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Federal Register / Vol. 86, No. 3 / Wednesday, January 6, 2021 / Rules and Regulations used in aviation, marine, and automotive fuel streams in the United States. Many current performance specifications for fuel require their use;
including for specialty fuels for aviation and the military. The Aerospace Industries Association identified critical uses of 2,4,6-TTBP as a fuel additive/
antioxidant in formulations designed to meet specific technical performance requirements that are documented in a number of engineering specifications over the service life of complex aerospace products EPAHQOPPT
201607340010. The American Petroleum Institute also confirmed that their members use 2,4,6-TTBP as an antioxidant in gasoline, diesel, and aviation fuels at concentrations of between five and 50 parts per million to reduce gasoline deposits in engines and subsequently reduce emissions EPA
HQOPPT201607340006. With respect to use as an antioxidant in the general fuel supply, EPA has received comment supporting the beneficial properties of 2,4,6-TTBP as an antioxidant component blended in fuel.
SI Group identified numerous U.S.
military and ASTM standards that its proprietary blended products containing 2,4,6-TTBP satisfy for the antioxidant requirements in fuel Ref. 8, notably jet fuel that is supplied to and used by the U.S. military. Although particular specifications do not list 2,4,6-TTBP by CASRN or trade name, 2,4,6-TTBP is the preferred antioxidant component for fuel standards due to its chemical reaction potential and physical property characteristics Ref. 8 and 9. According to the manufacturers and processors, any substitution of 2,4,6-TTBP with another alkylphenol or antioxidant compound would materially change the performance characteristics of that fuel and compliance with mandatory reference standards could not be assured Ref. 9. Introducing a new jet fuel component into use involves the fuel component supplier, engine manufacturers, airplane makers and regulators in a complicated process that may take several years and involve significant cost. New fuel additives must be tested and approved to ensure they would have no negative impact on engine safety, durability or performance Ref. 8.
Once blended into fuel, the resultant concentration of 2,4,6-TTBP in fuel is low, in the five to 50 ppm range.
Treated fuel is distributed through the nations fuel supply chain pipeline or vehicle transportation, storage and distribution to end points such as airports, gas stations and military facilities. 2,4,6-TTBP, a hydrocarbon, is
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destroyed burned as the fuel to which it is added is consumed during end use Ref. 7.
SI Group typically ships its product to refineries in tankers or other large containers. Fugitive air releases of 2,4,6TTBP are expected to be minimal due to the low vapor pressure from unloading and transfer operations.
Releases may possibly occur from spills and leaks from loading operations, but exposure would be addressed at these industrial sites through spill control measures. Waste from equipment cleaning with organic cleaning solutions is anticipated to be collected for incineration. Water releases are possible from equipment and general area cleaning with aqueous cleaning solutions. Dermal exposure to 2,4,6TTBP to workers may occur from transfer and fuel loading operations;
however, dermal exposure at fuel production facilities is expected to be minimal due to the required use of engineering controls and personal protective equipment PPE noted above EPAHQOPPT201803140018.
Refineries, fuel distribution and fuel storage facilities also operate with the same or similar engineering controls, PPE gloves, slickers, boots, respirators, etc., worker training, leak detection and spill control measures; vapor recovery systems are used during distribution and storage EPAHQOPPT2016
07340006, similar to procedures used at the manufacturing facility. Once blended into fuel, the resultant concentration of 2,4,6-TTBP in fuel is low, in the five to 50 ppm range, limiting the exposure resulting from handling and spills or leaks.
EPA has not identified releases, or potential releases from the use of 2,4,6TTBP for fuel treatment at refineries and fuel facilities that can be targeted for reduction with practicable measures under TSCA section 6a. Similarly, EPA
has not identified exposure or potential exposures to workers or the general population from refinery and fuel facility use that can be targeted for reduction with practicable measures under TSCA section 6a. As discussed in Unit II.F., EPA believes that in industrial settings worker protection measures used by employers reduce exposures to the extent practicable and EPA has determined that it is not practicable to regulate worker exposures in this rule through additional engineering or process controls or PPE
requirements.
The benefit to continuing the use of existing antioxidants containing 2,4,6TTBP is a result of the necessity of antioxidants to the nations fuel supply and the difficulties inherent in
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removing 2,4,6-TTBP in terms of standards and performance specifications. Given the absence of and difficulty with identifying and adopting alternatives, EPA did not propose to prohibit the manufacturing, processing, or distribution for use of 2,4,6-TTBP as an additive at refineries and fuel facilities.
iii. Formulations intended for the maintenance or repair of motor vehicles and machinery.
SI Group does not sell its Isonox or Ethanox mixtures directly to consumers.
However, a portion approximately 6%
of the 2,4,6-TTBP mixtures SI Group sells for use in fuels are sold to processors who blend and distribute antioxidant products that are intended to be added to the fuel tanks/systems in vehicles or machinery by repair shops or the owner/operators of the equipment themselves. These fuel stabilizer products, which contain a percentage of Isonox or Ethanox as an antioxidant component, are sold to consumers at various retail locations, as well as online. These additives are typically sold in small bottles containing up to 32
ounces; gallon containers are available through some retailers. Specialty products are also sold for cleaning fuel injectors or use in 2-stroke engines preblended with oil.
Regarding the retail sale of fuel additives and fuel injector cleaners, EPA
was unable to find any specifications or standards for retail fuel antioxidants or additives that explicitly require the use of 2,4,6-TTBP. As discussed in Unit III.B, EPA has identified a number of substitute chemicals and substitute products in the Exposure and Use Assessment for this rule for this specific use.
Use of retail fuel additive products which are sold in small containers to mechanics and consumers to service cars, boats, small engines, etc., present opportunities for release and dermal exposure during transfer activities if users are unprotected. Use of the product involves pouring it from the bottle either into a fuel storage container, such as a gas can that is used to refill equipment such as lawn mowers, or it may be poured directly into the fuel tank of the lawn equipment, or car, boat, etc.
EPA believes that the general public does not routinely use PPE while using this product in these mundane activities, and has not received special training in the handling of the product.
No PPE is specified for the use of retail fuel additive products and EPA has no information to indicate that the general public takes any further protective measures when adding this product to
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