v>EPA
EP A420-F-94-013
November 21, 1994
RFG/Anti-Dumping
Questions and Answers
November 21,1994
Fuels and Energy Division
Office of Mobile Sources
U.S. Environmental Protection Agency
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RFG/ANTI-DUMPING QUESTIONS AND ANSWERS, NOVEMBER 21,1994
The following are responses to most of the questions received by the Environmental
Protection Agency (EPA) through November 7,1994, 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 November 7,
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
Test Methods
RFG General Requirements
Compliance on Average
Downstream Oxygenate Blending
Product Transfer Documentation
Anti-Dumping Requirements
Transition Issues
Downstream Blending Issues
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TEST METHODS
1. Question: Since there may be interference between benzene and ethanol or methanol when
using the prescribed method for benzene, ASTM D 3606-92, how may instrument parameters be
adjusted to resolve benzene from ethanol or methanol as suggested in the final regulations?
Answer: During the rulemaking process, comments directed to the Agency encouraged
the use of ASTM D 3606-92. Other comments regarding that method warned against potential
interference in the determination of benzene in gasolines containing ethanol or methanol. As a
result of these comments, language was inserted into the regulation requiring, for ASTM D 3606-
92, that "Instrument parameters must be adjusted to ensure complete resolution of the benzene,
ethanol and methanol peaks..." during the operation of this test.
In light of uncertainty regarding what modifications would be considered acceptable by
the Agency, the decision was made to describe in detail the best set of modifications currently
known to EPA. These primarily include changes in two parameters (column and internal
standard) from those described in ASTM D 3606-92.
Column Type and Length:
Original ASTM D 3606-92
Two column sections, in order:
1) 5' X 1/8" Methyl Silicone on chromasorb
-valve-
2) 15' X 1/8" 1,2,3 tris(2-cyanoethoxy)propane (TCEP) on chromasorb
-detector-
Modified ASTM D 3606-92
Three column sections, in order:
1) 5' X 1/8" Methyl Silicone on chromasorb (10% OV101 on Chrom PAW 80/100)
-valve-
2) 5' X 1/8" TCEP on chromasorb (20% TCEP on Chrom PAW 80/100)
3) 15' X 1/8" Carbowax 1540 (15%) on chromasorb W (eg. Wasson-ECE K16)
-detector-
In the modified setup the total column length is extended by 5'. The original 15' section of TCEP
is replaced by two sections of column totaling 20' and connected in series, or one 20' column
packed to simulate the two columns. This combined 20' section of column is connected in the
same way as the original 15' TCEP, except that the TCEP end of the combined column is toward
the valve (which places the carbowax end next to the detector).
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Internal Standard:
Original ASTM D 3606-92
2-butanone (methyl ethyl ketone or MEK)
Modified ASTM D 3606-92
2-butanol (sec-butyl alcohol or SBA)
With the given column modifications, the retention time of the original internal standard, MEK,
is changed relative to the benzene and is no longer separated from it. The switch to 2-butanol
solves this problem, since the SBA has a slightly longer retention time, and is easily
distinguished from benzene. The SBA is considered a good choice for an internal standard as it
is not normally found in gasoline.
Other parameters:
GC temperature program Isothermal at 135° C.
Column Head Pressure 65 PSI
Total Flow Rate 26.6 cc/min.
Other parameters associated with the unmodified version of ASTM D 3606-92 are unchanged.
These modifications yield improved separation of the benzene and ethanol peaks in the
chromatogram to the point that a fuel containing 0.05% benzene and 10% ethanol will show near
baseline resolution between the two peaks. The methanol peak in the chromatogram occurs on
the other side of the ethanol peak from the benzene peak and is therefore completely separated
from the benzene. Calibrations for this procedure appear linear below 0.05% benzene.
