Margo T. Oge "The Debate over Sulfur - EPA's Perspective" World Fuels Conference October 24, 1997 remarks Introduction PLEASURE TO BE HERE AMONG MANY PEOPLE I KNOW AND WORK WITH REGULARLY HONORED TO BE ON DISTINGUISHED PANEL, TALKING ABOUT VERY IMPORTANT TOPIC I WANT TO MAKE IT CLEAR THAT I DON'T HAVE ALL THE ANSWERS FOR YOU ON THIS ISSUE. WHAT I WILL DO, HOWEVER, IS SHARE WITH YOU OUR THINKING TODAY ABOUT THIS ISSUE. IN MY PRESENTATION THIS AFTERNOON, WILL TALK ABOUT: WHY SULFUR IN GASOLINE IS A CONCERN IMPLICATIONS FOR MOBILE SOURCES PROGRAMS STUDIES OF THE EFFECTS OF SULFUR IN GASOLINE HOW WE AT EPA ARE ADDRESSING THIS ISSUE Why Is Sulfur in Gasoline a Concern? FIRST AND FOREMOST, AN AIR QUALITY CONCERN THE LEVEL OF SULFUR IN GASOLINE IN THE UNITED STATES HAS NOT CHANGED SINCE 1970. THE AVERAGE LEVEL IS ABOUT 300 PARTS PER MILLION WITH A RANGE BETWEEN 30ppm AND 1000ppm. THE STATE OF CALIFORNIA HAS SET A 30ppm AVERAGE WITH A CAP OF 80ppm FOR SULFUR IN GASOLINE. INDICATIONS ARE THAT HIGH LEVELS OF SULFUR IN GASOLINE CAN INHIBIT THE PERFORMANCE OF AUTOMOTIVE EMISSION CONTROL TECHNOLOGIES. IT IS REPORTED THAT SULFUR CAN INHIBIT THE CATALYST BY DECREASING THE CONVERSION EFFICIENCY AND LIMITING THE OXYGEN STORAGE CAPACITY (THE MEASURE OF CATALYST PERFORMANCE) THIS CAN LEAD TO CAN LEAD TO INCREASED EMISSIONS OF HYDROCARBONS, NOX, CARBON MONOXIDE, AIR TOXICS, AND PERHAPS PARTICULATE MATTER SULFUR IN GASOLINE CAN HAVE IMPLICATIONS FOR SEVERAL MOBILE SOURCE PROGRAMS, INCLUDING: OBDII NLEV POTENTIAL TIER II STANDARDS, AND PHASE II REFORMULATED GASOLINE OBDII BASED ON RECENT STUDIES DONE BY THE AUTO AND OIL INDUSTRIES, WE HAVE AN UNDERSTANDING OF THE POTENTIAL IMPACTS OF SULFUR IN GASOLINE FOR TIER 0 AND TIER I VEHICLES. ALSO, BASED ON STUDIES DONE BY THE AUTO INDUSTRY, WE BELIEVE THAT, IN GENERAL, SULFUR IN GASOLINE DOES NOT AFFECT THE OPERATION OF OBD SYSTEMS. THERE HAS BEEN A CONCERN THAT SULFUR CAN INTERFERE WITH THE OXYGEN SENSOR- A KEY PART OF OBD SYSTEMS. AND, THERE IS A CONCERN THAT HIGH LEVELS OF SULFUR MAY HAVE AN EFFECT ON HIGH MILEAGE VEHICLES. EPA IS WORKING WITH MANUFACTURERS TO ADDRESS THESE AND OTHER POSSIBILITIES ON CASE-BY-CASE BASIS ALSO, THIS ISSUE IS ADDRESSED UNDER THE RECENT PROPOSAL ON NLEV. NLEV AS YOU KNOW, WE RECENTLY PUBLISHED A SUPPLEMENTAL NOTICE OF PROPOSED RULEMAKING ON NLEV. THE ISSUE OF SULFUR IN GASOLINE HAS COME UP DURING THE NLEV DELIBERATIONS. WHILE WE KNOW THE EFFECTS ON TIER 0 AND TIER I VEHICLES, MOST OF AVAILABLE DATA ON NLEV VEHICLES IS ANECDOTAL AND THEREFORE NOT ADEQUATE. MANUFACTURERS HAVE IDENTIFIED SEVERAL CONCERNS REGARDING THE OPERATION OF NLEVS IN RELATION TO SULFUR IN GASOLINE, INCLUDING OBD HIGHER EMISSIONS WE HAVE MADE A COMMITMENT TO PUT TOGETHER A MULTI-STAKEHOLDER PROCESS TO ASSESS THIS. Phase II Reformulated Gasoline Program FEDERAL PHASE II REFORMULATED GASOLINE WILL LIKELY RESULT IN LOWER SULFUR LEVELS