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OAR Box 1868 

Prepped by Ollie Stewart 

Document Number: 

16)VI-E-1 

Docket Number: 

A-90-07 

Printed 11/26/2008 8:35:12 AM Sheet 16 of 258 
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Fuel/Fuel Additives Meeting Summary 

November 3, 1994 

Ann Arbor, Ml 

Present: Judy Gray, EPA 

Kent Helmer, EPA 

Doug Orrin, ORTECH 

Steve Howell, MARC-IV 

Alan Weber, National Biodiesel Board 

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The meeting convened at 10:00 a.m. After a short introduction, Weber and Howell 

described the National Biodiesel Board (NBB) and the various market segments in 

which biodiesel is being sold. Weber highlighted urban mass transits, marine 

activities, and underground mining work as key, near-term markets. Different biodiesel 

blends may be sold in each of these segments. Thus, the NBB is attempting to 

determine where biodiesel fits with the Fuel/Fuel Additive (F/FA) regulations. 

Biodiesel Market and F/FA Registration 

Because the F/FA registration regulations apply to on-road markets only (which 

includes the bus market), the mining and marine markets would not be affected in the 

near term. However off-road F/FA registration and health effects testing may be 

implemented in the future. 

"Trace" Elements 

F/FAs can be grouped into three categories: baseline, non-baseline and atypical. 

Atypical F/FAs contain elements other than C,H,N,S, and 0 . Baseline and nonbaseline F/FAs contain no other elements except C,H,N,S, and 0 but are allowed to 

contain trace levels of the atypical elements. The EPA confirmed that the presence 

of trace contaminants (not added intentionally) has no effect on the grouping of a 

F/FA. Since the presence of trace elements has no bearing on F/FA classification or 

grouping, biodiesel was confirmed as being either baseline or non-baseline, depending 

on the concentration of oxygen in the final blended fuel. 

Biodiesel Grouping 

Under the current regulations none of the alternative fuels, as defined in the 

regulation, are required to register as a F/FA. Biodiesel/biodiesel blends are not 

classified as alternative fuels for purposes of this regulation. It was made clear that 

the designation of "alternative" in this regulation only has meaning within this 

regulation and should not be construed to apply to other regulations or government 

policies such as those being considered by the Department of Energy. 
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According to the rule, classifications of F/FAs different than the baseline fuel which 

are used with the baseline fuel in amounts over 50% will be determined by EPA upon 

inquiry by the F/FA manufacturer. Since biodiesel fits within the guideline, the inquiry 

was presented at the meeting. EPA shared that, as the regulation was drafted, 

biodiesel was assumed to be non-baseline diesel fuel regardless of the blend level. 

EPA has no intention of classifying a high blend of biodiesel as an alternative fuel for 

the purpose of the F/FA regulations. Blends of biodiesel with baseline diesel which 

result in concentrations of oxygen less than 1%, however, will almost certainly be 

classified as a baseline diesel fuel. 

Vegetable Oils versus Animal Fats 

Currently the F/FA regulations create two non-baseline groups for biodiesel; one for 

vegetable oil-based biodiesel and one for animal fat-based biodiesel. Since the EPA 

was unfamiliar with the differences between animal fat and vegetable-based oils and 

they originate from two different sources, two groups were established. The NBB 

shared that information is available regarding both animal fats and vegetable oils, that 

fats and oils are very similar in composition, and that emissions between biodiesel 

based on differing fats and oils would not be qualitatively different from each other. 

The EPA agreed that the basic composition of the vegetable oils and animal fats were 

qualitatively similar (triglycerides), but had questions regarding the differences in other 

substances which may be contained in vegetable oils and animal fats. NBB shared 

that the materials other than triglycerides are also similar and that the data is available. 

EPA shared that they are willing to review this data and would consider a technical 

amendment to combine the animal and vegetable alkyl esters into one grouping if the 

data so warrants. 