Since there may be modifications to ASTM D 3606-92 other than those described above
that result in adequate separation of benzene from ethanol and methanol, EPA would appreciate
information on any such modifications and will consider disseminating information on promising
approaches through this bulletin board. Comments about such alternative modifications should
be directed to:
J. Bruce Kolowich
Branch Chief, FCAB
U.S. EPA/NVFEL
2565 Plymouth Rd.
Ann Arbor, MI 48105
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EPA will continue to consider the possibility of approving other benzene measurement
methods than ASTM D 3606-92. Such actions would require rulemaking.
RIG GENERAL REQUIREMENTS
1. Question: In what areas outside the continental U.S. must refiners and importers comply
with the RFG and anti-dumping requirements?
Answer: Under § 302(d) of the CAA, the term "State" means "a State, the District of
Columbia, the Commonwealth of Puerto Rico, the Virgin Islands, Guam, and American Samoa
and includes the Commonwealth of the Northern Mariana Islands." Sections 21 l(k)(5) and (6) of
the CAA impose the RFG requirements in all "covered areas" and "opt-in" areas within a State.
Under § 21 l(k)(8) of the CAA, the anti-dumping requirements apply to gasoline "sold or
introduced into commerce," which, under § 216(6), means commerce between any place in any
State and any place outside thereof, and commerce wholly within the District of Columbia. As a
result, refiners that operate refineries in any of the areas specified under § 302(d) of the CAA, or
importers who import gasoline into any of these areas, must meet the RFG and anti-dumping
requirements for this gasoline.
Section 325(a)(1) of the CAA provides that, upon petition by the Governor of Guam,
American Samoa, the Virgin Islands, or the Commonwealth of the Northern Mariana Islands, the
Administrator of EPA may exempt any person or source (or class of persons or sources) in such
territory from these requirements if the Administrator finds that compliance with such
requirements is not feasible or is unreasonable due to unique geographical, meteorological, or
economic factors of such territory, or such other local factors as the Administrator deems
significant. For further discussion of this exemption, see the last question ("Exemptions Under §
325(a)(1)") of the September 12, 1994 Questions and Answers document.
COMPLIANCE ON AVERAGE
1. Question: For purposes of RFG compliance on average, can refiners treat closely integrated
facilities operating in a single covered area as a single facility, or must compliance be achieved
separately for each facility? Suppose the refinery operation consists of mixing blending
components to produce finished RFG using tankage in multiple terminals in close proximity, the
blender is meeting all refiner requirements, and the blender is the responsible party for record
keeping, reporting, and compliance. Can the refiner/blender aggregate the operations at all the
facilities used for compliance on average purposes or must he meet the standards separately at
each terminal?
Answer: Under § 80.67(b)(1), refiners must meet all applicable averaged standards
separately for each of the refiner's refineries (i.e., for each facility at which gasoline is produced.)
This would include terminals at which RFG is produced through a blending process. However,
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under § 80.67(b)(3), an oxygenate blender may group "the averaged reformulated gasoline
produced at facilities at which gasoline is produced for use in a single covered area." Therefore,
whether the facilities producing RFG for a single covered area may be aggregated for purposes of
compliance on average will depend on whether the operation is a refinery operation or an
oxygenate blending operation.
2. Question: If average compilers have left over inventory of OPRG can they physically blend
it with GTAB having a lower oxygen content in order to make RFG with the required 1.5 weight
% minimum oxygen content?
Answer: Finished gasoline, including OPRG, may not be blended with GTAB.
3. Question: If average compilers have left over inventory of OPRG can they recertify the
product (oxygenate parameter) to use during the non-OPRG season?
Answer: OPRG with >2.0 wt% oxygen may be used outside the oxy program period.
No recertification is necessary.
DOWNSTREAM OXYGENATE BLENDING
1. Question: Please confirm that no specific registration requirements are needed to qualify for
the lower sampling rates in § 80.69 if an oxygenate blender uses computer controlled sequential
blending.
Answer: There is no specific registration requirement associated with computer
controlled in-line blending for an oxygenate blending operation. If such blending is used, then
the lower sampling rate in § 80.69(e)(2)(ii)(A) is appropriate.
