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The regulations state that no person may combine any RFG with any non-oxygenated blendstock unless that person meets each requirement specified as a refiner. Does this mean that if any such blending is done at a terminal then they would be required to have the full analytical capabilities required of a refinery. Could metering at the terminal be an acceptable substitute? Can documented blendstocks be blended and certified using meters?

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The addition of a blendstock to certified RFG, or the combination of several blendstocks to produce RFG, would result in the blender becoming a refiner under the RFG regulation with all the testing, certification and other requirements under the regulation. Metering at the terminal is not an acceptable substitute for the sampling and testing requirements for a refiner. (7/1/94)

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