Biodiesel Blend Selection 

The current regulations state that the F/FA health effects testing should be conducted 

on the highest in-use concentration recommended by the manufacturer for a product 

in the test group. The highest in-use concentration recommended for biodiesel would 

change, however, depending on the market being considered. For the urban bus 

market, the most common blend is 20% (B20) where in the mining or marine market 

100% biodiesel may be recommended. Since the purpose of the new F/FA regulations 

is to determine the maximum potential health effect impact, NBB suggested that the 

testing of 100% biodiesel would represent the maximum change from existing diesel 

fuel. Testing of 100% biodiesel (along with data on 100% petrodiesel) would then 

encompass all of the expected health effects. EPA shared that this would be true 

unless there were unexpected interactions with the blends. NBB shared that none has 

been seen thus far, and that exhaust speciation will be conducted on B20 blends this 

year. The B20 speciation data would indicate if any interactions occurred. It was 

agreed that this approach seemed reasonable and that Ann Arbor would confer further 

on the issue before providing a final answer. 
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Additives 

Testing an additive does not necessarily change the grouping of a F/FA. For example, 

if an additive is used with B10 and it does not change the fuel's characteristics 

(oxygen, etc.), then it would still be a part of the baseline grouping. The EPA advised 

to look for additives that are composed of only C,H,N,0, and/or S. This guidance was 

given due to the "sub sim" rulings that will be made in the future. The testing of 

additive combinations is generally not necessary. Additives which have completed 

their health effects testing with conventional diesel would not be required to have 

testing repeated with biodiesel. 

Engine Selection 

The top five selling diesel engine models may not necessarily represent the top selling 

engines in which biodiesel is being used. It was advised that testing procedures used 

should follow the API's procedures (including engine selection, to the extent that the 

same engine specifications are practical and applicable to biodiesel). This course of 

action will allow EPA staff to use the API baseline testing as a control for our results. 

Assuming biodiesel has fewer harmful effects, using the same test engine and 

procedures will benefit our efforts. The API has indicated that they will make their 

testing procedures public knowledge. 

API Consortium Participation 

Baseline diesel testing will be used in two ways. First, it serves as a control to the 

health effects testing with biodiesel. Second, a B10 blend will actually fall within the 

guideline for baseline diesel fuel. Therefore, a firm could join the API consortium or 

conduct the baseline diesel testing on their own. 

November 28, 1994 Deadline 

Current sales data (quantitative as well as geographic location) and indication of 

consortium participation should be delivered to the EPA by November 28, 1994. In 

order to meet the deadline, firms that are unsure of plans to participate in group 

testing may state this in their submission. 

What Groups Need to Register with the EPA 

Fuel manufacturers are firms that change the characteristics of a fuel. Therefore any 

firm that adds a bulk additive must register with the EPA and perform health effects 

testing. This definition would include distributors or fleets that add their own additive 

packages. In addition, fleets that splash blend biodiesel with petro-diesel at their 

facility would need to register with the EPA and provide health effects data. Health 

effects testing data can, however, be provided by another firm and presented to the 

EPA. Also, fleet operators will not be penalized for failing to register with the EPA in 

the past. 
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An additive manufacturer is a firm that produces, manufactures, and/or sells an 

additive. Therefore, firms selling B100 must register with the EPA and provide health 

effect data. Once again, each firm does not have to pay for health effects testing if 

another firm will provide the necessary data. 

Special Exemptions 

The $50 million exemption level for non-baseline additives includes other business 

sales. For example, if firm X had an esterification facility but also made rubber tires, 

the $50 million sales level would represent both tire sales and biodiesel sales. 

Other Notes: 

API will host a workshop on November 17, 1994 in Washington, D.C. to address F/FA 

issues. Commercial labs that are capable of performing the health effects research 

have been invited. 

The meeting concluded at 12:30 p.m. 

This summary fairly reflects the remarks and discussions held during the November 

3, 1994 meeting in Ann Arbor, Ml. 

Alan Weber, NBB