PRODUCT TRANSFER DOCUMENTATION
1. Question: It is our understanding that the conventional gasoline message for product
transfer documents "this product does not meet the requirements for reformulated gasoline.." is
intended to prevent the sale or use of conventional gasoline in reformulated gasoline covered
areas, and that, while other PTD information can be conveyed via product codes, this message
must be explicitly present on the PTD. It is understandable that this message be present on
PTD's of shipments to service stations so that carriers and service station operators are aware that
the product is conventional. However, for bulk custody transfers of gasoline between
sophisticated parties within the petroleum industry such as pipelines, marine vessels, railroad
cars, etc., the parties involved know what product they are handling, and the product is not
directly bound for a service station. Based on this, we believe the explicit conventional message
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should only be required on PTD's of deliveries to service stations and that other PTD's should be
allowed to convey this message implicitly via product code. Do you disagree with this rational?
Answer: The language regarding conventional gasoline specified at § 80.106(a)(l)(vii)
must be included in the product transfer documentation for all transfers of conventional
gasolines, and this specific language requirement may not be satisfied through the use of product
codes. However, in the case of transfers of title (as opposed to transfers of custody), where the
information is being transferred electronically using electronic data interchange (EDI), and where
product codes are used to meet the product transfer documentation, the specific language
regarding conventional gasoline at § 80.106(a)(l)(vii), and regarding certain blendstock at §
80.106(b), may be reflected as product codes and need not be recited verbatim. See also the
October 17, 1994 update to Question 2, Section VI.I., of the July 1, 1994 Question and Answer
Document.
2. Question: We expect RFG geographic areas to develop in which base gasoline
designated as "OPRG" with at least 2.0% oxygen but less than 2.7% oxygen will be sold. Will
the product transfer documentation requirements covering such a product be met if the PTD
shows the oxygen standards as 2.0% minimum and 2.7% maximum and also contains a message
that although the product is designated as OPRG, it does not fulfill the requirements for resale or
use in an oxygenated control area during a control period without the addition of oxygenates(s)?
Answer: The RFG regulations require the transferor to include in the PTDs the federal
minimum and maximum standards with which the gasoline conforms, including oxygen content
(i.e., 1.5 wt% minimum and 2.7 wt% or 3.5 wt% maximum). In the case of OPRG, the state
standards may be different from the federal min/max standards for oxygen; nevertheless, the
federal mix/max standards are the standards required to be on the PTDs. As a separate
requirement, the RFG regulations require the PTDs to state that the product is OPRG or is not
OPRG.
3. Question: In the October 17, 1994 EPA Q&A Product Transfer Documentation section, the
EPA said that the specific language regarding conventional gasoline [80.106(a)(l)(vii)] and
blendstocks [80.106(b)] may be reflected as product codes and need not be recited verbatim
when the information is being transferred electronically using electronic data interchange (EDI).
We are considering attaching information to both the invoice and exchange statement. These
statements are generated electronically and will be sent to the transferee's of title via an
automated fax system. Will the automated fax system be considered to be EDI for meeting the
requirements? If the transferee does not have a fax line available could the exchange statements
or invoices be mailed and still exclude the conventional and blendstock special wording if these
occurrences involved only a small volume of the exchange statements or invoices delivered?
The development of two systems for the same purpose would be costly.
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Answer: EPA does not consider automated faxing to be a form of EDI, therefore the
entire language in 80.106(a) and (b) would be required to be included verbatim.
4. Question: It is my understanding that under the RFG regulations the EPA mandates product
transfer documentation for conventional gasoline starting January 1, 1995, not December 1,
1994. Is this correct.
Answer: Yes.
ANTI-DUMPING REQUIREMENTS
1. Question: Since the oxygen content of conventional gasoline is not used for the simple
model compliance requirements, we believe it is not necessary to analyze for oxygen or
oxygenate in conventional gasoline during 1995-1997 even though we use oxygenate in certain
grades of conventional gasoline. Is this correct?
Answer: The anti-dumping regulations do not require oxygen analysis under the simple
model.
