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Gasoline Risk Management: A Compendium of Regulations, Standards, and Industry Practices

July 2014
Regulatory Toxicology and Pharmacology 70(2)

DOI:10.1016/j.yrtph.2014.06.022

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PubMed

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This paper is part of a special series of publications regarding gasoline toxicology testing and gasoline risk management; this article covers regulations, standards, and industry practices concerning gasoline risk management. Gasoline is one of the highest volume liquid fuel products produced globally. In the U.S., gasoline production in 2013 was the highest on record (API, 2013). Regulations such as those pursuant to the Clean Air Act (CAA) (Clean Air Act, 2012: § 7401, et seq.) and many others provide the U.S. federal government with extensive authority to regulate gasoline composition, manufacture, storage, transportation and distribution practices, worker and consumer exposure, product labeling, and emissions from engines and other sources designed to operate on this fuel. The entire gasoline lifecycle-from manufacture, through distribution, to end-use-is subject to detailed, complex, and overlapping regulatory schemes intended to protect human health, welfare, and the environment. In addition to these legal requirements, industry has implemented a broad array of voluntary standards and best management practices to ensure that risks from gasoline manufacturing, distribution, and use are minimized.

Threshold limit values for typical gasoline constituents.

…

The gasoline lifecycle.

…

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Available via license: CC BY-NC-ND 3.0

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Gasoline risk management: A compendium of regulations, standards,

and industry practices

Derek Swick

⇑

, Andrew Jaques

, J.C. Walker

, Herb Estreicher

American Petroleum Institute, 1220 L Street, N.W., Washington, DC 20005, United States

RegNet, 1250 Connecticut Avenue, N.W., Suite 700, Washington, DC 20036, United States

Keller and Heckman LLP, 1001 G Street, N.W., Suite 500W, Washington, DC 20001, United States

article info

Article history:

Available online 1 July 2014

Keywords:

Gasoline regulation

Risk management

Voluntary standards

Best management practices

Gasoline lifecycle

abstract

This paper is part of a special series of publications regarding gasoline toxicology testing and gasoline risk

management; this article covers regulations, standards, and industry practices concerning gasoline risk

management. Gasoline is one of the highest volume liquid fuel products produced globally. In the U.S.,

gasoline production in 2013 was the highest on record (API, 2013). Regulations such as those pursuant

to the Clean Air Act (CAA) (Clean Air Act, 2012: § 7401, et seq.) and many others provide the U.S. federal

government with extensive authority to regulate gasoline composition, manufacture, storage, transpor-

tation and distribution practices, worker and consumer exposure, product labeling, and emissions from

engines and other sources designed to operate on this fuel. The entire gasoline lifecycle—from manufac-

ture, through distribution, to end-use—is subject to detailed, complex, and overlapping regulatory

schemes intended to protect human health, welfare, and the environment. In addition to these legal

requirements, industry has implemented a broad array of voluntary standards and best management

practices to ensure that risks from gasoline manufacturing, distribution, and use are minimized.

Ó 2014 The Authors. Published by Elsevier Inc. This is an open access article under the CC BY-NC-ND

license (http://creativecommons.org/licenses/by-nc-nd/3.0/).

1. Introduction

Gasoline is a liquid fuel intended for use in spark-ignition,

internal combustion engines and the U.S., gasoline production in

2013 was the highest on record (API, 2013). It is typically composed

of hundreds of parafﬁnic, oleﬁnic, naphthenic and aromatic hydro-

carbons (generally referred to as PONA) reﬁned from petroleum

(crude oil) in the C4–C12 carbon-chain length range (API, 2008).

In addition to the hydrocarbon base, gasoline also can contain a vari-

ety of blending components, such as oxygenates (e.g., alcohols,

ethers). During gasoline manufacture, crude oil is fractionated, the

fractions are chemically modiﬁed, and resulting reﬁnery process

‘‘streams’’ are blended to meet speciﬁc physical and chemical prop-

erty requirements (e.g., octane rating, sulfur limits, oxygen content,

etc.), which comply with government regulations and industry per-

formance and quality speciﬁcations. The property requirements, in

turn, inﬂuence the chemical composition of gasoline.

This article summarizes current U.S. risk management measures

for gasoline at selected stages in its lifecycle (see Fig. 1)—from the

point where the gasoline is produced at a reﬁnery, through its

delivery at the retail station pump, and concluding with its use

as a motor fuel. It highlights both regulatory controls and current

industry standards and practices during the lifecycle. The start

and end points chosen for this analysis are appropriate for evaluat-

ing gasoline risk management from the viewpoint of a chemical

regulatory framework. Accordingly, this analysis focuses on the

management of gasoline, including:

 Registration requirements, including testing and formulation

requirements, for gasoline, its components and additives;

 Controlling potential safety and environmental risks from gaso-

line during reﬁning and distribution operations;

 Hazard communication and protecting occupational safety and

health during manufacturing and handling operations; and

 Controlling potential risks of gasoline to end-users/consumers.

2. Regulation of gasoline and gasoline additives

Federal regulations administered by the U.S. Environmental

Protection Agency (EPA) control the constituents in gasoline and

the gasoline additives in order to minimize the environmental

and public health consequences, and ensure proper performance

when used as a motor fuel. Gasoline regulations may require the

reduction of certain constituents (e.g., benzene) during reﬁning,

http://dx.doi.org/10.1016/j.yrtph.2014.06.022

0273-2300/Ó 2014 The Authors. Published by Elsevier Inc.

This is an open access article under the CC BY-NC-ND license (http://creativecommons.org/licenses/by-nc-nd/3.0/).

⇑

Corresponding author.

E-mail addresses: swickd@api.org (D. Swick), ajaques@regnet.com (A. Jaques),

walker@khlaw.com (J.C. Walker), estreicher@khlaw.com (H. Estreicher).

Regulatory Toxicology and Pharmacology 70 (2014) S80–S92

Contents lists available at ScienceDirect

Regulatory Toxicology and Pharmacology

journal homepage: www.elsevier.com/locate/yrtph

or the inclusion of oxygenates and additives, such as detergents,

prior to retail sale. Individual states may impose further, more

stringent controls to address local air quality concerns. As a result

of these layered requirements, the range of gasoline and additive

formulations available for manufacture, distribution, and use is

strictly controlled.

In addition to government regulations, industry contracting and

purchasing speciﬁcations generally require that gasoline meet

third-party voluntary performance and quality standards, such as

those developed by the American Society for Testing and Materials

(ASTM) International. As some standards are incorporated into

state fuel quality regulations, these third-party standards effec-

tively are mandatory. As gasoline must be used in, and subjected

to, a wide variety of mechanical, physical, and chemical environ-

ments, its formulation must provide satisfactory engine perfor-

mance over a wide range of operating conditions.

The Clean Air Act (CAA) (Clean Air Act, 2012: § 7401, et seq.)is

the primary mechanism by which EPA may seek to ‘‘control or pro-

hibit the manufacture, introduction into commerce, offering for

sale, or sale’’ of any motor vehicle or non-road engine fuel or fuel

additive if, in its judgment and after considering the available sci-

entiﬁc and economic data, the Agency determines that a fuel, fuel

additive, or their emissions could endanger public health or impair

the operation of motor vehicle emission control devices (Clean Air

Act, 2012: § 7545(c)). The CAA speciﬁes criteria that gasoline must

meet prior to retail sale, and prohibits the presence or use of cer-

tain constituents and mandates the addition of others to ensure

gasoline presents minimal impact on human health and the

environment.

EPA effectuates this mandate through its implementing ‘‘Fuels

Regulations’’ found at 40 C.F.R., Parts 79 and 80. Any manufacturer

or importer seeking to introduce gasoline or gasoline additives into

commerce must ﬁrst register the product with the Agency.

Depending on the type and nature of the gasoline or additive, the

Agency may require an extensive battery of environmental fate

and human effects testing as part of the registration process. In

addition to the fuel registration requirements, over time EPA has

regulated the properties of gasoline and gasoline additives in a

number of ways such as the following (all of which are discussed

in greater detail in Section 2.2):

 Banning the use of lead-containing additives in automotive

gasoline;

 Requiring the use of detergent additives to prevent engine

deposits;

 Regulating volatility (vapor pressure) to reduce evaporative

emissions from gasoline;

 Limiting the average and maximum sulfur content of gasoline;

 Limiting the average and maximum benzene content of

gasoline;

 Requiring the use of reformulated gasoline (RFG) in certain geo-

graphic areas; and

 Setting anti-dumping requirements that limit emissions of

speciﬁed pollutants from gasoline.

2.1. Testing requirements for registration

Companies seeking to register gasoline or gasoline additives

into U.S. commerce must submit to EPA a chemical description of

their product, as well as technical, marketing, and health-effects

information (Registration of Fuels and Fuel Additives, 2013: §

79.51). This information is intended to allow EPA to determine

the likely combustion products and other emissions that may be

released into the environment during the distribution, sale, and

Fig. 1. The gasoline lifecycle.

D. Swick et al. / Regulatory Toxicology and Pharmacology 70 (2014) S80–S92

S81

use of the gasoline or additive. Speciﬁcally, all registrants must

provide basic registration data, including product and manufac-

turer identiﬁcation, intended use and concentration, and the spe-

ciﬁc composition of the product. In addition, the registrant must

provide EPA with information on the product’s distribution and

use proﬁle, including data on total annual production and market-

ing distribution (Registration of Fuels and Fuel Additives, 2013: §

79.59(b)). Beyond the basic registration data, the Agency’s infor-

mation requirements follow a three-tiered approach. The ﬁrst

two tiers generally apply to most gasoline and gasoline additive

manufacturers with limited exceptions for certain specialized

additives and small businesses.

As part of the Tier 1 data requirements, gasoline and additive

manufacturers must submit to EPA the identity and concentration

of certain emission products and any available information on

health and welfare effects from exposure to the whole and speciat-

ed emissions from the gasoline or additive to be registered

(Registration of Fuels and Fuel Additives, 2013: § 79.52). Tier 1 data

requirements include both literature and health effects database

searches, as well as emissions characterization data. The literature

and database searches should provide to EPA all the information

available on the product, including the chemical composition and

potential adverse effects of the whole combustion and evaporative

emissions, relevant combustion emission fractions, as well as the

individual emission products. The search must extend back at least

30 years before the registration application, and also must capture

data on ‘‘welfare’’ effects such as plant and animal responses to the

emissions exposures.

For Tier 1, gasoline and additive manufacturers also must sub-

mit to EPA information characterizing emissions from the evapora-

tion and combustion of gasoline or the additive/gasoline mixture in

a motor vehicle. Manufacturers are responsible for generating, col-

lecting, and sampling the combustion emissions and, if applicable,

the evaporative emissions of their product, and to determine the

identity and concentration of individual emission products. This

includes characterizing:

 combustion emissions, by determining the concentration of

total hydrocarbons, carbon monoxide, nitrogen oxides (NO

and particulates;

 total evaporative hydrocarbon emissions;

 individual volatile hydrocarbon compound species, aldehydes,

ketones, alcohols, ethers, polycyclic aromatic hydrocarbon

(PAH) compounds, and nitrated polycyclic aromatic hydrocar-

bon (NPAH) compounds, as deﬁned in 40 C.F.R. § 79.52 (b)); and

 semi-volatile and particulate phases of combustion emissions to

identify concentrations of PAH detected to 0.001 micrograms,

and poly-chlorinated dibenzodioxins and dibenzofurans

(PCDD/PCDFs) detected to one part per trillion (ppt) in the air

of the combustion emissions.

Manufacturers may rely on existing characterizations in lieu of

conducting new tests provided that the data were obtained from

tests of either the product in question or a gasoline or gasoline/

additive mixture that meets the grouping criteria as deﬁned in

40 C.F.R. § 79.56. The existing characterization information also

must have been generated with the use of laboratory practices that

are of high quality (per 40 C.F.R. § 79.52 (b)) and properly docu-

mented, also per the procedures set out in 40 C.F.R. § 79.52 (b).

