What PTD language is required for gasoline that includes both GPA gasoline and S-RGAS, where the S-RGAS has a higher downstream sulfur standard than the GPA gasoline?

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Section 80.219(c)(ii) provides that all parties in the distribution system are prohibited from commingling GPA gasoline with gasoline not designated as GPA gasoline unless the mixture is classified as GPA gasoline. As a result, for a mixture of S-RGAS and GPA gasoline, the PTDs must identify the gasoline as GPA gasoline. As such, the gasoline may not be sold outside the GPA. See § 80.219(c)(i). Section 80.220(b) provides that the downstream sulfur standard applicable to a mixture of GPA gasoline and S-RGAS is the greater of the downstream standard for the GPA gasoline or the downstream standard for the S-RGAS.

We believe, where a mixture of GPA gasoline and S-RGAS has a S-RGAS downstream standard that is greater than the GPA downstream standard, the PTDs for the gasoline must identify the product as containing both GPA gasoline and S-RGAS and state the S-RGAS downstream sulfur standard. The PTDs must also include a statement that the gasoline may not be distributed or sold for use outside the GPA.