EPA420-F-01-017

May 2001

Guidance to Parties Submitting

Mobile Source Air Toxics

 Baseline Applications

Transportation and Regional Programs Division

Office of Transportation and Air Quality

U.S. Environmental Protection Agency
Disclaimer

The discussion in this document is intended solely as guidance. The statutory provisions and

EPA regulations described in this document contain legally binding requirements. This

document is not a regulation itself, nor does not it change or substitute for those provisions and

regulations. Thus, it does not impose legally binding requirements on EPA, States, or the

regulated community. This guidance does not confer legal rights or impose legal obligations

upon any member of the public. 

While EPA has made every effort to ensure the accuracy of the discussion in this guidance, the

obligations of the regulated community are determined by statutes, regulations, or other legally

binding requirements. In the event of a conflict between the discussion in this document and any

statute or regulation, this document would not be controlling. 

The general description provided here may not apply to a particular situation based upon the

circumstances. Interested parties are free to raise questions and objections about the substance of

this guidance and the appropriateness of the application of this guidance to a particular situation. 

EPA and other decisionmakers retain the discretion to adopt approaches on a case-by-case basis

that differ from those described in this guidance where appropriate. 

Mention of trade names or commercial products does not constitute endorsement or

recommendation for their use. 

This is a living document and may be revised periodically without public notice. EPA welcomes

public input on this document at any time.
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Background: On March 29, 2001, EPA promulgated new regulations setting standards for

gasoline toxics performance levels. 61 Fed. Reg. 17230. These new regulations, codified in

Subpart J of 40 CFR Part 80, require each refinery and importer to meet refinery/importerspecific compliance baselines for conventional and reformulated gasolines. To determine these

compliance baselines, refineries and importers need to apply to EPA for a toxics baseline

pursuant to 40 CFR § 80.910. The following guidance applies to any party applying to EPA for

such toxics baselines. This guidance deals only with establishment of a baseline. Where

necessary, EPA will provide future guidance on other aspects of the Subpart J regulations.

Baseline Application Due Dates: EPA’s regulations require refineries or importers seeking to

establish toxics baselines to apply by the later of June 30, 2001, or three months prior to the first

introduction of gasoline into U.S. commerce by the refinery or importer.

Required Information: Each baseline application must include the following information for

each batch of gasoline produced or imported in 1998-2000, and must provide this information

separately for conventional gasoline and combined reformulated gasoline and RBOB: 

1. Batch ID (Company ID, Facility ID, Report Year, and Batch Number);

2. Volume (gallons); and

3. Applicable toxics value (from Phase II Complex Model results). 

Note 1: Batch Reports for gasoline designated by the refinery or importer for use in

California are not required to be submitted under the RFG program and should not be

included in toxics baseline calculations if such gasoline meets the requirements of 40

CFR § 80.845.

Note 2: Not all RFG/Antidumping batch report (Forms 3520-20C and 3520-20F)

information reported to the Agency should be included in the development of toxics

baselines. EPA’s regulations at 40 CFR § 80.915 provide for calculations of a refinery’s

or importer’s baseline toxics value and baseline toxics volume using the toxics value and

volume (gallons) of each batch of gasoline produced during 1998-2000. Although

previously certified gasoline, which by definition has already been included in a

compliance calculation, should not be counted for purposes of calculating baselines,

gasoline added to previously certified gasoline must be accounted for in the toxics

baselines. Therefore, the data from only one of the three “Previously Certified Gasoline”

batch report forms (Form 3520-20F) - the one checked as “calculated,” which represents

the gasoline added to the previously certified gasoline – is appropriately included in the

computation of baseline toxics value and baseline toxics volume. Gasoline blendstocks

are not included separately in baseline calculations, although the gasoline produced

through blending of blendstocks is included. Data from batch reports (Form 3520-20C)

checked as “blendstocks” (including Gasoline Treated as Blendstock (GTAB) and

conventional blendstock) under the RFG/antidumping reporting program should not be

included in the calculations of toxics baselines. However, the data for conventional
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blendstock as provided in the Equivalent Emissions Performance (EEP) reports for

oxygenates blended downstream from a refining facility and included in that facility’s

baseline compliance reports for 1998-2000 must be included in the toxics baseline

calculations.

Note 3: The baseline toxics value and baseline toxics volume, for each type of gasoline

(CG and RFG/RBOB), as calculated under § 80.915, must be reported to two decimal

places as required by § 80.915 (e).

Electronic Submission Guidance: In order to make submission of the data as easy as possible

for both reporting parties and EPA, we will accept information in electronic format using any of

the major spreadsheet software applications available. These include Microsoft Excel, Corel

Quattro Pro, or Lotus 123. To further simplify electronic submission, we have developed

spreadsheet templates in several different versions of these software packages. These

spreadsheets are available on EPA’s Web site at: http://www.epa.gov/otaq. If you have any

problems utilizing the spreadsheet format, please contact the EPA staff person listed below. 

Spreadsheet files should be named by the 5-digit EPA facility ID preceded by “MSAT” (e.g., an

Excel file for facility ID 54321 should be named “MSAT54321.xls”). If a company chooses, all

facilities for that company may be included on several pages of the same spreadsheet. If you use

this approach, the spreadsheet pages should be named using the facility ID and the filename

should be the 4-digit company ID preceded by “MSAT” (e.g., a Lotus spreadsheet file using such

an approach for company ID 4321 should be named “MSAT4321.123").

Spreadsheets submitted as electronic files should be provided on 1.4 megabyte floppy disks along

with a letter from the appropriate corporate officer as described in the regulations at

§ 80.910(c)(3). The letter should reference, by name and EPA RFG/anti-dumping program

reporting number, the facilities covered by the data on the electronic disk and include the other

information required in section § 80.910(c). If you have already submitted your baselines, you

will be contacted if any change in format or additional information is needed.

EPA Contact:

John Weihrauch

(202)564-9477

Fax: (202)565-2085

Email: weihrauch.john@epa.gov
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If sent by U.S. mail, the toxics baseline request should be sent to:

U.S. EPA

Attn: Toxics Program (6406J)

1200 Pennsylvania Ave. NW

Washington, DC 20460

If sent by an overnight or courier service, the toxics baseline request should be sent to:

U.S. EPA

Attn: Toxics Program - John Weihrauch

501 Third Street, NW

Washington, DC 20001

Phone: (202)564-9477