Manufacturers must submit Tier 2 data, if they determine that

the Tier 1 literature and data searches have failed to yield compara-

ble existing information (as deﬁned in the rule) from previously per-

formed studies. EPA retains ﬁnal authority to determine whether the

Tier 1 data are adequate based on criteria set out in the rule, includ-

ing the age of the literature search data, as well as the scope and

quality of the prior studies. The Tier 2 data must be obtained through

testing designed to detect potential adverse health effects from the

inhalation of gasoline or gasoline/additive emissions. This generally

involves producing emissions from a vehicle or engine in a labora-

tory setting, exposing laboratory test animals to these whole emis-

sions, and conducting a 90-day subchronic inhalation study to

examine general systemic and organ toxicity, including pulmonary

effects (Registration of Fuels and Fuel Additives, 2013: § 79.53).

Ancillary tests that allow the assessment of several speciﬁc health

effect endpoints (carcinogenicity, mutagenicity, teratogenicity,

reproductive toxicity, and neurotoxicity) also may be conducted

within the same exposure schedule. In addition, a fertility assess-

ment also may be coordinated within the same time frame in order

to assess reproductive and teratogenic effects.

Following the submission of Tier 1 and Tier 2 data, EPA may at its

discretion require gasoline and additive manufacturers to conduct

additional health-effects testing if the Agency determines that

remaining uncertainties concerning the signiﬁcance of observed

health effects, welfare effects, and/or emissions exposures prevent

it from reasonably estimating the potential risks of exposure from

the gasoline or additive (Registration of Fuels and Fuel Additives,

2013: § 79.54). These may include additional carcinogenicity, repro-

ductive, and neurotoxicity tests. The Agency may also require the

submission of additional technical and marketing information. The

purpose of these submissions is to ensure that EPA has a comprehen-

sive suite of information on the likely effects from the evaporation or

combustion of gasoline and gasoline additives. In addition to the

health-effects data and testing requirements under the Fuel and Fuel

Additives Registration Program, EPA also requires manufacturers to

submit a quarterly and annual report on gasoline and additive pro-

duction volumes and the concentration range of each additive used

in a designated fuel in order to maintain their registration(s)

(Registration of Fuels and Fuel Additives, 2013: § 79.5).

A public website is being created that will permit viewing of the

reports submitted to EPA under the CAA 211(b) registration pro-

gram. That website address will be www.211bResearchGroup.org.

These reports can also be accessed at Regulations.gov with Docket

ID Number: EPA-HQ-OAR-2003-0065.

2.2. Physical, chemical and emission standards

Section 211 of the CAA directs EPA to implement speciﬁc

numerical limitations on particular gasoline components and

physical and emission properties to further address health and

environmental risks. EPA has codiﬁed these standards at 40 C.F.R,

Part 80. Part 80 establishes protective limitations and conditions

for gasoline and gasoline/additive mixtures, as well as recordkeep-

ing and reporting requirements.

Subpart B of Part 80 prohibits the introduction of leaded auto-

motive gasoline into U.S. commerce and establishes controls con-

cerning certain measures of gasoline volatility (Regulation of

Fuels and Fuel Additives, 2013: §§ 80.22–80.33).

Volatility is a property of a liquid fuel that inﬂuences its evap-

orative characteristics. EPA limits the Reid Vapor Pressure (RVP)

of gasoline introduced into commerce during the Summer months

in order to reduce evaporative emissions of volatile organic

compounds (VOCs)

that contribute to ground-level ozone

(Volatility Regulations for Gasoline and Alcohol Blends Sold in

Calendar Years 1992 and Beyond, 1990: 23,658).

Section 211(k) requires cities classiﬁed as ‘‘severe’’ with respect

to non-attainment of the ozone national ambient air quality stan-

40 C FR § 51.100(s) deﬁnes ‘‘vol atile organic compound s (VOCs)’’ as any

compound of carbon, excluding carbon monoxide, carbon dioxide, carbonic acid,

metallic carbides or carbonates, and ammonium carbonate, whi ch participates in

atmospheric photochemical reactions. Further to the deﬁnition, there is a list of

speciﬁc chemicals exempt from the VOC deﬁnition because they have ‘‘negligible

photochemical reactivity.’’

S82 D. Swick et al. / Regulatory Toxicology and Pharmacology 70 (2014) S80–S92

dard to use reformulated gasoline (RFG). Until 2006, RFG needed to

contain a minimum of 2.0% oxygen by weight. Reﬁners typically

used ethanol or methyl tertiary-butyl ether (MTBE) as oxygenates.

Congress amended Section 211(k) of the Act to eliminate the oxy-

genate content requirement for RFG (Energy Policy Act, 2012: §§

1502–1504).

The Antidumping

Program under Subpart E sets limits on con-

ventional (i.e., non-reformulated) gasoline emissions of nitrogen oxi-

des (NO

), benzene, and toxic air pollutants

(Regulation of Fuels and

Fuel Additives, 2013: §§ 80.90–80.106). NO

emission reductions

abate adverse respiratory effects and the formation of ground-level

ozone and particulate matter (PM) (USEPA, 2010). Most of the stan-

dards established under the Antidumping Program have been

replaced by newer programs.

Subpart F ensures the integrity of reports submitted under the

regulations by requiring attestation of these reports by an indepen-

dent certiﬁed public accountant or an internal auditor certiﬁed by

the Institute of Internal Auditors (Regulation of Fuels and Fuel

Additives, 2013: §§ 80.125–80.133). Subpart G sets forth require-

ments for adding detergent to gasoline. Detergent additives prevent

the formation and accumulation of deposits in engines and fuel sup-

ply systems, which has been shown to reduce NO

, hydrocarbon, and

carbon monoxide emissions in engine exhaust, while enhancing fuel

economy (Regulation of Fuels and Fuel Additives: Certiﬁcation

Standards for Deposit Control Gasoline Additives, 1996: 35,310).

Subpart H phased in increasingly stringent gasoline sulfur con-

tent limitations and implements a Sulfur Credit

Trading Program

(Regulation of Fuels and Fuel Additives, 2013: §§ 80.180–80.415).

The regulations currently prohibit reﬁneries from producing refor-

mulated or conventional gasoline containing sulfur in excess of

80 ppm (ppm) for any single gallon of gasoline produced and a

30 ppm limit on sulfur in gasoline on an average annual basis

(Regulation of Fuels and Fuel Additives, 2013: § 80.195). EPA esti-

mated that the program resulted in a 90% reduction of average

national levels of sulfur in gasoline by 2006 (USEPA, 2014). EPA also

estimated that limiting the level of sulfur in gasoline to 30 ppm

would result in about 700,000 tons of NO

reductions per year from

light duty vehicles and trucks by 2020 (Control of Air Pollution From

New Motor Vehicles: Tier 2 Motor Vehicle Emissions Standards and

Gasoline Sulfur Control Requirements, 2000: 6730). In April 2014,

EPA promulgated a ﬁnal rule with additional (Tier 3) regulations

on gasoline to limit annual average gasoline sulfur content to

10 ppm (Control of Air Pollution From Motor Vehicles: Tier 3

Motor Vehicle Emission and Fuel Standards, 2014: 23,414).

The Benzene Control Program of Subpart L establishes benzene

concentration limits in gasoline supported by a benzene credit

trading program (Regulation of Fuels and Fuel Additives, 2013:

§§ 80.1200–1363). Beginning January 1, 2011, reﬁners had to limit

the benzene content in reformulated and conventional gasoline to

an annual average of 0.62% by volume in the ﬁnished gasoline.

Additionally, starting July 1, 2012, a reﬁnery’s annual average ben-

zene concentration must not exceed 1.3% by volume, without the

use of benzene credits

(Regulation of Fuels and Fuel Additives,

2013: § 80.1230). EPA estimates that these limits will reduce total

benzene emissions from on-road and off-road mobile sources, porta-

ble fuel containers and gasoline distribution approximately 12% by

2015 (Control of Hazardous Air Pollutants From Mobile Sources,

2007: 8454). EPA expects the benzene and sulfur content limits of

Subparts H and L to provide greater air toxics reductions than under

the RFG and Antidumping Programs (Control of Hazardous Air

Pollutants From Mobile Sources, 2007: 8477). As a result, and effec-

tive January 1, 2011, these requirements replaced the annual average

toxics emission requirements of the RFG and Antidumping Programs

and the annual average benzene content limit of the RFG Program

(Control of Hazardous Air Pollutants From Mobile Sources, 2007:

8477 and Regulation of Fuels and Fuel Additives, 2013: §

80.815(d)(1)(ii)). The Benzene Control Program requirements also

replaced the Mobile Source Air Toxics (MSAT) Program for most gas-

oline blends, including conventional and reformulated gasoline

(Control of Hazardous Air Pollutants From Mobile Sources, 2007:

8477).

3. Regulation of gasoline manufacture at the reﬁnery

Gasoline manufacturing operations are subject to stringent

environmental control regulations enacted under the major envi-

ronmental statutes such as the Clean Air Act (CAA) (Clean Air

Act, 2012: § 7401, et seq.) and the Clean Water Act (CWA) (Clean

Water Act, 2012: § 1251, et seq.). These regulations govern various

emission and discharge sources within the reﬁning operations. The

CAA signiﬁcantly restricts reﬁnery emissions to the atmosphere of

harmful air pollutants, and the CWA protects human health and

the environment against risks stemming from intentional and

inadvertent discharges to water from reﬁneries. Regulations codi-

ﬁed by EPA under these statutes impose signiﬁcant testing, record-

keeping, and reporting requirements to ensure and demonstrate

compliance.

3.1. Regulation of reﬁnery emissions to air

Two regulatory schemes under the CAA regulate reﬁnery emis-

sions to the atmosphere. New source performance standards

(NSPSs) limit reﬁnery emissions of several ‘‘criteria pollutants,’’

including volatile organic compounds (VOCs), sulfur oxides, PM,

CO and NO

. Additionally, national emission standards for hazard-

ous air pollutants (NESHAPs) control reﬁnery emissions of ‘‘haz-

ardous air pollutants’’ (HAPs).

3.1.1. New source performance standards

Section 111 of the CAA requires EPA to establish New Source

Performance Standards (NSPSs) for new and modiﬁed stationary

sources within particular industrial categories to control emissions

of criteria air pollutants (e.g., ozone, carbon monoxide, particulate

matter, sulfur dioxide, nitrogen dioxide, and lead) (Clean Air Act,

2012: § 7411). EPA has promulgated NSPSs for reﬁnery processing

units and other equipment used at petroleum reﬁneries in order to

limit and control air emissions of criteria pollutants and also emis-

sions of VOCs (including petroleum), which are precursors to the

formation of ozone in the atmosphere. Below the NSPSs for reﬁnery

processing units are provided as an example of these standards.

Petroleum reﬁnery processing units must meet the NSPSs cod-

iﬁed at 40 C.F.R., Part 60, Subparts J and Ja (Standards of

Performance for New Stationary Sources, 2013: §§ 60.100–

60.109a). These regulations include emissions limitations and

work practice standards for ﬂuid catalytic cracking (FCC) units,

ﬂuid coking units, delayed coking units, fuel gas combustion

devices, and sulfur recovery plants. Subpart J applies to certain

‘‘Antidumping’’ in the context of gasoline regulations means not allowing reﬁners

to sell gasoline that is a lower quality (i.e., higher levels of regulated constituents and

emission products) than they had previously sold in those area s were only

conventional gasoline is required.

Under CAA § 211(k)(10), ‘‘toxic air pollutants’’ means the aggregate emissions of

benzene, 1,3-butadiene, polycyclic organic matter, acetaldehyde and formaldehyde.