TRANSITION ISSUES
NOTE: The following is an update to Question IX-A-3 of the July 1,1994 Question and
Answer document, which modifies the guidance concerning sampling and testing during
the transition from VOC-controlled RFG to non-VOC-controlled RFG in advance of the
high ozone season each spring:
IX-A-3. Question: How may terminals and retail outlets transition from VOC-controlled RFG
to non-VOC-controlled RFG in advance of the high ozone season each spring?
Answer: Section 80.78(a)(l)(v) requires that RFG must be VOC-controlled for the
proper VOC-control Region when stored or dispensed by terminals beginning May 1 of each
year, and for retail outlets and wholesale purchaser-consumers beginning June 1 of each year. As
a result, parties in the gasoline distribution system must transition from non-VOC-controlled
RFG to VOC-controlled RFG in advance of these dates.
The RFG regulations do not prohibit combining VOC-controlled RFG with non-VOC-
controlled RFG prior to these dates. As a result, VOC-controlled RFG may be added to a storage
tank that contains non-VOC-controlled RFG in order to turn over the storage tank to the VOC-
controlled specification, in advance of May 1 each year in the case of terminals, and in advance
of June 1 each year in the case of retail outlets and wholesale purchaser-consumers.
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A terminal that combines VOC-controlled and non-VOC-controlled RFG should treat the
mixture as non-VOC-controlled until the party has a test result that shows the RFG meets all
applicable VOC-controlled RFG standards. A terminal, therefore, should not supply product
transfer documents to distributors stating the gasoline is VOC-controlled until the terminal has a
test result that would support this designation. Sampling and testing is not required by retail
facilities in this situation; however, it may be prudent to conduct some testing at the retail level
to ensure that adequate turnover has been achieved and the product meets all applicable VOC-
controlled RFG standards.
NOTE: The following is an update to Question IX-A-4 of the July 1,1994 Question and
Answer document, which modifies the guidance concerning testing in a situation involving
the change of service of a gasoline storage tank:
IX-A-4. Question: The RFG regulations prohibit the mixing of various types of gasoline.
For example, RFG may not be mixed with conventional gasoline. What options are available to
a party to change the service of a gasoline storage tank, given the fact that often it is very
difficult to drain tanks completely dry? How may terminals change the service of manifolds and
storage tank connecting pipes?
Answer: Section 80.78(a) requires the segregation of several categories of gasoline.
These categories are:
RFG may not be mixed with conventional gasoline and sold as RFG.
RFG blendstock for oxygenate blending (RBOB) may not be mixed with RFG or
conventional gasoline, and RBOB's that have different oxygen requirements must
be segregated from each other.
During the period January 1 through September 15 each year VOC-controlled RFG that is
produced using ethanol must be segregated from VOC-controlled RFG that is
produced using any other oxygenate, including at the retail level.
Oxygenated fuels program RFG (OPRG) must be segregated from non-OPRG designated
RFG.
Upstream of the retail or wholesale purchaser-consumer level, RFG produced under the
simple model may not be mixed with RFG produced under the complex model.
Before January 1, 1998 each refinery's or importer's complex model RFG must be
segregated from every other refinery's or importer's complex model RFG, unless
the refineries or importers have identical baselines. This segregation requirement
does apply at the retail level.
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These segregation requirements preclude the mixing of any amount of the gasolines that
must be segregated.1 Thus, if the type of gasoline stored in a tank is changed (a change in the
tank's service), and the old gasoline type and the new gasoline type must be segregated, the new
gasoline may not be added unless the tank is completely free of any amount of the old gasoline
type.
EPA recognizes that when many gasoline storage tanks are pumped as low as possible, a
residual volume of gasoline remains in the tank (called the tank "heel"), and in the manifolds and
tank lines that serve the tank (i.e., the terminal's internal product transfer piping), and that it is
very difficult (but not impossible) to eliminate these residual volumes. As a result, and in order
to facilitate the orderly conduct of business by regulated parties, in the limited situation related to
changing the service of a gasoline storage tank, a party may operate as follows notwithstanding
the segregation requirements:
First, the party must be changing the tank service for a legitimate operational business
reason, i.e., not merely to blend the product in the tank heel or manifold with the
new product.
