C,CDA EPA420-F-94-015
December 1, 1994
RFG Questions and Answers
Special Update for December 1,1994
Fuels and Energy Division
Office of Mobile Sources
U.S. Environmental Protection Agency
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RFC Questions and Answers
Special Update for: December 1,1994
Evei'v-batch sampling and testing for averaging parties
Question: In the case of RFG oxygenate blenders who blend oxygenate in trucks and who
wish to meet the oxygen standard on average, what options are available for establishing the
oxygen content of the RFG produced? Specifically, is there any option other than every-batch
sampling and testing?
Answer: Under § 80.69(b)(4), an RFG oxygenate blender who meets the oxygen standard
on average is required to sample and test each batch of RFG produced to determine the batch's
oxygen content, and assign a number to the batch for reporting purposes. This every-batch
sampling and testing requirement applies regardless of whether the oxygenate blending is carried
out in a large terminal tank or through splash blending in trucks.
However, EPA currently is evaluating a proposal for oxygenate blenders that would allow
blenders to designate RFG for compliance on average with respect to oxygen content without
requiring every batch sampling. Under this proposal, the oxygenate blender would instead
maintain records of the oxygenate and RBOB volumes for each batch of RFG produced, the
purity of the oxygenate used and the oxygenate requirements for the RBOB, and quality
assurance sampling and testing of the RFG produced. The proposed approach would initially be
restricted to oxygenate blenders who operate using computer controlled blending operations.
EPA intends to issue further guidance with regard to this proposal within the next several weeks.
In the event that an alternative approach to oxygen averaging for oxygenate blenders is
allowed, EPA probably would apply this approach to all RFG that is produced during the entire
1995 oxygen averaging period (that includes RFG produced during 1994), including batches
produced prior to issuance of the final guidance. Thus the guidance could allow a party to
average after the interim period ends, even if the party had been complying on a per gallon basis
during the interim period. In the event the guidance is issued, .and a party has not collected all
information required by such guidance for prior batches, EPA will consider the information that
was: collected and the certainty it gives regarding the oxygen content of the RFG produced by the
pan:y, in evaluating an appropriate enforcement response, if any.
Blending Allowance
Question: EPA has previously offered guidance to refiners regarding a "blending allowance"
for MTBE in order to meet the requirements of the wintertime oxygenated fuels program. This
allowance permits the blending at refineries of MTBE up to 2.9 percent by weight oxygen
(instead of the maximum 2.7 percent by weight oxygen allowed under EPA's "substantially
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similar" definition), in order to allow for dilution as the gasoline is distributed to terminal and
retail stations downstream of the refinery. In separate guidance, recognizing that for some
refiners the flexibility to utilize oxygenated fuels program reformulated gasoline (OPRG) in non-
OPRG RFG areas is extremely important, EPA has previously stated that OPRG can be utilized
in non-OPRG RFG areas. (E.g., regarding minimum pipeline tender sizes, it is often highly
desirable for a refiner to ship a single shipment of OPRG to an oxygenated fuels area but to
utilize some small portion of this shipment in a smaller RFG area which does not require OPRG.)
Hov/ever, it is not clear that EPA's guidance on blending tolerance and on the use of OPRG in
non-OPRG RFG areas allows the use of OPRG blended using the 0.2 percent blending tolerance
in non-OPRG RFG areas. Does the blending allowance apply to OPRG when it is used in
refo:rmulated gasoline areas that are not part of the wintertime oxygenated fuels program?
Answer: EPA's guidance allowing for the use of OPRG in non-OPRG RFG areas was
meant to accommodate the previously issued guidance regarding the 0.2 percent oxygen blending
allowance at the refinery. Thus, the 0.2 blending allowance would apply to OPRG RFG
regEirdless of the area where the OPRG is ultimately used.
December 1,1994
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