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Rather than bracketing all components of a sample during the GC-MS analysis in section 80.46(f), can a laboratory use linearity curves for the components?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Yes. We only require that the calibration standards bracket the concentration range of samples. You may use the linearity curves when analyzing the unknowns. (7/1/94) This question and answer was posted at
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Recently, a natural gas pipeline condensate was refused at a fractionator. The condensate met all fractionator specifications and did not contain any hazardous materials. The operator of the fractionator advised that their facility could only take in previously manufactured materials as a direct result of the anti-dumping rules contained in the reformulated gasoline regulations. Within the anti-dumping Subpart E, we cannot find any mention of previously manufactured materials. However, Subsection 80.102 "Controls applicable to blendstocks" does define "gasoline blendstocks" as products that are produced by a refiner but it also goes on to include other blendstocks with properties certain.
The condensate described herein would not meet the definitional requirements of a gasoline blendstock as its end point would disqualify it as a gasoline (if an oxygenate was added). The fractionator would separate the condensate into a gasoline component and a diesel component.
Is it the intention of the EPA that only manufactured products be used in blending either reformulated or conventional gasoline? Is it the intent to restrict the use of naturally occurring hydrocarbons in a fractionator that produces gasoline?See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. The regulations do not prohibit or restrict the use or distribution of any gasoline or gasoline blendstocks regardless of their origin. Compliance with the anti-dumping requirements is based primarily on the properties of finished conventional gasoline. However, for the…
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Referring to § 80.69, will EPA consider alternative testing approaches if extreme circumstances prohibit testing as defined by EPA? As an example, the situation may exist where an oxygenate blender is prohibited by state law from taking truck samples. In this case the only way to comply with EPA sampling requirements would be to somehow sample the batch as it is being dropped at its destination. This may be prohibited if the terminal only sells to jobbers. In addition, product sampled from trucks or retail outlets does not necessarily reflect product blended by the oxygenate blender. Residual fuel in trucks and or retail tanks will mix with the terminal product before sampling. A quality oversight of the RBOB in conjunction with meter readings showing proper delivery of oxygenate volumes may better reflect a terminal's product? How does the EPA plan to test in these situations?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. EPA will consider extreme circumstances that may prohibit sampling and testing as required by section 80.69. However, to date, EPA is not aware of such circumstances. Some state laws may prohibit the opening of truck compartment hatches during loading…
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A refiner produces a tank of conventional gasoline on December 30, 1995. The tank is not shipped until January 2, 1996. Must the refiner include this batch in his 1995 volume or does he have the option of including it in either 1995 or 1996?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Compliance for a particular batch of conventional gasoline is based on the date the batch is produced, not shipped. As a result, the batch identified in the question would be included in the 1995 compliance calculations. However, the volume…
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For a refiner producing conventional gasoline, may oxygenate added at a nonproprietary terminal be included in the determination of the conventional gasoline properties, provided the refiner has a quality assurance program at the terminal to ensure the oxygenate was added?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. A refiner may include oxygenates added to conventional gasoline by a party downstream of the refinery, including a "non-proprietary terminal," provided the refiner has a program in place to ensure that the oxygenate is added as reported by the…
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Is there a required format for the wording of the certification for RFG? If not, is there a recommended or suggested format for certification in the PTD's, for downstream parties?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. No, to both questions. Section 80.106(a)(1)(vii) does specify certain language for conventional gasoline. (7/1/94) This question and answer was posted at
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Is there a deadline for the submittal of a petition requesting an exemption from the independent sampling and testing requirements? #17
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. There are no time frames for or limitations in the regulations or the statute for submitting or reviewing in-line blending petitions. However, since EPA will need adequate time to review and resolve any outstanding issues before acting on a…
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For those with graphical data on E200/E300, will EPA allow use of either the equation or graphical for both baseline and compliance?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Graphical approaches to calculating E200 and E300 for all fuels (i.e. both baseline and compliance fuels) can be used when curve-fitting or linear interpolation are not feasible. The conversion equations provided in the regulations can only be used if…
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There are two typing errors in the analyte list in method A. 1-ethyl-2methylbenzene and 2-ethyl-1,3-dimethylbenzene each appear twice in the list, each with a different retention time. What analytes have been mislabeled?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Corrections have been made to the table in section 80.46 and published in the technical amendments. The number of compounds has been increased from 32 to 34 and several of the specifications have been changed. (7/1/94) This question and…
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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…