Learn the Issues
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A procedure has been outlined by the EPA for the certification of oxygen content by meter for the oxyfuel program. Can this method be used for certification of oxygen content in reformulated gasoline? Is an exemption for in-line blending required?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. No. The regulatory method for oxygen testing, or the approved temporary method discussed in question 39, must be used for certification of reformulated gasoline produced at the refinery and also for blending oxygenate with RBOB. For further discussion of…
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For the purposes of the RFG sampling and testing requirements under § 80.65(e) and (f), may a refiner use the option under which the independent lab samples and tests 100% of the batches for some parameters, and use the option under which the refiner tests 100% of the batches and the independent lab samples 100% of the batches and tests 10% of the batches for other parameters?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Refiners and importers may not use the 100% independent lab analysis option for certain parameters and the 10% independent lab analysis option for other parameters, but must use the same option for all RFG parameters. However, a refiner or…
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Is Puerto Rico considered a domestic producer? There are no federal RVP standards there--do they use summer fuels in the winter complex model?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Puerto Rico refineries are considered federal gasoline producers. If their fuel remains seasonally the same throughout the year, they meet the criteria of a refiner marketing in an area with no seasonal changes, and they are only required to…
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For purposes of RFG compliance on average, can refiners treat closely integrated facilities operating in a single covered area as a single facility, or must compliance be achieved separately for each facility? Suppose the refinery operation consists of mixing blending components to produce finished RFG using tankage in multiple terminals in close proximity, the blender is meeting all refiner requirements. and the blender is the responsible party for record keeping, reporting, and compliance. Can the refiner/blender aggregate the operations at all the facilities used for compliance on average purposes or must he meet the standards separately at each terminal?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Under § 80.67(b)(1), refiners must meet all applicable averaged standards separately for each of the refiner's refineries (i.e., for each facility at which gasoline is produced.) This would include terminals at which RFG is produced through a blending process…
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Is a PTD required for transferring an unassigned RIN?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. No. PTDs are not required when transferring unassigned RINs. However, PTDs are required whenever there is a transfer of ownership of a renewable fuel. Where the fuel is being transferred with assigned RINs, then the PTD must include information…
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Putnam and Orange Counties in New York were not included in the list of RFG covered areas in § 80.70. Was there exclusion an oversight?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Yes. A correction has been made to include Putnam and Orange Counties in the New York City reformulated gasoline covered area. These counties are part of the New York City CMSA and are thus appropriately part of the New…
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Public terminals that "refine" and "blend" RFG, RBOB or conventional gasoline as defined in the RFG rules at 40 CFR Part 80, and obtain agreements from their customers to comply with the refiner/blender requirements of the rule, will not separately need to register with EPA. It is my understanding that terminals in such situations must not register. Is my understanding correct?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. No. In a situation in which more than one party fits the definition of a refiner or oxygenate blender under the regulations, each such party is subject to the requirements under the regulations, including registration requirements. Where, for a…
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Section 80.77(d) requires the PTD to provide "the location of the gasoline at the time of the transfer." In a situation where the transferor is a truck carrier, what does the term "location" refer to?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. For the PTD transferred from the terminal to the truck carrier, "the location of the gasoline at the time of the transfer" would be the terminal. For the PTD transferred from the truck carrier to the next party in…
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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 batch designation) identifies that exchange partner receiving title, we do not have to generate a separate transfer document to that exchange partner. Is this O.K?
