tested by the proposed test method.
It can be expected that a small amount of fuel enters the carburetor
Venturis through the main or other nozzles due to the fuel vapor
pressure in the float chamber and is then vaporized. A control
valve may have to be provided in the main nozzle path in order to
prevent this phenomenon... Considerable lead time will be
required to develop such a system.
2. Diurnal Breathing Loss
Our models generate about 3 g/test of evaporative emissions
during the diurnal breathing loss test.
a. ...a part of the HC vapor evaporated in the fuel tank is
not stored in the canister but flows to the carburetor through the
outer vent and is discharged into the enclosure through the inner
vent and air cleaner. We are now reinvestigating the structure of
a canister capable of preventing the vapor from by-passing the
canister. However, at this stage, satisfactory results have not
yet been obtained.
b. Our canister is designed to have sufficient HC vapor
storage capacity when the ...purge air... flow reaches about 400
liters, which can be achieved by the current preconditioning. In
our system, 100 liters of purged air flows during one cycle of
UDDS. ...in order to solve this problem, the purge air flow has to
be increased...It would take a great amount of time for us to
develop such a purge control device because we must investigate the
correlation between the exhaust emissions and purge air flow and
also to perform the necessary recalibration of the carburetor.
When considering the lead time and future exhaust emission regulations,
we cannot say, at this stage, that the proposed 2 g/test standard for
1979 model year would be technically feasible for us. We also think
that since it is only one year after the implementation of the 6 g/test
standard, it is not a reasonable idea to change to the 2 g/test standard
because this may prevent development of a reliable control system.
Therefore, we think it desirable that the 6 g/test standard is maintained
for more than one year."
VW - To minimize the risk of failing certification tests, evaporative
emission control systems will have to be designed for less than 1 g/test.
Technical feasibility is not demonstrated by single measurement on only a
very few vehicles. There is no doubt that technical solutions could be
developed which are capable of meeting a 2 g/test standard. But there is
no evidence that such a limit is necessary and efficient with regard to
ambient air quality.
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B. Discussion
Commentors were generally concerned with the technical feasibility
and lead time requirements for meeting a 2.0 g/test standard. No auto-
motive manufacturer stated that it could meet a 2.0 g/test standard in
1979. In fact, nearly all manufacturers stated that a 2.0 g/test stan-
dard in 1979 is infeasible. The manufacturers identified four major
problem areas connected with the 1979 implementation of a 2.0 g/test
standard. These problem areas are (1) test variability, (2) technical
ability to reduce emissions from vehicles with stabilized background to
a level required for certification, (3) vehicle background (i.e., non-
fuel) emissions, and (4) lead time for equipment definition, development
and production.
1. Test Variability - In regards to test variability Chrysler
stated that laboratory-to-laboratory test variability of 3.4 g/test and
test-to-test variability of 4.0 g/test is not uncommon. However, this
test data is from a vehicle (Plymouth Valiant in the EPA-MVMA crosscheck
program) whose mean emission level was about 7 g/test. And the numbers
which are referred to as variabilities are ranges in the test data, not
standard deviations. Since absolute variability is dependent on emission
level, these numbers cannot be applied to vehicles with evaporative
levels of around 2 g/test.
In addition to the Plymouth mentioned above, the EPA-MVMA cross-
check program also used a vehicle (Chevrolet Vega) which had a mean
evaporative level of 2.0 g/test. The standard deviation of al-1 test
data obtained with this vehicle at the five test labs was 0.20g or 10%
of the mean value. This standard deviation includes test-to-test vari-
ability and lab-to-lab variability. Another indication of the varia-
bility associated with certifying vehicles to a 2.0 g/test standard is
given by data from the most recent EPA-MVMA emission correlation pro-
gram. Although none of the vehicles in this program had evaporative
emission levels as low as the Chevrolet Vega in the prior EPA-MVMA
crossckeck program, the lowest emitting vehicle (an AMC Pacer) had a
mean of 2.57 g/test. The standard deviation of all test data obtained
with this vehicle (at six test labs) was 0.32g or 12.6% of the mean
value. This standard deviation, like that for the Vega, also includes
test-to-test and lab-to-lab variability. The amount of variability
showed by these two vehicles is no greater than typical variability of
HC and CO exhaust emissions, as desribed in reference (1).
In response to the NPRM, Ford reported replicate test data on 20
vehicles. Each vehicle was tested at least three times. The mean
emission level was 3.23 g/test with a pooled standard deviation of 0.82g
or 25%. Interestingly, the range of standard deviations on individual
vehicles ranged from 1% to 60%. This indicates that some vehicles were
much less repeatable than other vehicles. For the Vega tests in the
MVMA crosscheck program, Ford tests had a standard deviation of 12%.
Ihis was not significantly higher than the other test labs, so this too
indicates that the 25% standard deviation of the 20 vehicle tests at
Ford was due to the high variability of some of the Ford vehicles rather
than variability due to emission measurement equipment. Another factor
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which may contribute to the higher variability of the Ford vehicle tests
as compared to the EPA-MVMA crosscheck tests, is that the Ford tests
were done sometime before the crosscheck program was conducted. It is
probable that interim improvements and refinements in the test procedure
resulted in some reduction in test variability.
In their response to the NPRM, GM stated that based on car-to-car,
test-to-test and lab-to-lab variability, 50% of the 2bbl Vegas would
fail the proposed 2 g/test standard. This is an illogical statement.
The percentage of vehicles predicted to be above a given emission level
depends on the mean level of each vehicle, not on the variability of the
test results. If 50% of 2bbl Chevrolet Vegas have an evaporative level
greater than 2.0 g/test, it is because the mean emission level of over
50% of these vehicles is over 2.0 g, not because of high test variability.
Based on the data from nine Vegas, GM stated that an engineering
design target of about 1.0 g/test would be required to meet a 2 g/test
standard. This takes into account car-to-car, test-to-test and lab-to-
lab variability. However, of the nine vehicles included in the data
base, two of them had accumulated 50,000 miles and one had accumulated
35,000 miles. The average emission level for these three vehicles was
3.65 g/test, as compared to an average of 1.97 g/test for the other six
vehicles. Consequently, data from all nine vehicles 9hows a high car-
to-car variability (the car-to-car standard deviation was about 35%) and
contributes heavily to the low engineering design target of 1.0 g/test.
The Vega used in the EPA-MVMA crosscheck program has generated
information in regards to test-to-test and lab-to-lab variability of a 2.0
g/test vehicle. As stated earlier, for all tests conducted on this
vehicle the standard deviation was 0.20 grams or 10% of the mean value.
With this combined test-to-test and lab-to-lab variability of 10%, the
maximum mean emission level a particular vehicle can have in order to be
at or below 2.00 g on a single test at a 90% confidence level is 1.77
grams. Also, in the certification process, a retest can be requested if
a vehicle fails the first test. For a 90% probability of passing at
least one of two tests, again assuming a standard deviation of 10%, the
vehicle mean is 1.90 g/test. The much lower engineering design target
of 1.0 g/test stated by GM is mainly a result of two factors—a single
test per car assumption and a high car-to-car variability. And the car-
to-car variability is high because of what appears to be deterioration
of three high mileage vehicles.
More recent information regarding test variability was supplied by
the manufacturers at the California 2.0 g/test waiver hearings in May,
1977 (10). Ford stated that, "Current SHED test variability experience
indicates that results are only accurate to within +0.8 grams per test"
(Hearing Record p. 288, line 9). Assuming that the upper and lower
boundaries of this range are three standard deviations from the mean,
as were the limits which Ford used for their background upper and lower
values in Exhibit 2 of their post-hearing submittal (letter and attach-
ment to Mr. Benjamin R. Jackson from D.R. Buist, June 9, 1977), this
implies a standard deviation of 0.27 grams which is 13% of a 2.0 g
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level. This is consistent with the test variability shown in four tests
on the one low-emitting AMC vehicle on which data was submitted (AMC
June 3, 1977 post-hearing submittal from William C. Jones to Mr. B.R.
Jackson). The mean of these tests was 1.26 grams and the standard
deviation was 0.12 grams or 10% of the mean. GM also raised the issue
of test variability. At the May 17, 1977 hearing they stated, "We
estimated that, on the basis of test variability alone, a one gram per
test design target was necessary to provide reasonable confidence that a
system could be certified to a two gram standard. Our experience since
that time has not altered that conclusion significantly" (Hearing Record
p. 228, lines 4-9). However in their post-hearing submittal (letter
and enclosures to Mr. Benjamin R. Jackson from T.M. Fisher, June 17,
1977), GM presented results of 40 tests on 1978 certification vehicles
and stated, "Based on these more recent data and using accepted statis-
tical analysis methods, our current engineering target is now estimated
to be about 1.4 g/test to ensure that certification and production
vehicles will meet the 2.0 g/test standard" (p.8). This target level
would give 90% confidence of passing one test. The statistical infor-
mation submitted by GM indicates that the confidence in passing one of
two tests is about 1.73 grams. It is also noteworthy that the 40 tests
on which the above statistical analysis is based are tests on 40 differ-
ent vehicles (both data and durability vehicles included) so these
results include vehicle-to-vehicle (within an evaporative emission
family) variability as well as test-to-test and site-to-site (within one
manufacturer's facility) variability.
2. Technical Ability to Reduce Emissions from a Vehicle with
Stabilized Background to a Level Required for Certification - An area
which was of concern to all manufacturers was the ability to lower
vehicle evaporative emission levels to the level required for certifi-
cation. The above discussion of variability showed that due to test-to-
test and lab-to-lab variability, a vehicle's true emission level must be
no higher than 1.90 g/test in order to be 90% confident of emitting no
more than 2.00 g/test on at least one of two allowed tests.
In addition to the limited amount of 2.0 g/test SHED .evaporative
emission test results to which the Administrator referred in the notice
of proposed rulemaking, considerably more such data are now available.
Some of these data have been supplied by auto manufacturers and other
organizations. Other data have been generated in an EPA contract study
conducted by Exxon Research and Engineering(2), and certification data
on 1978 model year vehicles is now available.
2.0 g/test data on production vehicles and modified vehicles are
contained in reference (1). In that document, the compilation of test
results from production vehicles (Table I) shows that eight different
stock vehicle-engine combinations have given SHED test results of below
2.0 g/test. And Table II of reference (1) shows that ten different
manufacturers developed experimental vehicle-engine combinations have
yielded average SHED evaporative emission levels of less than 2.0 g/test.
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As part of the Exxon evaporative study, six vehicles were modified
in order to reduce evaporative emissions. These vehicles represented
the four largest U.S. manufacturers and two foreign manufacturers. Each
vehicle had SHED evaporative emissions greater than 6 g/test in pro-
duction condition. These vehicles were a 1975 Ford LTD (351-2bbl) , 1975
Pontiac Grand Prix (400-4bbl), 1975 Chrysler New Yorker (440-4bbl), 1974
AMC Hornet (232-lbbl), 1974 Mazda (80-4bbl) and a 1974 Volvo (121-fuel
injected). In final modified form the average of the total evaporative
emissions (including vehicle background) from each of these vehicles was
1.2, 1.9, 1.2, 1.9, 1.5, and 1.1 grams respectively.
Chrysler states that from their test work it is apparent that no
evaporative system on their 440 engine even approached the 2.0 g/test
level and only limited success was obtained with the 225 and 318 engines.
In regards to the 225 engine, Chrysler supplied data on two vehicles (3).
Various configurations of a carburetor bowl vent were tested on one of
these vehicles. Seven tests were conducted using this type of device
and five of these tests gave results of less than 2.0 g/test. The
average for all seven tests was 1.78. In addition, one production
Plymouth equipped with a 225 engine and standard bowl vent was given
multiple tests by Exxon Research and Engineering (2). The average total
evaporative emissions from this vehicle was 1.5 g. From available data,
it appears that in addition to having "limited" success with the Chrysler
225 engine, the 2 g/test evaporative control system for this engine has
already been defined.
In regards to the Chrysler 318 engine, Chrysler supplied results of
four tests on one car which had been equipped with various types of car-
buretor bowl vents (3). Three of the tests were conducted with a one-
way bowl vent and one test with a two-way bowl vent. The three test
results with the one-way vent average 4.2 g/test, and the one test with
a two-way bowl vent gave a test result of 1.78 g/test. So a two-way
bowl vent may be adequate for this particular engine.
In Chrysler development tests with the 440 engine, the lowest
evaporative emission level reported was 2.57 g (3). This was attained
by using two 2-way carburetor bowl vents and cooling the intake mani-
fold. Tests with the same vehicle indicated that sealing the air
cleaner resulted in an evaporative emission reduction of about 2.0 g/test.
For the tests which used the bowl vents, there was no indication that
the leaks in the air cleaner had been sealed. If this were the case,
then sealing the air cleaner in addition to bowl venting could well be
expected to bring the evaporative emission level to below 2.0 g/test.
Leaks were also found in the air-cleaner of the 440 engine in the Exxon
study (2). In that test program these leaks were sealed in addition to
using two carburetor bowl vents, two canisters and sealing a carburetor
leak. The combination of these modifications reduced total evaporative
emissions to an average of 1.9 g/test.
Ford supplied data on twenty vehicles which were equipped with
their evaporative control system designed to meet a 6 g/test standard.
The mean emission for all vehicles was 3.23 g/test. Two vehicles of
this group received three repetitive tests each, and all six test results
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were below 2.0 g/test. One of these vehicles was equipped with a 302
engine and averaged 1.45 g/test. The other vehicle had a 400 engine and
averaged 1.54 g/test. Tests on the other 302 and 400 equipped vehicles
did not give average emission results as low as on these two vehicles.
However, the two above cited vehicles do demonstrate that it is techni-
cally feasible to attain emission levels of less than 2.0 g/test on the
302 and 400 engines. And, as Ford stated, these low emission vehicles
resulted from an effort to meet a 6.0 g/test standard. Ford had not yet
made any effort to meet a 2.0 g/test standard.
