Should a distributor or blender wish to alter the parameters of RFG purchased from others by adding a blending component, are there limitations and/or restrictions on this type of activity? For example, in the Spring, will it be permissible to add a low-pressure blending component to gasoline in order to control volatility? Also, will it be permissible to blend octane deficient gasoline with an octane blending
component to restore octane to specification? If blending is allowed can only the end product be tested and certified or is it necessary to certify each blending step? Is blending in the above manner restricted to companies who have a history of blending gasoline or will the uninitiated also be permitted to blend components?
The addition of a blendstock to certified RFG would result in the blender becoming a refiner under the RFG regulation. Refiners must establish a baseline, register with EPA and comply with all the testing, certification and other refiner requirements under the regulation. In consequence, a blendstock may not be added to RFG unless that blendstock meets all RFG standards. Any company that does meet the requirements of an RFG refiner, however can produce RFG through blending.
RFG which is changed in this manner could, however, be sold outside the RFG covered areas as conventional gasoline. However, the blender is considered a refiner under the antidumping requirements and thus is responsible for the properties of the blendstock which is added to the finished RFG. Antidumping compliance calculations for blendstocks which are added to finished gasoline are discussed in section IX (D) of the preamble to the final regulations at 59 FR 7806. (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)