Second, the party must draw down the gasoline volume in the tank as low as is physically
possible through normal pumping operations before adding the new gasoline.
Third, the volume of old product from tank manifolds and tank lines that is added to the
new product must be as small as possible through normal operations.
Fourth, the party must fill the tank as full as possible with the new gasoline, taking into
account the volume of gasoline that is reasonably available. For example, if the
storage tank having a service change is at a terminal supplied with gasoline by a
pipeline, the tank should be filled with the maximum volume of gasoline available
as a result of the pipeline tender received. For another example, if the storage
tank having a service change is at a retail station, the tank should be filled with the
largest volume of gasoline that normally is delivered to that tank using a single
delivery truck. In any case where the following step involving sampling and
testing is not satisfied as a result of these reasonably available volumes, however,
additional gasoline volume must be added to the tank until the sampling and
testing step is satisfied.
Fifth, the party must collect a representative sample from the filled tank, and analyze this
sample for all the properties that are relevant to the downstream standards for
RFG using the regulatory test methods, or, in the alternative, test methods other
1 RFG may be mixed with conventional gasoline, so long as
the mixture is classified in the product transfer documents as
conventional gasoline and is used only outside any RFG covered
area.
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than the regulatory test methods if adequate correlation to the regulatory test
methods is demonstrated. This analysis must show that the gasoline meets each
downstream standard that applies to the new gasoline type.
Sixth, the party must retain documents that demonstrate these steps in the tank service
change process.
In another scenario, a storage tank's service may be changed in a manner that involves
conventional gasoline but not RFG. For example, a storage tank's or manifold's service could be
changed from blendstock (e.g., natural gasoline, raffinate, naphtha) to conventional gasoline,
which would result in mixing some volume of blendstock with conventional gasoline. In this
type of situation, the party would not be required to meet the standards and requirements that
apply to conventional gasoline refiners if the party meets steps one through four, and step six,
discussed above. The fifth step, involving sampling and testing, is not necessary for
conventional gasoline because there are no downstream standards that apply to conventional
gasoline.
DOWNSTREAM BLENDING ISSUES
**NOTE: The question on Downstream Blending Issues posted on November 7,1994,
regarding registration requirements as they apply to transmix blenders, had been
previously asked and answered on October 3,1994. As the October 3,1994 document
provided a more comprehensive answer to this question, the November 7 answer is
retracted.
**NOTE: The following is an update to Question 16 in the Downstream Blending Section
(Section IX-B) of the July 1,1994 Question and Answer Document, and as updated in the
August 29,1994 and October 3,1994 Question and Answer Documents. This update adds
a notation that the guidance applies to terminal transmix blending as well as pipeline
transmix blending.
IX-B-16. Question: What options are available to pipelines for dealing with interface material,
i.e., mixtures of two different types of product that result when the different products are
adjacent during pipeline movement?
Answer: Interface Mixtures Involving RFG or RBOB
First, the pipeline must minimize the instances of prohibited mixing, through the
sequencing together of product types that may be legally mixed, to the greatest
extent possible.
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Second, in those instances where illegal interface mixing occurs, the entire interface must
be added to the product that will most ensure no adverse environmental
consequences of the mixing. For example:
a. Interface mixtures of RFG or RBOB and conventional gasoline must be
classified as conventional gasoline.
b. Interface mixtures of VOC-controlled RFG and non-VOC-controlled RFG
must be classified as non-VOC-controlled RFG.2
c. Interface mixtures of VOC-controlled RFG for Region 1 and VOC-
controlled RFG for Region 2 must be classified as VOC-controlled
RFG for Region 2 or as non-VOC-controlled RFG.
d. Interface mixtures of OPRG-designated RFG and non-OPRG-designated
RFG must be classified as non-OPRG-designated RFG.
e. Interface mixtures of VOC-controlled, OPRG RFG and non-VOC-
controlled, non-OPRG RFG must be classified as non-VOC-
controlled, non-OPRGRFG.
f. Interface mixtures of RBOB and RFG must be classified as RBOB.
g. Interface mixtures of any-oxygenate RBOB and ether-only RBOB must be
classified as ether-only RBOB.
h. Interface mixtures of generic RBOB (i.e., any-oxygenate or ether-only
RBOB) and refiner-specific RBOB (under § 80.69(a)(1)) must be
classified as refiner-specific RBOB.
