Is EPA making any allowances for refiners that utilize a computer-controlled in-line blending operation?
EPA is allowing an alternative to the independent sampling and analysis requirement for certain refiners that produce RFG using computer-controlled in-line blending equipment. This option would be appropriate only in the case of relatively sophisticated in-line blending operations, where sufficient gasoline quality checks and cross-checks occur to ensure that fuel produced in-line meets the specifications for RFG. Under this alternative the refiner would have an independent audit conducted of the documents generated during the course of such in-line blending as confirmation of the refiner's reported batch properties and volume.
In order to use this option, a refiner is required to petition EPA to allow its use for a particular in-line blending operation. EPA will evaluate the petition on the basis of the particular equipment and procedures in place at the petitioner-refiner's refinery. The types of factors which are relevant to EPA's review of the petition are specified in the regulations at § 80.65(f)(4).
EPA believes this alternative for certain in-line blending operations is appropriate because of the difficulty of obtaining a representative sample of gasoline that has been produced through in-line blending, and because there can be sufficient confidence in the results from a paper audit of such an operation. EPA expects that a sophisticated in-line blending operation would have to have multiple safeguards to monitor and record the properties of the blend on an on-going basis to qualify for the exemption. (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)