0 CDA                                        EPA420-F-94-011
                                                 October 31, 1994
                   RFG/Anti-Dumping
                 Questions and Answers
                   October 31, 1994
                     Fuels and Energy Division
                      Office of Mobile Sources
                 U.S. Environmental Protection Agency

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       RFG/ANTI-DUMPING QUESTIONS AND ANSWER, OCTOBER 31,1994
       The following are responses to most of the questions received by the Environmental
Protection Agency (EPA) through October 17, 1994, concerning the manner in which the EPA
intends to implement and assure compliance with the reformulated gasoline and anti-dumping
regulations at 40 CFR Part 80. This document was prepared by EPA's Office of Air and
Radiation, Office of Mobile Sources, and Office of Enforcement and Compliance Assurance,
Office of Regulatory Enforcement, Air Enforcement Division.

       Regulated parties may use this document to aid in achieving  compliance with the
reformulated gasoline (RFG) and anti-dumping regulations.  However, this document does not in
any way alter the requirements of these regulations.  While the answers provided in this
document represent the Agency's interpretation and general plans for implementation of the
regulations at this time, some of the responses may change as additional information becomes
available or as the Agency further considers certain issues.

       This guidance document does not establish or change legal rights or obligations.  It does
not establish binding rules or requirements and is not fully determinative of the issues addressed.
Agency decisions in any particular case will be made applying the law and regulations on the
basis of specific facts and actual action.

       While we have attempted to include answers to all questions  received by October 17,
1994, the necessity for policy decisions and/or resource constraints may have prevented the
inclusion of certain questions.  Questions not answered in this document will be answered in a
subsequent document.  Questions that merely require a justification of the regulations, or that
have previously been answered or discussed either in a previous Question and Answer document
or the Preamble to the regulations have been omitted.
                                    Topics Covered
Standards/Model s
Test Methods
Downstream Oxygenate Blending
Regi strati on/Recordkeeping/Reporting
Product Transfer Documentation
October 31, 1994

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                               STANDARDS/MODELS

1.  Question: When will EPA publish a corrected version of the Complex Model? TheNOx
equation corrections published in the DFRM were not correct, and the published evaporative
VOC equations do not yield the published baseline emissions for baseline fuel.

       Answer:  Errors in the final rule for the reformulated gasoline program and the DFRM
are being corrected in an upcoming technical amendment.

       The spreadsheet version of the Complex Model does not contain the errors that appeared
in the Federal Register description of the Complex Model. However, the equation coefficients in
the spreadsheet have been rounded in comparison to the coefficient values given in the Federal
Register. This difference results in a disparity of less than 0.005% between the published
baseline emission values and the values calculated from the evaporative equations in the
spreadsheet, a disparity which is unlikely to affect any results. Nevertheless, EPA will update
the spreadsheet version of the Complex Model as soon as time permits.
                                  TEST METHODS

1.  Question: Concerning the OFID test method for oxygenates:

       a)  The method has a program run of 20 minutes, but over half the eluting peaks on the
table in the method come off after 20 minutes.  For example, the last oxygenate present on the
table elutes off at 38 minutes. Can one use other chromatographic conditions such as those
conditions set in the ASTM draft method for OFID analysis to achieve shorter retention times
and better analytical techniques?

       Answer:  Yes.
       b)  The method states that the chromatographic parameters for hydrogen (H2) and air
(O2) for the FID should be 370 ml/min for O2 and 15 ml/min for H2. According to the
manufacturer, these conditions cannot be met with the instrument we have. The manufacturer
recommendation is air at 300 ml/min and H2 at 30 ml/min. Will EPA accept requirements or
recommendations from the instrument manufacturers which are different than what is stated in
the method for the best chromatographic way of running their OFID system for oxygenate
determination?

       Answer: Yes.
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       c) Can one use the same vendor for purchasing calibration standards along with the
independent secondary Q.A. standard needed in the quality control part of this method? Please
outline all differences that there must be between the standards.

       Answer: It would generally be inappropriate to purchase prepared Calibration and
Independent Standards from the same purveyor; however, if one is purchasing pristine pure
compounds for the purported purpose of preparing precise standards, one vendor may be
acceptable.

       The main concept is that an inaccuracy caused by an impure standard material would be
identified by the use of a different compound, assuming that the second compound is not impure
by an identical amount. Similar logic is applied in that a different chemist should prepare the
second standard to avoid replicating an inadvertent mispreparation.
       d) Please clarify the quality control section by outline what is required to be run with
each batch of RFG.

       Answer:  Quality control for OFID (FR V59, No32, pp7828-7833)

             QC Provision              Required           Recommended
             CalCheck Standards
             1 per 10 samples
             or once per analysis
             batch.

             Independent Check Stds
             1 per 100 samples
             or once per analysis
             batch.

             Spikes
             Required only if matrix
             effects are suspected.
             One per analysis batch
             or one per ten samples
             recommended.