Third, the pipeline must retain documents that reflect the nature of any illegal interface
mixing and that the interface was classified in the proper manner, and must make
these documents available to EPA upon request.
2 The mixing of VOC-controlled RFG with non-VOC-controlled
RFG is not prohibited during the transition period prior to May 1
each year (prior to June 1 each year for retail outlets), and
subsequent to September 15 each year. During the VOC transition
period, however, mixtures of VOC-controlled RFG and non-VOC-
controlled RFG nevertheless must be classified as non-VOC-
controlled unless the resulting mixture meets the applicable VOC
downstream standard (as discussed in the Transition section of
this document), and during the VOC-control period such mixtures
also must be classified as non-VOC-controlled RFG.
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Interface Mixtures Involving Conventional Gasoline and Not Involving RFG
In the case of interface mixtures that do not involve RFG or RBOB, pipelines may follow
their historical practices, and will not be treated as a refiner based on such interface mixtures,so
long as:
First, the interface to be blended is generated through pipeline operations, i.e., the
blending does not involve blendstocks that are present for the purpose of blending.
Second, the conventional gasoline involved meets all standards and requirements that
apply to conventional gasoline, including the volatility standards and the substantially similar
requirements;
Third, the volumes of interface are recorded and made available for EPA inspections.
For example, in the case of interface mixtures that involve conventional gasoline and
blendstocks (natural gasoline, raffinate, naphtha, etc.), if a pipeline historically has used midpoint
cuts for this type of interface the pipeline could continue this practice without meeting the
"refiner" requirements as a result of any blendstock that would be mixed with conventional
gasoline through this process. It would not be appropriate, however, to classify all blendstock-
conventional gasoline interface mixtures as conventional gasoline, i.e., to "clean cut" the
interface into the conventional gasoline, because this practice would result in a net increase in
conventional gasoline volume.
Interface mixtures that include neither RFG nor conventional gasoline are not impacted
by the RFG/anti-dumping regulations.
Transmix
EPA understands there are certain types of interface mixtures that cannot be easily added
to either of the adjoining products that produced the interface. This primarily is the case of
interface mixtures of gasoline and distillate, commonly called "transmix." EPA further
understands that the current pipeline industry practice is to transport transmix via pipeline or
barge to a facility designed to separate the gasoline and distillate portions. The owner or
operator of such a facility is called a "transmix processor," and is a refiner under the RFG and
anti-dumping programs.
Transmix Processors
First, the gasoline produced must be classified as conventional gasoline, and not RFG. If
the gasoline produced is classified as RFG, the transmix processor must meet all
refiner standards and requirements applicable to any other refiner of RFG.
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Second, no additional blendstocks may be used. If blendstocks are used, in addition to
the transmix, the transmix processor must meet the anti-dumping refinery
standards and requirements for this blendstock in the same manner as any other
blender-refiner. A transmix processor could, of course, blend gasoline produced
through the process with other finished gasoline without invoking the anti-
dumping requirements, e.g., premium grade gasoline could be blended to improve
octane.
Third, the transmix used must be a mixture of distillate and gasoline - either RFG or
conventional gasoline. If the transmix is a mixture of distillate and blendstock,
the blendstock will never have been accounted-for, and the transmix processor
must meet the anti-dumping refiner standards and requirements for any gasoline
produced using this transmix.
This distinction between the treatment of a transmix processor who produces RFG versus
conventional gasoline is appropriate because the gasoline produced by a transmix processor is
not identical to the gasoline that went into the transmix. These changes in gasoline quality
through transmix processing are simply less critical for conventional gasoline than for RFG. In
addition, the gasoline portion of transmix often will be mixtures of conventional gasoline and
RFG, which would be appropriate for the conventional classification, but inappropriate for the
RFG classification.
