We assume that a terminal operator who stores gasoline for a terminalling customer is responsible for receiving transfer documentation on RFG and conventional gas moved into the terminal for the customer. The terminal then records and stores copies of the transfer documents, produces a new transfer document at the time of the transfer out of the terminal, and passes this document back to the customer after the move out.
The transfer documents for RFG require only minimum/maximum standards for benzene, oxygen, RVP, etc., rather than actual measurement of these specifications. Since the regulations require refiners and importers to report actual measurement of specs, we are assuming that a terminal does not have to report to the EPA the information on the transfer documents. Is this a correct assumption?
Yes. (9/12/94)
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)