One Ford vehicle was modified in the previously mentioned Exxon
research program in order to reduce evaporative emissions. This was a
1975 LTD with a 351 engine. In addition to equipping the vehicle with a
PCV purged canister (a part of the Ford system discussed above), vapor
leaks were found and sealed in the air cleaner and around the carburetor
choke shaft. This resulted in total evaporative emissions of 1.2 g and
1.3 g on repetitive tests. Hence, the technical feasibility of attain-
ing a total evaporative emission level necessary to meet a 2.0 g/test
level on three of Ford's largest sales volume engines (302, 351 and 400)
has already been demonstrated.
In regard to GM's comments, it is agreed that the technological
feasibility for a 2.0 g/test standard for all motor vehicles available
for sale in the United States has not been demonstrated. To do this
would require demonstrating that one vehicle from every vehicle evapora-
tive emission family can achieve an evaporative level of less than 2.0
g/test. This would require modification and testing of about 100
vehicles. This is an unreasonable task for the regulatory agency. Such
a task would do much more than show technical feasibility — it would
define the required hardware for essentially every vehicle. This is a
job for the manufacturer, certainly not the Agency.
Additional test data was submitted by the manufacturers in regard
to the California 2.0 g/test waiver request. The GM submittal of June
17, 197 7 contained results of 160 evaporative emission tests on experi-
mental systems. As GM pointed out, 72 (45%) of these tests have produced
results below the 2.0 g/test level. In addition, GM supplied results of
40 tests on 0-mile 1978 certification vehicles. Thirteen (33%) of these
test results were less than 2.0 g/test. Ford also submitted (in their
June 9, 1977 document) development data on several of their vehicles.
Their "best effort" data on six major vehicle-engine combinations were
0.90, 0.79, 1.81, 2.10, 1.53 and 3.36 g/test.
Since the California waiver hearings, additional test data was
supplied by GM in a meeting with EPA representatives on August 8, 1977
(7). Test results were presented on six vehicles which were equipped
with a new design 2500 cc canister and an engine air filter to which
activated carbon was bonded. Four of the six vehicles were passenger
cars and their emissions ranged from 0.73 to 1.37 g/test. The other two
vehicles were a pickup and a suburban, both with 40 gallon fuel capacity,
and their emissions were 2.35 and 2.85 grams, respectively. GM representa-
tives indicated that if the durability of the air filters were satis-
factory, which had not yet been established, their passenger cars should
not have a problem in meeting a 2.0 g/test standard.
-------
-14-
In a more recent meeting between EPA and GM (January 19, 1978), GM
representatives stated that they had still not defined equipment which
would permit certification of their large fuel capacity light-duty
trucks to a 2.0 g/test standard (9). Data which they presented indicated
that improved hot-soak control measures would be required on some of
these vehicles in order to lower emissions to below 2.0 g/test. GM is
currently involved in a development effort aimed at reducing evaporative
emissions from these vehicles. In view of statements which have been
made by Ford Motor Company representatives, it does not appear that
control of evaporative emission from large fuel capacity light-duty and
medium-duty trucks is significantly more difficult than light-duty
vehicle control (Reference (10) p. 301-2).
Perhaps the strongest indicator of technical feasibility of a 2.0
g/test standard is the number of 1978 emission certification data vehicles
which have given evaporative emission results of 2.0 g/test or less. As
of September 27, 1977, 597 valid evaporative emission tests have been
conducted on 1978 model year data (A,000 mi) vehicles at the EPA testing
laboratory. Table I describes the test vehicles and results, and a
distribution of the results is shown in Figure I. Of the 597 tests, 225
(38%) were less than 2.0 grams. These are the levels from vehicles
which were designed to comply with a 6.0 g/test standard. For the 1978
model year, manufacturers are required to submit evaporative emission
deterioration factors (DF) to the EPA for determining compliance. The
average of the DFs currently submitted is about 0.3 grams. With this
DF, a data vehicle must have an evaporative level of 1.7 g/test or less
to meet a 2.0 g/test requirement. Of the 597 federal certification
tests mentioned above, 158 (or 26%) were 1.7 g/test or less.
The data cited above covers a sufficient number of vehicle-engine
combinations to confirm the technical feasibility of achieving a total
SHED evaporative emission level of 2.0 g/test for essentially all
vehicles with stabilized backgrounds.
3. Background Emissions - In their comments to the NPRM, most
manufacturers were highly concerned about vehicle background (i.e., non-
fuel) emissions. Since very new vehicles may have background levels
which are higher than a 2.0 g/test standard, this concern is understand-
able. As was the case with the 6 g/test SHED standard, it is not the
intention of the proposed rules to regulate "unstabilized" background
emissions. However, due to the increased stringency of the 2.0 g/test
standard, background emissions become of greater concern.
Ideally, background emissions would be measured each time the
vehicle is tested and the evaporative emission test results would be
adjusted accordingly (to exclude the "unstabilized" portion of the
background emissions). However, for durability vehicles this is highly
undesirable because the vehicle's fuel system must be removed or at
least altered during the mileage accumulation process. And these
changes could have some effect on both exhaust and evaporative emission
levels.
-------
-15-
For emission data vehicles, it also is riot always possible to
measure background emissions after the official tests are conducted. If
the evaporative test results were to be adjusted for "unstabilized"
background, the only means of knowing if a vehicle had passed an evapor-
ative test would be to measure background. If a retest were then requested,
the fuel system (which already had been removed) would need to be re-
installed and both exhaust and evaporative emissions retested. As in
the case of the durability vehicle, the changes in vehicle performance
which may be caused by this "tampering" make this test procedure unwork-
able.
Providing a correction factor which could be applied to results
from the enclosure test to account for non-fuel evaporative emissions
{e.g., allow subtraction of 1 g/test) has been considered. Such an
allowance could be in the form of a single standard correction factor or
different correction factors for different types of vehicles. However,
in actual practice, a correction factor has serious disadvantages. It
would be difficult to specify a reasonably valid correction factor due
to the rapid change in non-fuel evaporative emission levels from new
vehicles. Also, if vehicles with low non-fuel evaporative emissions
were used, as is generally the case, the correction factor would serve
as a bonus towards meeting the evaporative emission standard. It should
be noted that even a 1.0 g/test allowance, as recommended by many manu-
facturers, does not account for very new, high background vehicles. So
even an allowance of one gram will not solve this problem.
The existence of higher than stabilized vehicle background emis-
sions for new vehicles can act to both lower and raise a vehicle's
certified evaporative level. In the case of a mileage accumulation
vehicle, the decrease in background emissions with time will result in
lower than actual deterioration for the fuel system. On the other hand,
an emission data vehicle which has higher than stabilized emissions will
give higher evaporative test results than a stabilized vehicle. To
minimize both these effects, it is desirable that all test vehicles have
background emissions near their stabilized levels. This is at least as
important for a 2.0 g/test standard as it was for the 6.0 g/test standard.
The background emissions issue was throughly evaluated as part of
the 6.0 g/test regulatory package. Since that time additional infor-
mation has been obtained regarding unstabilized non-fuel emissions from
new vehicles and the ability to accelerate the reduction of these
emissions. A study done at the EPA laboratory indicated that obtaining
low background levels by artifically aging (baking) vehicles is feasible
for a cost of roughly $500 per vehicle (4). Three vehicles were artifi-
cially aged by baking 4 times at a temperature of 160°F for 12 hours
each time. Two of the vehicles were also aged by accumulating mileage
on a chassis dynamometer. The background levels (hot plus cold) roughly
40 days after manufacturer were .22g, .21g and .35g for two 1976 Ply-
mouth Volare's and a 1976 Chevrolet Nova, respectively. A second con-
centrated study of this problem was recently completed under contract to
-------
-10-
EPA (5). This program was designed similarly to the program conducted
at EPA. Background levels for the four 1976 model year vehicles which
were artificially aged ranged . 12g to .30g at roughly 15 days after
manufacture.
The most recent background test data available is from a program
conducted by Ford on two 1977 Granadas. One was built according to
normal assembly line procedures, and the other was built omitting about
95% of the sealer/sound deadener. The vehicle without the sealer/sound
deadener reached a stabilized background level of 0.2 grams approximately
10 days after build, and the standard vehicle reached a stabilized
background level of 0.3 grams approximately 30 days after build. Since
these nonfuel emission levels are lower than those submitted by Ford on
previous model year vehicles, it appears that their 1977 model year
vehicles have lower background levels.
k . Lead Time for Equipment Development and Production - The above
discussion concludes that it is technically feasible to meet an enclosure
evaporative standard of 2.0 g/test. This section discusses an appropriate
model year for implementing this standard.
The automotive manufacturers, in their comments to the NPRM, unani-
mously agreed that implementation for the 1979 model year would be
extremely difficult if not impossible. Honda, Fiat, and Toyota indicated
that they need more than 1 year at a 6.0 g/test level in order to develop
a 2.0 g/test system. Chrysler stated that development of a 2.0 g/test
system cannot be achieved by the 1979 model year and is questionable for
the 1980 model year. Ford stated there is no chance of meeting a 2.0
g/test standard by the 1979 model year. GM made no statement in regards
to an implementation date for a 2.0 g/test standard.
In the NPRM comments, the manufacturers argued that the hardware
has not yet been defined which will allow their vehicles to certify to a
2.0 g/test standard. GM and AMC maintained this same argument at the
California waiver hearings for 1980. EPA's analysis indicates that the
hardware required to meet this standard has not yet been defined for all
vehicles. However, several production, experimental and 1978 certifica-
tion systems have given results low enough to certify to a 2.0 g/test
standard. This indicates that systems can be developed for essentially
all vehicles. The manufacturer's comments to the NPRM did not, however,
contain information on the time schedule required to define and develop
this hardware. Due to the lack of this information, a lead time analysis
was conducted using information submitted by the manufacturers at the
hearings concerning California's waiver request for an evaporative
emission standard in 1978. This analysis is contained in reference (6),
which is contained in the Appendix to this Analysis of Comments section.
As described in this reference, the longest expected tooling time for
carburetor changes is 12 months. This is time required for any carbure-
tor casting or tool changes including bowl vent modifications.
-------
-17-
Prlor to the beginning of tooling changes, the new equipment must
be designed and developed. The manufacturers have stated that this
process would take about 8 months for a 6.0 g/test standard. Since a
2.0 g/test standard is more stringent than a 6.0 g/test standard, it
might be expected that more time would be required for the production
design and development. However, the manufacturers have already gained
considerable experience with evaporative control system design to meet
the 6.0 g/test SHED standard. This is evidenced by the test results
which have been obtained on 1978 certification vehicles, many of which
are below 2.0 g/test. In view of this, it is concluded that eight
months is also a reasonable length of time for production design and
development of systems which would enable essentially all vehicles to
meet a 2.0 g/test requirement.
With the above lead time considerations, and the start of engine
production in June, 1979 (for a 1980 model year implementation), the
date by which the necessary carburetor changes must be defined is
determined. These dates for GM, Ford and Chrysler are October, 1977;
November, 1977 and January, 1978; respectively. (This time schedule is
presented in more detail in Table I of reference (6)).
Some recent lead time information was offered by GM in an August 8,
1977 meeting between GM and EPA representatives (7). GM representatives
presented data which indicated that an evaporative control system con-
sisting of an experimental 2500 cc canister and an air filter coated
with activated carbon"would allow their light duty vehicles to meet a
2.0 g/test standard. They stated that the canisters could probably be
supplied in sufficient quantity for nationwide application for the 1980
model year; however, only enough air filters could be produced for
California applications for 1980. Air filter production for nationwide
application would require building of a new plant, making 1981 the
earliest applicable model year. In a similar meeting on November 4,
1977, GM representatives stated that an air cleaner housing containing
activated carbon might be used instead of the air filters; however,
lead-time for this modification was not different (8). It is likely
that the GM vehicles which certified at the 2.0 g level and below in
1978 will not need further control to comply with a 2.0 g/test standard.
Of the 119 evaporative certification tests which were conducted on 1978
model year GM vehicles at the EPA test facility, 30 (or 25%) of the
tests were 2.0 g or less. If, to meet a 2.0 g/test standard, air fil-
ters containing activated carbon are to be used on the vehicles which
currently do not meet a 2.0 g level, approximately 75% of GM cars will
be equipped with this device. In reality, less than 75% would require
the special air filter since use of only the new larger canister and
improved carburetor seals would be sufficient to lower emissions to
below 2.0 g/test on some of the vehicles. The extent to which this
would occur is not known.
-------
-18-
C. Summary and Recommendations
SHED test variability at the 2.0 g/test level is no greater than
variability of exhaust emission testing. Therefore, variability is not
a unique problem associated with certifying vehicles to a 2.0 g/test
SHED evaporative standard.
In regard to vehicle background (i.e., non-fuel emissions), it is
desirable that all test vehicles have stabilized background levels. The
manufacturer should be allowed to minimize these emissions from his test
vehicle in any way (e.g., accelerated aging, sand blasting, removing
upholstery, etc.) which does not violate provisions of the regulations.
It is then recommended that the emission measurements include any re-
maining vehicle background level.
Test results on production, certification and modified vehicles
show that an evaporative emission standard of 2.0 g/test (including
stabilized vehicle background) is technically feasible; however, due to
the time requirement for equipment definition, design, development,
certification and production the proposed 1979 implementation date is
impossible and a 1980 implementation date appears unachievable for some
manufacturers. For example, General Motors has stated that some of the
equipment (other than carburetors) which they are developing to meet a
2.0 g/test standard could be produced for nationwide application in
1981, but not for 1980. If carburetor machining changes are also required,
the time by which the hardware must be defined is October 1977, assuming
1980 model year implementation. In addition, a 1981 implementation date
will hopefully allow manufacturers time to develop hot soak control
measures which will not require the use of equipment which needs periodic
replacement, such as engine air filters. In view of these factors and
in consideration of the manufacturer's unanimous objection to a 1980
California 2.0 g/test standard without an allowance for background
emissions, it is recommended that the 2.0 g/test standard be promulgated
for the 1981 model year. A more detailed analysis of the lead time
issue is contained in reference (6), which is contained in the Appendix
of this Analysis of Comments section.
