During tank transfers and other operations necessary to accommodate pipeline schedules, barrels of untested, uncertified reformulated gasoline may be mixed with barrels of previously certified product that have been included in the refiner's averaging calculations. If the total volume of mixed product is tested, certified, and booked, then double-accounting of the previously certified barrels will result. Can a procedure for unbooking of the quality and quantity of the previously certified product be used to avoid this double accounting problem?

If, as discussed above, batch volumes are reported based on shipments out of the refinery or import facility (and averaging calculations are based on these volumes), a volume of previously tested reformulated gasoline remaining in a tank, which is then mixed with untested gasoline, would be included in the volume reported (i.e., the next shipment out of the refinery from that tank) and double counting will not occur. (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) (18.2 MB, July 2003, EPA420-R-03-009).