Under the simple model only oxygen and benzene, and RVP in the case of VOC-controlled RFG, will involve downstream EPA testing for enforcement purposes. EPA has not set enforcement tolerances for standards that apply at the refinery or importer level, such as sulfur, T-90, and olefins. Moreover, enforcement tolerances are only appropriate when measuring for per-gallon or min/max standards. Sulfur, olefins and T-90 are averaging standards. Therefore, EPA does not anticipate issuing enforcement tolerances for sulfur, T-90, or olefins.(7/1/94)
Question and Answer was originally posted at http://www.epa.gov/otaq/regs/fuels/rfg/qa/420r03009.pdf
Although min/max standards do not apply to sulfur, olefins and T90, these parameters are regulated for both conventional and RFG. What tolerances will be available for these parameters?
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