-------
Table I - suM'*aPv of i9/ri crc r^TiO'i
vF°.
test no. rOiiE •••nnt.L rws^i. o. cyl.
7*174^
S 70
941 mLa'I'l <"MUSFW HT 2/4
?S / .9
6
7«4S31
260
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4
7R3131
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2<*t 1
t>l (1.
rt
7*537=. *
363
2a5 15M'3rt -(Tl^Lf
1 l'l.
4
7'JS34«
590
9700qti,J5 SlflTION W40fN 2?
12.i.
4
7^3111
?cn
2Site^S0,;Li
?7s.
M
7-1311'*
200
2H'V52*0*
167.5
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121
70 -iw / 131 4
19'-.
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7H3114
S9n
4P1?lWfS-
2*0
210 1 onn\rif. ctvir CvCC
91.0
4
70210
2iojthomi\ Aoropn
9 '.0
4
7-1yo 7
57o
940151 AN) CPillbFP HT 2/4
?b/.9
*
7-ttftl 5
363
28^0'j. ID' E 1
91 .0
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7M2M'.
120
7o 0= f* i (?0I
l2«0F
167.5
6
7d2~2t-
600
43r lr,2-'-,4
16 1.0
6
7 n4 5*i 1
2nd
21 (lO^H.-iNOi civic 3nk
7o . 0
4
78,-192
200
2Pi3s45GSt i_
276.
R
7^2760
200
2fi i4S4S(is[ L 6.9
41 J.O
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7*1 R94
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940 [si AN) (*iJlSEt> hT 2/4.
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7-T125
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SOO^iljOT !-(•* SnjiN
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4
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1 7 . S
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30
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91.0
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7*130'
30
1 30 1 -J Fi I- ilflT
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6
7«242<*
570
94015L'lf1 -MISfr' HT 2/4
25/.9
6
7<*30b*
570
3O03i'CPEssir<> sEO'-i
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6
78u372
30
191 IS 'U .1 '*0 II 2rw<6 t33»-
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19olb v«i)Sl-fjr, (^.9^)
141,.
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lv,os *>i\r
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4
783480
= 70
3«00Sr<)P(jLLi 4 )0 qc-Q m
71 .?
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7A3561
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7i120r!'"« / J 3 I
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7"4747
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784151
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T0TAL D I/\0
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Figure 1. - Results of EPA Conducted
Evaporative Emission Tests
on 1978 Model Year Certi-
fication Data Vehicles.
Note: 10 highest values
are not shown.
-------
-19-
References
(1) "Technical Feasibility of a 2.0 g/test SHED Evaporative Emission
Standard for Light Duty Vehicles and Trucks," Issue paper by
Michael W. Leiferman, U.S. EPA, Ann Arbor, Michigan, June 1976.
(2) Clarke, P. J., "Investigation and Assessment of Light Duty Vehicle
Evaporative Emission Sources and Control," Exxon Research and
Engineering, EPA Contract #68-03-2172, June 1976.
(3) "Progress Report on Chrysler's Efforts to Meet the 1977 and 1978
Federal Emission Standards for HC, CO and NOx," Vol III, Chrysler
Corporation, December 1975.
(4) "A Study of Methods for Reducing Evaporative Background Hydrocarbon
Emissions from New Vehicles", Technical Support Report for Regulatory
Action, OMSAPC, U.S. EPA, Ann Arbor, Michigan, October 1976.
(5) "Accelerated Decay of Non-fuel Evaporative Emissions", Automotive
Environmental Systems, Inc., EPA Contract No. 68-03-2413, Report
EPA-460/3-76-026, August 1976.
(6) "Lead time Requirements for an Evaporative Emission Standard of 2.0
g/test for Light Duty Vehicles and Trucks," Issue paper by Michael
W. Leiferman, U.S. EPA, Ann Arbor, Michigan, June 1976, (Revision
11/77).
(7) EPA Memorandum to the File entitled, "Meeting with General Motors
Concerning Their Development Efforts to Meet a 2.0 g/test Evaporative
Emission Standard", August 11, 1977.
(8) EPA Memorandum to the File entitled, "Meeting with General Motors Con-
cerning Lead Time Necessary for Implementation of a 2.0 g/test
Evaporative Emission Standard for Light Duty Vehicles and Light
Duty Trucks", November, 1977.
(9) EPA Memorandum to the File entitled, "Meeting with General Motors
(GM) Concerning GM's Progress in Developing Light-Duty Truck
Evaporative Control Systems for the Proposed 2.0 g/test Standard",
February, 1978.
(10) "Public Hearing on California Waiver Request", Hearing Record
Vol. II, pgs. 213-333, May 17, 1977.
-------
-20-
Issue - "Cost of a 2.0 g/test Standard"
The following comments were received regarding the costs involved
in meeting a 2.0 g/test standard.
A. Summary of Comments
AMC - American Motors cannot respond to the specific question
regarding lead time and component cost per vehicle for the 2 g/test,
1979 proposed standard, as we are still in the process of evaluating and
developing probable 1977 and 1978 systems.
Chrysler - Assuming a one gram background subtractive factor, the retail
price increase per light-duty vehicle is estimated at $50.00 over the
1977 models.
Council on Vfage ^and Price Stability - There is some disagreement
regarding the increased price that will result from the 2 g/test stan-
dard. EPA estimates the cost at $11, but one manufacturer (Chrysler)
gave the Council an estimate of $50. The Council urges that EPA resolve
this cost issue before a decision is rendered on the 2.0 g/test standard.
Department of Commerce - The draft environmental impact statement
estimates that the retail "sticker" price per vehicle will increase an
average of $11.00. However, Chrysler estimates the price increase at
$50.00 per vehicle.
"Although we do not wish to imply that the industrial estimate is
necessaily preferable to the EPA estimate, we do feel strongly that such
statements (along with others from various segments of the industry)
should be carefully considered in discussing the economic impact of the
proposed regulations."
IH - IH does not have sufficient information and experience to
attempt a cost estimate.
Nissan - Since the current production fuel injection system will
probably require no modification, there would be no additional retail
cost for these vehicles. In the case of carbureted vehicles, we are
unable to establish costs because we do not know what equipment will be
required. The following is the retail cost increment only for the
devices we used in our experimental work.
Retail cost increment (per/vehicle - 1977 model base)
Auxiliary cooling fan for carburetor
Delay timer
Air inlet shut-off valve
Carburetor external vent
Increased Canister capacity
$16.90
$ 5.05
$ 3.AO
$ 4.15
$ 1.80
Total
$31.30
-------
-21-
Assumption: Current price level
1 U.S. dollar = 304 Yen
Toyota - "Though a precise cost estimate cannot be made, the price
increase per vehicle would be about 18 to 23 dollars over the cost of
the current system, if modifications of the carburetor and/or canister
are made in order to meet the proposed 2 g/test standard."
B. Discussion
Three vehicle manufacturers gave cost estimates for control systems
which would allow current production vehicles to meet a 2.0
g/test standard. The estimated increases in vehicle retail price were
$50.00, $31.30 and $18-23 for Chrysler, Nissan and Toyota, respectfully.
Chrysler stated that the design changes which would be needed to
meet a 2 g/test standard would be at least the following:
1. Vent carburetor bowl to the charcoal canister
2. Add two-way vent (mechanical or solenoid operation) to
carburetor
3. Increase vapor storage capacity by 200%
A. Improve "0" ring shaft seals (fluorosilicone)
5. Provide heated air purge for canister
6. Add activated charcoal inner element to air cleaner
7. Relocate fuel tanks on some models away from exhaust
system (with rear underbody modifications)
8. Heat shielding between exhaust pipe and/or resonator and
fuel tank.
9. Provide carburetor blower fan with thermal switch
10. Provide vapor tight air cleaner door
11. Add carburetor thermal isolation
12. Recertify fuel system revisions to MVSS301 requirements
Some of the modifications listed above are redundant. For example,
if modification 2 were done, the internal carburetor vent would be
closed when the engine is not running and bowl vapors would be prevented
from going into the air cleaner. In this case modifications 6 and 10
would not be required. Or if modification 10 were done, modifications 2
-------
-22-
and 6 would not be required. Also modification 3 and 6 appear redundant.
Modification 6 increases vapor storage capacity which is covered by
modification 3.
It is also extremely doubtful if modifications 3 and 9 listed above
are both needed. Increasing the vapor storage capacity by 200% should
easily handle the vapors which are currently generated. In a vehicle
evaporative study conducted by Exxon Research and Engineering , a
Chrysler New Yorker with 440 engine was modified to reduce evaporative
emissions. On this vehicle the activated carbon vapor storage capacity
was increased 100%, and a barrier in the air cleaner was installed to
somewhat increase the vapor storage capacity of the air cleaner. With
this increase in vapor storage capacity, the vehicle emitted an average
of 1.9 g/test, without any carburetor cooling or carburetor modifications.
So a 200% increase in vapor storage capacity appears to be more than
adequate, even without a cooling fan.
The Nissan estimate of $31.30 is composed mainly of the cost for
the auxiliary cooling fan. As in the case of the Chrysler vehicle, if
the vapor storage capacity is sufficient, this cooling fan should not be
necessary. However, we do not have any test data for modifications on
Nissan vehicles.
The previously referenced study by Exxon has produced substantial
information on the types and costs of modifications which are necessary
to reduce total SHED evaporative emissions from current production
vehicles to levels below 2.0 g/test. Six vehicles were modified in
this test program, and each of the six vehicles averaged less than 2.0
g/test of total evaporative emissions (including vehicle background) at
completion of the study. Exxon also estimated the cost of each of the
modifications performed. These modifications and the cost of each are
summarized in Table I. As shown, the cost per vehicle ranged from $2.00
for the Ford vehicle to $25 for the Mazda. The costs listed are twice
the cost to the manufacturer. This was assumed to be representative of
the increase in vehicle retail cost for these modifications. More
details pertaining to these modifications, costs and the associated
emission levels are contained in references (1) and (2).
Although most manufacturers did not provide cost information on
control systems needed to meet a 2.0 g/test standard, all three of the
largest U.S. manufacturers did supply information on systems which had
been tested and which gave test results of less than 2.0 g/test. Using
Clarke, P.J., "Investigation and Assessment of Light Duty Vehicle
Evaporative Emission Sources and Control, "Exxon Research and
Engineering, EPA Contract //68-03-2172, June 1976.
(2)
"Cost Effectiveness of a 2 g/test SHED Evaporative Standard for Light
Duty Vehicles and Trucks," Issue paper by Michael W. Leiferman,
U.S. EPA, Ann Arbor, Michigan, June 1976.
-------
Table I. Summary of Vehicle Modifications and Costs in
Achieving a 2.0 g/test Level (EPA Contract No. 68-03-2172)
Vehicle
Modifications
Cost, $
¦75
Ford
Canister replacement
1.00
Seal carburetor leak
0.30
Barrier in air cleaner
0.20
Air cleaner sealing
0.30
Canister bottom cap
0.20
Total
2.00
'75
Pontiac
Bowl vent to canister
0.50
Seal carburetor leak
0.30
Air cleaner sealing
.30
Canister replacement with PCV
purge
1.20
Total
2.30
'75 Chrysler
Canister replacement
4.00
Canister bottom caps
0.40
Bowl vent to canister
0.50
Barrier in air cleaner
0.20
Seal carburetor leak
0.30
Air cleaner sealing
0.30
Total
5.70
¦74
Hornet
Seal carburetor leak
0.30
Bowl vent to canister
0.50
Air cleaner sealing
0.30
Canister replacement with PCV
purge
1.00
Canister bottom cap
0.20
Barrier in air cleaner
0.20
Total
2.50
'74
Mazda
2 bowl vents to canister
1.00
Canister installation with PCV
purge
7.00
Underhood ventilating fan
17.00
Canister bottom cap
0.20
Total
25.20
'74
Volvo
Canister replacement
1.00
Heat shield between tank
and muffler
1.00
Total
2.00
-------
Table II. Estimated Increase in Vehicle Retail Price for
Manufacturer Designed and Tested Systems Which Have
Yielded Evaporative Losses Less Than 2.0 g/test
Vehicle
No. Make Modification Cost, $
1 Oldsmobile Dry canister (PCV purged) 0.60
Sealed door in air cleaner snorkel 3.40(1)
Bowl vented to canister 0.50
Total 4.50
2 Chevelle Vapor purge valve (PCV purged) 0.60
Bowl vented to canister 0.50
Internal vent closed ,
(2-way bowl switch) 4.00
Total 5.10
3 Chrysler 2-way carburetor bowl vent switch 4.00
4 Chrysler Bowl vented to canister- 0.50
5 & 6 Ford Bowl vent valve 3.00
Enlarged canister 3.00
PCV purged canister 0.60
Auxiliary canister 3.00
Electronic air cleaner door 3.40
New gas cap 0.25
Total 13.25 (15.00)(2-
7 Oldsmobile Manually operated carb. bowl switch 3.00
8 Oldsmobile Vacuum operated carb. bowl switch 3.00
9 Oldsmobile Bowl vent to canister 0.50
Door in air cleaner snorkel 3.40
Total 3.90
10 Oldsmobile Manually operated carb. bowl switch 3.00
(1) From manufacturers' comments on "Proposed Evaporative Emission Regulations
for Light Duty Vehicles and Trucks", January 13, 1976.
(2) Ford's estimate for this system submitted to the EPA on February 27, 1976.
-------
-23-
the costs of modifications determined by the Exxon study, it is possible
to estimate the increase in vehicle retail price for these manufacturer
developed and tested systems. This has been done in reference (2) and
the vehicles, modifications and costs are listed in Table II.
For the Ford vehicles in Table II, the control system is one
developed to meet a 6.0 g/test standard. Ford has stated the cost of this
system is $15.00, which agrees quite well with the cost of $13.25 which
was obtained by summing the estimated costs of the major individual
components. As listed in the above table, the costs for the Chrysler
and GM modifications ranged from $0.50 to $5.10 per vehicle.
