Learn the Issues
-
What are the differences between the summer and winter models and what is their justification?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. The equations, extrapolations, and normal-to-high emitter ratios remain the same when one switches from the summer version of the Complex Model to the winter version. However, four changes do take place. First, the baseline fuel is changed from the…
-
What is the affect of a "clean" attestation and/or regulatory audit on subsequent compliance violations identified?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. An attestation engagement report for the refinery or importer that indicates no discrepancies has no bearing on a violation by the refiner or importer that may be determined by EPA. With regard to the CPA or CIA who conducted…
-
What is the responsibility of the independent lab in determining whether a tank of RFG meets the definition of "batch," i.e., is homogeneous with regard to the RFG properties?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. The independent sampling and testing provisions require the independent lab to collect a separate sample from each batch of RFG. "Batch of reformulated gasoline" is defined at § 80.2(gg) as "a quantity of reformulated gasoline which is homogeneous with…
-
When measuring total aromatics using a GC-MS, can either method A or method B be used, or must both be used?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Either method A or method B may be used. (7/1/94) This question and answer was posted at Consolidated List of Reformulated Gasoline and Anti-Dumping Questions and Answers: July 1, 1994 through November 10, 1997 (pdf) (333 pp, 18.17 MB…
-
When a portion of a batch is shipped to a customer while the batch is still being blended, assuming an approved in-line blending system, does the batch ID number for the shipping documents pertain to the portion shipped or to the whole batch?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. The batch identification number is assigned to the total batch volume as is represented by the composite sample. Section 80.77 does not require refiners to include the batch identification number or total batch volume on the product transfer documents…
-
When no oxygenates are added to gasoline, must an oxygenate analysis be performed?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Under the anti-dumping requirements, the refiner and importer is required to determine the properties of each batch of gasoline required for determining compliance with the applicable standards. Under the simple model, an analysis for oxygenates would clearly be unnecessary…
-
When performing simple and complex model calculations, what number of decimal places need to be entered for each of the gasoline properties?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Fuel parameters should be rounded to the following decimal places: RVP 2 decimal places Olefins 1 decimal place Benzene 2 decimal places E200 1 decimal place Sulfer 0 decimal places E300 1 decimal place Aromatics 1 decimal place (7/1/94)…
-
When presenting the gasoline pool data (EPA Table 6), is it ok to present just summer, winter, and annual average data, rather than monthly data?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Yes, it is acceptable to present seasonal gasoline pool data. The format of this table will depend on the data available. (7/1/94) This question and answer was posted at Consolidated List of Reformulated Gasoline and Anti-Dumping Questions and Answers…
-
When replacing conventional gasoline with RFG at a terminal, is it considered blending if the RFG is mixed with conventional bottoms?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. During the transition period prior to December 1, 1994, certified RFG may be put into tanks that contain conventional gasoline bottoms, as long as the tank is essentially filled with certified RFG gasoline on December 1, 1994, and the…
-
When preparing samples for oxygen analysis according to section 80.46(g), isn't there a risk of losing volatile components when allowing samples to come to room temperature?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. The fractional loss during "limited" sample handling is not measurable for these properties. (7/1/94) This question and answer was posted at Consolidated List of Reformulated Gasoline and Anti-Dumping Questions and Answers: July 1, 1994 through November 10, 1997 (pdf)…
-
Who is required to register for the Reformulated Gasoline and Anti-dumping Program?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Refiners and importers of conventional gasoline, reformulated gasoline or RBOB and oxygenate blenders producing reformulated gasoline by blending RBOB with oxygenates must register with EPA prior to producing or importing such products. Independent laboratories must register prior to being…
-
Who is the transferor and who is the transferee in the case of an exchange transaction? The sequence of physical custody is from terminal to truck to retail outlet, but the sequence of legal custody is from the terminal to exchange partner to marketer to
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Any party who is receiving title or custody of the delivery would be considered a transferee, any party who relinquishes title or custody would be considered a transferor and any party who both receives and relinquishes title or custody…
-
Who is a renewable fuel producer? Will the EPA recognize ethanol marketing companies as producers? Can the term "producer" apply to a marketing company who represents various producing plants?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Renewable fuel producers are parties that produce renewable fuel (i.e. convert a renewable feedstock into a renewable fuel). RINs must be generated by the producer and assigned to renewable fuel by the time title to the renewable fuel is…
-
Who is the oxygenate blender in a situation where a petroleum marketer who holds title to the gasoline engages a common carrier tank truck company to transport the gasoline, and, upon the completion of loading the truck, but before leaving the marketer's
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. In both scenarios, since the marketer owns the gasoline and the carrier owns the oxygenate blending facility (i.e., the truck in which blending takes place) and executes the blending operation, both parties fit the definition of an oxygenate blender…
-
To whom does the 20% limit on previous year RINs apply?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. This limit applies only to obligated parties. Under regulation Section 80.1127(a)(2), no more than 20% of the gallon-RINs used by an obligated party to meet its RVO can be previous-year RINs (having a YYYY code that is one year…
-
Why is the Digital Herzog excluded as a compliance test acceptable for RVP measurement under section 80.46?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Method 3 was selected for RVP measurement because it has been shown to have much greater precision than the Digital Herzog. (7/1/94) This question and answer was posted at Consolidated List of Reformulated Gasoline and Anti-Dumping Questions and Answers…
-
Would a refinery that receives RBOB from another refinery and blends oxygenate(s) with that RBOB to make RFG also have to register as an oxygenate blender?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Yes. Under § 80.2(mm), an oxygenate blender means "any person who owns, leases, operates, controls, or supervises an oxygenate blending facility, or who owns or controls the blendstock or gasoline used or the gasoline produced at an oxygenate blending…
-
Would it be permissible to send a manual to downstream parties detailing the minimum and maximum values and requirements of each standardized product code (including different product codes for the difference minimum and maximum standards that would apply
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. It would be permissible to use codes to represent all required PTD information except for the statements required under § 80.106(a)(1)(vii) and (b) for conventional gasoline and certain conventional blendstocks. The response to Question 4 of the Product Transfer…
-
Would it be permissible to combine (i.e., commingle) any-oxygenate RBOB with an RBOB designated for blending with 10 vol% denatured ethanol, provided the new RBOB (resulting from the combination) is designated for blending with 10% denatured ethanol?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Section 80.78(a)(7) provides that "no person may combine any reformulated gasoline blendstock for oxygenate blending with any other gasoline, blendstock, or oxygenate...," and § 80.78(a)(7)(ii), states that an RBOB may be combined with "other RBOB for which the same…
-
Are sampling requirements based on 50% of volume or on one-half of the number of batches?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Sampling requirements are based on the number of batches, not the volume, over a minimum of six months. (7/1/94) This question and answer was posted at Consolidated List of Reformulated Gasoline and Anti-Dumping Questions and Answers: July 1, 1994…