There are no sulfur testing requirements downstream of the refiner/importer. However, to meet their affirmative defense to presumptive liability, parties that blend >15 ppm sulfur additives into diesel fuel subject to the 15 ppm sulfur standard must conduct a periodic sampling and sulfur testing program after the additive is added to the fuel (see 40 CFR 80.613(d). Alternative affirmative defense requirements exist for blenders of >15 ppm anti-static additives that are based on a volume accounting reconciliation system (see 40 CFR 80.614).
Question and Answer was originally posted at http://www.epa.gov/otaq/diesel/documents/420b06010.pdf
Should testing at a terminal be done at the rack after injection of any additives?
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