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OAR Box 1846 

Prepped by Ollie Stewart 

Document Number: 

44) ll-E-4 

Docket Number: 

A-90-07 

Printed 11/18/2008 7:30:16 AM Sheet 44 of 93 
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

ANN ARBOR. MICHIGAN=-48,105? f"V. 

FEB L \ 1992 

MEMORANDUM 

V'M. OFFICE OF 

AIR ANO RADIATION 

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SUBJECT: Meeting Between EPA and API to Discuss Treatment of RFG 

Within the Draft FFA Registration Program 

FROM: Carolyn Krueger, Chemical Engineer (jW-^f^^j^^l) 

Standards Development and Support Bi/anch *" 

Dcotat NO. A-90-07 M^^/Ucar^h 

THRU: Glenn W. Passavant, Senior Project Manager 

Standards Development and Support Branch 

On Monday, October 21, 1991, representatives from EPA and the 

American Petroleum Institute (API) met at EPA's Motor Vehicle 

Emissions Laboratory in Ann Arbor, Michigan. (See Attachments for 

a copy of the briefing presented.) Areas discussed were the 

philosophy behind the fuel and fuel additive program development, 

emission characterization requirements of both the RFG and FFA 

programs, and product grouping in the draft fuel and fuel additive 

program. 

As a follow-up to the meeting discussed above, API submitted 

ideas to EPA on November 1, 1991, in regard to the preconditioning 

of vehicles prior to performing emissions characterizations. This 

input is also attached. 

Attachments 
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Treatment of Reformulated Gasolines Within 

the Draft Fuels and Fuel Additives Program 

October 21, 1991 
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Overview 

• Statutory Requirements 

• FFA Program Development Philosophy 

• FFA - RFG Program Interaction Concerns 

• Discussion of Approach 

• Discussion 
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Statutory Requirements 

• Section 211(b) prescribes broad and somewhat explicit 

requirements for the registration of all fuels/additives 

with regard to: 

- Emission characterization 

- Health effects 

- Welfare effects 

- Emission control systems 

• The statute contains several provisions designed to 

reduce regulatory burden; most notably groupings and the 

use of adequate pre-existing information. 

• The program is expected to commence in mid 1993 with 

requirements to be completed by mid 1996. 

• Section 211 (k) calls for the sale of RFG in nine 

nonattainment areas beginning in 1995. RFG is expected 

to provide VOC and air toxic benefits. 
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FFA Program Development Philosophy 

• The FFA program's goal has been to develop a program 

which causes the minimum economic/administrative burden 

while still achieving the mandates, goals, and purposes 

of the statute. 

- ECS impact program 

- Exemptions 

- Tiers 

- Previous information 

- Groupings 

• The development of these provisions has been based on 

the statutory authority granted EPA within the 

constraints of good science and sound public policy. 
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FFA - RFG Program Interaction Concerns 

1) Emission Characterization Requirements 

RFG FFA 

Determination of: Determination of individual: 

- benzene - hydrocarbons 

- 1,3-butadiene - aldehydes and ketones 

- formaldehyde - alcohols and ethers 

- acetaldehyde - PAH 

- POM - NPAH 

- non-methane VOC - atypical element emissions 

- NOx - regulated emissions 

• Both programs deal with combustion and evaporative 

emissions but their purposes are different. 

• RFG program goal is a decrease in total mass of 

selected air toxics, without regard to the amount or 

effects of individual pollutants; FFA program goal is 

the identification and quantification of individual 

pollutants and toxicity assessment of whole emissions. 

• RFG uses modeling with limited testing for model 

augmentation; FFA uses emission testing exclusively. 

• RFG is based on 1990 vehicle technology; FFA is based 

on current vehicle technology at the time of testing. 

• Since RFG emission characterization focus is much more 

limited than FFA, we could lose important data on other 

emissions (7 vs >100 compounds). 

• There appears to be a lack of data on effects of 

specific oxygenates or oxygenate interactive effects 

which reduces the credibility of RFG results. 

• Given FFA requirements for health effects testing, 

very little financial savings will result since vehicle 

acquisition and mileage accumulation will still be 

needed. FFA emissions results will be useful for 

refining the RFG model. 
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2) Product Grouping in the FFA Program 

• The 211 statute allows for grouping of fuels and 

additives to reduce compliance costs. 

• The most accurate method for grouping FFA would base 

groups on emission products. This method requires 

emission characterization procedures to be performed 

first and groups to be established subsequently. This 

method has been determined to be impractical due to time 

constraints specified by the statute. EPA is proposing 

groups based on uncombusted product composition. 

• Basing groups on product composition forces EPA to 

make decisions as to the range of product parameters 

that will produce similar emissions and therefore be 

grouped together. EPA must weigh the amount of allowable 

composition variability in a group against the expected 

emission variability. 

• Nevertheless, similar decisions regarding fuel 

composition variability and emissions variability occur 

when making grouping decisions regarding conventional 

gasoline (e.g., aromatic content, fuel species) and yet 

we are now considering that these could be grouped 

together. However, there are concerns that important 

health effects could be missed when one or more 

characteristics is permitted a large range. 

• Furthermore, it is recognized that fuels now produced 

under Section 211(f) waivers may have substantial 

oxygenate content of varying species. 

• It may be inconsistent to permit broad grouping of 

conventional gasolines with relatively large ranges in 

compositional characteristics while having less 

tolerance for oxygenates even though they are permitted 

under 211(f). 