C. Summary and Conclusion
The increase in vehicle retail price estimated by Chrysler ($50)
was much higher than what will be necessary to control SHED evaporative
emissions to 2.0 g/test. Tests have been conducted on a vehicle equipped
with the engine (440 CID) which this manufacturer indicated is their
most difficult to control. The SHED evaporative emissions from this
vehicle (including vehicle background) were controlled to an average
level of 1.9 g/test for an estimated retail price increase of $6. It is
also believed that more than the necessary amount of equipment has been
included in the estimated price from Nissan; however, test information
on modifications to Nissan vehicles Is not available.
In a test program conducted by Exxon Research and Engineering
Company, six production vehicles were modified to give total SHED
evaporative emission levels of below 2.0 g/test. From this work the
estimated U.S. sales weighted increase in vehicle retail price is $3
over current production vehicles. Based on the estimated costs of
manufacturer developed and tested systems which have given SHED evapora-
tive results of less than 2.0 g/test, the U.S. sales weighted increase
in vehicle retail price is $7 over current production vehicles. It is
expected that the actual increase in retail price of current production
vehicles due to implementation of the 2.0 g/test standard will be between
these two values, i.e., between $3 and $7 per vehicle.
From data gathered in the Exxon Study, the U.S. sales weighted
increase in vehicle ..retail price to meet a 6.0 g/test evaporative standard
has been estimated. This cost was $2 per vehicle. Considering the
cost information in the above paragraph, the estimated U.S. sales weighted
increase in retail price to go from a 6.0 g/test standard to a 2.0 g/test
standard is between $1 and $5 per vehicle.
(3)
Chrysler Corporation comments to "Proposed Evaporative Emission
Regulations," published in Federal Register 41 FR 2022 et seg
on Jan. 13, 1976, Feb. 27, 1976.
(4)
Based on sales data in "Automotive News Almanac, 1975," and
"Automotive News, Mar. 22, 1976."
-------
Issue Paper
Technical Feasibility of a 2.0 g/test SHED
Evaporative Emission Standard for Light Duty
Vehicles and Trucks
June 1976
Michael W. Leiferman
Standards Development and Support Branch
Emission Control Technology Division
Office of Mobile Source Air Pollution Control
Office of Air and Waste Management
U. S. Environmental Protection Agency
-------
Technical Feasibility of a 2.0 g/test SHED Evaporative
Emission Standard for Light Duty Vehicles and Trucks
1. Statement of the Problem
Does the technology exist to meet a SHED evaporative emission
standard of 2.0 g/test for light duty vehicles and trucks?
2. Facts Bearing on the Problem
a. Some 1974-76 production vehicles have evaporative emission
levels below 2 g/test as measured by the proposed 1978 SHED testing
procedure. Tests on 16 1975-76 2bbl Chevrolet Vegas showed that 10
of these vehicles averaged less than 2 g/test. Tests on a 1974
Plymouth Duster, a 1976 Datsun Pickup, a 1975 Volkswagen with fuel
injection (FI), a 1975 Cadillac with FI, a 1976 Vega with FI, a
1976 Audi with FI and three Datsuns with FI have also yielded
results of less than 2 g/test. Available test information for
these eight types of vehicles is listed in Table I.
b. Under EPA Contract No. 68-03-2172, Exxon Research and Engineering
modified the evaporative control systems and measured the evapora-
tive and exhaust emission levels of six vehicles . In the final
modified form, the SHED evaporative emissions, including background,
from each of these six vehicles averaged less than 2 g/test. For
only one of these vehicles was the exhaust emissions of CO or HC
significantly higher in the modified condition than in the stock
condition. The results of these tests are contained in Table II.
c. Some manufacturer-developed experimental evaporative emission
control systems have given SHED evaporative emission levels, including
background, of less than 2 g/test. These systems and test data are
given in Table III.
d. Tests have shorn that well purged canisters substantially
reduce diurnal emissions. This program was conducted at the EPA
Vehicle Emissions Laboratory and results are shown in Table IV.
e. Background SHED emissions were determined on 15 1973-75
production vehicles (all at least 90 days old) by Exxon under
Contract No. 68-03-2172. Seven of these vehicles had background
levels of 0.1 g/test or less, and the average value was 0.34 g/test.
These data are presented in Table V.
f. Variability of the SHED evaporative test was evaluated for a
vehicle near the 2 g/test level in a recent MVMA-EPA cross-check
test program. Within the five test sites, the standard deviation
ranged from 3% to 12%. The standard deviation of all tests at all
sites was 10%.
Clarke, P. J., "Investigation and Assessment of Light Duty Vehicle
Evaporative Emission Sources and Control," Exxon Research and Engineer-
ing, EPA Contract // 68-03-2172, May 1976.
-------
-2-
TABLE I. SHED Evaporative Tests on Production Vehicles
Tested
No. of
Average
Average
Total,
£
Vehicle
Engine
By
Tests
Diurnal, g
Hot Soak,
g Range
Average
'75 Vega
140-2 bbl
ARB
1
0.4
1.5
1.9
'75 Vega
140-2 bbl
ARB
1
0.4
1.1
1.5
'75 Vega
140-2 bbl
ARB
1
0.6
1.2
1.8
'75 Vega
140-2 bbl
ARB
3
0.2
0.9
1.2-1.3
1.2
'75 Vega
140-2 bbl
ARB
1
0.3
0.8
1.1
*75 Vega
140-2 bbl
GM
5
1.37
1.02
2.39
175 Vega
140-2 bbl
GM
2
0.40
1.59
1.99
'75 Vega
140-2 bbl
Exxon
2
0.27
4.48
3.82-5.67
4.75
'75 Vega
140-2 bbl
EPA
7
0.61
0.78
1.15-1.61
1.39
'76 Vega
140-2 bbl
EPA-MVMA
22
0.94
1.06
1.59-2.45
2.00
'76 Vega
140-2 bbl
GM
1
0.80
0.60
1.40
*76 Vega
140-2 bbl
GM
1
0.88
2.87
3.75
'76 Vega
140-2 bbl
GM
2
1.14
2.01
2.30-3.99
3.15
'76 Vega
140-2 bbl
GM
1
1.35
2.71
4.06
'7 6 Vega
140-2 bbl
GM
13
0.64
1.44
2.08
'76 Vega
140-2 bi?l
GM
5
0.69
1.16
1.85
'76 Vega
121-FI^
GM
1
0.64
0.87
1.51
'74 Ply.
225-1 bbl
Exxon
2
0.47
1.03
1.23-1.76
1.50
Duster
75 Cad.
500-FI
GM
2
0.25
1.07
1.32
2.01U;
'75 VW
97-FI
Exxon
3
0.67
1.34
1.55-2.61
'75 VW
97-FI
EPA
11
0.83
1.90
2.44-3.42
2.73
'75 VW
97-FI
ARB
1
-
2.90
'75 VW
97-FI
VW
3-5
-
-
3.8- 5.8
—
'7 6 Aud i
97-FI
VW
3-5
-
-
0.8- 2.4
-
'76 Datsun
]68-FI
Nissan
1
0.51
0.69
1.20
'76 Datsun
168-FI
Nissan
1
0.29
1.06
1.35
'76 Datsun
16S-FI
Nissan
1
0.38
1.13
1.51
'76 Datsun
119-2 bbl
Nissan
1
0.26
1.67
1.93
(1) FI = Fuel Injected
(2) Includes a background level of 1.5 grams.
-------
TABLE II. SHED Evaporative Tests on Vehicles Tested Under Contract No. 68-03-2172.
ECS
Evaporative Emissions, g
Exhaust
Emissions
, g/mi^
Condi-
No. of
Average
Average
Total
Vehicle
Engine tion
Tests
Diurnal
H. Soak
Range
Average
HC
CO
NOx
'75 Ford
351-2bbl Stock
2
3.4
3.2
6.2 -7.1
6.7
0.54
6.75
1.62
Modified
2
0.2
1.0
1.2 -1.3
1.2
0.52
4.44
1.87
'75 Pontiac
4Q0-4bbl Stock
2
0.4
7.1
7.2 -7.8
7.5
0.80
6.95
1.31
Modified
3
1.2
0.7
1.6 -2.5
1.9(2.
0.68
4.05
1.36
'74 AMC
232-lbbl Stock
2
0.5
10.3
10.8 -10.8
10.8
1.50
24.5
1.24
Modified
2
0.3
0.9
1.2 -1.3
1.2
1.51
26.9
1.13
'74 Mazda
80-4bbl Stock
2
0.2
10.4
10.5 -10.7
10.6
2.11
11.7
0.88
Modified
2
0.6
0.9
1.3 -1.8
1.5
1.82
9.90
0.65
'74 Volvo
121-FI Stock
2
4.7
3.2
7.1 -8.7
7.9
0.91
13.3
2.15
Modified
2
0.7
0.4
0.4 -1.7
1.1
1.24
22.6
1.58
'75 Chrysler
440-4bbl Stock
2
5.3
8.6
13.4 -14.6
13.9
2.32
23.2
1.98
Modified
2
!
0.6
1.3
1.9 -2.0
1.9
1.10
13.3
1.83
Average of 2 or more tests
(2)
This data is for an underhood ventilating fan system. A PCV-purged canister system was later
tested on this vehicle and average 1.6 g/test for 2 tests.
-------
-4-
TABLE III. Manufacturer's SHED Evaporative Tests on Experimental
Control Systems.
Vtehicle
No. Make
Engine, CID Carburetor
No. of
Tests
Diurnal
Average Emissions, g
Hot Soak
Total
1
2
3
4
5
6
7
Oldsmobile
(2)
Chevelle
Chrysler
Chrysler
Ford(5)
(1)
(3)
(4)
Ford
(5)
Oldsmobile
8 Oldsmobile
9 Oldsmobile
10 Dldsmobile
(6)
(7)
(8)
(9)
455
250
318
225
302
400
455
455
4 bbl
1 bbl
2 bbl
1 bbl
4 bbl
4 bbl
0.33
1.17
1.50
0.64
1.23
1.87
0.42
1.31
1.78
0.72
1.05
1.78
-
-
1.45
-
-
1.54
0.85
1.07
1.92
0.74
0.96
1.70
0.80
0.92
1.72
0.48
1.18
1.66
(1) Dry canister, closed air cleaner snorkel during hot soak and float bowl
vented to canister.
/"?) Vapor purge valve, float bowl vented to canister and internal vent closed.
) 2-way carburetor bowl vent.
v<+) Carburetor bowl vent to canister.
(5) Bowl vent valve,PCV purged enlarged canister, auxiliary canister, electronic
air cleaner door and new gas cap.
(6) Proposed production ECS design with manually operated carburetor bowl switch.
(7) Proposed production ECS design with vacuum operated carburetor bowl switch.
(8) Experimental V-8 engine with bowl vent and air cleaner door, 1978 prep.
(9) Experimental V-8 engine with manual bowl vent switch, 1976 prep.
TABLE IV. Effect of Pre-purged Canister on SHED Diurnal
Emissions from 1975 Model Vehicles
Model
Engine, CID
Carburetor
Proposed
Procedure, g
Procedure with
Pre-purged canister, g
Camaro
350
2 bbl
0.92
0.25
Vega
140
2 bbl
0.54
0.35
New Yorker
440
4 bbl
5.1
0.48
Matador
360
4 bbl
4.5
0.85
jrage
1
2.77
0.48
-------
-5-
TABLE V.
SHED Background Measurements
or Production
Vehicles
Vehicle
Background Emissions, g
Year
Make
Model
Cold
Hot
Total
'75
Chrysler
¦New Yorker
0.0
0.1
0.1
'75
Ford
Country Squire
0.0
0.1
0.1
'75
Mercury
Monarch
0.0
0.0
0.0
'75
Chevrolet
Vega
0.0
0.6
0.6
'75
Buick
LeSabre
0.1
0.3
0.4
'75
VW
Beetle
0.7
0.8
1.5(1)
'74
AMC
Hornet
0.0
0.1
0.1
'74
Dodge
Dart
0.0
0.1
0.1
'74
Mercury
Comet
0.0
0.1
0.1
'74
Ford
Pinto
0.0
0.2
0.2
'74
Chevrolet
Nova
0.0
0.1
0.1
74
Oldsmobile
98
0.2
0.3
0.5
'74
Datsun
610
0.1
0.2
0.3
'74
Mazda
RX-4
0.5
1.1
1.6(2)
'74
Volvo
144
0.1
0.1
0.2
'73
Plymouth
Fury III
0.1
0.7
0.8
<3>
Average
0.09
0.25
0.34
(1) Source tests indicate the emissions are coming from the external enamel
paint.
(2) Evidence of gasoline spillage in trunk.
(3) Omitting the 1974 Mazda.
-------
-6-
3. Discussion
a. Table I indicates that most 1975 Vegas have evaporative emis-
sions of less than 2 g/test. The evaporative control system (ECS)
used on this vehicle is unique in the automotive industry. It uses
the charcoal canister to store carburetor bowl vapors and the
canister purges through a line into the PCV system during off-idle
operation. Since this ECS was highly effective on its first applica-
tion, the successful use of this system on other vehicles looks
very encouraging. There is no technical reason why this basic
purge system cannot be installed on other engines.
, The ECS used on the Plymouth listed in Table I purges the
canister through a line into the carburetor. Since data on only
one of these production vehicles is available, the effectiveness of
this particular engine-ECS combination is not as well established
as that of the Vega. Similarly, there are only limited data on the
carbureted Datsun listed in Table I. The Cadillac, VWs, Audi, 168
Datsuns and 121 Vega in Table I are fuel injected, so induction
system losses are markedly reduced over non-controlled carbureted
engines.
b. The purpose of Contract No. 68-03-2172 with Exxon Research and
Engineering was to determine the amount of evaporative emissions
from late model production vehicles, the source of these losses,
and the hardware required to minimize these losses. The vehicles
tested were obtained from rental fleets or from private owners.
The Exxon data listed in Table I are from this program. Twenty
vehicles were tested for the specific sources of evaporative losses
and the largest source was found to be the engine air cleaner
during the hot soak. Most of these vapors were emitted through the
snorkel; however, some leaks were found at seams in the air filter
housing and between the housing and the carburetor. These losses
could be prevented by using a vapor tight air filter housing,
fastening the housing securely to the carburetor, equipping the
snorkel with a vapor eight door which would close vhen the engine
is not running or cranking, and venting the carburetor float bowl
to a carbon canister.