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 have…
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Should batch reports for blended gasoline be submitted by the facility at which gasoline is blended or the facility from which the blended gasoline is shipped?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. The facility where blending occurs. (7/1/94) This question and answer was originally posted at
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Should the summer toxics model be used for RFG during the 1995 California VOC transition seasons (i.e., before May 1 and after September 15) when California regulations limit RVP to 7.8 psi?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. RFG that is designated as VOC controlled by the refiner must use the summer model and must comply with the RVP standard for the appropriate VOC control region. RFG that is designated as non-VOC controlled by the refiner must…
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Should separate samples be collected for RVP analysis?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. One sample may be used for all of the RFG parameters that need to be determined, including RVP. However, because sample handling in the laboratory may affect various reformulated gasoline properties, such as RVP, analyses must be performed in…
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§ 80.101(i)(1) says that conventional gasoline cannot leave a refinery until testing is completed for all parameters used in the compliance calculation. (e)(2) of the same section says that for purposes of meeting (e)(1) a refiner may composite samples and treat that as one batch provided that the composite is not for materials produced or imported over more than one month. May material leave the refinery before analysis is run on the composite? Just a comment, is it really necessary to hold up a batch for at least three hours while an FIA is run for olefins especially since the results of an individual batch are irrelevant for conventional gasoline. Is it EPA's intention to preclude in-line blending of conventional gasoline by this requirement?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. The regulations have been revised at § 80.101(i)(1) to allow conventional gasoline to leave a refinery or importer facility prior to the completion of sample testing. Note that there are additional constraints related to composite samples at § 80.101(i)(2)…
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§ 80.77 of the proposed rule included conventional gasoline in the requirement for product transfer documents. This section, in the final rule, now excludes conventional gasoline and includes that product in § 80.106. This latter section however, states that it applies only "to product that becomes gasoline upon the addition of oxygenate only." Is it correct to interpret that, except for gasoline that has had an oxygenate added, conventional gasoline transfers do not require PTD's to be in compliance?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. No. All conventional gasoline, including blendstock that requires the addition of oxygenate only, must meet the product transfer document requirements in § 80.106. (7/1/94) This question and answer was posted at
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In a situation where Refinery A purchases finished conventional gasoline from Refinery B, Refinery B should include the gasoline in its compliance calculations and Refinery A should exclude it. If Refinery A blends the gasoline with its own blendstocks and, therefore, must mathematically adjust the volume and properties of the average conventional gasoline production to account for the gasoline from Refinery B, what properties should be used in this adjustment, the analysis performed by Refinery B prior to shipment, or the analysis performed by Refinery A as the product was received?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. The analysis of the product that is performed by Refinery A should be used. (4/18/95) This question and answer was posted at
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A tank of ethanol has become contaminated and must be disposed of. How would we treat this situation for RIN reporting under the RFS program?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. The RFS regulation envisions various scenarios under which RINs might be retired. The reporting section in the regulation names a few examples: retirement in satisfaction of enforcement action, spill, and use in a boiler or heater. We recognize that…
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If a downstream blender alters an RBOB by addition of other hydrocarbons, how is the baseline selected and how is the fuel regulated and reported?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Section 80.78(a)(7) prohibits any person from combining RBOB with any other gasoline, blendstock, or oxygenate except for oxygenate of the type and amount (or within the range of amounts) specified by the refiner or importer at the time the…
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If, due to piping constraints, a refiner must put a purchased or inter-refinery transferred batch of finished gasoline through the refinery blendstock system, but does so without the batch losing integrity, must the refiner include the batch in his compliance calculations?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. No. As per § 80.65(i) of the regulations, any refiner, importer, or oxygenate blender shall exclude from all compliance calculations, the volume and properties of any RFG that is produced at another refinery or oxygenate blending facility, or imported…
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If an oxygenate blender must transfer RINs with a volume of renewable fuel, who are they transferring to, if they are the final/end-user?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. If any oxygenate blender blends renewable fuel into gasoline or diesel, he is no longer required to transfer RINs and renewable fuel together. Question and Answer was originally posted at: Questions and Answers on the Renewable Fuel Standard Program…
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If EPA requests that an independent lab supply a portion of a sample to the EPA lab, what volume of gasoline should be sent to EPA?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. When EPA requests a sample from an independent lab, the independent lab should send EPA the entire one quart sample if the lab has not analyzed the sample. If the sample is one the independent lab has analyzed, the…