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News to service stations and distributors regarding
ethanol-blended RFG and MTBE-blended RFG
As many of you know, the States of Connecticut and New York have banned
methyl tertiary butyl ether, or MTBE, from gasoline effective January
1, 2004. At that time, it is expected that ethanol blended reformulated
gasoline (RFG) will be sold in these areas. In some cases, ethanol blended
RFG is already being sold in New England. The RFG regulations provide
that “no person may combine any VOC-controlled
reformulated gasoline that is produced using ethanol with VOC-controlled
reformulated gasoline that is produced using any other oxygenate during
the period January 1 through September 15.” See 40 CFR 80.78(a)(8).
This prohibition is in the federal rules to prevent the effect called
commingling, which would result in a more volatile fuel when the two
fuel types are mixed- than either of the fuels separately. This is also
called an RVP “kick” associated with ethanol blends. More
smog causing chemicals would be emitted if the two fuel types are mixed,
resulting in dirtier air. Although the VOC-control period begins on May
1 for upstream parties and June 1 for retailers, this prohibition is
in effect starting in January because refiners may begin their production
and distribution of VOC-controlled RFG as early as January. Again, both ethanol blended VOC-controlled RFG and MTBE blended VOC-controlled
RFG alone can meet the pollution reduction requirements of the RFG program-
it is the mixture of the two blends that causes the problem. This requirement
against mixing pertains to any person who sells gasoline at a service
station, who delivers gasoline to a service station, or any person further
up the gasoline distribution chain. Suppliers and service station owners
who may receive gasoline from Connecticut or New York suppliers should
be aware of this issue. Any upstream party or service station which wants to switch between
ethanol blended VOC-controlled RFG and MTBE blended VOC-controlled RFG
must draw down their tanks sufficiently before switching between blend
types. Any party, including a service station, that changes the service
of a tank to switch between these oxygenate blend types must have a sample
of the new product tested for compliance with the VOC standard before
the product is distributed or sold to consumers. See 40 CFR 80.78(a)(10).
If a party wants to avoid the sampling and testing requirement, it should
wait until after September 15 to switch between these blends. We expect that the ban on MTBE in Connecticut and New York could have
the greatest effect on folks that do business in Massachusetts or Rhode
Island, near the Connecticut border. Presumably, service stations in
Connecticut will only be selling ethanol blended RFG. This ban on MTBE
is currently scheduled to go into effect in January, 2004- but stay informed
of Connecticut and New York legislative activity for any changes. Anyone
who has any questions can contact Bob Judge of EPA in Boston at 617-918-1045.
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