The second greatest source of vapor losses found by the
Exxon study was the carburetor during hot soak. Most of these
losses were emitted around the accelerator pump shaft. Some
losses were also detected around throttle shafts. The losses
around the accelerator pump shafts could most simply be prevented
on most carburetors by fastening a vapor tight flexible boot around
the shaft and against the carburetor. Such a device has already
been used on some production carburetors. Another fix would be to
switch from plunger to diaphram type accelerator pumps. These also
are standard on some production carburetors. Leaks around throttle
shafts would probably best be prevented by an improved fitting
-------
-7-
between the throttle shaft and the carburetor wall. Many of the
vehicles tested did not have losses from around the carburetor
throttle shafts. Therefore, preventing these losses on all car-
buretors should present no major problem.
The final source of emissions which contributed a substantial
amount to the total loss from the production vehicles
was the carbon canister. The quantity of emissions from this
source was about equally divided between the diurnal and hot soak
phases. These losses can be prevented by increasing the working
capacity of the canister as previously discussed.
The next step in Exxon's contract was to modify or change the
evaporative systems on 6 of the production vehicles they had tested
and then evaluate the effect of these alterations on evaporative
and exhaust emissions. The final results of these tests were pre-
viously presented in Table II. As shown, the six vehicles selected
represent the four major U.S. vehicle manufacturers and two foreign
manufacturers. Final modifications resulted in an average level,
for each vehicle of below 2.0 g/test, including background. Only
one of the final 13 tests gave an emission of greater than 2.0 g
(the 2.5 g result on the Pontiac).
A listing of the specific modifications and corresponding
emission levels for each vehicle is contained in Attachments 1
through 6 of the Appendix. As listed, several different modi-
fications were evaluated on some of the vehicles. A summary of
these modifications is listed in Table VI. As shown in Table VI,
canister purge into the intake manifold via the PCV line was
installed on three of the vehicles and worked effectively. It was
expected that a PCV purge would also be effective on the Chrysler
and Pontiac, but other types of modifications were used on these
vehicles in order to investigate other types of control systems.
An underhood ventilating fan was used on the Pontiac; however, this
is a more complex solution than a PCV purge system. After the
originally scheduled tests were conducted on the modified vehicles,
the Pontiac was equipped and tested with a PCV purge system (with-
out the ventilating fan). Two evaporative tests gave results of
1.52 g and 1.75 g.
As shown by the vehicle descriptions in Attachment 1 through 6 of
the Appendix, the six vehicles which were modified by Exxon were
representative of popular models sold by major automotive
producers. The engines in the cars produced by the three largest
U.S. manufacturers were all medium or large V-8s, two of which had
four barrel carburetors. Evaporative emissions from large engines
with large carburetors are generally the most difficult to control.
This is because the amount of vapors generated by these vehicles
is large. So the level of control which was achieved by the Exxon
program, should be more easily accomplished on vehicles with smaller
engines. Consequently, results of this study strongly indicate that
essentially all vehicles can be modified to give evaporative emissions
of less than 2.0 g/test.
-------
-8-
TABLE VI. Vehicle Modifications Under Contract No. 68-03-2172.
Vehicle
Modifications
1975 Ford
Canister replacement with PCV purge
Seal-carb. leak
Barrier-snorkel base
Air cleaner leak sealing
Canister bottom cap
1975 Pontiac
Bowl vent to canister
Seal-carb. leak
Canister bottom cap
Air cleaner leak sealing
Fan
1975 Chrysler
Canister replacement
Canister bottom caps
Bowl ven,t to canister
Barrier-snorkel base
Seal-carb. leak
Air cleaner leak sealing
1974 Hornet
Canister replacement with PCV purge
Seal-carb. leak
Bowl vent to canister
Air cleaner sealing
Canister bottom cap
Barrier-snorkel base
1974 Mazda
Bowl vent to canister
Canister with PCV purge
Fan
Canister bottom cap
1974 Volvo
Canister Replacement
Baffel between tank and muffler
-------
-9-
c. Table III showed results of manufacturer's evaporative tests
on non-production engine-ECS combinations which have given total
evaporative levels of less than 2 g/test. On the Oldsmobiles,
carburetor venting to the canister is part of the production ECS.
The various modifications to these vehicles consisted of closing
the carburetor to canister vent line during engine operation, use
of a dry (well-purged) canister and blocking the air cleaner snorkle
during the hot soak. The dry canister effect can be achieved in
normal vehicle operation by either better purging of the current
canister (assuming its dry capacity is sufficient) or by increasing
the size of the current canister. Trapping vapors in the air
cleaner consists of making the air cleaner essentially vapor-tight
when the engine is not running or cranking. The experimental
system used on the Chevelle (1.87 g/test) does require some changes
to the production carburetor as listed in Table III.
The data on the 225 CID Chrysler Corporation vehicle consisted
of seven tests on one vehicle with various configurations of
carburetor bowl venting to the canister. The average of all seven
tests was 1.78 grams, so it appears that this type of modification
is sufficient to achieve a 2 g/test emission level, ^ata from one
test was reported on a vehicle equipped with a 318 in engine and a
2-way carburetor vent. The result of this test was 1.78 g as
listed in Table III. The engine modification used on this vehicle
was similar to that on the Chevelle listed in the same table. The
2-way carburetor bowl vent consists of a valve which vents the
carburetor bowl to the carburetor throat during engine operation
and to the canister when the engine is not running.
The system used on the Ford vehicles listed in Table III is a
system which has already been developed to meet a 6 g/test standard.
Ford supplied test data on many vehicles which were equipped with
this control system. Although most of these vehicles had evaporative
emission levels greater than 2 g/test, the two listed vehicles did
give emission levels below 2.0 g/test on all six tests (three tests
per vehicle).
d. Table IV listed results of tests to determine if the
working capacity of carbon canisters used in production evaporative
systems was sufficient for the diurnal test. The first part of
this experiment consisted of testing the production vehicles according
to the proposed SHED procedure. Then the procedure was repeated,
except that a well purged canister (same size and configuration as
the standard unit) was placed on the vehicle following the cold
soak period and just prior to the diurnal test. As Table IV shows,
the pre-purged canisters lowered the diurnal emissions of all four
vehicles. The amount of this reduction ranged from 0.2 g on the
Vega "to about 4 grams on the New Yorker and Matador. This indicates
that the working capacity of the canisters was not sufficient. As
(2) Ford Motor Company, "Comments in Response to the Notice of Proposed
Rulemaking Published in Fed. Reg. 2022 et. seq., dated Jan. 13, 1976,"
Feb. 27, 1976.
-------
-10-
demonstrated by the above discussed Exxon test program, this capacity
can be increased by either improved purging of the present canister,
use of a large canister or a combination of these two methods.
e. Table V listed the background emissions for 16 of the 20
vehicles tested by Exxon. Gasoline spills had occurred from an
auxiliary fuel tank in the interior of the first four vehicles
tested, and therefore realistic background data is not available
for those cars. All vehicles were at least 90 days old. From
Table V it does not appear that background emissions were related
to vehicle age. In fact, except for the VW and the Mazda, the
oldest vehicle had the highest background emissions. One-half
of the 1975 vehicles had background levels of 0.1 g or less. From
this data it appears that the variation in background level is
dependent on characteristics of the specific vehicles. Limited testing
for the source of emissions from the VW indicated that it originated
from the exterior of the vehicle and probably from the paint. The
enamel paint used on this vehicle apparently drives slower than the
paint typically used on U.S. manufactured cars.
f. Attachment 7 in the Appendix lists the results of SHED evapora-
tive emissions on a 1976 Chevrolet Vega. These data are from a
cross-check program in which AMC, Chrysler, EPA, Ford and GM partic-
ipated. At least three tests were conducted at each facility. For
all tests conducted on this vehicle the standard deviation was 0.20
grams or 10% of the mean value. With this combined test-to-test
and lab-to-lab variability of 10%, the maximum mean emission level
a particular vehicle can have in order to be at or below 2.00 g on
a single test at a 90% confidence level is 1.77 grams. Also, in
the certification process, a retest can be requested if a vehicle
fails the first test. For a 90% probability of passing at least one
of two tests, again assuming a standard deviation of 10%, the
vehicle mean is 1.90 g/test.
To compare the variability of these SHED tests with current
exhaust emission variability, results of an exhaust correlation
test between EPA.and Ford are presented in Attachment 8 of the
Appendix. This program consisted of 5 tests at each facility
conducted according to the federal exhaust emission testing proce-
dure. The car used was a 1977 Ford durability vehicle.
As shown by Attachments 7 and 8, the variability-of the SHED
evaporative tests was typical of the variability encountered in
exhaust emission testing. The percent standard deviation for all
evaporative test results is 10%, and the standard deviation for all
exhaust HC, CO, and NOx test results is 14%, 13% and 6% respectively.
Since relatively little experience has been gained with the SHED
evaporative test as compared to the exhaust test, SHED variability
should decrease with improvements and refinements in the procedure.
-------
-11-
g. The proceeding parts of this discussion have shown that there
are two basic methods of reducing evaporative losses from vehicles.
The first method is reducing the amount of gasoline which evaporates,
and the second method is preventing the gasoline which has evaporated
from entering the atmosphere.
The amount of gasoline which evaporates from a fuel system
is determined mainly by the volume of gasoline and the increase in
temperature of the gasoline. Therefore, techniques for reducing
evaporative losses by the first method are reducing fuel tank size,
reducing carburetor gasoline bowl volume, heat shielding the fuel
tank from exhaust and engine heat, and reducing carburetor tempera-
tures by heat shielding and external cooling (ventilating underhood
area with fans, louvers, etc.). The second method of vapor control
consists of capturing and disposing of gasoline vapors. When the
vehicle is operating, this is accomplished by ducting the vapors
into the engine induction system. However, when the engine is not
operating the vapors must be stored if they are to be disposed of by
the engine. Locations where vapors can be stored are in the
engine crankcase or induction system or in an external container such as
an activated carbon canister. For maximum effectiveness, it is
important that these storage devices do not leak gasoline vapors. As
demonstrated by the previously referenced Exxon study, hydrocarbon
leakage from vapor storage devices (air cleaners and carbon canisters)
was the major source of evaporative emissions.
Most production and experimental vehicle evaporative control
systems consist mainly of the second method of control (capture
and disposal of generated vapors). This method has generally shown
to have greater feasibility and be less expensive than preventing
gasoline vaporization. The particular system which has currently
shown to be most effective is the one used on the Chevrolet Vega.
This system stores both fuel tank and carburetor vapors on activated
carbon. These vapors are subsequently purged into the engine
induction system at a rate which is determined by engine load
(intake manifold vacuum signal). This system, even when used
without closing the internal carburetor bowl vent or sealing the
air cleaner snorkel during engine-off condition, has given SHED
evaporative test results of less than 2 g/test on many production
Vegas and on several modified vehicles. The use of sealed air
cleaners or internal vent valves would be expected to reduce these
emissions to even lower levels. There is no reason why this type
system cannot be adopted to all carbureted engines.
h. An area of concern in regards to low evaporative emission levels
is the effect on exhaust emission levels. In the Exxon contract
study, the vehicles having lowest exhaust emissions were not adversely
affected by the ECS modifications. However, at exhaust levels
necessary to meet the statutory standards (.41 g/mile HC .and 3.4
g/mile CO) there could be a significant interaction effect between
evaporative and exhaust emissions. The size of any such effect
would depend on the particular type of evaporative-exhaust control
system combination.
-------
-12-
The evaporative systems that might be expected to have the
greatest effect on exhaust emissions are those which store a large
portion of the vapors in the engine induction system. During
engine cranking and/or start-up these vapors are drawn into the
engine and can have a large effect on the air-fuel ratio. This
type of interaction can be minimized (and perhaps essentially
eliminated) by not using the induction system for vapor storage.
Vapors stored in a canister can be purged into the engine during
periods of relatively high air flow rates when the effect on over-
all air-fuel ratio should be negligible. This type of purging is
used most effectively by the current production Vegas.
For catalyst equipped vehicles, the level of HC and CO exhaust
emissions are very low under warmed-up conditions. For this reason
it may be desirable to time delay canister purging until the
catalyst bed is up to operating temperature. Another possible
purging technique for catalyst equipped vehicles would be to inject
the canister stored vapors into the exhaust system during warmed-up
operation. Such an exhaust purge system should essentially elimin-
ate evaporative-exhaust interactions.
4. Conclusions
The above discussion strongly indicates that existing technology
can be applied to meet an evaporative standard of 2.0 g/test by the
proposed SHED procedure. Based on recent variability tests, a
vehicle which has a true SHED evaporative level of 1.90 g/test has
a 90% probability of passing a 2.0 g/test standard. The data cited
in this issue paper cover a wide range of vehicle types. The
results show that some current production vehicles are below a 1.9
g/test level. Other vehicles have met a 1.9 g/test level after
receiving some modifications to the production evaporative control
system.
-------
APPENDIX
-------
APPENDIX v
TABLE I
SUMMARY OF EVAPORATIVE EMISSIONS FROM MODIFIED VEHICLES
Make: Ford "LTD"
Year: 75
No. : 1
Displ. cu. in./Litre: 351/5.75
Evap. Emissions,
Modifications r/SHED Test Remarks
I,a. Purge froa inside air cleaner element,
b. Barrier In air cleaner at bass of snorkel. 6.1
e. Choke shaft passage sealed.
II. Steps a, b» c
d. Air horn to body gasket modified to allow more bowl 9.6
vapors to be stored In air cleaner.
IlI.e. Purge to air cleaner snorkel as well as air cleaner.
Measurements were made of parge rates for both an air cleaner and a snorkel purge system. Next, & curve
of grams removed from canister vs. total purge volume was made. From these data it was estimated that aJ
combination air cleaner-snorkel purge system would remove 13 to 15 grams from the canister during the SHED
preconditioning period (4-LA-4s). This is not an adequate system because the combined diurnal and hot soak
Input to the canister is about 23 grams for the modified vehicle. Consequently, a PCV purge system was installed
using a 1974 Vega canister which had been in daily usage up to this time.