             Duplicates
10% EtOH
      MeOH
+13% MTBE
      t-BuOH

10% EtOH
      MeOH
13% MTBE
      t-BuOH

13% EtOH
      MeOH
16% MTBE
      t-BuOH
6%  EtOH
      MeOH
10% MTBE
      t-BuOH

6%  EtOH
      MeOH
10% MTBE
      t-BuOH

10% EtOH
      MeOH
13% MTBE
      t-BuOH
             Limit to Range

MeOH       0.043C +0.010
             (0.27-1.07%)
MeOH       0.053C(1.07-12.73%w/w)
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             (Duplicates are not          EtOH        0.053C
             required, but it is            MTBE       0.029C + 0.069
             recommended that one       DIPE        0.048C
             sample in tenor one          ETBE        0.074C
             per analysis batch           TAME       0.060C
             be duplicated)
2.  Question: Concerning the EPA method for total aromatics:

       a) Does EPA know of a source where all the components on the table in the method can
be purchased?  We have not been able to find one component, 1,3 diethyl benzene. Please state
the manufacturer and the availability of each aromatic component in the method table.

       Answer: EPA is using the five level calibration mixture recommended in the ASTM
draft method for aromatics in gasoline. Pre-made standards for that method can be purchased
from at least two vendors. The list of compounds used in the ASTM calibration are generally
available from at least one vendor. For further information, contact Carl Scarboro at (313) 668-
4209.
       b)  If all the aromatic components listed in the method table cannot be found to calibrate
the GC-MS, how can someone get an accurate result?

       Answer:  Precise results are possible by using a multi-level calibration using the
compounds listed in either the ASTM procedure and by using: the response factor for Indan for
all uncalibrated aromatics with a molecular mass of 117, the response factor for 1,2,3,5-
tetramethylbenzene for all uncalibrated aromatics with a molecular mass of 134, and the response
factor for pentylbenzene for all uncalibrated aromatics with a molecular mass of 148. There are
undoubtedly some errors in the quantification but they are probably less than 1.0 of the total
aromatic number. Leaving out the uncalibrated aromatics would underestimate the total aromatic
number. We have no evidence that using a response factor of one is as good as using a response
factor of a calibrated compound of a similar mass and structure.
       c)  A previous Q&A document stated that one had to determine all aromatic components
in a sample by comparing them to the closest calibrated component. How can this be done?
Since response factors are so widely different between the different aromatics, how can one get
an accurate total aromatic result?

       Answer:  Using the above calibration standards and a reconstructed chromatogram at the
masses 117, 134, and 148 of a gasoline like RFA or other high aromatic gasoline, one can
identify uncalibrated aromatics with the above molecular weights, assign a single point through
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zero calibration curve using the curves generated for one of the above three calibrated
compounds and produce an adequate calibration table for this procedure.
       d) 25 vol% is the lowest concentration for the internal standard recommended by EPA.
We believe this is not good analytical practice when the largest component is around 5 vol% and
almost all other aromatic components are below 2 vol%.  Can a refiner pick a level for the
internal standard that fits the level of the aromatic components in their fuel sample? If one
cannot pick a level for the internal standard, please indicate why and how to get accurate results.

       Answer: The 25 vol% only refers to the volume of a single internal standard in the total
internal standard mixture; i.e., a compound is specified as 25 vol% of the internal standards.
That translates to a much lower number when it is mixed into a sample or standard. Presently,
EPA is using 6.0 wgt% ethylbenzene-dlO, 2.5 wgt% benzene-d6, and 2.0 naphthalene-d8. This
seems to work well, but methylbenzene may be better quantitated with the addition of
methylbenzene-d8. We believe other compounds should work as well.
       e)  The quality control section of the aromatic method states that the samples must be
within 2 vol% of the RFG sample at a 95% confidence level.  Does this mean that you must run
each sample 10 times to get a statistical average and compare it with 10 runs of a previous
statistical average so that one can compare it to a 95% confidence level. Please explain the
quality control section in more detail. We assume this to mean that any 2 runs of a sample
cannot deviate by more than 2 vol% in a fuel sample.

       Answer:  The 2 vol% is the allowable difference for lab duplicates of a sample. That is,
duplicate analyses should not differ by more than 2 vol%. In addition, the analysis of the quality
control standard or reference material should also not differ from its nominal concentration by 2
vol%.  These are fairly wide targets.  EPA is currently seeing a precision of 5.0% of point at the
95% confidence interval. That figure translates in a standard or sample containing 25 vol%
aromatics as 1.25 vol% for a 95% confidence interval and less than 1.9 vol% at a 99%
confidence interval.
       f) The issue of handling aromatics that are found in the sample but are not part of the
calibration list must also be resolved.  In a previous question and answer session, EPA indicated
that other aromatics found in the sample but not part of the system calibration should be
approximated by comparing the peak area of the non-calibrated compound to the closest
calibrated analyte.  This type of calculation is difficult for instrument manufacturers to program
and, therefore, places a large burden of manual calculations on the chemist.  These
approximations can also corrupt the quantitation data. Why build calibration curves for 30 to 40
analytes and follow the QA/QC protocol for verification of these curves only to corrupt the final
result by adding in a number of estimated aromatic levels. In other EPA methods such as 524,
525, 8260, and 8270, unknown peaks that are not part of the calibration are tentatively identified

October 31, 1994                                                                      5

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by a library search against a commercial library and their approximate concentration calculated
by assuming a response factor of 1 for the unknown peak. These compounds are reported as
potentially being present in the sample but are not involved in any of the calculations involving
calibrated analytes. Software for this sort of a calculation is available from any GC-MS vendor.

