What basis is to be used for reconciliations, volume (gallons or barrels) or weight? What does EPA consider to be perpetual inventory? (Is a plant balancing considered a perpetual inventory?)
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Section 80.128 (Agreed upon procedures for refiners and importers) provides for comparison of records on the basis of volume except in section 80.128(b) which provides for analysis of gasoline inventory reconciliation records. While EPA anticipates that the standard practice…