I?, PCV purge with Vega canister. The bottom of the 1.3
canister is capped. An unmodified carburetor body 1.2
to air horn gasket used along with modifications
b and c above.
-------
Attachment 2
Table II
Summary of Evaporative Emissions from Modified Vehicles
Make: Pontiac
Year: 75
No. : 2
Displ. cu. in./Litre: 400/6.56
Modifications
Evap. Emissions,
g/SHED Test
Remarks
I.a. Vented carb. bowl to canister,
b. Sealed leak around accel.
pump shaft.
10.5 (diurnal)
II. Steps a and b
c. Restriction in line from
bowl to canister.
Canister dried up
before run.
3.4
III. Steps a, b, c
d. Underhood ventilated with
a fan.
e. Bottom on canister.
1.6
2.5
1.7
Fan lowers carb.
temp, about 30°F
NOTE: Upon completion of these tests, a Vega canister was installed,
and tests were conducted without use of the underhood ventilating
fan. Two repeat tests were performed and results were 1.52 and
1.75 g/test.
-------
APPENDIX V
TABLE XV
SUMMARY OF EVAPORATIVE EMISSIONS FROM MODIFIED VEHICLES
Make: Chrysler
Year 75
No.: 21
Displ. cu. in./Litres 440/7.21
Hodifica tiers o
I Original ECS
Original ECS
Evap. Emissions,
g/SBED Teat
13.4
14,6
Remarks
Diurnal - 6.3 gt K.S. - 7.1 g
Diurnal - 4.4 g, H.S. - 10.2 g
II Modified ECS! '
h
(a) Two canisters in parallel used i
(b) Second earbl bowl vented directly to canister ^ _
rf
rf
M
O
tT
0
P
rf
-------
APPENDIX V
TA3LE V
SUMMARY OF EVAPORATIVE EMISSIONS FROM MODIFIED VEHICLES
Make: Hornet
Year: 74
No.: 11
Displ. cu. in./Litre: 232/3.80
Eva p. Emis 9 ions,
Modifications r/SHED Test
I.a. Carb. bowl vented to the canister. 3.9
b. Accel, pump shaft leak sealed.
II. Steps a and b above - restriction in line from carb. 3.1
bowl to canister.
c. Barrier installed in air cleaner at base of snorkel.
III. Steps a, b, c above
d. Bottom of canister closed. 2.5
IV. ECS modified to a PCV purge system using a 1974 Vega ^ 1.2
canister. Steps a, b, c, and d above also continued. r 1.3
-------
APPENDIX V
TABLE VI
SUMMARY OF EVAPORATIVE EMISSIONS FROM MODIFIED VEHICLES
Make: Mazda
Year! 74
No.; 15
Displ. Cu In./Litre: 80/1.31 (Rotary)
Evap. Emissions
Step Modifications g/SHED Test Remarks
I Both carburetor bowls vented to 4.8, 3.8 Hydrocarbon vapors escaping from
a 3 tube canister (Chrysler). snorkel.
Purge is through existing purge
line to PCV. Original ECS used
for diurnal.
II Next, the modifications indicated below were tested. In each case, the hydrocarbon level from the
SHED test exceeded 2.0 grams.
1. Canister moved outside of engine compartment to a cooler environment. •
2. Canister dried up on vacuum pump prior to diurnal and hot soak. J®
3. Air cleaner canister closed off and 3 Lube canister used for both diurnal and not aoak.** ,
At this point, additional' source determination tests indicated hydrocarbon vapors emanating from
carburetor throat due to fuel drippage. To alleviate pressure in the carburetor bowl, a fan
installed to lower bowl temperature by ventilating the underhood engine compartment.
Ill Modifications for Step I0 2.8
Underhood fan to ventilate
underhood.
At this point, the 3 tube canister was changed to a 4 tube Vega with a purge control valve. (Used
canister from 1974 Vega.) High diurnal losses in above runs due to tank vapor3 passing into engine
crankcase, then through PCV purge line into 3 tube canister. Vapors then moved out of the canister rt
into the carburetor bowl and air cleaner through the vent line from the bowl to the canister. The J
purge control valve prcvancs this migration of vapors into the carburetor bowl and air cleaner.
3
IV Modifications for Step I with 1.8, 1.3 S
exception of replacing 3 tube ^
canister with a 4 tube unit.
Fan to ventilate underhood.
-------
APPENDIX V
TABLE VII
SUMMARY 0? EVAPORATIVE EMISSIONS FROM MODIFIED VEHICLES
Make: Volvo
Year: 74
No. s
Displ
1?
eu. in./Litre: 121/1.98
Modifications
Evap. Emlsa iona
g/SHEP Test
Remarks
I.a. Equalizing valve modified so as to relieve fuel tank
pressure at 0.5 paig.
0.4
CO and HC exhaust levels
higher with modified ECS
"b. Baffle installed between fuel tank and muffler
c» American Motors canister used
1.7
-------
Attachment 7
MVMA" SHED CROSS-CHECK RESULTS
3 970 Chevrolet Vega #76008
Test Laboratory
SHED Emissions (Grams)
Diurnal
Hot Soak
Total
American Motors
Mean
S.D.
.98
1.06
.84
.86
1.03
.95
.10
1.18
1.12
1.06
.93
1.19
1.10
.11
2.16
2.18
1.90
1.79
2.22
2.05
.19 (9%)
Chrysler Corporation
Mean
S.D.
.78
.76
.71
.75
.04
1.12
1.10
1.05
1.09
.04
1,90
1. 86
1.76
1.84
.07 (4%)
EPA
Mean
S.D,
.77
.86
,78
.80
. 05
1.19
1.16
1.28
1.21
.06
1.96
2.02
2.06
2.01
.06 (3%)
Ford Motor Company
Mean
S.D.
1.21
.92
1.15
1.09
1.09
.12
1.24
1.05
1.19
.85
1.08
.17
2.45
1.97
2,34
1.94
.17
.26 (12%)
General Motors
Mean
S.D.
.89
.82
1,19
1.25
1.05
.91
.69
.97
.20
.92
1.18
1.04
.84
.99
.89
.90
.97
.12
1.81
2.00
2.23
2.09
2.04
1.80
1.59
1.94
.22 (11%)
-------
Attachment 8
EPA-Ford Correlation Program with Durability Vehicle
7A1-400-5A1NP and 1977 FTP
Test Lab
Exhaust
Emissions
(g/mi)
""""¦'—""-Si
EPA
HC
CO
NOx
.376
5.55
1.86
.390
5.21
1.86
.356
6.15
1.75
.386
5.97
1.68
.379
4.97
1.68
Mean
.377
5.57
1.77
S .D.
.013
.50
.090
S.D., %
4%
9%
5%
Ford
.464
5.94
1.54
.419
5.38
1.60
.449
6.20
1.63
.556
7.64
1.76
.420
5.23
1.79
Mean
.462
6.08
1.66
S.D.
.056
.96
.107
S.D., %
12%
16%
6%
-------
Issue Paper
Lead Time Requirement for an Evaporative
Emission Standard of 2.0 g/test for Light Duty Vehicles and Trucks
June 1976
(Revision 11/77)
Michael W. Leiferman
Standards Development and Support Branch
Emission Control Technology Division
Office of Mobile Source Air Pollution Control
Office of Air and Waste Management
U.S. Environmental Protection Agency
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-2-
Lead Time Requirement for an Evaporative Emission Standard of 2.0 g/test
for Light-Duty Vehicles and Trucks
1. Statement of the Problem
Is the implementation, of a nationwide 2.0 g/test evaporative emission
standard for light duty vehicles and trucks feasible for the 1980 model
year?
2. Facts Bearing on the Problem
a. In response to California's request for waiver with respect to
1977 evaporative emissions, several automotive manufacturers submitted
information in regards to lead time requirements for a 6.0 g/test standard.
Information submitted by GM is contained in the/ Appendix as Attachment
1, and information submitted by Ford is contained as Attachments 2 and 3
of the Appendix. This information, along with lead time considerations
submitted by Chrysler and AMC, is summarized and presented in Table I.
Major events in the vehicle certification schedule are also indicated.
Table I has been constructed with the assumption that an evaporative
standard will be implemented with the 1980 model year. Lead time re-
quirements are then based relative to start of 1980 model year engine
production.
b. In their comments to the evaporative NPRM, manufacturers did
not submit detailed lead time information in regards to implementation
of a 2.0 g/test standard.
3. Discussion
a. Table I compares the lead time requirements of the four larg-
est U.S. manufacturers in regards to a SHED evaporative standard imple-
mentation for the 1980 model year. The manufacturers agree quite closely
in regards to the Looling txi"e needed for making carburetor vent changes.
This lead time, which varies from 10 to 12 months, includes both inter-
nal and external vent modifications. Beyond the carburetor vent changes,
Ford indicated in May 1975 (Attachment 2 of the Appendix), that they
need to make major changes to their model 2700 carburetor. These tooling
changes have already been made for compliance with the 6.0 g/test stan-
dard. It is anticipated that lead time for carburetor vent modifications
is the longest tooling lead time requirement for a 2.0 g/test standard.
In May 1975, Ford also indicated that they would need to use EGR
cooling, requiring a tooling lead time of 22 to 24 months, to meet a 6.0
g/test evaporative standard. However, Ford has complied with the 6.0
g/test standard without EGR cooling and it is not expected to be used in
their 2.0 g/test systems.
^ "Comments in Response to the Notice of Proposed Rulemaking,
published in 40 Fed. Reg. 2022 et seq., dated January 13, 1976,"
Ford Motor Company, February 27, 1976.
-------
-3-
The manufacturers also agree reasonably well on the time required
for the production design, development, and testing before tooling can
begin. The estimates for the 3 largest manufacturers, as shown in Table
I, range from 7 to 9 months.
Prior to the production design, development and testing, the hard-
ware to be used on each vehicle-engine combination must be defined.
Since many 1978 emission certification vehicles and several modified
vehicles have given evaporative test results of less than 2.0 g/test,
the technical feasibility.of producing vehicles to meet this level has
already been demonstrated ' . Defining the required hardware for all
vehicles will be a process of applying the current technology to attain
an effective system for each vehicle-engine combination.
The amount of additional time required for defining the hardware is
dependent on several factors. Perhaps the major factor is the quantity
and quality of evaporative emission'control work which has already been
done by the manufacturers. Since a SHED evaporative standard of 6.0
g/test was implemented for the 1978 model year, all manufacturers have
already defined, designed, and tooled hardware for the 6.0 g/test
standard. This has developed much information which can be applied to
defining hardware for a 2.0 g/test standard.
GM, Ford and Chrysler have supplied the EPA with a sizable amount
of data from evaporative emission testing of various control system
configurations. Each of these three manufacturers have tested systems
which gave below 2 g/test (described in reference (3)). In addition,
vehicles modified and tested by Exxon Research and Engineering under
Contract No. 68-03-2172 (reference (2)) gave test results of less than
2 g/test, and many 1978 certification vehicle test results were under
2.0 g. So the hardware required for several vehicle-engine combinations
has already been defined. Continuing effort will be required to determine
which specific combination of hardware will be effective for other
vehicle-engine combinations. Although it is not expected that costly
modifications will be required, it will take some time to determine
which modifications are necessary.
Another important consideration in lead time requirement is cost of
the control system. If an inadequate period of time is allowed for
defining the hardware, the control system may be more complex and cost
more than necessary.
b. Because of essentially non-existent lead time estimates from
the manufacturers for a 2.0 g/test standard, the above analysis was
based on manufacturer lead time estimates for a 6.0 g/test standard.
(2)
Clarke, P.J., "Investigation and Assessment of Light Duty Vehicle
Evaporative Emission Sources and Control," Exxon Research and
Engineering, EPA Contract //68-03-2172, May, 1976.
(3)
"Technical Feasibility of a 2 g/test SHED evaporative Emission Standard
for Light Duty Vehicles and Trucks, Issue Paper by Michael W. Leiferman,
U.S. EPA, Ann Arbor, Michigan, June, 1976.
-------
-4-
If additional carburetor changes are necessary for the 2.0 g/test
standard, the tooling lead time for this modification should be no
greater than for the 6 g/test standard. Assuming that carburetor
machining changes will require the longest tooling lead time of all
equipment changes, tooling will need to begin by about June 1978 as
shown in Table I.
Automotive manufacturers have estimated that production design,
development and testing for a 6 g/test standard must begin 7 to 9 months
before tooling can begin. Due to the increased difficulty of meeting a
2.0 g/test standard, it would be expected that, without any prior SHED
test work, this phase of the program would take longer than 7 to 9
months. However, with implementation of the 6.0 g/test standard, consid-
erable experience has been gained by the manufacturers in regards to
designing systems to comply with a SHED test procedure. Considering
this prior experience, it is believed that a production design and
testing time of 7 to 9 months prior to hardware tooling for a 2.0 g/test
standard is reasonable.
Based on lead time estimates for tooling and production design,
development and testing, the date by which the manufacturers must have
defined carburetor changes is determined. As shown in Table I, a new
test standard for the 1980 model year would require that GM, Ford and
Chrysler have defined these changes by October 1977, November 1977, and
January 1978, respectively.
It is also informative to view lead time relative to the rulemaking
time table. In the event that carburetor changes are needed, most
manufacturers must have defined the hardware prior to expected rule
promulgation (March, 1978).
C. Status of Manufacturers as of November, 1977.
On January 13, 1976 the Notice of Proposed Rule Making for both the
6.0 and 2.0 g/test standard was published. When final rule making for
the 6.0 g/test standard was published (August 23, 1976), the original
regulatory action was divided into two separate rule making actions.
The August 23, 1976 publication stated that "final rulemaking for a
longer term evaporative emission standard is presently being considered"
and the 1978 ,standard will remain in effect for subsequent model years
"until revised". These and other statements in the August 23 publication
(as well as discussions between manufacturer and EPA representatives
which followed) enforced the EPA's position that a standard less than
6.0 g/test was being developed and would be promulgated when some issues
regarding its implementation were resolved. It was assumed that the
manufacturers would make valuable use of the additional lead time, since
they had stated in comments to the NPRM that more effective control
equipment needed to be designed and developed in order to meet a 2.0
g/test standard.
