Learn the Issues
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When a party lifts gasoline at a terminal, there is usually both a transfer of custody (to the carrier) and a transfer of title (to the person taking title). If all required PTD information is given to the carrier through a bill of lading, is it also nece
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The transferor must provide PTD information to both the transferee of custody and the transferee of title. As a result, the required PTD information must be provided to both the carrier (the transferee of custody) and the person…
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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…
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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…
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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…
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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…
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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…
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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…
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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…
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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…
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We believe that computer controlled sequential blending of oxygenates at the rack is at least as accurate as computer controlled in line blending. Is sequential blending of oxygenates at the rack considered sufficiently equivalent to computer in line blen
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . For purposes of § 80.69, computer controlled sequential blending is considered to be a form of computer controlled in line blending, and qualifies for the sampling and testing rates applicable to computer controlled oxygenate blending under §§ 80.69(a)(7)(i)(B)(2)…
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Agriculture
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We assume that a terminal operator who stores gasoline for a terminalling customer is responsible for receiving transfer documentation on RFG and conventional gas moved into the terminal for the customer. The terminal then records and stores copies of the
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Yes. (9/12/94) 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)
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A refinery places two batches of gasoline that have been sampled and certified as reformulated gasoline with the same designation into a tank. Must the refinery assign a new batch ID to the mixture or can it be identified with the two previously assigned
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . No new ID is necessary. Batches of reformulated gasoline may be fungibly mixed, subject to the segregation provisions of § 80.78. (7/1/94) This question and answer was posted at Consolidated List of Reformulated Gasoline and Anti-Dumping Questions and…
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Section 80.101(i) provides a composite sampling and testing option to determine conventional gasoline properties. One provision to this option is that composite samples will need to be prepared as described in § 80.91(d)(4)(iii). Part B of this procedure
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The best process would be to avoid the butane adjustment by blending the fuels in such a way that butane loss is avoided. Practically, this means having all fuel samples at or below 32 degrees Fahrenheit before their…
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With respect to section 80.65(a), would there be any violation by the terminal located in an RFG covered area selling only conventional gasoline to stations in attainment areas?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . No. However, the terminal should take extra precautions to ensure that no conventional gasoline is distributed to a RFG area. See the discussion in the Prohibitions and Liabilities Section. (7/1/94) This question and answer was posted at Consolidated…
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The regulations require a refiner or importer to determine and report properties for each batch of reformulated and conventional gasoline it produces or imports. The wording would indicate that a refiner would report the volume produced into a tank. A bet
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The method described above is appropriate for determining the volume and properties of a batch of conventional gasoline as required by the anti-dumping regulations provided the sample analyses and volume determination are supported by appropriate documentation. (7/1/94) This…
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The regulations require that an importer be registered 90 days before imports are received. Does this mean the company or the facility?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Both. If an importer chooses to register individual import facilities it must register them 90 days prior to shipping into them. However, an importer is only required to register its activities in each PADD (still 90 days in…
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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)…
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The regulations dictate specific equipment and methodologies for reformulated gasoline analysis. We recommend that the EPA only specify the precision or level of accuracy it requires and let the chemist or laboratory decide which method and type of equipm
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Although this may be possible at some time in the future, at the present time, tolerance issues dictate that we specify equipment and method. (7/1/94) This question and answer was posted at Consolidated List of Reformulated Gasoline and…
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Regulation Section 80.1126(d)(1), which says "must," seems in conflict with Section 80.1126(d)(2) which says "may". Is the correct reading that any volume of renewable fuel that leaves a producer's gate on or after 9/1/07 MUST have RINs assigned?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Renewable fuel producers and importers may generate RINs for renewable fuel they own on September 1, 2007 that was produced or imported earlier, and must generate RINs for renewable fuel produced or imported on or after September 1…
