Learn the Issues
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When measuring total aromatics using a GC-MS, can either method A or method B be used, or must both be used?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Either method A or method B may be used. (7/1/94) This question and answer was posted at Consolidated List of Reformulated Gasoline and Anti-Dumping Questions and Answers: July 1, 1994 through November 10, 1997 (pdf) (333 pp, 18.17…
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What is the responsibility of the independent lab in determining whether a tank of RFG meets the definition of "batch," i.e., is homogeneous with regard to the RFG properties?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The independent sampling and testing provisions require the independent lab to collect a separate sample from each batch of RFG. "Batch of reformulated gasoline" is defined at § 80.2(gg) as "a quantity of reformulated gasoline which is homogeneous…
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What are the differences between the summer and winter models and what is their justification?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The equations, extrapolations, and normal-to-high emitter ratios remain the same when one switches from the summer version of the Complex Model to the winter version. However, four changes do take place. First, the baseline fuel is changed from…
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What is the affect of a "clean" attestation and/or regulatory audit on subsequent compliance violations identified?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . An attestation engagement report for the refinery or importer that indicates no discrepancies has no bearing on a violation by the refiner or importer that may be determined by EPA. With regard to the CPA or CIA who…
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A refinery places two batches of gasoline that have been sampled and certified as reformulated gasoline with the same designation into a tank. Must the refinery assign a new batch ID to the mixture or can it be identified with the two previously assigned
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . No new ID is necessary. Batches of reformulated gasoline may be fungibly mixed, subject to the segregation provisions of § 80.78. (7/1/94) This question and answer was posted at Consolidated List of Reformulated Gasoline and Anti-Dumping Questions and…
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Section 80.101(i) provides a composite sampling and testing option to determine conventional gasoline properties. One provision to this option is that composite samples will need to be prepared as described in § 80.91(d)(4)(iii). Part B of this procedure
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The best process would be to avoid the butane adjustment by blending the fuels in such a way that butane loss is avoided. Practically, this means having all fuel samples at or below 32 degrees Fahrenheit before their…
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With respect to section 80.65(a), would there be any violation by the terminal located in an RFG covered area selling only conventional gasoline to stations in attainment areas?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . No. However, the terminal should take extra precautions to ensure that no conventional gasoline is distributed to a RFG area. See the discussion in the Prohibitions and Liabilities Section. (7/1/94) This question and answer was posted at Consolidated…
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The regulations require a refiner or importer to determine and report properties for each batch of reformulated and conventional gasoline it produces or imports. The wording would indicate that a refiner would report the volume produced into a tank. A bet
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The method described above is appropriate for determining the volume and properties of a batch of conventional gasoline as required by the anti-dumping regulations provided the sample analyses and volume determination are supported by appropriate documentation. (7/1/94) This…
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The regulations require that an importer be registered 90 days before imports are received. Does this mean the company or the facility?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Both. If an importer chooses to register individual import facilities it must register them 90 days prior to shipping into them. However, an importer is only required to register its activities in each PADD (still 90 days in…
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On the registration forms it seems you are forced to check only one primary activity (refiner, oxygenate blender, importer, or independent lab). Do you submit two forms if you are both a refiner and importer?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . No. The final forms have been changed to register each company once for all applicable activities. As before, each facility will be registered separately for each activity that is undertaken at the facility. Import facilities need not be…
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Regarding a batch for which the blend completion date is on the last day of the EPA reporting quarter, what if shipments, as EPA defines them, are not complete by the time reporting for that quarter is required? Is there going to be any facility to allow
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Sections 80.65(c) and 80.101(d)(1) require refiners to include in compliance calculations each batch of gasoline that is "produced." As a result, a batch of gasoline should be included in the averaging period when the batch is produced, rather…
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Stakeholder Meetings on Black Carbon from Diesel Sources in the Russian Arctic
From January 28-February 1, 2013, EPA and its partners held meetings in Murmansk and Moscow with key Russian stakeholders to gather input into the project’s emissions inventory methodologies and potential pilot project ideas.
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With regard to the record keeping requirement for test results, please clarify the document which must be kept.
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Section 80.74(a)(2)(iii) requires any regulated party who samples and tests reformulated gasoline or RBOB to maintain records containing the results of the tests. The headnotes of § 80.74 specifies that the record keeping period is five years from…
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For a refinery with an in-line gasoline blending exemption, can the annual in-line blending audit be conducted by the same attestation auditor as outlined under Subpart F of the RFG and Anti-dumping regulations? Must the auditor for an in-line blending op
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . An in-line blending exemption exempts a refiner from the independent sampling and testing requirements of § 80.65(f). As one of the conditions of the exemption, the refiner must carry out an independent audit program of its in-line blending…
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A refinery has streams (alkylate, butane, platformate, etc.) being blended into two tanks, 95 and 85 octane. Products from these two tanks are in-line blended at the rack to give 87, 89, and 92 octane product. Can just the 85 and 95 octane tanks be certif
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Conventional gasoline that has been included in a refiner's compliance calculations may be fungibly mixed, including multi-grade mixing, without the need for additional sampling and testing. (8/29/94) This question and answer was posted at Consolidated List of Reformulated…
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Support Document for Asbestos Information Collection for the CDR Rule Section 21 Petition
Documents supporting the Section 21 petition submitted by the Asbestos Disease Awareness Organization.
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Is anti-dumping compliance the only restriction on conventional gasoline? Are there any future emissions reductions for conventional gasoline?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . All gasoline requirements currently in place, except for those applicable to reformulated gasoline, apply to conventional gasoline (e.g., volatility requirements, lead requirements, state oxygenated fuel requirements, etc.). The anti-dumping requirements are in addition to these. It is possible…
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The RIA method for aromatics and olefins doesn't result in agreement with finished gasoline, i.e., the sum of the blendstock parameters doesn't equal the finished gasoline value (>6% delta). Are alternative methods okay?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Alternative test methods may be considered, based on the individual situation as explained in an alternate test method petition. (7/1/94) This question and answer was posted at Consolidated List of Reformulated Gasoline and Anti-Dumping Questions and Answers: July…
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In RFG areas, at unattended cardlock fueling facilities, where should the three most recent PTDs be maintained? It seems to make little sense that they be stored on-site, since the driver normally does not leave any paperwork at the unattended cardlock fa
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . In the situation described, it would be acceptable for the PTDs to be maintained at the marketer's nearest office. (5/23/95) This question and answer was posted at Consolidated List of Reformulated Gasoline and Anti-Dumping Questions and Answers: July…
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The regulations state that a party must register three months prior to producing or importing gasoline or blendstocks under the RFG and anti-dumping Program (40 CFR 80.76). If a party receives its ID numbers from EPA prior to the end of the three month pe
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The party does not need to wait. The three month period was intended to give EPA adequate time to process registrations. A party may proceed with production and importation after receiving an EPA registration number. (1/30/95) This question…