
                 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                NATIONAL VEHICLE AND FUEL EMISSIONS LABORATORY
                             2000 TRAVERWOOD DRIVE
                           ANN ARBOR, MI  48105-2498
							     OFFICE OF
							AIR AND RADIATION
April 30, 2013

MEMORANDUM

SUBJECT:  	Meeting with American Petroleum Institute (API) Test Methodologies Workgroup

FROM:	Joe Sopata, Chemist
		USEPA/OAR/OTAQ/CD/FCC

THROUGH:	John Weihrauch, Center Director
		USEPA/OAR/OTAQ/CD/FCC

TO:  		EPA Docket # EPA-HQ-OAR-2011-0135


This memo documents a meeting held on April 18, 2013 between representatives of API Test Methodologies Workgroup and the United States Environmental Protection Agency (EPA) to discuss EPA's Performance Based Analytical Test Method Approach (PBATMA)  included in the proposed rule entitled, "Control of Air Pollution from Motor Vehicles: Tier 3 Motor Vehicle Emission and Fuel Standards" (Tier 3).  The meeting attendees from API Test Methodologies Workgroup included David Lax (API), Frank Disanzo, (Exxonmobil), Kathryn Brtko (BP), Janice Raburn (BP), Kishore Nadkarni, Barbara Schroeder (Shell), Richard Stanley (RMS Statistics), Al Verstuyft (Al Verstuyft Consulting), Alex Lau (TCL-Consulting), John Rizzo (Marathon Petroleum), Peg Broughton (Marathon Petroleum), and from EPA included Joe Sopata and John Weihrauch.

The PBATMA discussion topics included background, proposed qualification criterion, statistical quality control requirements, implementation dates and Agency approval options which are presented in detail the preamble and regulations of the Tier 3 proposal.  The API Test Methodologies Workgroup requested that EPA provide flow chart examples of qualification requirements for Absolute Fuel Parameters and Method Defined Fuel Parameters.  These flowcharts are attached.  These flow charts are not intended to cover all aspects of the Performance Based Analytical Test Method Approach proposed requirements.  EPA encourages review of both the preamble and regulations for details on the PBATMA proposal not covered in these flow charts. 

Flow Chart Example: Absolute Fuel Parameter (Absolute) - Sulfur in Gasoline 
Note: EPA proposes that fuel parameters categorized as "Absolute" are sulfur in gasoline and sulfur in butane (VCSB  -  Voluntary Consensus Standards Body)

Precision - the maximum allowable standard deviation of 20 test results on a 10 ppm gasoline would be 0.95 ppm.
Accuracy  -  the average of 10 consecutive results on a 1-10 ppm gravimetric sulfur standard cannot be more than 0.71 ppm and the average of 10 consecutive results on a 10-20 ppm gravimetric sulfur standard cannot more than 1.00 ppm

Method Qualified

Is Alternative Test Method a Voluntary Consensus Standard Body (VCSB Method)?


				YES									YES
															
                                                                                                            
                                                                                                            


															
		NO
					          NO							           	         
Lab determines if ASTM D6708 reveals that sample-specific biases cannot be determined as random?


														Method Disqualified
			      NO																	
							




		
 Method Disqualified.
	YES Flow Chart Example: Method-Defined Fuel Parameter (Method-Defined) Aromatics in Gasoline: Note: EPA proposes that all other fuel parameters besides sulfur in gasoline and sulfur in butane currently designated in our gasoline and diesel fuel programs are Method-Defined  (VCSB  -  Voluntary Consensus Standards Body)

Obtain use of a Reference Installation of Designated Test Method (DM):
1) DM near middle distribution of industry monthly inter-laboratory crosscheck program.
2) DM has been shown to be in statistical control. 
(Both for 5 months)

Is Alternative Test Method a Voluntary Consensus Standard Body (VCSB) Method?

	Precision - the maximum allowable standard deviation of 20 test results on a 32 volume percent aromatics gasoline would be 0.70 volume percent
                                                
Same as ** but Lab also determines if the cross method reproducibility (Rcm) is <= 70% of published R of DM.

VCSB determines if use of ASTM D6708 yields a null result compared to designated test method (DM)?(**)
Method Disqualified.
VCSB uses ASTM D6708 to determine correlation equation to DM.
Use Alternative Test Method result w/o correlation.					
Lab determines if ASTM D6708 reveals that sample-specific biases cannot be determined as random?

																																																																																																							YES			NO																																																																																																																																								YES		NO				YES			NO																																			 

