P.1 

OAR Box 1834 

Prepped by Keeia Richards 

Document Number: 

46) IV-F-04 

Docket Number: 

A-90-07 

Printed 11/10/2008 2:14:35 PM Sheet 46 of 61 
A-<=)0-OT 

IV- (•» 0 4 

Oral Comments by Philip Bush 

J Amoco Oil Company 

May 28, 1992 

on 

CAA Section 211(e) Proposed Rules 

Fuel and Fuel Additive Test Requirements 

~3 

ho 
The Decision Making Process of What Additional 

Test Work is Needed and Useful Should Remain in 

the Regulatory Arena - Rather Than Be Placed in 

the Bureaucratic Arena. 

- Public Debate to Focus Efforts on the 

Highest Priority Issues First, is Invaluable. 

CO 
Those Sections of the Proposal That Would 

Require Extensive Measurements of Fuel Speciation, 

Emissions Speciation and Mass Emission Rates Before 

Registration of Each Fuel Would Provide Very Little, 

New and Significant Data That is Useful For Risk 

Assessments. 
Toxicology Tests Overdose the Animals By 

Many, Many Orders of Magnitude. 

Human Exposure is Best Determined From 

Ambient Concentration Measurements, Not Vehicle 

Mass Emission Rates. 

For Practical Purposes, All Gasolines That 

Meet the Definition of Substantially Similar, Produce 

the Same Chemical Species in the Exhaust. What Can 

Change By Relatively Small Amounts is the Mass Emission 

Rates of the Various Species. 
P.6 

SERA U.S. Environmental Protection Agency (EN-397F) 

Office of Mobile Sources 

Office of Fuel and Fuel Additive Registration 

Washington, DC 20460 

Form Approval 

OMB No. 2060-0150 

Approval Expires 3-31-91 

Fuel Manufacturer Notification for Motor Vehicle Fuel 

1. Fuel Manufacturer Leave Blank 

2. Address: 

3. Type of Fuel 

(Check Only One) • (a) Unleaded Premium 

• (b) Unleaded Regular 

D (c) Unleaded Midgrade 

• (d) Leaded Regular 

• (e) Leaded Premium 

• (f) Grade 1-Diesel 

• (g) Grade 2-Diesel 

• (h) Other (Specify) 

4. Brand name(s) of the motor vehicle fuel covered by this notification (list): 

5. Fuel Properties: Percent Weight 

Highest Lowest Average 

Methods of Analysis 

(a) through (f) only 

(a) Aromatlcs 

(b) Olefins 

(c) Saturates 

(d) Porynuclear Organic Material 

(e) Sulfur 

(f) Trace Elements 

Gasoline: 

(g) RekJ Vapor Pressure (kPa or psi) 

(h) DlstlUatlon: 10% Point (°C) 

(1) DistDlation: End Point (°C) 

(]) Research Octane Number 

(k) Motor Octane Number 

Diesel Fuel: 

(I) Distillation: 90% Point (°C) 

(m) Distillation: End Point (°C) 

(n) Cetane Number or index 

EPA form.3820-12 (03-00) Replaces EPA Form OUR 0314, which is obsolete. 

Prmud aft RtcycUd faptr 

j 
PROPOSED ADDITIONS TO 

EPA's FORM 3520-12 (03-90) 

"FUEL MANUFACTURER NOTIFICATION OF MOTOR VEHICLE FUEL" 

'EPA defines gasolines and diesel fuels for motor fuel use as 

"substantially similar" according to the following definitions: 

Substantially similars 

Gasolines - (add definition and CFR reference here) 

Diesel fuels for motor fuel use — (add definition and CFR ref. here) 

Does this product satisfy EPA's definition of substantially similar: 

Gasoline? Yes or No 

Diesel fuel for motor fuel use? Yes or No 

If the answer to both of the previous questions was no, answer the 

following. 

Does this product satisfy one of EPA's previously granted fuel or 

additive waivers? Yes or No 

Does the health and welfare effects information relevant to the 

categories of substantially similar or waivered fuels and fuel 

additives which EPA already has in its possession apply to the 

best of your knowledge to this product? Yes or No ." 

__