We have no intent to do so. The VAR approach was developed for the specific situation of conductivity improver additives where no additive option existed with less than 15 ppm sulfur and the additive was required to be added at the terminal.
Question and Answer was originally posted at http://www.epa.gov/otaq/diesel/documents/420b06010.pdf
Will EPA consider allowing the volume accounting reconciliation (VAR) approach with lubricity additives greater than 15 ppm sulfur?
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