Learn the Issues
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Section 80.74(a)(2)(ii) requires "the identification of the person who collected the sample and the person who performed the testing." In the case where samples are taken and analysis performed by an independent testing company, would it be sufficient to identify the independent testing company in place of the sampler and tester?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Yes. (4/18/95) This question and answer was posted at
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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…
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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…
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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…
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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…
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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…
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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…
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The preamble to the final rule states that "oxygenate added to a refiner's or importer's gasoline or blendstock downstream of the refinery or import facility may be included in the refiner's or importer's compliance calculations only if the refiner or importer is able to demonstrate with certainty that the oxygenate has been added to that party's gasoline." The preamble further states that "as a result of the complexities inherent in tracking gasoline through the fungible distribution system, EPA believes in most cases it will be impracticable for refiners or importers to effectively monitor downstream oxygenate blending with gasoline that is shipped fungibly, and as a result the refiner or importer normally would be precluded from the oxygenate in compliance calculations".
The scenario in question is:
o a refiner ships conventional gasoline produced by the refiner through a common-carrier pipeline;
o batch shipments allow for tracking of the refiner's gasoline within the pipeline;
o shipments are received into the refiner's storage;
o these receipts might be commingled fungibly with conventional gasoline produced by another refiner;
o oxygenate is added at the rack into all of the fungible gasoline.
a) Can the refiner gain oxygen credits for anti-dumping compliance for a prorata share of the oxygenate added to all gasoline, on the basis of the proportion of gasoline blended that was produced by the refiner?
b) Is the refiner's ability to gain oxygen credits impacted, in any way, by the configuration of the common-carrier pipeline (e.g. breakout tanks, batch versus open-stock system, etc.)?
c) Is the refiner's ability to gain oxygen credits impacted, in anyway by the configuration of the refiner's storage (e.g., dedicated versus community, etc.)?
d) Could the accounting be done on a monthly basis, or would the refiner have to track the ratio of gasoline produced by the refiner versus that produced by another refiner after each batch?See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . a) Yes, provided there is sufficient documentation to calculate the proportion of gasoline produced by the refiner, and, all other requirements of §80.101(d)(4)(ii) are met. b) The configuration would have to be such that the refiner could, indeed…
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Cleaning Up, Protecting and Preserving Tribal Lands
EPA provides funding and technical assistance in Indian country and Alaska Native Villages to build tribal environmental cleanup and waste management capacity that supports tribal self governance.
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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…
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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…
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Must the refiner track the barrels and qualities of each batch of gasoline beyond the tank in which it was certified?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . No, but the batch volume is not determined by tank volume; rather, it is determined based on shipment volume. (7/1/94) This question and answer was posted at
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Must reformulated gasoline be sold only in those areas designated as reformulated gasoline areas by the EPA? Can a refiner produce and designate certified reformulated gasoline for distribution and sale even though there may be no immediate reformulated gasoline market for that product except as a replacement for conventional gasoline? Are the volume and fuel parameters of the gasoline to be incorporated into the anti-dumping compliance calculations?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Reformulated gasoline may be sold in areas not designated as RFG areas. However, if the reformulated gasoline is mixed with conventional gasoline, it may not be sold as reformulated gasoline. Certified reformulated gasoline used in a non-RFG area…
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May RFG that is found to be off-spec downstream of the refinery or import facility be corrected by blending "clean" non-oxygenate blendstocks?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Any party who combines blendstocks other than oxygenate with RFG is producing gasoline, and must meet all the RFG standards and requirements applicable to a refiner. In addition, all applicable RFG standards must be met by the blendstock…
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Tools for Tidal Restriction Avoidance and Removal Webinar
Tools for Tidal Restriction Avoidance and Removal
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Watershed Academy Webcast Certificate October 15, 2015
A downloadable completion certificate.
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May a party add more oxygenate to RBOB than is specified in the product transfer documents for the RBOB?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Section 80.78(a)(7)(i) requires that RBOB may be blended only with oxygenate of the type and amount (or within the range of amounts) specified by the RBOB refiner, and recited in the RBOB product transfer documents. Nevertheless, there is…
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Find Out About Health and Economic Impacts from Water Utility Emergencies
Provides and overview and allows utilities to download the Water Health and Economic Analysis Tool