Learn the Issues
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During a transition period, refiners will produce VOC-controlled RFG that is blended with non VOC-controlled RFG downstream of the refinery in order to blend down RVP prior to the beginning of the VOC season. How will the resultant mixture be classified a
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The resulting gasoline should be listed as non VOC-controlled RFG on the PTD's, unless the resulting blend meets the requirements to be designated as VOC-controlled gasoline.(7/1/94) This question and answer was posted at Consolidated List of Reformulated Gasoline…
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Does EPA make any distinction in terms of timeliness between PTD's which memorialize a transfer of title as opposed to those which memorialize a transfer of custody? For example, exchange statements detailing liftings by an exchange partner ordinarily are
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Section 80.77 does not distinguish between transfers of custody and transfers of title. Nevertheless, EPA believes the two situations may be different in terms of the timing necessary for PTD information. In the case of transfers of custody…
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Does EPA intend to grant approval for in-line blending systems that do not have the opportunity for sampling and analysis prior to fungible mixing?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . As discussed in the answer to question #7 above, samples taken for determining the certified properties of the fuel, and some analysis of the gasoline properties, must occur before the gasoline is fungibly mixed with other gasoline.(7/1/94) This…
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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…
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Confirm that an RFG property measured from a sample collected during an EPA inspection is in technical violation if that property exceeds an applicable standard, but that no enforcement action will be brought by EPA unless the property exceeded the standa
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . As stated in the preamble to the RFG final rule, at 59 FR 7764 (February 16, 1994), EPA will not initiate an enforcement action on the basis of a test result from a gasoline sample collected at a…
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We understand it is not necessary to use the words "transferor" and "transferee" on PTD's as long as the parties giving and receiving custody/title are identified. Our concern was with the carrier receiving custody from a marketing terminal and then passi
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Your interpretation is correct. If the paperwork properly reflects the chain of custody through the carrier and shows the proper dates and locations for the different transfers, you have met the PTD requirements with regard to the transfer…
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There are situations where ethanol will be present in very small quantities in RFG produced using other oxygenates. For example, ETBE often contains very small amounts of ethanol, less than 2%. As a result, will EPA apply a de minimis exception to the pro
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Section 80.78(a)(8) prohibits the mixing of VOC-controlled RFG produced using ethanol with VOC-controlled RFG produced using any other oxygenate during the period January 1 through September 15. EPA will not consider this prohibition violated, however, in the case…
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We would like to preprint as much of the PTD information as possible on our bill of lading for gasoline sales at our terminals. We would like to print a statement such as the following on all tickets: "Maximum RVP of 8.3 psi if gasoline is designated as V
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . A statement such as the one in the question would be acceptable assuming that the product is also identified as being VOC controlled or not VOC controlled in accordance with § 80.77(g)(1)(i).(1/17/95) This question and answer was posted…
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On a shipment from our refinery to a pipeline we are often providing transfer of title to another oil company while simultaneously transferring custody to the pipeline. Pipeline companies are telling us that as long as the shippers code (as part of the ba
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . No. As the transferor, you would be responsible for providing PTD information to any party that directly receives custody or title of a delivery of RFG, RBOB or conventional gasoline from you. In the above scenario you would…
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We are a domestic refiner who also will be importing (paying customs duties) conventional and reformulated gasoline into our own marketing terminal. It is our understanding that we would be the transferor, not the foreign refiner from whom the product was
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The foreign refiner's paperwork would satisfy the PTD requirements if you provide it to the transferee and it includes all of the required PTD information, including the proper date and location of the transfer. (10/31/94) This question and…
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Science & Case Studies
EPA conducts analysis and research to address important issues related to the potential health, ecological, and socio-economic impacts of trash and debris in the aquatic environment.
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What are the requirements for reporting to EPA in the case of an independent lab that conducts sampling and testing that is unrelated to the independent sampling and testing requirements that apply for refiners or importers, such as quality assurance samp
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . There is no requirement that the results of downstream quality assurance sampling and testing must be reported to EPA. This is true both in the case of quality assurance sampling and testing by downstream parties such as pipelines…
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Under the RFG regulations, RBOB cannot be mixed with RFG. However, normal tank blending of oxygenates will require the presence of residual "heels" of RFG from prior batches of RBOB and oxygenate blending, or routinely large portions of the preceding batc
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . EPA would not treat the prohibition against mixing RFG and RBOB as having been violated in the situation you describe as long as the volume and oxygen content of the residual RFG from the prior batch have been…
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U.S. Customs regulations allow duty free entry for certain products produced in the United States that are exported from one U.S. port and imported at another U.S. port. These products are classified under U.S. Customs regulations as American Goods Return
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . 40 CFR §§ 80.65 and 80.101 require importers of RFG or conventional gasoline to meet applicable standards, and to meet other requirements including sampling, testing, record keeping, and reporting. EPA considers gasoline to be imported for purposes of…
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Frequent Questions Related to Hazardous Waste Recycling, the Definition of Solid Waste and Other Exemptions and Exclusions
Frequent Questions Related to Hazardous Waste Recycling, the Definition of Solid Waste and Other Exemptions and Exclusions
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Rather than bracketing all components of a sample during the GC-MS analysis in section 80.46(f), can a laboratory use linearity curves for the components?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Yes. We only require that the calibration standards bracket the concentration range of samples. You may use the linearity curves when analyzing the unknowns.(7/1/94) This question and answer was posted at Consolidated List of Reformulated Gasoline and Anti-Dumping…
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When does the independent sampling and testing requirement begin?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The independent sampling and testing requirements apply to each batch of RFG that is produced or imported, unless an in-line blending waiver has been obtained. As a result, the independent sampling and testing requirements begin for any refiner…
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What testing must an oxygenate blender conduct at the point of blending?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The requirements for oxygenate blender testing are contained in §§ 80.69(b) through (e) of the regulations.(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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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…
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What constitutes "periodic sampling and testing"?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . EPA has not defined the frequency or scope of sampling and testing that is necessary to meet the quality assurance program defense element, because there is no single program that is appropriate in all situations. In addition, EPA…