Can a transmix processor recover gasoline from transmix and call it conventional gasoline without meeting the requirements that apply to a conventional gasoline refiner, and mix the conventional gasoline with other conventional gasoline?
In the answer to question IX-B-16 of the July 1, 1994 Question and Answer Document, EPA described procedures for transmix processors to follow when producing conventional gasoline or RFG through the transmix processing.
In the case of conventional gasoline produced through the transmix processing, and under the conditions specified in the July 1, 1994 Question and Answer Document, the processor need not meet the requirements that apply to conventional gasoline refiners, and the conventional gasoline produced may be fungibly mixed with other conventional gasoline.
A transmix processor who produces conventional gasoline must, however, provide product transfer documents that identify the gasoline as conventional and that contain the statement required under § 80.106(a)(1)(vii), that "[t]his product does not meet the requirements for reformulated gasoline, and may not be used in any reformulated gasoline covered area." (10/3/94)
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)