NOTE:

DATE:	January 20, 2010

TO:		Docket EPA-HQ-OAR-2005-0161

FROM:	Jeff Herzog, Mechanical Engineer, U.S. EPA

SUBJECT:	Phone Conversations with Conoco Phillips Regarding EPA’s
Registration Requirements for Manufactures of E85 and on the Composition
of the Gasoline Blendstocks Used to Manufacture E85

July 30, 2009 Conference Call

Participants:

Marla Benechek, Conoco Phillips

Jeff Herzog, EPA

Marla Benechek from Conoco Phillips called me to discuss the existing
EPA requirements for the gasoline used with denatured ethanol to blend
E85 at terminals.  We also discussed EPA requirements related to whether
a terminal operator who blends butane during the manufacture of E85
would be considered as a refiner.  Ms. Benechek related that the
composition of the gasoline used to blend E85 at terminals should not be
required to comply with the RFG and anti-dumping requirements that are
applicable where the terminal is located.  She also related that
terminal operators who blend butane during the manufacture of E85 should
not be considered as refiners by EPA.  Ms Benechek related that the
rationale for Conoco Phillips position on these issues will be detailed
in their formal written comments on the RFS2 proposal.  

August 4, 2009 Conference Call

Participants:

Marla Benechek, Conoco Phillips

Jeff Kodish, EPA

Jeff Herzog, EPA

We discussed EPA’s determination that the gasoline portion of E85 must
comply with the applicable requirements for reformulated or conventional
gasoline.  Ms. Benechek related that she did not necessarily agree that
EPA has sufficient grounds to require that the gasoline used in blending
E85 must be EPA certified gasoline.  

Ms Benechek related that it will likely continue to be necessary to
blend butanes and pentanes during the manufacture of E85 in order to
meet minimum ASTM volatility specifications.  She related that that
there are currently widespread difficulties in manufacturing E85 to meet
minimum ASTM volatility specifications.  ASTM will likely raise the
limit on the amount of hydrocarbons that can be used in manufacturing
E85 to facilitate meeting ASTM volatility specifications.   This is
likely to resolve much of the difficulty in meeting minimum ASTM
volatility specifications.  However, even if these changes to the ASTM
E85 specification are adopted, it will likely continue to be necessary
to blend in high vapor pressure hydrocarbons (such as butane and
pentane) into E85 to meet minimum volatility specifications under some
circumstances.  She related that requiring the high volatility
blendstocks to be considered part of the gasoline used to manufacture
E85 and to require that this mixture meet EPA gasoline certification
specifications would represent an obstacle to the manufacture of E85 in
circumstances where high-volatility blendstocks are needed to meet
minimum E85 volatility specifications. 

