Learn the Issues
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Do PTDs have to accompany gasoline going to customers who receive the product in containers of less than 550 gallons, since these customers are technically not wholesale purchaser-consumers under the regulations?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Section 80.77 provides that on each occasion when any person transfers custody or title to any RFG or RBOB, other than when gasoline is sold or dispensed for use in motor vehicles at a retail outlet or wholesale purchaser-consumer…
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Concerning the EPA method for total aromatics: a) Does EPA know of a source where all the components on the table in the method can be purchased? We have not been able to find one component, 1,3 diethyl benzene. Please state the manufacturer and the and the availability of each aromatic component in the method table.
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. a) EPA is using the five level calibration mixture recommended in the ASTM draft method for aromatics in gasoline. Pre-made standards for that method can be purchased from at least two vendors. The list of compounds used in the…
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For conventional gasolines, can a refiner use the same methods that were accepted for baseline determination for compliance testing if they are correlated to the regulatory methods?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. No. The methods specified in § 80.46 must be used for conventional gasoline. See § 80.101(i)(1)(i)(A). (7/1/94) This question and answer was posted at
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The Complex Model upper limit for RVP of conventional gasoline is 11.0 psi. Will winter gasoline meeting ASTM Class C and D specifications of 11.5 psi and 13.5 psi vapor pressures be allowed?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. As described in §80.45(c)(2), (d)(2), and (e)(2)(i), use of the winter version of the Complex Model requires that the RVP be set to 8.7 psi for both the baseline and target fuels. Thus the valid range limits associated with…
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Can refiners ship RFG with an RVP result of less than 6.4 psi, but use 6.4 psi in the emission parameter calculations?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. The valid range limits associated with the Complex Model are given in §80.45(f). These standards apply to every batch of RFG. Since the lower end of the valid range limit for RVP is 6.4 psi, no valid batches of…
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Can refiners use the E300 and E200 conversion equations in lieu of re-graphing the distillation data?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Refiners should use the most accurate means available to determine values for E200 and E300. If these parameters cannot be measured directly, they must be converted from distillation data via curve-fitting. Only if no distillation data exists can the…
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Are there any circumstances where a pipeline could be considered an oxygenate blender?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. If a pipeline otherwise meets the definition of oxygenate blender (i.e., 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…
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Section 80.65(f)(2)(i) & (ii) Independent analysis requirement. states that any importer shall designate one independent laboratory for each import facility at which RFG or RBOB is imported and identify the designated independent laboratory to the EPA according to the registration requirements in § 80.76. However, § 80.76(c)(3) requires separate facility registrations only for refineries and oxygenate blending facilities. How and where do importers provide the required facility information?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. There are two ways that an importer may designate which independent lab(s) it will use. The first, which is reflected in § 80.76(c) of the corrections to the RFG regulations, is to complete a facility registration for each PADD…
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Resources for Safer Choice Product Manufacturers
A portal to help Safer Choice partners locate technical and other information most relevant to their operations
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Webinar: Updates to GSA Advantage and what it means for Safer Choice-certified products
On April 9, 2024, EPA will host a webinar discussing updates to federal purchasing and GSA Advantage that highlight Safer Choice-certified products.
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Section 80.65(e) states that oxygen, benzene, and RVP must be known for each batch of RFG prior to release from the refinery. Does this requirement apply to RBOB?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Section 80.75(a) requires a refiner or importer of RBOB to report the properties, pursuant to §§ 80.65 and 80.66, of each batch of RBOB it produces or imports. Section 80.69(a)(2) requires refiners and importers of RBOB to test a…
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Section 80.41(p) states that if a maximum or minimum standard is changed to be more stringent, the effective date for such a change shall be ninety days following the date EPA announces the change. Yet in 80.40(k)-(o) it is stated that the more stringent standard goes into effect beginning in the following year. Is this inconsistent?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. In the case of the average standard, a more stringent ratcheted standard will be effective for the entire year even if the ratchet is not announced by EPA until late in the previous year or early in the year…
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Section 80.101(d)(3) states that "Any refiner for each refinery, or any importer, shall include in its compliance calculations. . . any gasoline blending stock produced or imported during the averaging period which becomes conventional gasoline solely upon the addition of an oxygenate." Should the volume reported to the EPA be the blendstock volume or the volume after the addition of the oxygenate (blendstock + oxygenate)?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Under § 80.101(d)(3), the refiner or importer must include in its compliance calculations the volume of gasoline blending stock that was used in the production of conventional gasoline produced solely upon the addition of oxygenate, and not the volume…
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Review of fungibility issues - what types of RFG may or may not be combined: at terminals? at retail? by consumers?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Section 80.78(a) requires the segregation of several categories of gasoline. These categories are: RFG may not be mixed with conventional gasoline, and sold or used as RFG. RFG blendstock for oxygenate blending (RBOB) may not be mixed with RFG…
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The regulations state that no person may combine any RFG with any non-oxygenated blendstock unless that person meets each requirement specified as a refiner. Does this mean that if any such blending is done at a terminal then they would be required to have the full analytical capabilities required of a refinery. Could metering at the terminal be an acceptable substitute? Can documented blendstocks be blended and certified using meters?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. The addition of a blendstock to certified RFG, or the combination of several blendstocks to produce RFG, would result in the blender becoming a refiner under the RFG regulation with all the testing, certification and other requirements under the…
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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
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Climate Resilience: What to Expect, How to Prepare, and What You Can Learn from Others
Flyer, presentation, and additional resources for the Climate Resilience: What to Expect, How to Prepare, and What You Can Learn from Others, Oct.29, 2014
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At a recent seminar hosted by SIGMA, EPA officials indicated that transfer documentation would be satisfactory if initiated by the transferee as long as both parties agreed to this system. Please confirm this understanding?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Your understanding is correct. However, while EPA would not object to a cooperative agreement between the transferor and the transferee, the transferor remains liable if the transferee does not have all the required PTD information for each batch. (9/26/94)…
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Outstanding gasoline exchange balances are commonly closed out between trading partners on an accounting basis because they are too small for an economic physical shipment. These "book transfers" do not in themselves cause the transportation or storage of product. Is it correct to assume that these activities are not subject to a requirement for PTD's?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. The PTD requirements refer only to the transferring of custody or title of any reformulated gasoline, RBOB, or conventional gasoline. If these "book transfers" involve the transferring of custody or title of such fuels then the PTD requirements would…
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Our computerized control system collects, calculates, and historizes data for blends and product movements. The data can include volumes, analyzer results, manually entered lab results, etc. Data is historized by writing a file to the equivalent of a personal computer hard disk. The data collected in the files will be used for reformulated fuels documentation. The file is protected such that only a person with a physical engineering key can unprotect the file. Is this acceptable data control to the EPA?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Data control and recording systems should be proposed in the exemption request as part of an overall quality control, record keeping and review plan. All data that is generated for the batch that is intended to form a basis…