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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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All I do is produce corn ethanol and sell it all to X Company, which is an ethanol marketer. Do I have to do anything, or can X Company generate the RINs for me?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Each producer of renewable fuel is responsible for generating the RINs that represent that renewable fuel. This function cannot be delegated or assigned to any other party, including a party to whom a producer sells its product. Question…
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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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When preparing samples for oxygen analysis according to section 80.46(g), isn't there a risk of losing volatile components when allowing samples to come to room temperature?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The fractional loss during "limited" sample handling is not measurable for these properties. (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…
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When replacing conventional gasoline with RFG at a terminal, is it considered blending if the RFG is mixed with conventional bottoms?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . During the transition period prior to December 1, 1994, certified RFG may be put into tanks that contain conventional gasoline bottoms, as long as the tank is essentially filled with certified RFG gasoline on December 1, 1994, and…
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Would it be permissible to combine (i.e., commingle) any-oxygenate RBOB with an RBOB designated for blending with 10 vol% denatured ethanol, provided the new RBOB (resulting from the combination) is designated for blending with 10% denatured ethanol?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Section 80.78(a)(7) provides that "no person may combine any reformulated gasoline blendstock for oxygenate blending with any other gasoline, blendstock, or oxygenate...," and § 80.78(a)(7)(ii), states that an RBOB may be combined with "other RBOB for which the…
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Who reports expired RINs?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Every party must report RINs owned that have expired as of the end of the fourth quarter of each year. This report is due on February 28 of the following year and will identify RINs that expired in…
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Confirm that an RFG property measured from a sample collected during an EPA inspection is in technical violation if that property exceeds an applicable standard, but that no enforcement action will be brought by EPA unless the property exceeded the standard in question by at least the enforcement tolerance for that property.
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . As stated in the preamble to the RFG final rule, at 59 FR 7764 (February 16, 1994), EPA will not initiate an enforcement action on the basis of a test result from a gasoline sample collected at a…
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How do the changes in the 2006 Amendments apply to mobile refuelers?
Mobile refuelers are now exempt from the following sized secondary containment provisions that still apply to all other bulk storage containers and mobile/portable bulk storage containers: • Sections 112.8(c)(2) and (11) for petroleum oils • Sections 112.12(c)(2) and (11) for animal fats and vegetable oils These provisions previously required sized…
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Confirm that ASTM method D-1319, Fluorescent Indicator Adsorption (FIA) can be used to determine aromatic and olefin levels until January 1, 1997.
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Yes, the current version, ASTM method D-1319-93, is the regulatory method for olefins and may be used as an alternate for aromatics until January 1, 1997. For aromatics, it must also be correlated to the GC-MS method. Correlation…
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The July 1, 1994 Question and Answer Document indicates that sulfur, T90, and olefins are the only simple model RFG standards that can be seen on a refinery aggregated basis. We interpret this clarification to apply only to simple model RFG compliance and believe that it does not affect the anti-dumping provisions of § 80.101(b). Please confirm that all simple model anti-dumping standards can be met on a refinery-aggregate basis including sulfur, olefins, T90, and the exhaust benzene standards.
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . All simple model anti-dumping standards can be met on a refinery-aggregate basis pursuant to § 80.101(h). (11/28/94) This question and answer was posted at
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For conventional gasolines, the annual compliance report is based on all gasolines. Can one monthly composite be made up of all grades of gasolines and all seasons produced in that month, rather than one composite for each grade and season when compliance is demonstrated with the simple model? the complex?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . For the criteria for using composite samples for compliance calculations, see § 80.101(i)(2). (10/17/94) This question and answer was posted at
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If an independent lab temporarily cannot run a required test, may the independent lab use a substitute lab for the test until the independent lab regains its testing capacity? May a refiner use one independent lab to collect samples at a refinery, and another independent lab to analyze those samples? If a second lab is used, must the primary independent lab notify EPA of the role of the second lab?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . An independent lab may use a second lab to collect samples or perform required tests, provided that: (1) the second lab is independent as defined in § 80.65(f)(2)(iii); (2) the primary independent lab is responsible for the quality…
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Do I have to register to use CDX and is this a separate registration process?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . You will have to register with CDX. (Registering with CDX is not the same as registering under regulation Section 80.1150.) Instructions are available via our Reporting for Fuel Programs web site. Question and Answer was originally posted at…
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If one company acquires foreign product in transit, then sells it to a second company while still in transit, who is the importer?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The importer is the party identified above, the party primarily liable for payment of duties for Customs purposes when the gasoline enters the United States. (7/1/94) This question and answer was posted at
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