Question 14, Section VI.C., of the July 1, 1994 Question and Answer Document provides an example of the creation and addition of two different batches to form a composite mixture. All or a portion of this composite is shipped as RFG. How will the refinery account for this shipment under recordkeeping and averaging requirements (assuming the refinery is averaging), based on the scenario outlined in Question 14?
Question 14 relates to in-line blending operations that have petitioned EPA for and received an exemption from the independent sampling and testing requirements of the RFG regulations. In such petitions, refiners often define a "batch" of in-line blended gasoline as the volume of gasoline blended by the operation through the blender. The gasoline is then certified by the refiner based on the volume that has been sampled by an automated compositor for testing.
Once it is certified, this product can then be pumped directly into a pipeline or into a tank for storage. At this point, it is fungible with other similar product. Accordingly, the batch volume that the refinery accounts for under the recordkeeping requirements and for purposes of averaging is the volume of product that is certified before the product goes into the pipeline or is stored in a storage tank where it may be fungibly mixed. (11/28/94)
This question and answer was originally posted at List of Reformulated Gasoline and Anti-Dumping Questions and Answers: July 1, 1994 through November 10, 1997 (pdf)