Learn the Issues
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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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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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Does the product transfer documentation have to physically accompany a shipment of gasoline or could the documentation be sent electronically or by facsimile to the destination prior to the delivery arrival?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Whenever possible the PTD's should accompany the shipment of gasoline. However, in circumstances like pipeline transfers where this would be impossible, the PTD's do not have to physically accompany the shipment. The regulations (§ 80.77 and § 80.106) require…
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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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Is EPA making any allowances for refiners that utilize a computer-controlled in-line blending operation?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. EPA is allowing an alternative to the independent sampling and analysis requirement for certain refiners that produce RFG using computer-controlled in-line blending equipment. This option would be appropriate only in the case of relatively sophisticated in-line blending operations, where…
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EPA has stated that "product codes may never be used to meet the requirements for specific language regarding conventional gasoline." We believe that some pipeline companies have published conventional gasoline specifications with the required statement "This product does not meet the requirements..." with the intent that use of that product's code in the batch designation will meet the product transfer document requirements. Will the EPA accept this?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. No, the specific language regarding conventional gasoline at § 80.106(a)(1)(vi) and certain conventional blendstocks at § 80.106(b), can not be included only in product codes. The actual statements must be included in the product transfer documentation. (8/29/94) This question…
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A foreign cargo of RFG is to be imported into several terminals. Can the cargo be certified before discharge at the first U.S. port of entry and that certification used for all subsequent ports of entry, or must it be tested and certified separately at each U.S. port of entry?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Certification of every batch of imported RFG must occur separately for Customs purposes at each U.S. port of entry. For example, if a vessel goes first to New York to discharge half its cargo, then proceeds on to Philadelphia…
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In the GC-MS test for aromatics, why must the calibration curves be forced through the origin? All mass spectrometers will show some noise at a zero concentration level.
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Calibration curves are not required to be forced through the origins. The reference in the regulation is a suggested method. (7/1/94) This question and answer was posted at
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If a pipeline must be classified as a refiner, how would that be handled administratively by EPA? Since pipelines don't own the product, would pipeline have to become buyers and sellers for regulatory purposes?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Refiners must be registered with EPA. The pipeline need not be an owner of the gasoline to be a refiner. (7/1/94) This question and answer was posted at
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How may terminals and retail outlets transition from non-VOC-controlled RFG to VOC-controlled RFG in advance of the high ozone season each spring?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Section 80.78(a)(1)(v) requires that RFG must be VOC-controlled for the proper VOC-control Region when stored or dispensed by terminals beginning May 1 of each year, and for retail outlets and wholesale purchaser-consumers beginning June 1 of each year. As…
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The valid range limits for the Simple and Complex Models given in § 80.42(c)(1) and § 80.45(f)(1), respectively, give the ranges outside of which fuels cannot be evaluated with the compliance models. What are you supposed to use if the fuels to be evaluated are outside of the specified valid range limits?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. If a target fuel contains one or more fuel parameters which are outside the valid range limits, the compliance models generally cannot be used to evaluate that fuel. To use the compliance models, a refiner may reformulate the fuel…
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We are best described as an "intermediate feedstock processor." We produce gasoline by processing feedstocks (that are derived from crude oil) in processing units which are the same as those used in crude oil refineries. We process less than 75,000 barrels of feedstocks per day, and are not owned or affiliated with anyone else. Are we a "small refinery" under the RFS regulation and not an obligated party until 2011, unless we opt into the program?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Yes. EPA's definition of "small refinery" is identical to the definition used in EPAct, as it was intended to implement the EPAct provisions. EPAct defines a small refinery as a refinery for which the average aggregate daily crude oil…
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