Multi-functional additive packages that contain a >15 ppm anti-static additive and/or red dye may use the VAR method. However, the other components in the additive package must be <15 ppm. If any component of a multi-functional additive package other than red dye or an anti-stat is >15 ppm, then the VAR method may not be used (§ 80.614). However, if the entire package is under 15 ppm, then the VAR method is not required.
This question and answer was originally posted on http://www.epa.gov/otaq/diesel/documents/420b06010.pdf.
The anti-static additive sulfur contribution to ULSD will be resolved and tracked through VAR. All other non-complying additives will require analysis. We have been asked by some customers to acquire the anti-stat additive and blend it into packages they
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