‘‘Sulfur credit’’ is a concept where a reﬁner that does better than the stated

average requirements for sulfur content in gasoline generates a credit that could be

sold to another reﬁner that cannot meet the requirements. (See 40 CFR, Part 80,

Subpart H-Gasoline Sulfur).

‘‘Benzene Credits’’ is a concept where a reﬁner that does better than the stated

average requirements for benzene content in gasoline generates a credit that could be

sold to another reﬁner that cannot meet the requirements. (See 40 CFR § 80.1275).

D. Swick et al. / Regulatory Toxicology and Pharmacology 70 (2014) S80–S92

S83

reﬁnery equipment constructed, reconstructed, or modiﬁed in var-

ious speciﬁed timeframes.

Under Subpart J, FCC unit catalyst regenerator emissions of PM,

from coke burn-off, cannot exceed 1.0 kilogram/metric ton (kg/MT)

(2.0 lb/ton (lb./ton)) (Standards of Performance for New Stationary

Sources, 2013: § 60.102). Additionally, gases emitted by these units

cannot exhibit greater than 30% opacity or contain CO in excess of

500 ppm (Standards of Performance for New Stationary Sources,

2013: §§ 60.102–60.103).

Subpart J further prohibits the burning, in fuel gas combustion

devices, of fuel gas containing hydrogen sulﬁde in excess of

230 mg/dscm (0.10 gr/dscf) (Standards of Performance for New

Stationary Sources, 2013: § 60.104). To facilitate compliance,

reﬁners must install, calibrate, maintain, and operate continuous

emissions monitoring systems on the regulated equipment

(Standards of Performance for New Stationary Sources, 2013: §

60.105). In 2008, EPA updated the reﬁnery processing unit emis-

sion standards. Subpart Ja prescribes new, more stringent limits

for those reﬁneries constructed, reconstructed or modiﬁed after

May 14, 2007. These standards will further reduce PM emissions

by approximately 1300 tons/year, sulfur dioxide (SO2) emissions

by approximately 17,000 tons/year, NO

emissions by approxi-

mately 11,000 tons/year, and VOC emissions by approximately

200 tons/year (Standards of Performance for Petroleum

Reﬁneries, 2008: 35,861).

3.1.2. National emission standards for hazardous air pollutants

(NESHAPs)

Section 112 of the CAA directs EPA to develop a list of ‘‘major’’ and

‘‘area’’ stationary sources that emit listed HAPs and establish

national emission standards for those sources, known as NESHAPs.

NESHAPs for major sources must reﬂect the maximum achievable

control technology (MACT) available, while NESHAPs for area

sources can reﬂect generally available control technology (Clean

Air Act, 2012: § 112(d)). Major sources include any stationary

source, or group of stationary sources located within a contiguous

area and under common control, that emits or has the potential to

emit at least 10 tons per year of a single HAP or 25 tons/year of

any combination of HAPs (National Emission Standards for

Hazardous Air Pollutants for Source Categories, 2013: § 63.2). Area

sources include stationary sources of HAPs that do not qualify as

major sources.

Petroleum reﬁneries that qualify as major sources must comply

with the NESHAPs codiﬁed at 40 C.F.R., Part 63, Subparts CC and

UUU. The Appendix to Subpart CC lists the HAPs of concern for

reﬁning operations, such as benzene, toluene, ethylbenzene, and

xylenes (BTEX). Together, these NESHAPs require monitoring and

reduction of emissions from process vents, storage vessels, marine

tank vessel loading operations, gasoline loading rack operations,

equipment leaks, and wastewater treatment systems.

For process vents on FCC units, reﬁners can control emissions by

employing a variety of control devices, including cyclones, electro-

static precipitators, and wet scrubbers (National Emission

Standards for Hazardous Air Pollutants for Source Categories,

2013: § 63.1579). For other covered emissions sources, the NES-

HAPs require more speciﬁc control measures. For example, reﬁners

must install vapor collection and processing systems on gasoline

loading racks that will reduce emissions to 10 mg of total organic

compounds per liter of gasoline loaded into cargo tanks (National

Emission Standards for Hazardous Air Pollutants for Source

Categories, 2013: § 63.650). Of course, for all covered emission

sources reﬁners must perform testing, conduct monitoring, main-

tain records, and submit reports to EPA concerning HAPs emission

production and control.

3.2. Regulation of reﬁnery discharges to water

The CWA prohibits unpermitted discharges to waters of the U.S.

from gasoline manufacturing operations. The primary regulatory

regimes applicable to petroleum reﬁneries are the National Pollu-

tant Discharge Elimination System (NPDES) permitting program,

the National Pretreatment Program, and the Oil Pollution Preven-

tion Program.

3.2.1. NPDES permitting program for intentional discharges to

navigable waters

Under Section 402 of the CWA, petroleum reﬁneries must

obtain NPDES permits in order to discharge industrial wastes and

other pollutants from a point source into navigable waters of the

U.S. (i.e., surface waters–Clean Water Act, 2012: § 1342). Note:

Under the CWA, the EPA has the authority to delegate the NPDES

program to states for implementation; in those instances, the state

program operates the permitting program. NPDES permits contain

industry-speciﬁc, technology-based and/or water quality-based

efﬂuent limits and pollutant monitoring and reporting require-

ments. EPA has codiﬁed its technology-based efﬂuent limitations

for the petroleum reﬁning point source category at 40 C.F.R., Part

419 (Petroleum Reﬁning Point Source Category, 2013: §§ 419.10–

419.57).

These regulations specify different efﬂuent discharge limita-

tions (based on production rates) according to the speciﬁc pollu-

tant or pollutant property controlled and reﬁning operation

covered. The controlled pollutants include total suspended solids

(TSS), hexavalent chromium, and phenolic compounds, among oth-

ers. Covered reﬁning operations include topping, cracking, lube oil

manufacturing processes, and petrochemical operations.

In general, the efﬂuent limitations represent the best available

control technology economically achievable by the petroleum

reﬁning industry. Efﬂuent limitations for new sources are also

more demanding than those applicable to existing sources. When

EPA last amended the efﬂuent limitations for the petroleum reﬁn-

ing point source category, it estimated incremental industry-wide

reductions in discharges of 286,000 lb per year for total chromium,

18,300 lb per year for hexavalent chromium, and 75,000 lb per year

for phenolic compounds (Petroleum Reﬁning Point Source

Category, Efﬂuent Limitations Guidelines, 1985: 28,516 and

28,520).

In addition to efﬂuent guidelines, NPDES permits for reﬁnery

operations include water-quality-based permit limits for dis-

charges to water bodies not meeting ambient water quality stan-

dards. These permit limits for such water bodies are designed to

protect ambient water quality and meet the ambient standards.

3.2.2. National pretreatment program for intentional discharges to

publicly-owned treatment works

In accordance with CWA § 307(b), numerical pretreatment

efﬂuent guidelines apply to discharges from petroleum reﬁneries

to publicly-owned treatment works (POTWs) (Clean Water Act,

2012: § 1317(b)(1)). These technology-based standards are also

codiﬁed at 40 C.F.R., Part 419. Speciﬁcally, a reﬁnery’s total daily

discharge to a POTW cannot contain more than 100 mg/L of oil

and grease and 100 mg/L of ammonia. In addition to these limits,

new sources must not discharge more than 1 mg/L per day of total

chromium to a POTW. In addition to the pretreatment efﬂuent

guidelines, indirect discharge permits for reﬁnery discharges to

POTWs also include local limits developed by the POTW for pre-

vention of pollutant pass-through or interference with POTW

treatment processes, and compliance with POTW sludge disposal

limits. Attainment of its NPDES permit efﬂuent limits often also

apply to reﬁneries.

S84 D. Swick et al. / Regulatory Toxicology and Pharmacology 70 (2014) S80–S92

3.2.3. Oil spill prevention, notiﬁcation, and cleanup

Section 311 of the CWA prohibits the discharge of oil or another

substance determined to be harmful if the amount meets or

exceeds an EPA-designated ‘‘reportable quantity’’ into or upon nav-

igable waters of the U.S. and adjoining shorelines, or the waters of

the contiguous zone, or other speciﬁed waters (Clean Water Act,

2012: § 1321). The oil pollution prevention regulations, codiﬁed

at 40 C.F.R., Part 112, require certain non-transportation-related

facilities to prepare and implement Oil Spill Prevention, Control

and Countermeasure (SPCC) plans. Note that transportation-

related facilities, such as pipelines and common carriers, must pre-

pare oil spill prevention and response plans under separate regula-

tory schemes.

A facility must develop, certify, and implement a SPCC plan if it

has an aggregate aboveground oil storage capacity exceeding 1320

U.S. gallons or a completely buried oil storage capacity exceeding

42,000 U.S. gallons not regulated under federal Underground Stor-

age Tank (UST) regulations and, due to its location, could reason-

ably be expected to discharge oil in quantities that are harmful

into covered waters (Oil Pollution Prevention, 2013: § 112.1). The

regulations cover oil of any type and in any form and mixture,

including petroleum, fuel, sludge, oil refuse, oil mixed with wastes

other than dredged soil, and oils from renewable sources. SPCC

plans must identify the type and location of stored oil and lay

out discharge prevention measures, secondary containment in

the event of a release, discharge or drainage controls, and counter-

measures for discharge discovery, response, and clean-up.

Additionally, under the Oil Pollution Act (OPA) (Oil Pollution

Act, 2012: § 2701, et seq.), facilities covered by the SPCC regula-

tions that pose a threat of substantial harm to covered waters

due to their location and volume of oil storage (over 1 million gal-

lons) must prepare and submit to EPA a Facility Response Plan

(FRP). FRPs are intended to assist in preparing for and responding

to a worst case discharge. Facilities must demonstrate the avail-

ability of response resources in a timely manner, thereby reducing

a discharge’s impact and severity (Oil Pollution Prevention, 2013:

Part 112, Subpart D—Response Requirements). FRPs are also

intended to aid local and regional response authorities to better

understand the potential hazards and response capabilities in their

area. The OPA imposes strict liability on owners and operators of

facilities responsible for oil spills.

4. Risk management in gasoline storage, transportation and

distribution operations

A variety of statutes and industry standards ensure the safe

storage, transportation, and distribution of fuel by establishing

baseline standards for the design and construction of equipment,

imposing strict handling procedures and emissions controls, and

requiring the preparation of hazard warnings and accident preven-

tion plans. These standards serve to protect workers, public health,

and the environment.

4.1. Pipeline safety standards

The federal pipeline safety regulations prescribe a comprehen-

sive scheme of minimum safety standards and reporting require-

ments for pipeline facilities used in the transportation of

‘‘hazardous liquids,’’ including gasoline and other petroleum prod-

ucts. The U.S. Department of Transportation (DOT) promulgated

these regulations, codiﬁed at 49 C.F.R., Part 195, under the Pipeline

Safety Statute (Pipeline Safety Statute, 2012: § 60101, et seq.). The

Pipeline and Hazardous Materials Safety Administration (PHMSA)

within the DOT administers these regulations.

Pipeline facilities must meet performance standards applicable

to the design, construction, testing, and operation and maintenance

of pipeline systems. Design standards, for example, include speciﬁ-

cations for internal and external pipeline pressure, new and used

pipe materials, valves, ﬁttings, and closures (Transportation of

Hazardous Liquids by Pipeline, 2013: §§ 195.100–195.134). Pipe-

line operators must prepare and follow a procedures manual for

conducting normal operations and maintenance activities and han-

dling abnormal operations and emergencies. They must also estab-

lish and conduct a continuing emergency response employee

training program (Transportation of Hazardous Liquids by

Pipeline, 2013: §§ 195.402–195.403). To assure regulatory compli-

ance, pipeline facilities must submit reports on an annual basis and

in the event of an accident or discovery of a ‘‘safety-related condi-

tion,’’ such as general corrosion or leaks (Transportation of

Hazardous Liquids by Pipeline, 2013: §§ 195.48–195.64).

