Can a company which is both a refiner and importer transfer oxygen and benzene credits from its import operations to its refineries?

Yes, through a transfer of credits meeting all conditions of § 80.67(h). (7/1/94)

This question and answer was posted at  List of Reformulated Gasoline and Anti-Dumping Questions and Answers: July 1, 1994 through November 10, 1997 (pdf) (2.98 MB, July 2003)