       If it is necessary to add the unknown aromatics into the total aromatic content, we suggest
using the same type of calculation used in the other EPA methods (assume a response factor of
1).  This would allow for easy modification of existing software to handle the calculations.

       Answer:  We believe that by following the steps outlined in paragraphs b and c above,
and the ASTM procedure one can produce satisfactory results.  The use of a response factor of
one may  or may not produce similar results. We have no data at this time to make an evaluation.
                      DOWNSTREAM OXYGENATE BLENDING

1.  Question: Would a refinery that receives RBOB from another refinery and blends
oxygenate(s) with that RBOB to make RFG also have to register as an oxygenate blender?

       Answer: Yes. Under  80.2(mm), an oxygenate blender means "any person who owns,
leases, operates, controls, or supervises an oxygenate blending facility, or who owns or controls
the blendstock or gasoline used or the gasoline produced at an oxygenate blending facility."
Under  80.76(a), registration is required for "any oxygenate blender that produces any
reformulated gasoline." In addition, the refiner-oxygenate blender would be required to
demonstrate compliance with the oxygen standard for the RFG produced in its oxygenate
blending capacity separately from the RFG produced as a refiner.
                 REGISTRATION/RECORDKEEPING/REPORTING

1.  Question: By our reading of the regulations, the only reporting required of the oxygenate
blender who elects to comply with the oxygen standard on a per gallon basis is a yearly report
due the last day of February of each year (beginning in 1996) that states the total volume of RFG
produced along with the certification statement.  Is our interpretation correct? Are we correct in
assuming that batch numbers and individual batch data are not required as part of the report?

       Answer: Your interpretation is correct.
                     PRODUCT TRANSFER DOCUMENTATION

1.  Question: We understand it is not necessary to use the words "transferor" and "transferee" on
PTD's as long as the parties giving and receiving custody/title are identified. Our concern was
with the carrier receiving custody from a marketing terminal and then passing it on to another

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party. This makes him a transferee and then a transferor.  The concern was having the carrier
alter the bill of lading to reflect this change.  We understand that as long as we show the name
and address of the carrier (or show a carrier identification number that is directly related to the
carrier's address) on the PTD and also show the party to whom the product is being shipped, we
have sufficient information to satisfy the obligation for us as well as the carrier. Please confirm
that this is a correct interpretation.

       Answer: Your interpretation is correct. If the paperwork properly reflects the chain of
custody through the carrier and shows the proper dates and locations for the different transfers,
you have met the PTD requirements with regard to the transfer of custody and the carrier can use
the same document to meet his PTD requirements. There normally would be additional PTD
requirements concerning the transfer of title, however, because by definition a party other than
the carrier has title.
2.  Question: We are a domestic refiner who also will be importing (paying customs duties)
conventional and reformulated gasoline into our own marketing terminal.  It is our understanding
that we would be the transferor, not the foreign refiner from whom the product was obtained. If
we were importing into another party's terminal, the PTD would have to show them as receiving
the product (transferee).

       EPA reiterated they expect that most, if not all, of the PTD information would be
included on existing type documents.  New documents would only be required when there is no
existing paper path with the necessary EPA information to follow product movements.  If the
necessary PTD information is included on the foreign refiner's transfer papers, is it necessary to
originate another document since we are the first U.S. party  involved in the transfer.

       Answer: The foreign refiner's paperwork would satisfy the PTD requirements if you
provide it to the transferee and it includes all of the required PTD information, including the
proper date and location of the transfer.
3.  Question: The regulations state that, "other than when gasoline is sold or dispensed for use
in motor vehicles at a retail outlet or wholesale purchaser-consumer facility," transfer documents
must be exchanged with the requisite information. In many areas of the country, the petroleum
industry is using cardlocks, unmanned fueling facilities, to dispense gasoline into motor vehicles.
These cardlocks provide access to fleet operators via an electronic card, which is also used to
access the pumps. The pumps transmit an electronic message regarding the purchase and the
customer is invoiced.  There is no opportunity for the delivery of written paper at the time of
purchase. In EPA's judgment, are these cardlock facilities considered retail outlets?

       Answer: As you describe them, these cardlock facilities would be considered retail
outlets for purposes of the product transfer document requirements.
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