4.2. Hazardous materials regulations

The hazardous materials regulations (HMR) govern the trans-

portation of gasoline and other hazardous materials by highway,

rail, water, and air. These regulations mitigate the risks to life,

property, and the environment inherent in the transportation of

hazardous materials by imposing requirements related to shipping

papers, packaging materials, hazard communication, safe handling,

incident reporting, training, and security. The PHMSA also admin-

isters these regulations, codiﬁed at 49 C.F.R., Parts 105–180, in

accordance with the Hazardous Materials Transportation Act

(Hazardous Materials Transportation Act, 2012: § 5101, et seq.).

The HMR, coupled with the pipeline safety regulations, control

all modes of transportation of fuels.

To ensure appropriate hazard communication, gasoline trans-

porters must afﬁx speciﬁc placards indicating that gasoline is a

class 3 ﬂammable liquid, to each side of a bulk package, freight

container, unit load device, transport vehicle or rail car containing

any quantity of gasoline (Hazardous Materials Table, Special

Provisions, Hazardous Materials Communications, Emergency

Response Information, Training Requirements, and Security Plans,

2013: § 172.542). Additional labeling and marking requirements

apply to gasoline shipments in order to communicate information

such as volume and appropriate handling (Hazardous Materials

Table, Special Provisions, Hazardous Materials Communications,

Emergency Response Information, Training Requirements, and

Security Plans, 2013: §§ 172.300–172.450). The HMR also require

use of speciﬁc packaging materials that depend on whether gaso-

line is transported in bulk or non-bulk form. Bulk gasoline must

be packaged in specialized rail cars or cargo tanks, while non-bulk

gasoline may be packaged in steel or aluminum drums, among

other types of containers (Shippers—General Requirements for

Shipments and Packagings, 2013: §§ 173.202 and 173.242).

In addition, the regulations limit the maximum quantity of gas-

oline on passenger transport modes. Passenger-carrying aircraft or

rail cars cannot transport packages containing more than 5 L of

gasoline, whereas cargo-only aircraft can transport packages con-

taining up to 60 L of gasoline (Hazardous Materials Table, Special

Provisions, Hazardous Materials Communications, Emergency

Response Information, Training Requirements, and Security Plans,

2013: § 172.101 (Hazardous Materials Table)). The regulations pro-

hibit motor vehicles carrying passengers for hire from transporting

any quantity of gasoline, unless no other practicable means of

transportation is available (in which case only a limited quantity

may be transported) (Carriage by Public Highway, 2013: §

177.870).

D. Swick et al. / Regulatory Toxicology and Pharmacology 70 (2014) S80–S92

S85

4.3. Marine occupational safety and health standards

All tank ships and barges carrying benzene or benzene-contain-

ing liquids in bulk must comply with the marine occupational

safety and health standards of 46 C.F.R., Part 197. The regulations

require operators of covered vessels to either ensure adherence

to permissible exposure limits (PELs) for benzene, or require

employees to wear respirators and personal protective clothing

and equipment in areas where the airborne benzene concentration

can reasonably be expected to exceed PELs (General Provisions:

Marine Occupational Safety and Health Standards, 2013: §§

197.515, 197.520, and 197.535).

The regulations set forth benzene PELs of 1.0 ppm, as averaged

over an 8-h period, and 5.0 ppm, as averaged over any 15-min per-

iod (General Provisions: Marine Occupational Safety and Health

Standards, 2013: § 197.505). These PELs mirror those established

by the Occupational Safety and Health Administration (OSHA) for

the on-shore work-place. In addition, employers must provide

information to workers on covered vessels regarding benzene haz-

ards, including a material safety data sheet (MSDS) and training on

benzene risks and protective measures (General Provisions: Marine

Occupational Safety and Health Standards, 2013: § 197.565).

Employers also must provide, and employees exposed to benzene

must submit to, initial and periodic medical examinations. If the

examination demonstrates abnormal health conditions, employers

must remove employees from areas where the airborne benzene

concentration may exceed 0.5 ppm (a concentration lower than

both PELs) (General Provisions: Marine Occupational Safety and

Health Standards, 2013: § 197.560 and Appendix C to Subpart C

of Part 197).

4.4. Chemical accident prevention provisions

Facilities that produce, handle, process, store, or distribute

threshold quantities of toxic or ﬂammable substances listed under

Section 112(r) of the CAA, including various gasoline constituents,

must comply with the chemical accident prevention provisions of

40 C.F.R., Part 68. These provisions aim to prevent accidental

releases of substances that can cause serious harm to the public

and environment from short-term exposures and to mitigate the

severity of releases that do occur.

The regulations require operators of covered facilities to imple-

ment a risk management program. This program involves assessing

the hazards that may result from accidental releases, implement-

ing accident prevention measures, and developing an emergency

response program (Chemical Accident Prevention Provisions,

2013: § 68.12). The centerpiece of the regulations is the prepara-

tion and submission to EPA of a risk management plan (RMP).

The RMP must describe the facility and regulated substances han-

dled, the general accidental release prevention program and chem-

ical-speciﬁc prevention steps, the facility’s 5-year accident history,

the emergency response program, and planned changes to improve

safety (Chemical Accident Prevention Provisions, 2013: §§ 68.150–

68.195).

EPA exempted several substances, when used in certain mix-

tures, from the required threshold quantity determination. Such

an exemption exists for gasoline being stored or distributed for

use as fuel in internal combustion engines (Chemical Accident

Prevention Provisions, 2013: § 68.115(b)(2)(ii)). EPA speciﬁcally

exempted gasoline because the Agency found it generally does

not meet the criteria for a National Fire Protection Association

(NFPA) ﬂammability hazard rating of four (severe hazard), and it

does not represent a signiﬁcant threat to the public of vapor cloud

explosions (List of Regulated Substances and Thresholds for

Accidental Release Prevention, 1998: 640 and 641–642).

4.5. Regulation of air emissions from gasoline distribution and

dispensing facilities

Gasoline distribution and dispensing facilities must also comply

with NSPS and NESHAP emission limitations for criteria and haz-

ardous air pollutants. These standards, together with the NSPSs

and NESHAPs applicable to petroleum reﬁneries (addressed in Sec-

tion 3), control harmful air emissions from nearly every stage of

the gasoline lifecycle.

4.5.1. New source performance standards

Bulk gasoline terminals must meet the NSPS codiﬁed at 40

C.F.R., Part 60, Subpart XX (Standards of Performance for New

Stationary Sources, 2013: §§ 60.500–60.506). These regulations

limit VOC emissions from loading racks used to deliver gasoline

into tank trucks. Speciﬁcally, operators must equip loading racks

with a vapor collection system designed to collect the total organic

compounds (TOC) vapors displaced from tank trucks during prod-

uct loading (Standards of Performance for New Stationary Sources,

2013: § 60.502(a)). Emissions from the vapor collection system

must not exceed 35 mg of TOC per liter of gasoline loaded

(mg TOC/L gasoline), or 80 mg TOC/L gasoline loaded where load-

ing racks are equipped with existing vapor processing systems

(Standards of Performance for New Stationary Sources, 2013: §§

60.502(b)–(c)). In addition, operators must only load gasoline into

vapor-tight gasoline tank trucks (Standards of Performance for

New Stationary Sources, 2013: §§ 60.502(e)). To assure adherence

to this requirement, they must obtain vapor tightness documenta-

tion and follow other speciﬁed procedures. The regulations also

prescribe testing methods, inspection, and recordkeeping and

reporting requirements.

4.5.2. National emission standards for hazardous air pollutants

(NESHAP)

Hazardous air pollutant emission limitations apply to major and

area source gasoline distribution facilities, as well as area source

gasoline dispensing facilities (GDFs).

4.5.2.1. Major source gasoline distribution facilities.

Bulk gasoline

terminals and pipeline facilities that qualify as major sources

under the CAA must comply with emission limits and management

practices set forth at 40 C.F.R., Part 63, Subpart R (National Emis-

sion Standards for Hazardous Air Pollutants for Gasoline Distribu-

tion Facilities, 2013: §§ 63.420–63.429). These requirements apply

to all storage tanks, cargo tanks (railcars and tank trucks), loading

racks, and equipment leaks within the gasoline distribution facil-

ity. Facilities must control VOC emissions from large storage tanks

(i.e., those at or above 20,000 gallons capacity) by installing either

speciﬁed ﬂoating roofs and seals or a closed vent system and con-

trol device reducing emissions by 95% (National Emission

Standards for Hazardous Air Pollutants for Source Categories,

2013: § 63.423 (cross referencing 40 C.F.R. § 60.112(b)–Standards

of Performance for New Stationary Source, 2013)). Total organic

compound emissions from cargo tanks must also be controlled

through use of vapor collection and processing systems and must

not exceed 10 mg TOC/L of gasoline loaded (National Emission

Standards for Hazardous Air Pollutants for Source Categories,

2013: § 63.422(b)). Control efﬁciencies for vapor recovery units

range from 90% to over 99%, depending on both the nature of the

vapors and the type of control equipment used (USEPA, 2008).

EPA has assumed a collection efﬁciency of 99.2% for tank trucks

passing the MACT-level annual leak test; 98.7% for trucks passing

the NSPS-level annual test; and 70% for trucks not passing one of

these required annual leak tests.

S86 D. Swick et al. / Regulatory Toxicology and Pharmacology 70 (2014) S80–S92

4.5.2.2. Area source gasoline terminals, pipeline facilities, and dis-

pensing facilities.

All other facilities in the gasoline distribution net-

work that do not qualify as major sources must comply with the

NESHAP requirements for area sources at 40 C.F.R., Part 63, Sub-

parts BBBBBB and CCCCCC (National Emission Standards for

Hazardous Air Pollutants for Source Categories, 2013: §§

63.11080–63.11132). The former subpart covers bulk gasoline ter-

minals, bulk gasoline plants, pipeline breakout stations and pipe-

line pumping stations, and generally imposes emission limits on

the same operations covered under Subpart R (discussed above).

The latter subpart governs emissions from gasoline dispensing

facilities (GDFs), which include stationary facilities used for dis-

pensing gasoline into the fuel tank of an on-road or off-road vehicle

or vehicle engine (National Emission Standards for Hazardous Air

Pollutants for Source Categories, 2013: § 63.11132). Subpart

CCCCCC limits emissions occurring during the off-loading of gaso-

line from cargo tanks into storage tanks located at a GDF.

State environmental agencies, which normally enforce the

NESHAP regulations, can and do impose even more stringent limits

on these emission sources. For example, many states require the

installation of a vapor balance system between the storage tank

at a GDF and the cargo tank (termed Stage I vapor recovery) (Ill.

Admin. Code, Tit. 35, §§ 215.583, 218.583, and 219.583 and Mich.

Admin. Code, r.336.1606–r.336.1703). Vapor balance systems min-

imize the release of gasoline vapors during GDF storage tank ﬁlling

operations through a combination of pipes and hoses that collect

displaced gasoline vapors from the storage tank and route them

back into the cargo tank. The gasoline terminal then recovers the

vapors when the cargo tank returns to reload. The control efﬁ-

ciency of vapor balance systems ranges from 93% to 100%

(USEPA, 2008 at 5.2–14). Organic emissions from underground

tank ﬁlling operations at a GDF employing a vapor balance system

and submerged ﬁlling are not expected to exceed 40 mg/L (0.3 lb/

1000 gallons) of transferred gasoline.

4.6. Regulation of releases to water from gasoline distribution facilities

Facilities involved in the storage, transportation, and distribu-

tion of gasoline must also obtain NPDES permits covering dis-

charges to waters of the U.S. and comply with local pretreatment

standards applicable to discharges to POTWs. For more informa-

tion on NPDES permit and POTW pretreatment requirements, see

Sections 3.2.1 and 3.2.2.

