Recently, a natural gas pipeline condensate was refused at a fractionator. The condensate met all fractionator specifications and did not contain any hazardous materials. The operator of the fractionator advised that their facility could only take in previously manufactured materials as a direct result of the anti-dumping rules contained in the reformulated gasoline regulations. Within the anti-dumping Subpart E, we cannot find any mention of previously manufactured materials. However, Subsection 80.102 "Controls applicable to blendstocks" does define "gasoline blendstocks" as products that are produced by a refiner but it also goes on to include other blendstocks with properties certain.
The condensate described herein would not meet the definitional requirements of a gasoline blendstock as its end point would disqualify it as a gasoline (if an oxygenate was added). The fractionator would separate the condensate into a gasoline component and a diesel component.
Is it the intention of the EPA that only manufactured products be used in blending either reformulated or conventional gasoline? Is it the intent to restrict the use of naturally occurring hydrocarbons in a fractionator that produces gasoline?
The regulations do not prohibit or restrict the use or distribution of any gasoline or gasoline blendstocks regardless of their origin. Compliance with the anti-dumping requirements is based primarily on the properties of finished conventional gasoline. However, for the reasons discussed in the preamble to the final rule, the regulations also require the tracking and accounting of certain "applicable blendstocks" as defined in the regulations. The regulations do not intend to restrict the use of naturally occurring hydrocarbons. (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)