Learn the Issues
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If a party identifies RFG that is out of spec for a downstream standard, and the party wants to bring the gasoline back into spec by blending it with other RFG or with blendstock, must the party be registered with EPA as a refiner, and must the party meet
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . If RFG at a location downstream of the refinery or import facility level is found to violate a downstream standard, a violation of the RFG requirements has occurred for which various parties will be liable, and for which…
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Must oxygenate be added to RBOB downstream of the refinery?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Yes. Oxygenate must be added to RBOB in the proper type and amount regardless of where it is sold. Specifically, section 80.77(a)(7) prohibits any person from combining RBOB with any other gasoline, blendstock, or oxygenate except oxygenate of…
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Must a refiner identify a single independent lab for each refinery?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Yes. Although an independent lab may use a substitute lab for certain tasks, a refiner is required to name a single independent lab for each refinery. It is this independent lab with which EPA will communicate regarding the…
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May import facilities be grouped together for compliance and reporting purposes?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . For the most part, separate import facilities owned by one importer must be grouped together. All compliance demonstrations are to be made based on the aggregate of all gasoline imported into the United States by an importer. This…
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It is my understanding that under the RFG regulations the EPA mandates product transfer documentation for conventional gasoline starting January 1, 1995, not December 1, 1994. Is this correct.
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Yes.(11/21/94) 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, EPA420-R-03-009, July 2003, About PDF )
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Is Puerto Rico considered a domestic producer? There are no federal RVP standards there--do they use summer fuels in the winter complex model?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Puerto Rico refineries are considered federal gasoline producers. If their fuel remains seasonally the same throughout the year, they meet the criteria of a refiner marketing in an area with no seasonal changes, and they are only required…
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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…
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If a refiner produces gasoline at the direction and to the specifications of a distributor who will ultimately purchase it, and a violation is discovered at the refinery, will both parties be jointly and severally liable for the violation? How can the dis
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . In a case where a refiner produces gasoline to specifications that are set by a distributor, and where that gasoline does not meet applicable refiner-level standards, the refiner who actually produces the gasoline clearly would be liable for…
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If a new area decides to opt-in to the reformulated gasoline program, what determines the effective date that reformulated gasoline must be supplied to that area?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The effective date of the program in any area which opts into the program is January 1, 1995, or one year after EPA receives the request to include the area in the program, whichever is later. EPA will…
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May an importer classify imported product as GTAB when that product meets all the EPA requirements for RFG or conventional gasoline, and take advantage of any specification "slack" in imported gasoline through component blending under the GTAB guidance?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . An imported product that meets the definition of gasoline may be classified as GTAB by the importer if the conditions specified in the August 29, 1994 Question and Answer document are satisfied, regardless of whether the gasoline meets…
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Many states have adopted a 1.0 psi waiver for ethanol blends during the RVP control period. In areas where RFG is required, do states need to amend that regulation in any fashion in order to not be in conflict with RFG requirements?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . In areas where RFG is required, states are preempted from having RVP requirements which are different from the RFG simple model requirements unless those requirements are approved by EPA as a SIP amendment which is necessary to attain…
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Is there a required format for the wording of the certification for RFG? If not, is there a re ommended or suggested format for certification in the PTD's, for downstream parties?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . No, to both questions. Section 80.106(a)(1)(vii) does specify certain language for conventional gasoline. (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…
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Is there a "recommended" calculation tool for performing Complex Model calculations?Related question: In view of inconsistencies between the current regulations and the Complex Model spreadsheet posted by EPA, which should industry follow? If the answer i
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The version of the Complex Model that is legally binding is that contained in the Federal Register. 9 The printed version of the Complex Model in the Federal Register does contain several minor errors which are under correction…
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Is it possible to get an exemption to use conventional gasoline in an RFG covered area for testing purposes?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The RFG regulations do not provide an exemption from the RFG requirements for testing purposes. However, EPA would consider allowing the use of conventional gasoline in an RFG covered area for purposes of a testing program if sufficient…
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Is independent sampling and testing required of a refiner who has an in-line blending program?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Refiners who produce RFG using computer controlled in-line blending, and who have received an exemption from EPA from independent sampling and testing, are not required to conduct independent sampling and testing of RFG produced with this blending operation…
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How is the RVP and distillation non-linearity handled?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The RVP of hydrocarbons and oxygenates should actually blend very linearly, with the exception of the lighter alcohols, methanol and ethanol. Methanol is not expected to be used as an oxygenate due to its high RVP, and there…
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Must imported RFG be tested at the import facility or may the importer use the test results from a foreign source, or alternatively, from vessel samples secured from the vessel after loading is completed? Many independent labs operate internationally. Als
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Importers must certify each batch of RFG and conventional gasoline based upon samples collected after the vessel carrying the gasoline has entered the U.S. port of entry where the gasoline will be discharged. Under § 80.65(f)(2)(ii), importers must…
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Must a terminal be registered as a refinery in order to blend transmix?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . EPA has described procedures for pipelines to blend transmix into conventional gasoline and RFG under certain situations. A pipeline that blends transmix into either conventional gasoline or RFG using the procedures described in these answers will not be…
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May survey samples be used as a substitute for a refiner's quality assurance program for enforcement purposes?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Surveys may not be used as a substitute for a regulated party's own quality assurance program.(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…
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May a refiner use the same independent lab to satisfy the RFG independent sampling and testing requirements and to conduct sampling and testing needs that are unrelated to the RFG requirements (e.g., internal quality assurance or custody transfer sampling
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Yes.(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, EPA420-R-03-009, July 2003, About PDF )