-------
-5-
At a EPA hearing in May, 1977 regarding California's request for
waiver of 2.0 g/test standard (with a 1.0 g/test allowance for non-fuel
emissions from data vehicles) in 1980, only three manufacturers (AMC,
Ford and GM) presented information concerning their development efforts
to achieve low evaporative levels. Considering the imminence of both
California and Federal regulations more stringent than the 6.0 g/test
standard, the level of effort by most manufacturers was not as high as
anticipated. The level of effort and current status of some of the
largest manufacturers are discussed below:
Ford - They basically supported the California request for waiver
of a 2.0 g/test evaporative emission requirement in 1980. At these
waiver hearings Ford presented test results from a program aimed at
identifying the source of and eliminating HC emissions from carburetors.
Their aggressive effort and success in developing effective evaporative
control system is demonstrated by the fact that 61% of the valid certi-
fication tests on Ford's 1978 certification vehicles (conducted at EPA's
Ann Arbor facility) gave results below 2.0 g. Ford is currently confi-
dent that about two-thirds of their present vehicles will meet a 2.0
g/test requirement with two modifications—(1) improved sealing and
gasket materials and (2) improved canister purging. They also expect
these two modifications to be adequate for the remaining .one-third of
their vehicles; however, this hasn't yet been determined
GM - They favored a nationwide standard in 1981 as opposed to a
California 2.0 g/test standard in 1980. They stated that a 2.0 g/test
standard was not technologically feasible for the 1980 model year.
Their lack of aggressiveness in developing 2.0 g/test control equipment
is demonstrated by the fact that Rochester Products did not start working
on the carburetor leak problem until this year (1977). Because of the
slow pace in development, GM has now stated that 20 months time is
required for them to obtain some of the equipment (air cleaner containing
activated carbon) which is needed to meet a 2.0 g/test standard.
Others - AMC presented a small amount of data at the California
waiver hearing and stated their dependency on the carburetor manufac-
turers for a "leak-proof" carburetor. Little or no information has been
submitted by any other manufacturers since comments to the NPRM; and
consequently their status in regards to lead time for a 2.0 g/test
evaporative standard is not known.
(A)
Information obtained in a phone conversation on October 19, 1977
with Donald Buist, Executive Engineer for Certification, Ford
Motor Company.
^ EPA Memorandum to the File entitled, "Meeting with General Motors
Concerning Lead Time Necessary for Implementation of a 2.0 g/test
Evaporative Emission Standard for Light Duty Vehicles and Light
Duty Trucks," November, 1977.
-------
-6-
Conclusion
Although some manufacturers may have little trouble meeting a 2.0
g/test requirement in 1980, others have made such little constructive
development effort that they would be faced with a high degree of risk
if such a standard were promulgated. In retrospect, if any lesson can
be learned from the development of the 2.0 g/test evaporative package,
it is that delaying rule promulgation to give manufacturers requested
time for development of control systems is an ineffective way of reducing
emissions.
If, as one manufacturer stated, 20 months lead time is now required
to obtain the necessary control equipment, a 1981 implementation date
would provide the necessary time for hardware design and tooling. A
1981 implementation date may also result in the use of some control
system components which would be more cost-effective and more durable
than those which might be used for 1980. For example, a 1981 implementation
date would hopefully allow manufacturers time to develop hot soak
control measures which will not require the use of equipment which needs
periodic replacement, such as engine air filters.
4. Recommendation
It is recommended that the proposed 2.0 g/test evaporative standard
be promulgated for the 1981 model year.
-------
Table I. Lead Time Considerations for a New SHED Evaporative Standard in 1980
M
. 1977 _
M| J | J
0
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-
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1978 —
J , J | A
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1979
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I
Define Hardware
1 If V
Typical Certification Schedule: Submit Start Start
Part I Durability Data
Vehicles Vehicles
GM
I
Define
Hardware
FORD
Production Design and Development
Tooling for Carb. Vent Changes
|Design and Development
| Tooling for Carb. Vent Changes
z
CHRYSLER
Z
AMC
Define Hardware
Define Hardware
Design and Development
Tooling for Carb. Vent Changes
1 Design & PevT~|
Tooling for Carb. Vent Changes
Start ]980
Engine Production
t
-------
APPENDIX
Lead-time Information Submitted by
Automotive Manufacturers in Regard to the
California Waiver Request for a
6 g/test Standard in 1977
-------
<¦ ^GHMSKT.2
1977 EMISSIONS PROGRAM
TEST FACILITY & PROCEDURES
BACKGROUND TESTING
HARDWARE
DEVELOPMENT &
DURABILITY
DESIGN
PRODUCTION TOOLING
PRACTICE AMA
CERTIFICATION:
PART I SUBMISSION
DURABILITY VEHICLES
DATA FLEET
1974 1975 1976 1977
SONDJFMAMJJ[ASONDJF M A MJ J A S O N D J F M A
Start of
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1977 -EXHAUST EMISSIONS PROGRAM IMMilSM
PROPOSED CALIFORNIA EVAPORATIVE EMISSIONS PROGRAM
-------
Attachment 2
Ford Lead Time Information
The impact of the tooling lead time is summarized by passenger
car engine family in the following table;
Engine
2-3L 1-4
2.8L V-6
200 CID 1-6
250 CID 1-6
302 CID V-8
351W CID V-8
351M/400 CID V-8
460 CID
Carburetor
Lead Time
EGR Cooler
Fuel Tank
Series/Months
2 2-24 Months
11 Months
5200 / 12
Not required
X
2700 / 18
Not required
X
YFA / 12
Not required
X
YFA / 12
X
X
2700 / 18
Not required
X
2150 / 12
Not required
X
2150 / 12
X
X
4350 / 12
X
X
-------
19'/ 7 SnFO TEST
CONTROLLING COMPf IT TOOLING TIME
(EXCLUSIVE OF CONCEPT FEAS1.. ..jblTY AND PRODUCTION DESIGN)
1974
1975
1976
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20
19
18
17
16
15
14
13
12
11-
10
9
8
7
6
5
4
3
2
1
Samples J
Due 1
\T
Carburetor - Major Change (18 Months)
Other Carburetors (12 Months)
EGR Cooler (22 - 24 Months)
Fuel Tanks (11 Months)
File
Part I
Start
50,000 Mile Testing
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-------
Issue Paper
Cost effectiveness of a 2.0 g/test SHED
Evaporative Standard for Light Duty
Vehicles and Trucks
June 1976
Michael W. Leiferman
Standards Development and Support Branch
Emission Control Technology Division
Office of Mobile Source Mobile Air Pollution Control
Office of Air and Waste Management
U.S. Environmental Protection Agency
-------
Cost Effectiveness of a 2.0 g/test SHED Evaporative Standard for Light
Duty Vehicles and Trucks
1. Statement of the Problem
What is the cost effectiveness of reducing light duty vehicle SHED
evaporative emissions from a level of 6.0 g/test to 2.0 g/test?
2. Facts Bearing on the Problem
a. Exxon Research and Engineering Company conducted an evapora-
tive test program under EPA Contract No. 68-03-2172 . In this study,
six production vehicles which represented the four major U.S. manu-
facturers and two foreign manufacturers, were modifed in order to reduce
evaporative emissions. Costs for the required modifications were then
estimated. The resulting manufacturers' sales weighted retail price
increase to achieve an evaporative level of less than 6 g/test on each
vehicle was $2 per vehicle. The sales weighted retail price increase to
achieve an evaporative level of less than 2.0 g/test on each vehicle was
$3 per vehicle.
b. Automotive manufacturers have supplied evaporative emissions
data on vehicles equipped with experimental control systems. Some of
the vehicle test data submitted by GM, Ford and Chrysler were less than
2.0 g/test. The increase in vehicle retail price for these modifica-
tions was estimated based on Exxon's Contract No. 68-03-2172 cost estimates.
From this information, the calculated sales weighted retail price in-
crease (over 1976 production vehicles) to achieve the 2.0 g/test level
was $7 per vehicle.
c. For the twenty production vehicles tested for evaporative
emissions under Contract No. 68-03-2172, 83% of the emissions occurred
during the hot-soak test and 17% during the diurnal test. For the six
vehicJes modified to an evaporative level of less than 2.0 g/test, 59%
of the emissions occurred during the hot-soak and 41% during the diurnal.
3. Discussion
a. In the Exxon program, the vehicles which were eventually
modified were also tested for evaporative emissions in their production
configuration. In production form all six vehicles had evaporative
emissions greater than 6.0 g/test. On most of these vehicles several
different modifications were made during the test program. At some
point in the program, the evaporative emissions from each vehicle de-
creased from a value above 6.0 g/test to a value of below 6.0 g/test.
Based on the cost of these modifications, the retail increase required
to achieve the 6.0 g/test level was estimated. As explained in reference
(1), the estimated vehicle retail price increase for a certain modification
^ ^Clarke, P. J., "Investigation and Assessment of Light Duty Vehicle
Evaporative Emission Sources and Control," Exxon Research and Engineer-
ing, EPA Contract // 68-03-2172, June 1976.
-------
-2-
is assumed to be twice the cost to the manufacturer of that modifica-
tion. The modifications performed on each vehicle and the estimated
price increase are listed in Table I. As shown, the estimated retail
price increase of the modifications ranged from $1.10,to $5.70. The
resulting manufacturers' sales weighted average is $2
After final modification, each of the six vehicles in the Exxon
program had an evaporative emission level of less than 2.0 g/test. The
retail price increase estimate was made and these are contained in Table
II. As shown the retail price increase estimates ranged from $2.00
on the Ford to $25.20 on the Mazda. The cost on the Mazda consisted mainly
of the underhood ventilating fan cost. Also worth mention is the fact
that the costs for the Pontiac are those associated with the Vega can-
ister system, not the ventilating fan system which was also tested.
On a manufacturer's sales weighted basis, the retail price increase
to reduce evaporative emissions from the current production level to the
2.0 g/test level is $3 per vehicle. This value was calculated similarly
to the 6.0 g/test cost as previously discussed. A detailed listing of the
modifications and corresponding emission levels for each vehicle are
contained in Attachments A-I through A-VI of Appendix A. Attachment VII
of Appendix A summarizes the initial and final emission levels for the
six vehicles.
b. Attachment B-I of Appendix B lists test results and information
on ten experimental vehicles which have given SHED evaporative test
results of less than 2.0 g/test. These vehicles were prepared and tested
by their respective manufacturers. Data on the GM and Ford vehicles
were supplied in response to California and Federal proposed evaporative
regulations, and the Chrysler data was contained in Chrysler's, "Progress
Report on Chrysler's Efforts to Meet the 1977 and 1978 Federal Emission
Standards for HC, CO and NOx" (Dec. 1975). Using this information,
along with the equipment cost information in Exxon's work under Contract
No. 68-03-2172, the estimated vehicle retail price increase for the
modifications on the vehicles listed in Table B-I has been calculated.
This information is contained in Table III. As shown the cost of the
modifications on these ten vehicles range from $0.50 for the Chrysler 6-
cylinder vehicle to $13.25 for the Ford vehicles.
The Ford control system listed in Table III is the one that Ford
has already developed to meet a 6 g/test standard. As indicated in
Table III, Ford estimates the cost of this system as $15.00. This
agrees quite well with the value of $13.25 which was obtained by summing
the costs of the major components of the system. GM and Chrysler did
not supply cost information for the modifications listed. Using the
Ford cost estimate of $15.00 for the Ford system and the cost estimate
as described above for the GM and Chrysler vehicles, the average costs
of the GM, Ford, and Chrysler systems listed in the Table III are $3.75,
$15.00 and $2.25 respectively. A sales weighted average of these costs
(2)
Based on sales data in "Automotive News Almanac," 1975 and "Automotive
News," Mar. 22, 1976.
-------
-3-
Table I. Summary of Vehicle Modifications and Costs in
Achieving a 6.0 g/test Level (EPA Contract No. 68-03-2172)
Vehicle
Modifications
Cost, S
'75 Ford
Canister replacement with PCV purge
1.00
Seal carburetor leak
0.30
Barrier in air cleaner
0.20
Air cleaner sealing
0.30
Canister bottom cap
0.20
Total
2.00
'75 Pontiac
Bowl vent to canister
0.50
Seal carburetor leak
0.30
Air cleaner sealing
0.30
Total
1.10
'75 Chrysler
Canister replacement
4.00
Canister bottom caps
0.40
Bowl vent to canister
0.50
Barrier in air cleaner
0.20
Seal carburetor leak
0.30
Air cleaner sealing
0.30
Total
5.70
'74 Hornet
Seal carburetor leak
0.30
Bowl vent to canister
0.50
Air cleaner sealing
0.30
Total
1.10
174 Mazda
2 bowl vents to canister
1.00
Canister installation
6.00
Total
7.00
'74 Volvo
Canister replacement
1.00
Heat shield between tank
and muffler
1.00
Total
2.00
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-4-
Table II. Summary of Vehicle Modifications and Costs in
Achieving a 2.0 g/test Level (EPA Contract No. 68-03-2172)
Vehicle
Modifications
Cost, $
'75 Ford
Canister replacement
1.00
Seal carburetor leak
0.30
Barrier in air cleaner
0.20
Air cleaner sealing
0.30
Canister bottom cap
0.20
Total
2.00
'75 Pontiac
Bowl vent to canister
0.50
Seal carburetor leak
0.30
Air cleaner sealing
.30
Canister replacement with PCV purge
1.20
Total
2.30
'75 Chrysler
Canister replacement
4.00
Canister bottom caps
0.40
Bowl vent to canister
0.50
Barrier in air cleaner
0.20
Seal carburetor leak
0.30
Air cleaner sealing
0.30
Total
5.70
'74 Hornet
Seal carburetor leak
0.30
Bowl vent to canister
0.50
Air cleaner sealing
0.30
Canister replacement with PCV purge
1.00
Canister bottom cap
0.20
Barrier in air cleaner
0.20
Total
2.50
'74 Mazda
2 bowl vents to canister
1.00
Canister installation with PCV purge
7.00
Underhood ventilating fan
17.00
Canister bottom cap
0.20
Total
25.20
'74 Volvo
Canister replacement
1.00
Heat shield between tank
and muffler
1.00
Total
2.00
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-5-
Table III. Estimated Increase in Vehicle Retail Price for
Manufacturer Designed and Tested Systems Which Have
Yielded Evaporative Losses Less Than 2.0 g/test
No.