Storage and distribution facilities also must prepare and imple-

ment oil spill prevention and response plans. Under 49 C.F.R., Part

194, onshore pipeline facilities that, due to their location, could

reasonably be expected to cause substantial harm to the environ-

ment by discharging oil into navigable waters of the U.S. or adjoin-

ing shorelines must prepare and submit to the PHMSA an oil spill

response plan. The response plan must include procedures and a

list of resources for responding to a worst case discharge and to

a substantial threat of such a discharge (Response Plans for

Onshore Oil Pipelines, 2013: § 194.107). Employee training and

response plan review and update procedures must also be

included. Off-shore pipeline facilities must also prepare an oil spill

response plan and submit the plan to the Bureau of Safety and

Environmental Enforcement of the U.S. Department of the Interior

for approval under 30 C.F.R., Part 254 (Oil-Spill Response

Requirements for Facilities Located Seaward of the Coast Line,

2013: §§ 254.1–254.54).

Similarly, 49 C.F.R., Part 130 prescribes prevention, contain-

ment, and response planning requirements applicable to motor

vehicles and railcars that transport oil (Oil Spill Prevention and

Response Plans, 2013: §§ 130.1–130.33). Marine vessels must also

prepare oil spill response plans under 33 C.F.R., Part 155 (Oil or

Hazardous Material Pollution Prevention Regulations for Vessels,

Tank Vessel Response Plans for Oil, 2013: §§ 155.

1010–155.1070). The U.S. Coast Guard must approve the plan prior

to the vessel handling, storing, or transporting oil on navigable

waters of the U.S. or any other port or place subject to U.S.

jurisdiction.

4.7. Industry standards for equipment and handling procedures

Numerous standards have been developed to cover all aspects

of gasoline storage, transport, and handling. These standards cover

the design, construction, and operation of virtually every piece of

equipment from aboveground and underground storage tanks, to

piping, terminals and loading racks, to tank trucks, rail cars, and

barges.

4.7.1. Operation of gasoline transport, storage, and marketing facilities

The American Petroleum Institute (API) has an array of stan-

dards that cover the various types of facilities that transport, store,

and ultimately dispense gasoline. For example, API Standard

2610—Design, Construction, Operation, Maintenance & Inspection

of Terminal and Tank Facilities—covers the design, construction,

operation, inspection, and maintenance of petroleum terminal

and tank facilities associated with marketing, reﬁning, pipeline,

and other operations. Covered topics range from site selection

and spacing, to pollution prevention and waste management, safe

operations, ﬁre prevention and protection, tanks, dikes and berms,

mechanical systems (pipe, valves, pumps, and piping systems),

product transfer, corrosion protection, structures, utilities and

yard, and removals and decommissioning.

4.7.2. Storage tanks

API has developed a series of standards and guidelines address-

ing the design and construction of gasoline storage tanks and their

safe operation. Gasoline can be stored in either aboveground stor-

age tanks (ASTs), typically the type of tank used at terminals (i.e.,

tank farms), or underground storage tanks (USTs), typically used

a retail locations (i.e., gas stations). API Standards 620, Design

and Construction of Large, Welded, Low-Pressure Storage Tanks,

currently in its Eleventh Edition, and 650, Welded Tanks for Oil

Storage, are the 2 most commonly used industry standards for

ASTs in gasoline service. There are also numerous supporting stan-

dards and publications for ASTs that cover tank inspection, repair

and reconstruction (API Std 653), leak detection (API Publ 334),

venting (API Std 2000), cathodic protection (API Std 651), linings

for the bottoms of AST (API Std 652), to name just a few areas.

For shop-fabricated and smaller ﬁeld-erected tanks, the Steel Tank

Institute provides its Standard, SP001. There is a similar set of stan-

dards for USTs, which have been the subject of extensive federal

and state programs to replace all existing USTs and replace them

with new tanks designed to prevent leaks. Commonly referenced

API standards for USTs include Installation of Underground Petro-

leum Storage Systems (API RP 1615), Closure of Underground

Petroleum Storage Tanks (API RP 1604), and Storing and Handling

Ethanol and Gasoline-ethanol Blends at Distribution Terminals and

Filling Stations (API RP 1626).

4.7.3. Static electricity during loading and unloading

A static electric charge can be created by the movement and

agitation of gasoline during the loading and unloading process,

requiring that tanks, transport containers, transfer lines, and so

forth be electrically bonded together and grounded. Bonding

ensures that connected objects (for example, the loading tube

and the tank truck) have the same electrical charge, thereby elim-

inating the chance for a static spark to be created as the two are

disconnected. Grounding allows any built-up static charge to dissi-

pate to ground. There are numerous standards that mandate bond-

D. Swick et al. / Regulatory Toxicology and Pharmacology 70 (2014) S80–S92

S87

ing and grounding in the design and operation of equipment used

to store and handle ﬂammable and combustible liquids, including

NFPA 1, Fire Code™; NFPA 30, Flammable and Combustible Liquids

Code; NFPA 30A, Code for Motor Fuel Dispensing Facilities and

Repair Garages; NFPA 70B, Recommended Practice for Electrical

Equipment Maintenance; IEEE Standards 81 and 142; and the

International Fire Code and others. NFPA 77, Recommended Prac-

tice on Static Electricity, and API RP 2003, Protection Against Igni-

tions Arising Out of Static, Lightning, and Stray Currents, provide

detailed discussions on static electric charge, the evaluation of

charge generation, and bonding and grounding. Additionally, elec-

trical devices and installations in speciﬁc designated areas where

ﬂammable materials are handled should comply with the require-

ments for Class I Group D hazardous locations (as covered by Chap-

ter 5 of NFPA 70, National Electrical Code).

5. Controlling worker exposure to gasoline

The petrochemical industry has numerous programs to address

the safety and health of workers. In the U.S., regulations addressing

worker safety and health have been established by the U.S. Occu-

pational Safety and Health Administration (OSHA), state and local

agencies. In addition, national standard setting organizations such

as the National Institute for Occupational Safety and Health

(NIOSH), American Conference of Governmental Industrial Hygien-

ists (ACGIH)

, and the National Fire Protection Association (NFPA),

have developed standards, programs, and voluntary exposure lim-

its for workers engaged in all aspects of the petrochemical indus-

try. Epidemiology research has also been conducted to evaluate

the effects on workers in reﬁning and gasoline handling occupa-

tions. This research is discussed in a separate paper under this ser-

ies ‘‘Gasoline Toxicology: Overview of Regulatory and Product

Stewardship Programs’’ (Swick et al., 2014).

Although there are many occupational safety and health pro-

grams in the industry addressing potential ﬁre and physical haz-

ards, this section will focus on the regulations and programs

related to worker exposure to hazardous substances. As it relates

to gasoline production, handling and distribution, worker exposure

programs focus on controlling both exposure to gasoline itself and

also exposures to hazardous constituents of gasoline (e.g., ben-

zene). Given the high volatility of gasoline and many of its constit-

uents, inhalation exposure is often the focus of occupational

exposure programs; however, there are also procedures and pro-

grams in place to limit dermal exposure. Occupational exposure

programs include both setting and implementing limits for expo-

sure (i.e., occupational exposure limit (OEL), permissible exposure

limit (PEL), Threshold Limit Values (TLV

)) and also hazard com-

munication and training programs to educate workers about

potential hazards and properly handling procedures.

There is a considerable difference between the composition of

whole gasoline (in its liquid form) and the composition of the gas-

oline vapor to which an individual could be exposed. Thus, in con-

sidering the exposure regulations addressed in this section, it is

important to recognize that although a chemical may be a constit-

uent of gasoline in its liquid form, its potential for exposure may

not necessarily be proportional to its quantity in the gasoline. For

example, light chemical constituents such as pentanes will be

much more present in gasoline vapor as compared to aromatic

hydrocarbons (BTEX, C9 aromatics that have much lower vapor

pressures). More information regarding this can be found in ‘‘Inha-

lation Toxicity of Gasoline and Fuel Oxygenates: Generation and

Characterization of Test Articles’’ (Henley et al., 2014) that is also

a publication in this series.

It is also important to consider the additive feature of the occu-

pational exposure regulations and standards discussed in this sec-

tion. Worker exposure limitations are imposed on top of the

already considerable emissions reductions and exposure limita-

tions achieved through the imposition of air emissions controls

to reduce HAPs and ozone precursors. As production operations

have fugitive and other releases to meet air regulations (see Sec-

tion 3.1), there has been a side beneﬁt of lowering occupational

exposure. Commensurate reductions in consumer and general pub-

lic exposure also are realized when improvements in emission con-

trols on automobiles, ﬁlling stations, and petroleum operations

(reﬁneries, tank farms, etc.) are taken into consideration.

5.1. Occupational exposure limits

5.1.1. OSHA permissible exposure limits

OSHA has established a series of inhalation occupational expo-

sure limits—permissible exposure limits (PELs)—for hazardous

substances in 29 CFR § 1910.1000 (Z-Tables) or in individual chem-

ical standards (e.g., 29 CFR § 1910.1028 for benzene). While there

is not a speciﬁc PEL for gasoline, there are PELs for a number of

constituents including pentane, n-hexane, heptane, benzene, tolu-

ene, xylenes, cumene, and octane. Additionally, several gasoline

additives or blending components, such as ethanol, also have PELs.

PELs establish a full-shift (8-h) time-weighted average (TWA)

exposure for a substance. This means average exposure concentra-

tion for the entire 8-h period needs to be below the PEL. A worker

could be exposed to a concentration above the PEL for a short per-

iod as long as the 8-h average exposure is below the PEL. However,

in some cases OSHA also establishes ceilings of short-term expo-

sure limits (STELs) in order ensure that short-term exposures (typ-

ically 15 min or less) do not go above a certain limit.

In addition to PELs, OSHA health standards, such as the one for

benzene, establish medical surveillance and monitoring programs

and require regular evaluations of workers who are regularly

exposed to these chemicals. Such programs ensure that a worker’s

health is being evaluated and protected beyond simply meeting

the OEL requirements. For substances with health standards, OSHA

typically establishes an ‘‘action level’’ at 50% of the PEL. This means

that if workers have exposures to greater than 50% of the PEL, they

would be required to participate in various aspects of the regula-

tion (e.g., medical surveillance, training, etc.). In many instances,

the OSHA PELs have become dated and as such industry has often

more recently adopted OELs established by ACGIH or internal com-

pany standards based on most recent information.

5.1.2. ACGIH threshold limit values

The ACGIH

, has been recommending occupational exposure

limits (OELs) for a wide variety of chemical and physical workplace

Table 1

Threshold limit values for typical gasoline constituents.

Substance TLV

(8 h TWA) (ppm) STEL (15-min) (ppm)

Gasoline 300 500

Possible constituent chemicals

Benzene 0.5 2.5

Cumene (isopropylbenzene) 50

Cyclohexane 100

Cyclopentane 600

Ethylbenzene 20

Heptane (all isomers) 400 500

n-Hexane 50

Hexane (other isomers) 500 1000

Nonane (all isomers) 200

Octane (all isomers) 300

Pentane (all isomers) 600

Toluene 20

Xylene (all isomers) 100 150

S88 D. Swick et al. / Regulatory Toxicology and Pharmacology 70 (2014) S80–S92

hazards for decades. The most common OEL for chemical sub-

stances, including gasoline and many of its constituents (Table 1),

are the Threshold Limit Values (TLV

Most constituents of gasoline have TLVs

in a range similar to

the TLV

of gasoline. The noteworthy exception is benzene, which

has a unique hazard proﬁle and, as discussed above, its own OSHA

health standard. The TLV

of benzene is 0.5 ppm (8-h TWA), which

is the same as the action level for benzene under the OSHA health

standard. Due to its much lower TLV

and PEL, much of the occu-

pational exposure controls related to gasoline and petroleum oper-

ations have been focused on meeting the benzene occupational

exposure requirements. Generally, the industry has found that

the procedures, practices, and equipment (e.g., leak prevention,

vapor control, exhaust, etc.) used to meet the benzene exposure

limits results in the operations meeting the exposure limits for gas-

oline and other constituents.

