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• If an independent lab temporarily cannot run a required test, may the independent lab use a substitute lab for the test until the independent lab regains its testing capacity? May a refiner use one independent lab to collect samples at a refinery, and ano

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . An independent lab may use a second lab to collect samples or perform required tests, provided that: (1) the second lab is independent as defined in § 80.65(f)(2)(iii); (2) the primary independent lab is responsible for the quality…

  • Last published: July 15, 2024

• If a purchased lot of certified RFG is combined with another lot of fungible certified RFG in a terminal, and a portion of the mixture is then sold to a third party, what form would the product transfer documentation take? Would it be necessary to convey

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . There is no specific form or required format for the produce transfer document (PTD) information. It should be included on the documents used to memorialize the transfer of the fuel and should reflect the amount and type of…

  • Last published: July 14, 2024

• If a refiner produces only conventional gasoline, what is the purpose of the added burden of testing, auditing, documentation, and general compliance requirements? Since there is only conventional gasoline produced, there can be no dumping. Also, if the E

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The Clean Air Act requires that all conventional gasoline on average be at least as clean as it was in 1990 regardless of who produces the conventional gasoline. Therefore, all refiners and importers are subject to requirements that…

  • Last published: July 14, 2024

• If an oxygenate blender adds oxygenate only to conventional gasoline downstream of the refinery, please confirm that the oxygenate blender is not considered a "refiner" and therefore is not subject to record keeping, reporting, or attest engagement requir

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . This party would not be considered a "refiner" for purposes of the anti-dumping requirements, and is not required to meet the anti-dumping requirements specified in the question.(7/1/94) This question and answer was posted at Consolidated List of Reformulated…

  • Last published: July 14, 2024

• Section 80.77 states that product transfer documents should include the name and address of the transferor and transferee. In the interest of keeping the PTD's as a single document, would it be permissible to retain the addresses of the transferees in a p

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Under § 80.77(a) and (b), the product transfer documents for each transfer of title or custody must include both the name and address of the transferor and the transferee. However, EPA will consider this requirement to be met…

  • Last published: July 12, 2024

• Should separate samples be collected for RVP analysis?

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . One sample may be used for all of the RFG parameters that need to be determined, including RVP. However, because sample handling in the laboratory may affect various reformulated gasoline properties, such as RVP, analyses must be performed…

  • Last published: July 12, 2024

• Terminal blending of mid-grade gasoline (using a premium and regular mix) is common practice in the industry. We interpret that terminals engaging in this practice are not considered refiners under the regulations based on the comment "that the EPA believ

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Parties who only mix different grades of certified reformulated gasoline will not be considered refiners or blenders under the reformulated gasoline regulations. Similarly, parties who mix different grades of conventional gasoline which were produced in compliance with the…

  • Last published: July 12, 2024

• The July 1, 1994 Question and Answer Document indicates that sulfur, T90, and olefins are the only simple model RFG standards that can be seen on a refinery aggregated basis. We interpret this clarification to apply only to simple model RFG compliance and

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . All simple model anti-dumping standards can be met on a refinery-aggregate basis pursuant to § 80.101(h).(11/28/94) This question and answer was posted at Consolidated List of Reformulated Gasoline and Anti-Dumping Questions and Answers: July 1, 1994 through November…

  • Last published: July 12, 2024

• The regulations and reporting requirements imply that credit trading for oxygen and benzene is allowed across nonattainment areas [and] not just within an area. Is that correct? Is there any geographic restriction with regard to benzene and oxygen trading

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Oxygen and benzene credits may be traded across RFG areas. However, all conditions specified in 80.67(h) must be met.(7/1/94) This question and answer was posted at Consolidated List of Reformulated Gasoline and Anti-Dumping Questions and Answers: July 1…

  • Last published: July 12, 2024

• The regulations require that if "refiners, importers, and oxygenate blenders" supplying a covered area do not complete a survey for that area, then the covered area would be deemed to have failed. Would the subsequent ratchet also apply to "suppliers" to

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Although, from a practical standpoint in the marketplace, there are "suppliers" in the sense it is used in the question, enforcement of average standards are refiner, blender, and importer-based. Therefore, as is mentioned in Survey Question 2 (above)…

  • Last published: July 12, 2024

• The transfer document requirements state that the name and address of the transferor and transferee be present. When other oil partners, exchangers, are picking up product, will the address of the company headquarters be sufficient since EPA will still be

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Yes, the headquarters address of the transferee would be acceptable. When jobbers pick up gasoline they are the transferees in the transaction and the regulations specifically require that an address for all transferees be included on the product…

  • Last published: July 12, 2024

• What constitutes a batch of reformulated gasoline? What method should be used by refiners, importers and oxygenate blenders for determining the volume of a batch of reformulated gasoline? What method should be used by independent laboratories? If a refine

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Section 80.2(gg) defines a "batch of reformulated gasoline" as "a quantity of reformulated gasoline which is homogeneous with regard to those properties which are specified for reformulated gasoline certification." The reported volume for the batch should be the…

  • Last published: July 11, 2024

• What basis is to be used for reconciliations, volume (gallons or barrels) or weight? What does EPA consider to be perpetual inventory? (Is a plant balancing considered a perpetual inventory?)

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Section 80.128 (Agreed upon procedures for refiners and importers) provides for comparison of records on the basis of volume except in section 80.128(b) which provides for analysis of gasoline inventory reconciliation records. While EPA anticipates that the standard…

  • Last published: July 12, 2024

• What is the definition of oxygenated fuels program control area and oxygenated fuels program control period?

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . As per section 80.2 of the regulations, an oxygenated fuels program control area means a geographic area in which only oxygenated gasoline may be sold or dispensed during the control period. An oxygenated fuels program control period means…

  • Last published: July 11, 2024

• What options are available to pipelines for dealing with interface material, i.e., mixtures of two different types of product that result when the different products are adjacent during pipeline movement?

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Interface Mixtures Involving RFG or RBOB First, the pipeline must minimize the instances of prohibited mixing, through the sequencing together of product types that may be legally mixed, to the greatest extent possible. Second, in those instances where…

  • Last published: July 12, 2024