Vehicle
Make
Modification Cost, $
1
Oldsmobile
Dry canister (PCV purged)
0.60
Sealed door in air cleaner snorkel
3.40(1)
Bowl vented to canister
0.50
Total
4.50
2
Chevelle
Vapor purge valve (PCV purged)
0.60
Bowl vented to canister
0.50
Internal vent closed
( 1 \
(2-way bowl switch)
4.00
Total
5.10
3
Chrysler
2-way carburetor bowl vent switch
4.00
4
Chrysler
Bowl vented to canister
0.50
5 &
6
Ford
Bowl vent valve
3.00
Enlarged canister
3.00
PCV purged canister
0.60
Auxiliary canister
-3.00
Electronic air cleaner door
3.40
New gas cap
0.25
Total 13.25
(15.00)(2)
7
Oldsmobile
Manually operated carb. bowl switch
3.00
8
Oldsmobile
Vacuum operated carb. bowl switch
3.00
9
Oldsmobile
Bowl vent to canister
0.50
Door in air cleaner snorkel
3.40
Total
3.90
10
Oldsmobile
Manually operated carb. bowl switch
3.00
(1) From manufacturers' comments on "Proposed Evaporative Emission Regulations
for Light Duty Vehicles and Trucks", January 13, 1976.
(2) Ford's estimate for this system submitted to the EPA on February 27, 1976.
-------
-6-
results in an estimated retail price increase (as calculated in Exxon's
contract work) to reduce evaporative emissions from the current production
level to 2.0 g/test of $7 per vehicle.
c. The cost-effectiveness of emission control strategies is
commonly presented in units of dollars- per ton of pollutant removed. To
calculate such a cost-effectiveness for evaporative emission control, it
is convenient to express the evaporative emission reduction in units of
g/day and then g/mi. To calculate g/day, a relationship between the
quantity of hot-soak and diurnal emission must be assumed. Based on
Exxon test results under Contract No. 68-03-2172, it is assumed that
vehicles at a 6 g/test level will emit 80% during the hot soak test and
20% during the diurnal; and vehicles at a level of 2 g/test will emit
60% during the hot-soak and 40% during the diurnal.
The above assumption, along with th^. assumption that the average
vehicle undergoes 3.3 hot-soaks per day , results in evaporative
hydrocarbon (HC) emissions of 17 g/day for a 6.0 g/test level vehicle, and
4.8 g/day for a 2.0.^/test vehicle. Assuming that the average vehicle
travels 29.4 mi/day , the 6.0 g/test level vehicle and the 2.0 g/test
vehicle emit 0.58 and 0.16 g/mi of HC evaporative emissions, respectively.
The reduction in decreasing from 6.0 g/test to 2.0 g/test is 0.42 g/mi.
Assuming a vehicle lifetime of 100,000 miles, this reduction in HC
emission over the lifetime of the vehicle is 0.046 tons.
The contract work done by Exxon showed that the estimated sales
weighted increase in vehicle retail price in going from a 6.0 g/test level
to a 2.0 g/test level was $1. Estimating the associated reduction in HC
emission over the life of the vehicle as 0.046 tons, the cost effective-
ness is $22/ton.
The sales weighted cost estimate for the manufacturer's experi-
mental systems which achieved 2.0 g/test was $7. This is $5 greater than
the $2 cost of the Exxon modifications used to achieve a 6.0 g/test level.
Assuming this $5 incremental cost, the cost effectiveness of going from
6.0 g/test to 2.0 g/test becomes $109/ton.
4. Summary
The cost effectiveness of removing HC emissions via reducing light
duty vehicle and truck evaporative emissions from 6.0 g/test to 2.0 g/test
has been estimated from both EPA contract study and manufacturers'
supplied data. The cost effectiveness values obtained from these two
sources of data are $22/ton and $109/ton, respectively. The true cost
effectiveness of reducing evaporative emissions from 6.0 g/test to 2.0
g/test on a nationwide basis is expected to be between these two estimates.
(3)
"Compilation of Air Pollutant Emission Factors, Supplement 5", U.S.
EPA, December 1975.
-------
Appendix A
-------
APPENDIX V
TABLE I
SUMMARY OF EVAPORATIVE EMISSIONS FROM MODIFIED VEHICLES
Make: Ford "LTD"
Year: 75
Ho. : 1_
Displ. cu. in./Litre: 351/5.75
Evap. Emissions,
Modifications g/SHED Test Remarks
I.a. Purge from Inside air cleaner element.
b. Barrier in air cleaner at base of snorkel. 6.1
c. Choke shaft passage sealed.
II. Steps a, b, c
d. Air horn to body gasket modified to allow more bowl 9.6
vapors to be stored in air cleaner.
IlI.e. Purge to air cleaner snorkel as well as air cleaner.
Measurements were made of purge rates for both an air cleaner and a snorkel purge system. Next, a curve
of grams removed from canister vs. total purge volume was made. From these data it was estimated that a
combination air cleaner-snorkel purge system would remove 13 to 15 grams from the canister during the SHED
preconditioning period (4-LA-4s), This is not an adequate system because the combined diurnal and hot soak
input to the canister is about 23 grcrns for the modified vehicle. Consequently, a PCV purge system was installed
using z. 1574 Vega canister which had bcei In daily usage up to this time.
IV. rcV ?
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Attachnent A-II
Table II
Summary of Evaporative Emissions from Modified Vehicles
Make: Pontiac
Year: 75
No. : 2
Displ. cu. in./Litre: 400/6.56
Modifications
Evap. Emissions,
g/SHED Test
I.a. Vented carb. bowl to canister,
b. Sealed leak around accel,
pump shaft.
10.5 (diurnal)
Remarks
II. Steps a and b
c. Restriction in line from
bowl to canister.
Canister dried up
before run.
3.4
III. Steps a, b, c
d. Underhood ventilated with
a fan.
e. Bottom on canister.
1.6
2.5
1.7
Fan lowers carb.
temp, about 30°F
NOTE: Upon completion of these tests, a Vega canister was installed,
and tests were conducted without use of the underhood ventilating
fan. Two repeat tests were performed and results were 1.52 and
1.75 g/test.
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APPENDIX V
TABLE IV
SUMMABY OF EVAPORATIVE EMISSION'S FROM MODIFIED VEHICLES
Make: Chrysler
Year 75
No.; 21
Diopl. cu. in./Litre: 440/7.21
Modifications
Evap. Enissions,
r/SHED Test
Remarks
I Original ECS
Original ECS
13.4
14.6
Diurnal - 6<3 g, H.5. - 7.1 g
Diurnal - 4.4 g, H.S. - 10,2 g
II Modified ECS:
\D
M
(a) Two canisters in parallel used
o
3*
3
CD
3
>
i
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APPENDIX V
TABLE V
SUMMARY OF EVAPORATIVE EMISSIONS FROM MODIFIED VEHICLES
Make: Hornet
Year: 74
No.; 11
Displ. cu. in«/Lltre: 232/3,80
Evap. Emissions,
Modifications k/SHEP Test
I.a. Carb* bowl vented to the canister. 3.9
b. Accel, pump shaft leak sealed.
II. Steps a and b above - restriction in line from carb. 3.1
bowl to canister.
c. Barrier installed in air cleaner at base of snorkel.
III. Steps a, b, c above
d. Bottom of canister closed. 2.5
IV. ECS modified to a PCV purge system using a 1974 Vega 1 1.2
canister. Steps a, b, c, and d above also continued. ? 1.3
-------
APfgHPIX y
TABLE VI
summary ot mmmmvm emissions from modified temples
Kake: Kazda
Year; 74
Ho.: 15
Displ. Cu In./Litre: 80/1.31 (Rotary)
SMS.
I
Modifications
Both carburetor bowls vented to
a 3 tube canister (Chrysler).
Purge is through existing purge
line to PCV. Original ECS used
for diurnal.
Evap. Emissions
r/SH£P lest
4.8, 3.8
Remarks
Hydrocarbon vapor# escaping froa
snorkel.
II Eext» the modifications indicated below were tested. In each case, the hydrocarbon level from the
SHED test exceeded 2.0 grams.
1. Canister moved outside of engine compartment to a cooler environment. '
2. Canister dried up on vacuum pump prior to diurnal and hot soak, j®
3. Air cleaner canister closed off and 3 Lube canister used for both diurnal and hot soak. ,
At this point, additional source determination tests indicated hydrocarbon vapors emanating from
carburetor throat due to fuel drippage. To alleviate pressure in the carburetor bowl, a fan
installed to lower bowl temperature by ventilating the underhood engine compartment.
III Modifications for Step I. 2.8
Underhood fan to ventilate
underhood.
At this point, the 3 tub# eanietcr was changed to a 4 tuba Vega with a purge control valve, (used
canister from 1974 Vega.) High diurnal losses in above rune due to tank vapors passing into engine
crankcase, then through PCV purge line into 3 tube canister. Vapora then moved out of the canister
into the carburetor bowl and air cleaner through the vent line from the bowl to the canister. The ^
purge control valve prevents this migration of vapors into the carburetor bowl and air cleaner. £
R>
If Modifications for Step I with 1.8, 1.3 5*
exception of replacing 3 tube 1
canister with a 4 tube unit. **
Fan to ventilate underhood, >
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APPENDIX V
TABLE VII
SUMMARY OF EVAPORATIVE EMISSIONS FROM MODIFIED VEHICLES
Makes Volvo
¥ear: 74
No.: 17
Dlapl. cu. in./Mere: 121/1.98
Modifications
I.a. Equalizing valve modified so as to relieve fuel tank
pressure at 0.5 psig.
b. Baffle installed between fuel tank and muffler.
c* American Motors canister used.
Evap. Emissions,
g/SHSD Test
0.4
1.7
Remarks
CO and HC exhaust levels
higher with modified ECS.
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TABLE II. SHED Evaporative Tests on Vehicles Tested Under Contract No. 68-03-2172.
Vehicle r
ECS
Condi-
Eneine tion
Evaporative Emissions, g
Exhaust
Emissions
, g/mi^
No. of
Tests
Average
Diurnal
Average
H. Soak
Total
HC
CO
NOx
Range
Average
*75 Ford
351-2bbl Stock
2
3.4
3.2
6.2 -7.1
6.7
0.54
6.75
1.62
Modified
2
0.2
1.0
1.2 -1.3
1.2
0.52
4.44
1.87
'75 Pontiac
400-4bbl Stock
2
0.4
7.1
7.2 -7.8
7.5
0.80
6.95
1.31
Modified
3
1.2
0.7
1.6 -2.5
1.9(2:
0.68
4.05
1.36
'74 AMC
232-lbbl Stock
2
0.5
10.3
10.8 -10.8
10.8
1.50
24.5
1.24
Modified
2
0.3
0.9
1.2 -1.3
1.2
1.51
26.9
1.13
'74 Mazda
80-4bbl Stock
2
0.2
10.4
10.5 -10.7
10.6
2.11
11.7
0.88
Modified
2
0.6
0.9
1.3 -1.8
1.5
1.82
9.90
0.65
*74 Volvo
121-FI Stock
2
4.7
3.2
7.1 -8.7
7.9
0.91
13.3
2.15
Modified
2
0.7
0.4
0.4 -1.7
1.1
1.24
22.6
1.58
'75 Chrysler
440-4bbl Stock
2
5.3
8.6
13.4 -14.6
13.9
2.32
23.2
1.98
Modified
2
0.6
1.3
1.9 -2.0
1.9
1.10
13.3
1.83
(1)
(2)
Average of 2 or more tests
This data is for an underhood ventilating fan system. A PCV-purged canister system was later
tested on this vehicle and average 1.6 g/test for 2 tests.
-------
Appendix B
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Attachment Bs-I
-4-
TABLE III. Manufacturer's SHED Evaporative Tests on Experimental
Control Systems.
Vfehicle
No. of
Average
Emissions,
8
No * Make
Engine, C1D
Carburetor
Tests
Diurnal
Hot Soak
Total
i Oldsmobile^
455
4 bbl
1
0.33
1.17
1.50
2 Chevelle(2)
250
1 bbl
1
0.64
1.23
1.87
3 Chrysler^
318
2 bbl
1
0,42
1.31
1.78
4 Chrysler(A)
225
1 bbl
7
0.72
1.05
1.78
5 Ford(5)
302
-
3
-
-
1.45
6 Ford<5)
400
-
3
-
-
1.54
7 01dsmobile(6)
455
4 bbl
1
0.85
1.07
1.92
8 ''dsmobile^
455
4 bbl
1
0.74
0.96
1.70
9 ^xdsmobile^
-
-
1
0.80
0.92
1.72
10 Dldsmobile^
-
-
2
0.48
1.18
1.66
(1) Dry canister, closed air cleaner snorkel during hot soak and float bowl
vented to canister.
(2) Vapor purge valve, float bowl vented to canister and internal vent closed.
(3) 2-way carburetor bowl vent.
(4) Carburetor bowl vent to canister.
(5) Bowl vent valve,PCV purged enlarged canister, auxiliary canister, electronic
air cleaner door and new gas cap.
(6) Proposed production ECS design with manually operated carburetor bowl switch.
(7) Proposed production ECS design with vacuum operated carburetor bowl switch.
(8) Experimental V-8 engine with bowl vent and air cleaner door, 1978 prep.
(9) Experimental V-8 engine with manual bowl vent switch, 1976 prep.
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APPENDIX to the ANALYSIS OF COMMENTS
-------
EPA-420-R-78-101
United States
Environmental Protection
mm Agency
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