RFG/ANTI-DUMPING QUESTIONS AND ANSWERS, MAY 2, 1996 The following are responses to questions received by the Environmental Protection Agency (EPA) concerning the manner in which the EPA intends to implement and assure compliance with the reformulated gasoline and anti-dumping regulations at 40 CFR Part 80. This document was prepared by EPA's Office of Air and Radiation, Office of Mobile Sources, and Office of Enforcement and Compliance Assurance, Office of Regulatory Enforcement, Air Enforcement Division. Regulated parties may use this document to aid in achieving compliance with the reformulated gasoline (RFG) and anti-dumping regulations. However, this document does not in any way alter the requirements of these regulations. While the answers provided in this document represent the Agency's interpretation and general plans for implementation of the regulations at this time, some of the responses may change as additional information becomes available or as the Agency further considers certain issues. This guidance document does not establish or change legal rights or obligations. It does not establish binding rules or requirements and is not fully determinative of the issues addressed. Agency decisions in any particular case will be made applying the law and regulations on the basis of specific facts and actual action. While we have attempted to include answers to all questions received, the necessity for policy decisions and/or resource constraints may have prevented the inclusion of certain questions. Questions not answered in this document will be answered in a subsequent document. Questions that merely require a justification of the regulations, or that have previously been answered or discussed either in a previous Question and Answer document or the Preamble to the regulations have been omitted. MODELS [NOTE: The following replaces Question and Answer number 3, 6, 7 and 8 from the March 7, 1996 Question and Answer document. The following answer describes the manner in which early complex model standards are calculated under  80.41(j). This methodology for calculating standards also applies under the alternative simple model described in the January 22, 1996 Question and Answer document.] 1. Question: Please explain how to determine the proper aromatics value to use in calculating early complex model standards. Answer: Section 80.41(j)(2) states that early complex model standards should be calculated using "the aromatics value which, together with the [applicable simple model] values for benzene, RVP, and oxygen meets the simple model toxics requirement." Thus, when calculating early complex model standards that are being met on a per-gallon basis, the simple model per-gallon standards under  80.41(a) for oxygen (2.0 wt%) and benzene (1.00 vol%), and the applicable standard for RVP (7.2 psi for Region 1, 8.1 psi for Region 2, and 8.7 psi for winter) are used to determine the aromatics value that results in a 15 % toxics reduction calculated under the simple model. These aromatics values are the following: Category of Gasoline Aromatics Value VOC Controlled for Region 1 37.1 VOC Controlled for Region 2 33.1 Not VOC Controlled 23.8 A refiner then can calculate the per-gallon standards for VOC, toxics and NOx that apply at a particular refinery. Consider, for example, a refiner who operates Refinery X. Assume that the relevant individual baseline values for Refinery X are: sulfur, 310 ppm; E300, 81 %; and olefins, 12.9 vol%. Using the complex model, the following early complex model per-gallon standards are calculated: Gasoline Category Per Gallon Standards (% change) VOC Toxics NOx VOC Controlled for Region 1 -33.31 -18.72 0.68 VOC Controlled for Region 2 -14.03 -18.23 1.00 Not VOC Controlled n/a -15.45 -0.77 The average standards for VOC, toxics and NOx, however, address gasoline in three categories (VOC controlled for Region 1, VOC controlled for Region 2, and not VOC controlled), so that calculating the proper annual aromatics value requires weighting the proportions of gasoline in these categories, such that the overall toxics reduction under the simple model is 16.5 %. The regulations establish a precedent for the weighting of summer gasoline (Region 1 plus Region 2 gasoline) and winter gasoline of 39.6 %, and 60.4 %, respectively, representing a national average gasoline volume split between the two seasons. The annual average baseline fuel parameters and emissions given in  80.91(c)(5) were calculated on the basis of this 39.6 to 60.4 summer to winter ratio. In addition, this same ratio was used in generating the complying simple model reformulated gasolines given in Section IV.H of the preamble to the Final Rule, subsequently evaluated under the complex model to determine the Phase I standards under  80.41(c) and (d). As a result, these weightings also should be used when calculating the applicable standards under the early-use complex model. Thus, in every instance a refiner should use a summer weighting of 39.6 % and a winter weighting is 60.4 %, regardless of the actual portions of a refinery's gasoline that are classified as VOC controlled or non-VOC controlled. The regulations do not contain any precedent for establishing the ratio of summer gasoline that is in the Region 1 versus Region 2 category, however. As a result, under the early complex model a refiner should use the actual volumes of gasoline produced in these summer categories to establish the weighting of summer gasoline in the Region 1 versus Region 2 category. Thus, for example, if the classification of the gasoline produced at Refinery X is 25 % VOC controlled for Region 1, and 75 % VOC controlled for Region 2, the refiner would calculate the weighting of gasoline in the two summer gasoline categories as 9.9 % Region 1 (0.25 X 39.6 = 9.9 %), and 29.7 % Region 2 (0.75 X 39.6 % = 29.7 %). The winter category is given a weighting of 60.4 % in every instance, regardless of the portion of a refinery's gasoline that is classified as winter. The simple model then is used to determine a single aromatics value that, when applied in all three gasoline categories, results in an overall toxics reduction of 16.5 %. In the case of the Refinery X example, this aromatics value is 26.6 vol%, determined as follows: Category of Gasoline Category Weighting (%) Toxics Reduction @ 26.6 vol% aromatics Category Weighting X Toxics Reduction VOC, Region 1 9.9 - 25.1 - 2.5 VOC, Region 2 29.7 - 21.9 - 6.5 Not VOC Controlled 60.4 - 12.4 - 7.5 Total 100 - 16.5 In order to calculate the average standards for VOC, toxics and NOx emissions performance, the emissions are calculated using the complex model for each of the three gasoline categories on the basis of an aromatics value of 26.6 vol%. The average VOC emissions performance standards for Refinery X are the percent changes shown by the complex model runs, as follows: Category of Gasoline Average VOC Standards (% change) VOC Controlled for Region 1 Annual Average Standard -36.79 Per-Gallon Minimum -32.79 VOC Controlled for Region 2 Annual Average Standard -17.19 Per-Gallon Minimum -13.19 In the case of the annual average standards for toxics and NOx, the emission results must be combined using the same seasonal weightings that were used to calculate the annual aromatics value. For Refinery X this calculation is shown as follows: Standard Category of Gasoline Category Weighting (%) Emissions Reduction (% change) Category Weighting X Emissions Reduction (% change) Toxics VOC, Region 1 9.9 -27.76 -2.75 VOC, Region 2 29.7 -24.22 -7.19 Winter 60.4 -13.92 -8.40 Annual Average Toxics Standard -18.35 NOx VOC, Region 1 9.9 -0.44 -0.04 VOC, Region 2 29.7 0.00 0.0 Winter 60.4 -0.07 -0.04 Annual Average NOx Standard -0.08 Per-Gallon NOx Maximum 3.92 2. Question: Under the alternative Simple Model as described in a Question and Answer dated January 22, 1996, segregation of alternative Simple Model and Simple Model RFG is not required. Must conventional gasoline produced under the Simple Model be segregated from conventional gasoline produced under the early Complex Model? Answer: There is no requirement for the segregation of Simple Model and early-use Complex Model conventional gasoline. In addition, the alternative Simple Model approach does not apply to conventional gasoline, so this RFG alternative does not alter the conventional gasoline requirements. 3. Question: In terms of setting standards for reformulated gasoline according to 80.41(j), what is the difference between the early-use Complex Model and the alternative Simple Model approach as described in a Question and Answer dated January 22, 1996? Answer: The process of setting standards for RFG is exactly the same under the early- use Complex Model or the alternative Simple Model. The alternative Simple Model approach requires that a refiner meet standards set under the early-use Complex Model as well as all the standards under the Simple Model, except for the caps on sulfur, olefins, and T90. 4. Question: Under the early-use Complex Model, conventional gasoline compliance is determined only on the basis of exhaust benzene per 80.101(b)(2). The valid range limits given in 80.45(f)(2)(ii) indicate that any conventional gasoline having an olefins content higher than 30 vol% cannot be evaluated with the Complex Model. However, the olefins content of any conventional gasoline evaluated under the early-use Complex Model will have no effect on exhaust benzene because there is no olefins term in the equations for exhaust benzene. Are refiners still required to comply with the valid range limits for olefins for conventional gasoline complying under the early-use Complex Model? Answer: The olefin level of any conventional gasoline complying under the early-use Complex Model play no role in compliance. As a result, the valid range limits for olefins do not apply to conventional gasoline produced under the early-use Complex Model. Note that this answer does not apply to the alternative Simple Model because the alternative Simple Model approach does not apply to conventional gasoline.