ACGIH

also establishes Biological Exposure Indices (BEI

including BEIs for benzene, ethylbenzene, n-hexane, toluene and

xylenes. Although TLVs

are used to evaluate air samples collected

on or near a worker, these BEIs

are used to evaluate biomonitor-

ing samples (e.g., urine) collected from workers. In some cases, the

BEIs

are based on an established metabolite of the chemical; for

example, the BEI

for benzene is based on S-phenylmercapturic

acid or t,t-muconic acid in urine.

5.2. Occupational hazard communication

Hazard communication is a key information exchange between

chemical substance manufacturers/importers and their employees

who need this information. Hazard communication regulations

and programs are intended to provide potentially exposed workers

with information about the hazards of a substance so that a worker

can take appropriate actions to protect himself or herself. Hazard

communications can cover a wide range of potential health (e.g.,

irritation, sensitization, and carcinogenicity) and physical hazards

(e.g., ﬂammability, corrosion, and reactivity). Gasoline and its con-

stituents are covered under various hazard communication regula-

tions in the U.S. and globally so that potentially exposed workers

are warned about hazards and appropriate safety measures to

avoid excessive exposure, ﬂammability risks, and other hazards.

5.2.1. OSHA hazard communication standard

OSHA’s Hazard Communication Standard (HCS) at 29 CFR §

1910.1200 requires that information about a chemical substance’s

hazards and associated protective measures are disseminated to

potentially impacted workers. This regulation requires chemical

manufacturers and importers to evaluate the hazards of their

chemicals and to provide information about them through con-

tainer labels and more detailed safety data sheets (SDSs)—formerly

referred to as material safety data sheets (MSDSs). All employers

with hazardous chemicals in their workplaces must prepare and

implement a written hazard communication program, and must

ensure that all containers are labeled, employees are provided

access to SDSs, and an effective training program is conducted

for all potentially exposed employees.

One aspect of hazard communication that has led to consider-

able confusion and additional paperwork was the situation of dif-

fering classiﬁcation and labeling standards and regulations across

the globe. Due to these differences in regulations, it was not

uncommon for the same substance to be classiﬁed differently (in

some cases very differently) from country to country with different

labels and SDSs for each country. In order to address this issue, the

United Nations undertook an extensive effort to develop a Globally

Harmonized System (GHS) for classiﬁcation and labeling of sub-

stances. The GHS hazard communication system was ﬁrst released

in 2003 and is in the process of being implemented around the

world (United Nations, 2013). There have been several subsequent

updated/revised versions of the GHS system released by UNEP in

2005, 2007, 2009, 2011, and 2013. GHS has now been implemented

in a number of countries (e.g., the EU and Japan), and in the U.S.,

EPA and Consumer Product Safety Commission are now in the pro-

cess of revising their regulations to implement GHS. OSHA issued a

ﬁnal rule in March 2012 to align its Hazard Communication Stan-

dard with the GHS (Hazard Communication, 2012: 17,574).

Providing industry guidance on GHS implementation, the

December 2013 issue of Regulatory Toxicology and Pharmacology

includes an article entitled ‘‘A GHS-consistent approach to health

hazard classiﬁcation of petroleum substances, a class of UVCB sub-

stances.’’ The paper discusses petroleum process streams and

petroleum products and their treatment as substances of unknown

or variable composition, complex reaction products and biological

materials (UVCBs) under various regulatory frameworks. The paper

presents a systematic approach for the health hazard evaluation of

petroleum substances using chemical categories and the GHS

(Clark et al., 2013).

6. Controlling commercial and consumer exposure

An array of equipment speciﬁcations and chemical reporting

requirements protect commercial and consumer end users from

ﬁre risks and harmful exposure to gasoline, its constituents, and

emissions. These include design and performance speciﬁcations

applicable to gasoline underground storage tanks (USTs), fuel

pumps, and other fuel dispensing equipment. The reporting

requirements under the Emergency Planning and Community

Right to Know Act (EPCRA) (Emergency Planning and Community

Right to Know Act, 2012: § 11001, et seq.) and the Comprehensive

Environmental Response, Compensation and Liability Act (CERCLA)

(Comprehensive Environmental Response, Compensation and

Liability Act, 2012: § 9601, et seq.) improve community access to

information about chemical hazards and facilitate emergency

response actions by federal, state, and local governmental bodies.

6.1. Equipment speciﬁcations

6.1.1. Underground storage tank regulations and standards

The regulations at 40 C.F.R., Part 280 require owners and oper-

ators of USTs containing petroleum, fuels, or hazardous substances

to meet performance standards related to tank and pipe design,

construction, installation, and release detection. Covered facilities

must use speciﬁed spill and overﬁll prevention equipment

(Technical Standards and Corrective Action Requirements for

Owners and Operators of Underground Storage Tanks, 2013: §§

280.20–280.30). Spill prevention equipment, such as spill buckets,

must prevent release of product into the environment upon

detachment of the transfer hose from the ﬁll pipe. Operators must

use one of the following overﬁll prevention controls: automatic

shut-off valves that activate upon the tank reaching 95% capacity;

technologies that alert the operator when the tank reaches 90%

capacity; or ﬂow restrictions that automatically activate 30-min

prior to overﬂow.

To prevent UST leaks due to corrosion, the regulations prescribe

the use and maintenance of corrosion protection systems in accor-

dance with a speciﬁed code of practice developed by a nationally

recognized association or independent testing laboratory. To avoid

releases to surface and ground water, operators must only use

USTs made of or lined with materials that are compatible with

the substance stored in the UST. Finally, operators must implement

release detection methods and report a spill or overﬁll to the EPA

or state environmental authority within 24 h of detection

(Technical Standards and Corrective Action Requirements for

D. Swick et al. / Regulatory Toxicology and Pharmacology 70 (2014) S80–S92

S89

Owners and Operators of Underground Storage Tanks, 2013: §§

280.40–280.67). Of course, operators are responsible for response

efforts and any necessary clean up.

As demonstrated by the corrosion prevention requirements, the

regulations incorporate numerous industry standards for installa-

tion, performance, and operation of USTs. These include American

Petroleum Institute (API) Recommended Practice (RP) 1615,

‘‘Installation of Underground Petroleum Storage Systems,’’ RP

1621, ‘‘Recommended Practice for Bulk Liquid Stock Control at

Retail Outlets,’’ and RP 1632, ‘‘Cathodic Protection of Underground

Petroleum Storage Tanks and Piping Systems’’ (Technical Standards

and Corrective Action Requirements for Owners and Operators of

Underground Storage Tanks, 2013: § 280.20). The regulations also

reference several National Fire Protection Association (NFPA)

standards.

6.1.2. Suite of regulations and standards applicable to fuel dispensing

equipment

Several legal requirements and industry standards govern the

design and use of fuel dispensing equipment to ensure the safety

of gasoline station attendants and the general public during

refueling.

As discussed in Section 4.5.2., a variety of federal requirements

promulgated under the Clean Air Act limit air emissions and pre-

scribe the use of vapor recovery systems at gasoline dispensing

facilities. In addition, OSHA regulations require the use of

‘‘listed’’ devices for dispensing ﬂammable liquids such as gasoline

(Occupational Safety and Health Standards, 2013: §§

1910.106(g)(3)(iv)(b)(1) and 1910.106(g)(3)(vi)). Listed devices are

those that have been approved by a nationally recognized testing

laboratory (Occupational Safety and Health Standards, 2013: §

1910.106(a)(35)–(36)). The OSHA regulations include limitations

on the location and pressure of gasoline pumps, and prescribe

the installation of circuit breakers to cut off power to all dispensing

devices in the event of an emergency (Occupational Safety

and Health Standards, 2013: §§ 1910.106(g)(3)(iii) and

1910.106(g)(3)(v)(b)). Facility operators must also install control

and impact valves (Occupational Safety and Health Standards,

2013: § 1910.106(g)(3)(v)(d)–(e)). Control valves permit pump

operation only upon removal of the dispensing nozzle from its

bracket on the dispensing unit and manual activation of the dis-

pensing unit switch. Impact valves incorporate a fusible link that

closes automatically upon severe impact to the dispenser or ﬁre

exposure.

Many states also regulate fuel-dispensing devices through their

ﬁre codes. For example, Colorado has simply adopted by reference

the minimum standards for design, construction, location, installa-

tion, handling, and operation of liquid fuel systems and equipment

prescribed by the National Fire Code, as published by the NFPA and

discussed in detail below (Colo. Rev. Stat., 2013: § 8-20-231). Cal-

ifornia and New York have adopted ﬁre codes largely based on the

ﬁre prevention code developed and published by the International

Code Council (ICC). Their requirements address the location and

protection of dispensing devices, and prescribe the installation of

emergency power circuit breakers and use of listed electrical

equipment, dispensers, hose, nozzles, and submersible or subsur-

face pumps (Cal. Code Regs., 2013: Tit. 24, § 2201, et seq.; N.Y.

Comp. Codes R. & Regs., 2013: Tit. 29, § 2201, et seq.). California

and New York also require periodic inspections by the ﬁre code

ofﬁcial to verify that fuel-dispensing and containment equipment

is in proper working order and not subject to leakage, and facility

testing of emergency shutoff valves and leak detectors at least once

per year.

New Jersey and Oregon are the only states in the U.S. that stat-

utorily prohibit operation of gasoline dispensing devices by the

general public (N.J. Stat. Ann., 2013: § 34:3A-4, et seq.; N.J.

Admin. Code, § 12:196-1.1, et seq.; and Or. Rev. Stat., 2013: §

480.310, et seq.). To limit ﬁre hazards directly associated with

the dispensing of fuel and public exposure to fumes, these states

require that only trained and certiﬁed attendants dispense gaso-

line. These states have also adopted requirements speciﬁc to the

dispensing equipment.

NFPA and the ICC both have standards that address safety and

ﬁre protection with fuel dispensing equipment and operations at

gasoline retail outlets (gas stations) in general. API recently revised

its Recommended Practice for Ethanol Storage and Handling (API

RP 1626) to include an extensive Fire Protection section to manage

the unique risks encountered with ethanol and gasoline ethanol

blends. As discussed above, a number of jurisdictions have incorpo-

rated these standards into local regulations.

Perhaps the most important NFPA standard related to fuel dis-

pensing is NFPA 30A–Code for Motor Fuel Dispensing Facilities

and Repair Garages, 2008 current edition. NFPA 30A sets out base-

line details for the design and operation of motor fuel dispensing

facilities; marine/motor fuel dispensing facilities; and motor fuel

dispensing facilities located inside buildings, at ﬂeet vehicle motor

fuel facilities, and at farms and isolated construction sites. This

code also covers motor vehicle repair garages. NFPA 1–Fire Code,

2009 current edition, and NFPA 30–Flammable and Combustible

Liquids Code, 2008 current edition, also have provisions that relate

to retail fuel operations. Similar to NFPA, the ICC also has a com-

prehensive standard—the International Fire Code—which covers a

wide range of operations and facilities including aspects of fuel dis-

pensing operations.