IN GASOLINE. AS YOU KNOW, IN 2000, PHASE II RFG WILL BE IMPLEMENTED. THIS NEW FUEL WILL RESULT IN ABOUT 7% OF NOx REDUCTION IT IS BELIEVED THAT THIS NEW REQUIREMENT WILL REDUCE SULFUR LEVELS IN FEDERAL RFG. NO SULFUR REDUCTION IS REQUIRED, SO LEVEL OF CONTROL WILL VARY BY REFINER AND REFINERY, BUT AREAS WITH WORST AIR QUALITY PROBLEMS SHOULD SEE SOME SULFUR REDUCTIONS EPA's Study of Gasoline Sulfur AS YOU KNOW, EPA IS REQUIRED UNDER THE CLEAN AIR ACT TO ASSESS THE NEED FOR ADDITIONAL EMISSION CONTROLS FROM LIGHT DUTY VEHICLES AND LIGHT DUTY TRUCKS. THIS IS THE TIER II STUDY. AS WE CONSIDER THE NEED FOR AND TECHNOLOGICAL OPTIONS FOR ADDITIONAL EMISSION CONTROLS, THE ROLE OF SULFUR IN GASOLINE WILL BE CONSIDERED. WE BELIEVE THE EXISTING DATA IS INSUFFICIENT TO IDENTIFY HOW EMISSIONS VARY WITH SULFUR MANY PREVIOUS TEST PROGRAMS ONLY FOCUS ON EXTREMES (e.g., 30ppm vs. 900ppm) UNACCEPTABLE SULFUR LEVEL MAY VARY WITH TECHNOLOGY DATA SEEN THUS FAR SHOWS SUBSTANTIAL VARIATION AMONG VEHICLES TO OBTAIN ADDITIONAL DATA, THE AGENCY SOLICITED OIL AND AUTO INDUSTRIES' HELP AS RESULT, TWO TEST PROGRAMS CURRENTLY UNDERWAY DOMESTIC AND FOREIGN AUTO MANUFACTURERS (AAMA & AIAM) JOINTLY EVALUATING EMISSIONS PERFORMANCE OF TEN DIFFERENT PROTOTYPE LEV VEHICLES AT DIFFERING SULFUR LEVELS TO SIMULATE EMISSION IMPACTS OF SULFUR IN GASOLINE ACROSS THE COUNTRY SECOND TEST PROGRAM JOINTLY LED BY AUTO AND OIL COMPANIES, WITH EPA PARTICIPATION, UNDER COORDINATING RESEARCH COUNCIL TESTING CALIFORNIA CERTIFIED LEVS AT DIFFERENT SULFUR LEVELS RESULTS OF TWO TEST PROGRAMS AVAILABLE LATER THIS YEAR AS PART OF OUR OVERALL EFFORTS WE WILL CONSIDER THE FOLLOWING: GASOLINE SULFUR IMPACT ON EMISSIONS FOR LEV AND POTENTIAL TIER II COSTS/FEASIBILITY/EMISSIONS PERFORMANCE OF MORE SULFUR- RESISTANT EMISSION CONTROL TECHNOLOGIES COST TO CONTROL IN-USE SULFUR LEVELS IF GASOLINE SULFUR REDUCTION IS DEEMED APPROPRIATE, WE WILL ALSO ADDRESS IF WE SHOULD: CONTROL SULFUR ONLY FOR TIER 2 VEHICLES, OR FOR ENTIRE FLEET? AND IF WE SHOULD APPLY CONTROLS TO ALL FUEL NATIONWIDE, OR JUST TO CERTAIN REGIONS? DEPENDING ON THE FINDINGS OF STUDY, RULEMAKINGS MAY BE INITIATED LATE IN 1998 WE ARE ALSO CONTINUING OUR DIALOG WITH OTAG PARTICIPANTS, OTC, AND OTHER CONCERNED PARTIES WHO HAVE EXPRESSED DESIRE FOR SOME LEVEL OF GASOLINE SULFUR CONTROL Conclusion IF EPA DECIDES THERE IS ENOUGH DATA TO SUPPORT SULFUR CONTROLS, EITHER FOR FUTURE VEHICLE STANDARDS OR THE CURRENT FLEET, AGENCY WILL CONVENE MULTI-STAKEHOLDER PROCESS TO DETERMINE MOST COST-EFFECTIVE AND APPROPRIATE STRATEGY TO EXPLORE ANY REMAINING QUESTIONS OR TO IDENTIFY APPROPRIATE MITIGATION STRATEGIES SUCH A PROCESS WOULD LIKELY BEGIN NEXT YEAR, AFTER RELEASE OF TIER 2 STUDY IF SULFUR CONTROL PROGRAM INDICATED, RULEMAKING WILL LIKELY PROCEED ON SIMILAR TRACK PLEASURE TO BE HERE TODAY LOOK FORWARD TO WORKING WITH MANY IN AUDIENCE TODAY ON THIS IMPORTANT ISSUE