Confirm that the only specification for a blendstock being added to finished gasoline in early use of the Simple Model is a per gallon specification not exceeding the antidumping baseline exhaust benzene level, (per Section 80.101(g)(3)), and later the exhaust toxic and exhaust NOx baseline levels in 1998 and beyond. This is very important to clearly understand as regular CBOB is not a fungible grade of gasoline. Component blending with finished regular and ethanol is a very important option to blending regular CBOB with ethanol in terminals. This option is critical whenever the refinery that feeds the CBOB terminals requires maintenance or has operational problems, and no other refinery that feeds that terminal makes regular CBOB.
Under the simple model for 1995-1997, refiners and importers are required to meet standards for exhaust benzene, sulfur, olefins and T90 on an annual average basis for conventional gasoline and, under certain conditions, applicable blendstocks as specified in § 80.102. Beginning in 1998, refiners and importers are required to meet standards for exhaust NOx and toxics emissions on an annual average basis.
There are no "per-gallon" requirements for conventional gasoline. The anti-dumping requirements do not preclude the blending of ethanol with finished gasoline or with blendstocks which become gasoline upon the addition of oxygenates. (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)