6.1.3. Gasoline pump speciﬁcations

To reduce refueling spillage and spitback emissions, the regula-

tions at 40 C.F.R. § 80.22 impose design and performance require-

ments on gasoline pumps. Speciﬁcally, the outside diameter of the

terminal end of a nozzle spout must not exceed 0.840 inches

(2.134 cm), and the terminal end must have a straight section of

at least 2.5 inches (6.34 cm). The retaining spring must also termi-

nate at least 3.0 inches (7.6 cm) from the terminal end. The regula-

tions also prescribe a maximum fuel ﬂow rate for each nozzle not

to exceed 10 gallons per minute (37.9 L/min). These speciﬁcations

prevent ﬁres involving spilled gasoline and the reduce consumer

inhalation of gasoline vapors (Evaporative Emission Regulations

for Gasoline- and Methanol-Fueled Light-Duty Vehicles, Light-

Duty Trucks and Heavy-Duty Vehicle, 1993: 16,002 and 16,005 ).

6.2. Reporting requirements

Congress enacted EPCRA and CERCLA to provide citizens with

information on chemicals and their uses and releases at facilities

across the nation. Most importantly, these laws ensure that federal,

state, and local emergency responders are equipped with informa-

tion vital to chemical risk management and emergency planning.

6.2.1. Emergency planning and community right to know act

Under Section § 302(c) of EPCRA, industrial facilities that store

or manage certain speciﬁed chemicals must report to state emer-

gency response commissions (SERCs) and local emergency plan-

ning committees (LEPCs) regarding the nature and quantity of

chemicals present at the facility. Speciﬁcally, facilities must notify

the SERC and LEPC of the on-site presence of any ‘‘extremely haz-

ardous substance’’ (EHS) in excess of the substance’s ‘‘threshold

planning quantity’’ (TPQ) and appoint an emergency response

coordinator. The list of EHSs and their corresponding TPQs is cod-

iﬁed at 40 C.F.R., Part 355. Petroleum reﬁneries generally produce a

number of EHSs during manufacturing processes. Facilities must

also immediately report accidental releases of reportable quanti-

ties of EHSs or CERCLA ‘‘hazardous substances’’ in accordance with

S90 D. Swick et al. / Regulatory Toxicology and Pharmacology 70 (2014) S80–S92

EPCRA § 304. CERCLA hazardous substances include gasoline con-

stituents such as benzene, toluene, ethylbenzene, and xylene.

Facilities manufacturing, processing, or storing OSHA ‘‘hazard-

ous chemicals’’ must provide MSDSs to SERCs, LEPCs, and local ﬁre

departments pursuant to Sections 311 and 312 of EPCRA. The reg-

ulations codiﬁed at 40 C.F.R., Part 370 also require facilities to sub-

mit an annual inventory report to such authorities, if they maintain

certain chemicals at or above speciﬁed quantities. The annual

inventory reporting threshold is 75,000 gallons (all grades com-

bined) for gasoline stored in a UST at a retail outlet; 100,000 gal-

lons (all grades combined) for diesel fuel stored in a UST at retail

outlet; either 500 lb or the TPQ for an EHS, whichever is lower;

and 10,000 lb for all other hazardous chemicals. This information

helps local emergency responders and governments to know the

types and amounts, locations and nature of hazardous substances

stored at a facility when they respond to chemical spills or releases.

EPCRA § 313 requires facilities manufacturing or otherwise

using chemicals listed on the Toxics Release Inventory (TRI), codi-

ﬁed at 40 C.F.R. § 372.65, at or above threshold quantities to submit

an annual report to EPA. The report covers releases and transfers of

toxic chemicals to various facilities and environmental media. EPA

publishes the data, which are used by EPA and other public bodies

to facilitate oversight. Petroleum reﬁners generally produce a num-

ber of the approximately 600 chemicals listed on the TRI, including

but not limited to ammonia, benzene, chlorine, hydrogen sulﬁde,

methyl mercaptan, and sulfuric acid. API has published a compila-

tion of methods for calculating air emission under the TRI provi-

sions (API, 2010). From 1988 to 2006, petroleum facilities

reduced their releases, disposals, and transfers to the environment

by 75% (API, 2006).

6.2.2. Comprehensive environmental response, compensation and

liability act

CERCLA authorizes EPA to respond to releases, or threatened

releases, of hazardous substances, and to force responsible parties

to undertake cleanup or reimburse the Superfund for response or

remediation costs. As noted above, CERCLA hazardous substances

include several gasoline constituents, in addition to wastes from

the reﬁning process. The regulations at 40 C.F.R., Part 302 require

owners or operators of a facility to report any environmental

release of a hazardous substance at or above a reportable quantity

to the National Response Center (Designation, Reportable

Quantities, and Notiﬁcation, 2013: § 302.4). EPA responds to

releases according to procedures outlined in the national oil and

hazardous substances pollution contingency plan at 40 C.F.R, Part

300.

Critically, Section 101(14) of CERCLA exempts petroleum and

indigenous petroleum constituents from the deﬁnition of ‘‘hazard-

ous substance.’’ Thus, listed hazardous substances that would

otherwise fall within the ambit of CERCLA, such as benzene, are

exempt when contained in petroleum, unless the concentration

of these substances is increased by contamination or by addition

after reﬁning. The EPA Ofﬁce of the General Counsel has inter-

preted the petroleum exemption as including gasoline blended

during the reﬁning process (USEPA, 2011). On the other hand, spe-

ciﬁcally listed waste oils, such as F010 and K048 through K052, do

not fall within the petroleum exemption. Separated gasoline base-

stocks may also remain subject to reporting requirements, if spilled

in excess of their established reportable quantities.

7. Conclusions

This review of risk management measures currently in effect in

the U.S. demonstrates that they comprehensively address and mit-

igate the environmental and human health risks posed by

automotive gasoline. Indeed, the entire gasoline lifecycle—from

manufacture, through distribution, to end-use—is subject to

detailed, complex, and overlapping regulatory schemes intended

to protect both human health and the environment. In addition

to these legal requirements, industry has implemented a broad

array of standards and best management practices to ensure that

risks from gasoline manufacturing, distribution, and use are

minimized.

Conﬂict of interest

Swick reports that he is an employee of the American Petroleum

Institute. Jaques reports receiving personal fees from the American

Petroleum Institute during the development of the manuscript

submitted for publication and also personal fees from the Ameri-

can Petroleum Institute for additional consulting services outside

the submitted work. Walker and Estreicher both report receiving

personal fees from the American Petroleum Institute.

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Glossary

Acronym: Deﬁnition

API: American Petroleum Institute

AST: Aboveground storage tank

ASTM: American Society for Testing and Materials; now called ASTM International.

CAA: Clean Air Act; 1990 reauthorized version

CERCLA: Comprehensive Environmental Response, Compensation and Liability Act

CFR: Code of Federal Regulations

CO: Carbon monoxide

CONCAWE: Conservation of Clean Air and Water Europe

CWA: Clean Water Act

DOT: Department of Transportation

EHS: Extremely hazardous substance

EPA: Environmental Protection Agency; see also USEPA

EPCRA: Emergency Planning and Community Right to Know Act

GDF: Gasoline dispensing facility

HAP: Hazardous air pollutant

HPV: High Production Volume—more than 1 million pounds per year of production

MSAT: Mobile source air toxics

MTBE: Methyl tertiary-butyl ether

NESHAP: National emission standards for hazardous air pollutants

NFPA: National Fire Protection Association

NOx: Nitrogen oxides; includes nitrogen dioxide (NO2), nitrous acid, and nitric acid

NPAH: Nitrated polycyclic aromatic hydrocarbon; NPAHs are deﬁned to include: 7-

nitrobenzo[a]anthracene, 6-nitrobenzo[a]pyrene, 6-nitrochrysene, 2-nitroﬂuo-

rene, and 1-nitropyrene

NPDES: National Pollutant Discharge Elimination System

OPA: Oil Pollution Act

OSHA: Occupational Safety and Health Administration

PAH: Polycyclic aromatic hydrocarbon; PAHs are deﬁned to include:

Benzo(a)anthracene, Benzo[b]ﬂuoranthene, Benzo[k]ﬂuoranthene, Benzo(a)-

pyrene, Chrysene, Dibenzo[a,h]anthracene, and, Indeno[1,2,3-c,d]pyrene

PEL: Permissible exposure limit

PM: Particulate matter

PONA: Parafﬁns, oleﬁns, naphthenes, and aromatics—key chemical constituents in

gasoline blending streams

POTW: Publicly-owned treatment works

RFG: Reformulated gasoline

RVP: Reid vapor pressure

: Sulfur dioxide

TRI: Toxics Release Inventory

TLV: Threshold limit value

USEPA: United States Environmental Protection Agency

UST: Underground storage tank

UVCB: Unknown or Variable compositions, Complex reaction products and Biolog-

ical; a class of chemical substances that includes most gasoline blending

streams

VOC: Volatile Organic Compound, as deﬁned by U.S. EPA at 40 CFR § 51.100

S92 D. Swick et al. / Regulatory Toxicology and Pharmacology 70 (2014) S80–S92

Occupational Exposure Estimate of Benzene and the Effectiveness of Control Measure in Gabon’s Gasoline Storage and Distribution Facility

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Full-text available

Dec 2018

The processing of petroleum products in gasoline storage and distribution facility for loading operation, has caused the generation of vapor emissions sources. Benzene is one of those vapor emissions that workers are likely to be exposed at high exposure level during conducting out specific tasks such as loading gasoline to various petroleum storage transport modes. This results in many problems on human health such as cancer and non-cancer diseases. However, the estimate of benzene exposure to indicate the control measures has not been fully explored in previous researches. In this study, the occupational exposure estimate of benzene in Gabon’s gasoline storage and distribution facility was investigated by using a quantitative and predictive exposure inhalation model; to estimate benzene concentration before and after applying control measures. The results indicate that the benzene concentrations varied between 9.46 mg/m³ and 187 mg/m³ for short term and has the value of 187 mg/m³ for long term. The implementation of control measures including using vapor recovery system, chemical filter mask and improving worker’s behavior might contribute to significantly reduce benzene concentration to the range of 4.52 – 29.08 mg/m³ for short term and down to 4.55 mg/m³ for long term. This almost meets the Agency Governmental Industrial Hygienists standard, in which occupational exposure limit for short term and long term exposure is 8.1 mg/m³ and 3.16 mg/m³, respectively.

Exposure to volatile organic compounds (VOCs) at gas stations: a probabilistic analysis

Article

Full-text available

Mar 2022

Gasoline evaporation and spills may cause high air pollution at gas stations. This study aimed to assess exposure to volatile organic compounds (VOCs) at gas stations among customers. Ambient air samples were collected in the fuel dispensing area of 51 gas stations in the Greater Memphis Area, USA, in summer 2017. For the comparison purpose, samples were collected in the ambient air at 20 community sites and in the indoor air of 30 homes, 11 offices, and 15 running vehicles in the same region. Air sampling used Tenax TA thermal desorption (TD) tubes and samples were analyzed by TD-gas chromatography/mass spectrometry (GC/MS) for 70 target compounds. Gasoline-related VOCs were identified using factor analysis, and exposure at gas stations was evaluated using Monte Carlo analysis. Benzene, toluene, ethylbenzene, and xylenes (BTEX) showed the highest concentrations ranging from 2 to 15 μg/m3, ten times higher than those in the community air. Factor analysis confirmed gasoline as the common source of aromatic compounds. VOC concentrations had no association with the number of cars present or environmental parameters. Exposure to aromatic compounds at gas stations represented 2% of the total exposure (i.e., the sum of indoor and outdoor exposures) but 38% of the outdoor exposure among customers. The exposure levels were below the acute health thresholds and presented 0.3 × 10−6 lifetime excess cancer risk. In conclusion, customers’ exposure to VOCs at gas stations has negligible non-cancer and cancer risks. It is also suggested that customers stand away from the nozzle to avoid high personal exposures during refueling.

