Most pipeline companies conduct an internal pipe corrosion control program pursuant to DOT regulations. These programs generally involve the injection of corrosion inhibitor additives into the petroleum products (gasoline, distillate, etc.) being transported by the pipeline company. Does this injection of corrosion inhibitors result in the pipeline company coming under the reformulated gasoline regulations' definition of a (blender) refiner?
No. EPA does not view the blending of de minimis amounts of additives, such as detergents or corrosion prevention additives, into finished RFG to be the "production" of gasoline, and does not believe such blending will cause resulting gasoline to fail to meet RFG standards. (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)