Response to Comments Document for Final Rule concerning the use of 

ASTM D6550-05 as an alternative test method for olefin content of gasoline

On January 31, 2011, EPA proposed to allow ASTM D6550-05 (SFC) as an 

alternative to the designated test method, ASTM D1319-03ε1 (FIA), for measuring 

olefin content of gasoline, provided the results are correlated to ASTM D1319-

03ε1 using a site-specific correlation of FIA (volume percent) versus SFC (weight 

percent). The Agency also proposed that correlation be completed on a sitespecific basis. To ensure a proper site-specific correlation, the gasoline fuel set 

used to develop the correlation shall span the range of the olefin properties 

representative of that refinery’s or importer’s gasoline production. This gasoline 

fuel set would be analyzed by the test facility’s laboratory using both ASTM 

D1319-03ε1 (also known as FIA, or the designated test method) and ASTM 

D6550-05. A resulting correlation equation would then be developed in terms 

of ASTM D1319-03ε1 in volume percent and ASTM D6550-05 in weight percent. 

Thus, the applicable range of the resulting correlation from a facility’s site 

specific correlation would be consistent with that specific facility’s olefin content 

range.1 In response to this proposed rule, EPA received five comments from the 

American Petroleum Institute (API), BP America Incorporated (BP), the National 

Petroleum and Refiners Association (NPRA), Western States Petroleum 

Association (WSPA), and Shell Oil Products U.S. (SOPUS). All comments were in 

support of the proposal.

 

1

76 FR 5319, January 31, 2011.
2

The following is a brief summary of additional comments provided by the American 

Petroleum Institute (API), the National Petroleum and Refiners Association (NPRA), Western 

States Petroleum Association (WSPA), and Shell Oil Products US (SOPUS) and EPA’s responses to 

them. 

Comments:

API, NPRA and SOPUS also recommended that EPA update its regulations to incorporate 

by reference the 2010 year version of both ASTM D1319 and ASTM D6550. 

Response:

EPA will undertake this issue in a future rulemaking. 

Comments:

WSPA commented that a refinery may choose to have neither of the test methods 

(ASTM D1319 or ASTM D6550) in its laboratory if it is relying on a third party commercial 

laboratory to conduct 100 percent of its certification testing. WSPA asked EPA for clarification 

that a third party laboratory may assist a refinery laboratory in its development and 

maintenance of the required correlation using samples from the specified refinery. 

Response:

EPA believes in the case where a refinery or importer may be relying on a third party 

commercial laboratory to conduct its certification testing, it would be acceptable for the third 

party commercial laboratory to assist the refinery or importer in the development and 
3

maintenance of the required correlation using samples from that specific refinery. In addition, 

although not the subject of this rulemaking, EPA intends to establish a performance-based test 

method approach (PBTMA) rule which would provide criteria for the qualification of alternative 

test methods.