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Is there any problem with supplying RFG designated as VOC-controlled for VOC Control Region 1 to an area requiring VOC Control Region 2 gasoline?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. RFG designated as VOC-controlled for VOC Control Region 1 may be supplied to an area requiring RFG designated as VOC-controlled for VOC Control Region 2. The converse is not true, however. (7/1/94) This question and answer was posted at
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The transfer document requirements state that the name and address of the transferor and transferee be present. When other oil partners, exchangers, are picking up product, will the address of the company headquarters be sufficient since EPA will still be able to trace the path of title and custody to the fuel. In addition, when jobbers pick up product we will have multiple account numbers for one main jobbership. These individual accounts do not contain the address of the jobbership. Is it sufficient that we provide the business name of the jobbership on the transfer document? If the address is later required we could provide it from our internal computer record.
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Yes, the headquarters address of the transferee would be acceptable. When jobbers pick up gasoline they are the transferees in the transaction and the regulations specifically require that an address for all transferees be included on the product 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 prohibition against mixing VOC-controlled RFG produced using ethanol with VOC-controlled RFG produced using any other oxygenate because of minimal oxygenate content?
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 of…
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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 batch impossible to completely move into a pipeline shipment prior to receipt of more RBOB. Will EPA confirm that this mixing is not the subject of the prohibition against mixing RFG and RBOB provided no material is transferred from the blending tank between the time of new RBOB receipt (with oxygenate type and amount matching previous RBOB batches) and addition of the specified type and amount of oxygenate? Testing of finished RFG for required oxygen content and volume would be conducted in accordance with the regulations.
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 accounted…
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Under what environmental conditions must RFG samples be shipped and stored?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. The sample container specifications outlined in 40 CFR part 80, Appendix D, limit the materials and closure systems for sample containers, such that RFG properties will be maintained under normal conditions encountered during shipping (by air or ground), and…
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Under § 80.81(b)(2), California refiners are exempt from the independent analysis requirements set forth in § 80.65(f). Does this exemption allow California refiners to use a computer-controlled in-line blending operation without first obtaining an exemption from EPA?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Yes. Refiners of California gasoline may use computer-controlled in-line blending to produce RFG without obtaining an exemption under § 80.65(f)(4). However, RFG that does not meet the definition of "California gasoline" in § 80.81(a)(2) is subject to the independent…
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Unlike the PTD requirements for RFG and RBOB contained in § 80.77, the PTD requirements for conventional gasoline contained in § 80.106 do not indicate that PTD's are not required when gasoline is sold or dispensed for use in motor vehicles at a retail outlet or wholesale purchaser-consumer facility. Does this mean that retail stations that provide conventional gasoline must provide PTD's to their customers?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. PTD's are not required when conventional gasoline is sold or dispensed for use in motor vehicles at a retail outlet or wholesale purchaser-consumer facility. EPA intends to amend the regulations to reflect this. (10/17/94) This question and answer was…
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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 Returning to the U.S. This approach has been used, for example, in the case of certain gasoline and distillate products that are produced at U.S. refineries located on the Gulf coast and transported by ship to terminals located in Canada, and where the
product then is transported by truck to markets in the United States. What standards and requirements apply to imported gasoline in the case of gasoline that is classified by the U.S. Customs Service as American Goods Returning to the U.S.?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 the…
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What defines a batch for refineries utilizing in-line blending?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Section 80.2 of the regulations defines a "batch" as "a quantity of reformulated gasoline which is homogeneous with regard to those properties which are specified for reformulated gasoline certification." For refiners who are exempt from the independent sampling and…
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What documentation will be needed downstream to show certification of RFG?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Downstream of the refinery level, RFG may be considered to be "certified" if it is accompanied by product transfer documents, specified in § 80.77, that identify the gasoline as RFG. Of course, if downstream testing shows that gasoline does…
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What is the EPA definition of an importer under the RFG final rule?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. EPA's importer definition is found at 40 CFR § 80.2(r), which states that an importer is "a person who imports gasoline, gasoline blending stocks or components, or diesel fuel from a foreign country into the United States (including the…
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What is the Equivalence Value for E85? Is it 0.85 since its renewable content is only 85 percent?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. No. Equivalence Values are generated and apply to renewable fuel at the point of production or importation, not at the point of blending. Thus it is denatured ethanol, not E85 (nor E10) to which the Equivalence Value applies. A…
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What field test methods are acceptable for oversight programs?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. For purposes of meeting the downstream quality assurance defense element, parties may use any test method, so long as that method is performed in accordance with sound engineering and laboratory principles in a manner which provides reasonable correlation to…
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What is EPA's intent on requiring the location of off-site records on the facility registration?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. EPA needs to know where records are stored so that EPA inspectors may inspect those records. If a facility keeps some or all of its records off-site EPA needs to know the address of the primary off-site storage facility…
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What is the frequency of correlation samples for laboratories to remain qualified for reform testing?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. There is no definition of "qualified" laboratories under the regulations. The principle requirement for correlation relates to the use of one of the alternate methods allowed until 1/1/97. When one elects to use ASTM D1319 for measuring aromatic content…
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In what form should independent laboratories report batch test results?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Independent laboratories should use the same reporting forms and EDI formats used by regulated parties for reporting on batch test results. They will not need to report designations for each batch or the results of emissions calculations. (7/1/94) This…
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What happens if, after submitting his annual compliance demonstration report, a refiner discovers that he exceeded the 20% cap on the use of previous-year RINs in meeting his RVO? Is he required to replace those RINs with new valid RINs at the old market price?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Annual compliance demonstrations must include a showing that the RINs used to comply with the RVO include no more than 20% previous-year RINs. If it is determined that this showing was incorrect due to either a mathematical error or…
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What is the maximum oxygen content a refiner, importer or blender may certify, including blending allowances? Does this maximum oxygen content vary according to oxygenate type?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. In general, refiners, importers, and oxygenate blenders may not certify fuel at an oxygen level above the maximum cap of 2.7% by weight for VOC controlled RFG, or 3.5% by weight for non-VOC controlled RFG. The maximum oxygen content…
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What information needs to be included on RBOB product transfer documents? Is any information about min/max's required?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. The PTD requirements pertaining to RBOB can be found in § 80.77. They include the type of RBOB and the type and amount of oxygenate to be added as well as the min/max's for benzene and RVP, for VOC…
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What mechanisms exist to suspend RFS program requirements, should renewable supply be limited due to natural disasters?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. A: EPAct contains a provision to address unforeseen circumstances that may occur which result in a shortage of renewable fuel and available RINs and we believe that the statutory provision is sufficient to address unforeseen circumstances that may occur…