What is a satisfactory quality assurance program that ensures oxygenates are being added to RBOB at a non-proprietary terminal?
For refiners and importers who wish to claim the actual oxygenate type and amount blended with RBOB, a program of contractual controls and quality assurance sampling and testing over the downstream oxygenate blending operation must be carried out. Under §§ 80.69(a)(6) and (7), a quality assurance sampling and testing program must be carried out at the facilities of each oxygenate blender who blends any RBOB with any oxygenate. The testing methodology used must be consistent with § 80.46(g). Section 80.69 specifies, among other things, mandatory sampling and testing rates and where samples must be taken.
Refiners and importers have a second compliance option which allows them to make certain default assumptions regarding the type and amount of oxygenate blended downstream. Rather than claim the actual amount of oxygenate blended, these parties make certain default ("worst case") assumptions regarding the type and amount of oxygenate blended downstream. Under §80.69(a)(8), these assumptions are in lieu of the contractual and quality assurance requirements of §§ 80.67(a)(6) and (7). (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)