Ecotoxicological effects, human and animal health risks of pollution and exposure to waste engine oils: a review

Article

Full-text available

Sep 2024
ENVIRON GEOCHEM HLTH

Waste engine oils are hazardous waste oils originating from the transportation sector and industrial heavy-duty machinery operations. Improper handling, disposal, and miscellaneous misuses cause significant air, soil, sediments, surface water, and groundwater pollution. Occupational exposure by prolonged and repeated contact poses direct or indirect health risks, resulting in short-term (acute) or long-term (chronic) toxicities. Soil pollution causes geotoxicity by disrupting the biocenosis and physicochemical properties of the soil, and phytotoxicity by impairing plant growth, physiology and metabolism. Surface water pollution impacts aquatic ecosystems and biodiversity. Air pollution from incineration causes the release of greenhouse gases creating global warming, noxious gases and particulate matter eliciting pulmonary disorders. The toxicity of waste engine oil is due to the total petroleum hydrocarbons (TPH) composition, including polycyclic aromatic hydrocarbons (PAHs), benzene, toluene, ethylbenzene, xylene (BTEX), polychlorinated biphenyls (PCBs) congeners, organometallic compounds, and toxic chemical additives. The paper aims to provide a comprehensive overview of the ecotoxicological effects, human and animal health toxicology and exposure to waste engine oils. It highlights the properties and functions of engine oil and describes waste engine oil generation, disposal and recycling. It provides intensive evaluations and descriptions of the toxicokinetics, metabolism, routes of exposure and toxicosis in human and animal studies based on toxicological, epidemiological and experimental studies. It emphasises the preventive measures in occupational exposure and recommends risk-based remediation techniques to mitigate environmental pollution. The review will assist in understanding the potential risks of waste engine oil with significant consideration of the public health benefits and importance.

Current frameworks for environmental and health assessment of hydrocarbon streams and products are flexible and ready for alternative non crude oil-based feeds

Article

Full-text available

Jul 2024

Hazard and risk assessment of complex petroleum-derived substances has been in a state of continuous improvement since the 1970s, with the development of approaches that continue to be applied and refined. Alternative feeds are defined here as those coming into a refinery or chemical plant that are not hydrocarbons from oil and gas extraction such as biologically derived oils, pyrolysis oil from biomass or other, and recycled materials. These feeds are increasingly being used for production of liquid hydrocarbon streams, and hence, there is a need to assess these alternatives, subsequent manufacturing and refining processes and end products for potential risk to humans and the environment. Here we propose a tiered, problem formulation-driven framework for assessing the safety of hydrocarbon streams and products derived from alternative feedstocks in use. The scope of this work is only focused on petrochemical safety assessment, though the principles may be applicable to other chemistries. The framework integrates combinations of analytical chemistry, in silico and in vitro tools, and targeted testing together with conservative assumptions/approaches to leverage existing health, environmental, and exposure data, where applicable. The framework enables the identification of scenarios where de novo hazard and/or exposure assessments may be needed and incorporates tiered approaches to do so. It can be applied to enable decisions efficiently and transparently and can encompass a wide range of compositional space in both feedstocks and finished products, with the objective of ensuring safety in manufacturing and use.

Evaluating the effects of olefin components in gasoline on GDI engine combustion and emissions

Article

May 2021
FUEL

Olefins are part of the most important components in gasoline fuel. In this paper, olefin component diisobutylene (DIB), 1-pentene and 1-hexene are involved into research. Three quinary gasoline model fuels containing each of these three olefins are used to support this research. Results prove these three olefins exhibit comparable effects on engine combustion and regulated emissions. However, their differences in affecting VOC and particulate matter emissions are of great significance. DIB leads to higher ethane emission while 1-hexene results in remarkably lower acetylene emission. 1-pentene generally leads to lower formaldehyde and acetaldehyde emissions. Nevertheless, these three olefins lead to comparable total VOC emissions. Further analyses show that alkane, olefin and aromatics take the most part of VOCs while olefin in emission take the most responsibility of ozone formation potential. Although 1-pentene in gasoline does not lead to the lowest VOC emissions, it results in the lowest OFP value when compared with DIB and 1-hexene. Such a finding signifies that gasoline with more 1-pentene content help to alleviate emission photochemical effect when compared with olefin content DIB or 1-hexene, which hints that gasoline with C5 olefin might be favorable than C6 olefin content when OFP of engine VOC emission is considered.

Hexane Isomers Separation on an Isoreticular Series of Microporous Zr Carboxylate Metal Organic Frameworks

Article

Jul 2020

A series of isoreticular Zr carboxylate MOFs, MIL-140A, B and C, exhibiting 1D microporous triangular shaped channels and based on different aromatic dicarboxylate ligands (1,4-BDC, 2,6-NDC and 4,4’-BPDC, respectively), were investigated by chromatographic breakthrough experiments regarding their ability to separate hexane isomers (nC6/2MP/3MP/23DMB/22DMB). Both single and equimolar multicomponent experiments were performed covering the temperatures 343, 373, and 423 K and total hydrocarbon pressure up to 50.0 kPa using MIL-140B form. The elution order is similar to the normal boiling point of the compounds nC6>2MP>3MP>23DMB>22DMB. Noteworthy, this material enables a separation of the hexane isomers by classes linear > mono-branched > di-branched with a selectivity (linear + mono-branched isomers / di-branched isomers) up to 10 at 343 K, decreasing however as the temperature increases. Grand Canonical Monte Carlo simulations were further performed to gain insight into the adsorption/separation mechanisms highlighting the crucial need to consider a tiny tilting of the organic linkers for capturing the experimental observations. The impact of the pore size was finally assessed through the comparison with MIL-140A and MIL-140C, respectively, based on multicomponent experiments at 343 K. We evidenced a significant decrease of the selectivity (about 2) in both cases while the loadings were decreased or increased for MIL-140A and MIL-140C respectively. Additionally, MIL-140C was demonstrated to exhibit an uncommon shift in the elution order occurring between nC6 and 3MP, the 3MP being the last compound to saturate in the column.

La complejidad química de las gasolinas de automoción

Article

Full-text available

Dec 2019

Utilizadas principalmente como combustibles en motores de combustión interna, las gasolinas son mezclas complejas de hidrocarburos que incluyen en su composición distintos aditivos para mejorar su estabilidad y prestaciones. Su composición química es no solo diversa, sino también variable, dependiendo del crudo de procedencia, del proceso de obtención y de las normativas existentes. Estas fijan el contenido máximo permitido de determinados compuestos que, por su toxicidad, deben quedar limitados. Las gasolinas se obtienen por destilación fraccionada del petróleo y también a partir de fracciones más pesadas del mismo, mediante craqueo térmico o catalítico, procesos que junto al reformado catalítico van a tener una incidencia directa en su composición. El objetivo de esta revisión es abordar la compleja composición que presentan las gasolinas, así como algunos procesos básicos del refinado de petróleo. Estos procesos determinan en buena medida la naturaleza química de los componentes de este combustible, algunos de los cuales se relacionan con la emisión de sustancias nocivas para la salud y el medio ambiente. De esta forma, proporcionamos un contexto más exacto sobre los agentes contaminantes de la gasolina, a la vez que ponemos de manifiesto la necesidad de contar con normativas avanzadas que regulen la composición de los combustibles.

Ensuring Safety and Compliance: Material Safety Data Sheet (MSDS) Implementation in On-Board Blending of Pertalite (RON90)

Article

Oct 2023

The high public demand for Pertalite (RON90) has significantly increased, causing Indonesia should choose to import, one from Jamnagar Sikka Marine Terminal, India. In application, the loading port uses the onboard blending technique of mixing cargo with additives to achieve the desired octane number. According to the International Safety Guides for Oil Tankers and Terminals (ISGOTT) 6th edition chapter 12.1.6.15, the ship is not designed as a blending instrument, which in its operation experiences several incompatibilities that pose a risk of danger. As mitigation, cargo manufacturers include Material Safety Data Sheet (MSDS) or work safety guidelines before operations begin to be understood and realized by all parties involved. The research method used in this research is a qualitative method with an explanative pattern. The unavailability of personal protective equipment (PPE) by the MSDS, the lack of blending facilities from the terminal and skilled personnel, lack of awareness and familiarization with the MSDS itself cause several impacts during its operation, including health threats, environmental stability, and even material losses that will be obtained by the company. So it is necessary to apply and actualize the implementation of MSDS on board, as well as create good harmonization between the company and the terminal so that this blending procedure can run optimally and produce fuel products that are by specifications.

Impacts of the new NR 20 for the operation of fuel stations

Article

Sep 2022

Effects of ethanol and aromatic compositions on regulated and unregulated emissions of E10-fuelled China-6 compliant gasoline direct injection vehicles

Article

Apr 2021
RENEW ENERG

This research examined the effects of ethanol and aromatic compositions in E10 match-blends on the exhaust regulated, greenhouse gases, and unregulated toxic emissions of five China-6 compliant gasoline direct injection vehicles at room and low ambient temperatures. Emissions of a China-6 compliant gasoline and four E10 match-blends having roughly the same total aromatic concentration but containing different aromatic compositions were measured using Fourier transform infrared spectrometer, gas chromatogram-mass spectrometer, and high-performance liquid chromatogram. The results show that ethanol content decreases the fleet-averaged regulated gas and particulate mass (PM) emissions and increases the particulate number (PN), benzene, and toluene emissions. As the aromatic compositions in E10 match-blends shift from toluene to C8 and C9 aromatics, PM and PN emissions significantly increase. The low temperature leads to higher emission factors than the room temperature, especially the emissions from the fuel with more toluene content. C8 and C9 aromatics are found to have larger impacts on PM emissions but smaller impacts on PN emissions than the C10 and C10+ aromatics. It is noticed that benzene emissions at the low temperature heavily depend on the fuel toluene concentration.

Gasoline Toxicology: Overview of Regulatory and Product Stewardship Programs

Article

Full-text available

Jun 2014

Significant efforts have been made to characterize the toxicological properties of gasoline. There have been both mandatory and voluntary toxicology testing programs to generate hazard characterization data for gasoline, the refinery process streams used to blend gasoline, and individual chemical constituents found in gasoline. The Clean Air Act (CAA) (Clean Air Act, 2012: § 7401, et seq.) is the primary tool for the U.S. Environmental Protection Agency (EPA) to regulate gasoline and this supplement presents the results of the Section 211(b) Alternative Tier 2 studies required for CAA Fuel and Fuel Additive registration. Gasoline blending streams have also been evaluated by EPA under the voluntary High Production Volume (HPV) Challenge Program through which the petroleum industry provide data on over 80 refinery streams used in gasoline. Product stewardship efforts by companies and associations such as the American Petroleum Institute (API), Conservation of Clean Air and Water Europe (CONCAWE), and the Petroleum Product Stewardship Council (PPSC) have contributed a significant amount of hazard characterization data on gasoline and related substances. The hazard of gasoline and anticipated exposure to gasoline vapor has been well characterized for risk assessment purposes.

Health Assessment of Gasoline and Fuel Oxygenate Vapors: Generation and Characterization of Test Materials

Article

Full-text available

Nov 2014
REGUL TOXICOL PHARM

In compliance with the Clean Air Act regulations for fuel and fuel additive registration, the petroleum industry, additive manufacturers, and oxygenate manufacturers have conducted comparative toxicology testing on evaporative emissions of gasoline alone and gasoline containing fuel oxygenates. To mimic real world exposures, a generation method was developed that produced test material similar in composition to the re-fueling vapor from an automotive fuel tank at near maximum in-use temperatures. Gasoline vapor was generated by a single-step distillation from a 1000-gallon glass-lined kettle wherein approximately 15 to 23% of the starting material was slowly vaporized, separated, condensed and recovered as test article. This fraction was termed vapor condensate (VC) and was prepared for each of the seven test materials, namely: baseline gasoline alone (BGVC), or gasoline plus an ether (G/MTBE, G/ETBE, G/TAME, or

Gasoline Risk Management: A Compendium of Regulations, Standards, and Industry Practices

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