• An approach is possible to assess concerns about these 

varying ranges in fuel parameters: 

- baseline class 

- non-baseline class 
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Discussion of Approach 

• The definition of the "Baseline Formulation" class 

would be expanded to include all fuels within the sub. 

sim. definition and waivered limits as of the FFA ANPRM 

publication date, under the stipulation that the fuel 

resemble the baseline fuel used to represent the group. 

• The "Oxygenated Formulation" class would be eliminated 

and a new class be formed termed the "Non-baseline 

Formulation" class. The "Non-baseline Formulation" class 

would contain all formulations that are not within the 

bounds of what EPA determines to be in baseline fuels. 

Bounds would be placed on the parameters that EPA 

determines to have potential/unknown effects on the 

emissions and health. 

• EPA anticipates these parameters may include at least 

oxygenate content and aromatic content. Other candidate 

parameters include bounds on oxygenate and aromatic 

species (benzene, toluene, xylene) and PAH content. 

• The oxygenated fuels that are beyond the waivered 

limit that would have previously been part of the 

"Oxygenated Formulation" class will become part of the 

"Non-baseline Formulation" class. 

• The NPRM asks for comment on the parameters that 

should be used to make the distinction between baseline 

and non-baseline formulations and the values the bounds 

on these parameters should be. 

• Depending on the information submitted, possible 

outcomes are no fuels/additives in the non-baseline 

group or a limited number focused on addressing 

identified concerns relative to bounds on the 

parameters. RFG would be in the baseline fuel class 

pending the outcome of the rule (i.e., the bounds on the 

chosen parameters). 
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-ED AGENCIES TC:9i313S£343c3 NDU i, 1991 4:02PM S752 P.02 

VEHICLE PRECONDITIONING REQUIREMENT IN 

EPA'S FUELS AND FUELS ADDITIVES ANPRM 

EPA proposes that vehicles be conditioned for 25,000 miles on 

only the fuel intended to be tested. The intent of this 

requirement, as API understands it, is to completely eliminate 

the probability that an emissions effect may be due to anything 

other than the properties of the fuel being tested. 

This requirement is not necessary for the majority of fuels and 

fuel additives likely to be registered under this proposed rule. 

The usual break-in period for a new vehicle to be used for 

emission testing is about 4,000 miles. Above 4,000 miles, 

enissions are reasonably stable but slowly increase with mileage 

over the remaining life of the vehicle. The important 

consideration (and normal practice) for emission testing is to 

choose a vehicle according to its emission level, hardware type 

and/or total accumulated mileage. The Joint Auto/Oil Air Quality 

Improvement Research Program (AQIRP) tested vehicles 

representative of current emission control technology which had 

about 10,000 accumulated miles. This criterion was recommended 

by API in our comments on the reformulated gasoline NPRM. For 

consistency, we recommend that EPA adopt a similar criterion for 

tests conducted under this proposed rule. 

Once a vehicle is selected, it is important to "condition" the 

charcoal evaporative emissions control canister to the test fuel 

to minimize carry-over effects from any previous gasoline used in 

the automobile. The standard practice is to replace the fuel in 

the vehicle tank with the fuel to be tested and to operate the 

vehicle over a short distance of no more than 10 to 30 miles of 

typical stop-and-go urban driving prior to measuring the 

emissions. 

For EPA's new vehicle emissions certification, vehicles are 

driven for 50,000 miles on a mileage accumulation test fuel. At 

each 10,000 mile interval, emissions are measured with the 

vehicle operated on certification fuel which is different than 

that used for the mileage accumulation. Prior to each test, 

fuels are switched and the vehicle is preconditioned by driving 

it over one Federal Test Procedure (FTP) cycle which amounts to 

about 11 miles of stop-and-go driving. 

Since the use of new fuels and fuel additives may only result in 

small differences in the mass emissions of individual hydrocarbon 

species, API recommends that the preconditioning procedure used 

by the Joint Auto/Oil Air Quality Improvement Research Program 

(AQIRP) be adopted by EPA. Vehicles in the AQIRP were 

conditioned over 3 FTP cycles for a total of about 30 miles 

because of concern about possible fuel carryover effects when 

fuels were switched. Due to a similar concern about the 
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.;:FED fidENCIEs T0:913i3SS343SB NOU 1. 1931 <S :03PM S750 P.E3 

potential fuel carryover effects of gasoline oxygenated blends, 

an EPA contractor also used a 3 FTP cycle conditioning procedure 

in a recent test program.1 

While the AQIRP procedure should be sufficient for the vast 

majority of testing performed under the proposed rule, there may 

be some situations where more extensive vehicle conditioning is 

necessary. Pot example, the registration of a fuel or fuel 

additive which is suspected to influence the proper functioning 

of the catalyst in the vehicle emission control system would 

necessitate durability testing whereby vehicles are operated on 

the proposed fuel for several thousands of miles. However, these 

cases would be handled under the EPA regulations pertaining to 

fuel and fuel additive waivers and need not be duplicated in this 

proposed rule. If health effects testing is necessary for these 

situations, we recommend that it be coordinated with the vehicle 

mileage accumulation conducted in support of the waiver request 

process. 

1 M, Warner-Selph and L. Smith, Southwest Research Institute, 

Assessment of Unregulated Emissions From Gasoline Oxygenated 

Blends, prepared for U.S. Environmental Protection Agency, March 

1991, EPA 460/3-91-002.