Transmix Blending
EPA understands that in certain limited situations where transmix cannot be transported
via pipeline to a transmix processor, current pipeline industry practice is to add the transmix to
gasoline in very small quantities - 0.25 percent or less of the gasoline volume - and to test the
resulting gasoline to ensure it remains on-spec.3 This practice would be treated as illegal
blending under the RFG and anti-dumping programs, unless the blender meets all applicable
refiner standards and requirements.
In the case of transmix added to conventional gasoline:
First, the transmix must result from normal pipeline operations.
Second, the transmix must be present in a terminal from which there is no out-bound
pipeline or water transportation by which the transmix could be transported to a
transmix processor, or the pipeline's historical practice at the terminal (the practice
3 The transmix is added to gasoline instead of to
distillate, because the consequences of any motor vehicle
driveability problems resulting from distillate being mixed with
gasoline are less serious than the consequences of explosions
that could result from gasoline being mixed with distillate.
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beginning at least before January, 1994) has been to blend transmix into
conventional gasoline without further processing.
Third, the transmix is blended at a rate no greater than the historical rate the pipeline can
document was used by the pipeline, and pipeline documents the current rate of
transmix blending.
In the case of transmix added to RFG:
First, the transmix must result from pipeline operational necessity.
Second, the transmix must be present in a terminal from which there is no out-bound
pipeline or water transportation by which the transmix could be transported to a
transmix processor.
Third, conventional gasoline must not be among the slate of products that arrive at the
terminal (transmix must be blended with conventional gasoline if possible).
Fourth, the blending rate of transmix to RFG must be no greater than 0.25 percent by
volume.
Fifth, the transmix must be blended with RFG in a batch mode, so that a sample may be
collected of the entire batch.
Sixth, the transmix-RFG blend must be sampled and tested, and the resulting blend must
meet all applicable RFG downstream standards, before any of the blended
gasoline leaves the terminal.
Seventh, the pipeline must retain documents that reflect the rate of transmix blending and
the results of all testing on the transmix-RFG blend, and must make these
documents available to EPA upon request.
As an alternative to blending the transmix in a batch mode with sampling and testing
before any of the RFG blended with transmix leaves the terminal, the transmix may be blended
with RFG in line provided that the pipeline carries out the following program to ensure the
transmix will not cause any adverse environmental consequences.
First, the pipeline must conduct a program of laboratory testing, in which samples of
transmix are mixed with RFG to determine the effects of the transmix on the RFG. In this
program, the transmix samples must to the greatest extent possible represent the full range of the
transmix types that are typically blended by the pipeline, and the RFG must to the greatest extent
possible represent the full range of the types of RFG into which transmix will be blended by the
pipeline. These different transmixes and gasolines must be blended at the maximum rate of
transmix blending the pipeline intends to use, but a maximum of 0.25% transmix by volume.
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Second, the RFG must be tested for each RFG parameter (RVP, oxygen, benzene, sulfur,
olefins, aromatics, E200, and E300), and the RFG transmix blend must be tested for each of these
parameters, using the testing methods specified at § 80.46.
Third, the results of all of the laboratory tests must show that the maximum change in
properties of the RFG for any RFG-transmix blend is not more than the ranges specified at
§ 80.65(e)(2)(i).
Fourth, the pipeline must conduct RFG-transmix blending as described in steps 5 and 6 of
the first RFG-transmix procedure, above, for a period of 30 days, and the results of the blending
must show that the maximum change in properties of the RFG for any RFG-transmix blend is not
more than the ranges specified at § 80.65(e)(2)(i).
Fifth, the pipeline must conduct monthly tests of the RFG-transmix blended, and the
results of the blending must show that the maximum change in properties of the RFG for any
RFG-transmix blend is not more than the ranges specified at § 80.65(e)(2)(i).
The procedures outlined above for transmix blending would be applicable to terminals as
well as pipelines.
November 21, 1994
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