Public terminals that "refine" and "blend" RFG, RBOB or conventional gasoline as defined in the RFG rules at 40 CFR Part 80, and obtain agreements from their customers to comply with the refiner/blender requirements of the rule, will not separately need to register with EPA. It is my understanding that terminals in such situations must not register. Is my understanding correct?
No. In a situation in which more than one party fits the definition of a refiner or oxygenate blender under the regulations, each such party is subject to the requirements under the regulations, including registration requirements. Where, for a particular operation, more than one party fits the definition of refiner or oxygenate blender, the parties may agree that one party will register. There is no prohibition against the terminal registering in this situation. (8/29/94)
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)