Interpretation ID: 1984-3.22

TYPE: INTERPRETATION-NHTSA

DATE: 09/10/84

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Purna Saggurti -- Research and Development, Nu-Fuel Industries Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Purna Saggurti Senior Executive Engineer Research & Development Nu-Fuel Industries, Inc. P.O. Box 220 Loretto, TN 38469

This responds to your letter of August 8, 1984, concerning the use of compressed natural gas (CGN) in vehicles. You asked the agency to clarify its position on CNG and to answer several questions about the alteration of a gasoline power vehicle so that it is both gasoline and CNG powered.

You are correct that Safety Standard No. 301, Fuel System Integrity, does not apply to CNG powered vehicles. The standard does not apply to vehicles using fuel, such as CNG, which has a boiling point below 32oF. Thus, the standard does not prevent the use of CNG in motor vehicles.

At the present time, the agency has no plans to extend the standard to CNG fuel systems. If you believe that a regulation on CNG systems is necessary, you can petition the agency to commence rulemaking. A copy of the agency's regulation on rulemaking petitions is enclosed.

The agency has prepared an extensive information sheet which explains how the standard applies to aftermarket installation of dual fuel systems in motor vehicles. Since the information sheet addresses the issues you have raised concerning CNG conversion, I am enclosing a copy for you review.

If you have any further questions, please let me know.

Sincerely,

Frank Berndt Chief Counsel Enclosure

August 8, 1984 Mr. Frank A. Berndt, Chief Counsel N.H.T.S.A. NOA-30 U.S. Department of Transportation Washington, D.C. 20590

Dear Mr. Berndt,

As an alternate energy consulting agency, gaseous fuel Research and Development unit and a manufacturer of High Pressure Natural Gas Compressors, Carburetion Equipment and High Pressure Flow Meters, all of which are used in the automotive section for the application of Compressed Natural Gas as an alternative to gasoline and diesel, Nu-Fuel Industries, Inc. is concerned about the vague perspective of the Federal Motor Vehicle Safety Standard (FMVSS) 301-75 and the lack of a comparable standard for Compressed Natural Gas.

The purpose of FMVSS 301-75 "is to reduce deaths and injuries occuring from fires that result from fuel spillage during and after motor vehicle crashes", and applies to vehicles using fuel "with a boiling point above 32oF".

The purpose of FMVSS 301-75 is commendable and is quite the priority of all users and manufacturers but the boiling point limitation eliminates the applicability of this standard to such alternate fuels like Compressed Natural Gas, whose boiling point is way below 32oF.

It has become an unjustified norm in the State Commission offices like those of the State Board of Education and their Superintendents that as the FMVSS 301-75 does not apply to CNG and as there is no comparable standard written by the National Highway Traffic Safety Administration for CNG, the usage of this economically incentive fuel is prohibited and as such shy away from it. It is thus imperative that the National Traffic Safety Administration make it very clear to the public where it stands and what its going to do about CNG and its usage. For example: "FMVSS 301-75 does not apply to CNG and does not prevent the usage of CNG. As a standard for CNG usage does not exist/is in the making, all those fuel systems that are manufactured and installed as per the National Fire Protection Agency Standard 52 written for Compressed Natural Gas vehicles would be accepted."

The safety record of Compressed Natural Gas powered vehicles is enviable. The fuel containers used are DOT 3AA high pressure steel cylinders which have an incomparable safety factor attached to them. A recent severe abuse test done on composite reinforced aluminum storage cylinders (Society of Automotive Engineers Conference proceedings P-129, paper 831O68, June 22-23, 1983) only help in emphasizing with authority the superior structural strength and stability of these fuel containers over those containing gasoline and diesel.

A theoretical analysis done by the Los Alamos National Laboratory (Gaseous Fuel Safety Assessment for light duty automotive vehicles-LA-9829-MS) shows that CNG is a far superior fuel from safety perspective, over gasoline and diesel, in both primary hazard and secondary hazard situations.

It is thus an irony that in spite of all these advantages the state level controlling agencies refuse to endorse this most economically viable fuel, all because the NHTSA has not taken a stand on this issue.

Almost all CNG conversions are done on used vehicles and all of them are done on vehicles that are sold without the intention of resale, thus the installers and component manufacturers are not required to go through the recertification process.

Is an alterer who converts a used gasoline powered vehicle so that it is both a gasoline-powered and a CNG-powered vehicle, responsible for recertification according to FMVSS 301-75 and if so what else does he have to meet?

A tamperer from the NHTSA stand point is one who changes components of a fuel system and he is supposedly exempt from the penalties if he does not indulge in the removing, disconnecting or reducing the performance of the already existing equipment. From a structural integrity standpoint the new component; have a safety factor of 4 to 1 and meet and exceed all of the NFPA 52 requirements. As the FMVSS 3O1-75 does not have specs written down for these components it would be beneficial to both parties to accept some norms set down by another Federal Agency which has covered both, component quality and installation procedures.

In conclusion, an indepth study of the CNG conversion process should be done by NHTSA and then necessary standards should be set up. A clear definition of an alterer, tamperer and their liability on working on used vehicles should be spelled out.

I would appreciate your responding to this at the earliest possible date letting me know of any applicable violations. I would also appreciate your making it very clear if NHTSA prohibits the usage of Compressed Natural Gas in passengers vehicles including school buses.

Please find enclosed, a brochure that explains our conversion process. Feel free to get in touch with me if you have any questions.

Thanking you.

Sincerely Yours, Purna R. Saggurti Senior Executive Engineer Research & Development PRS/sa Encl.