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• For downstream compliance, has EPA addressed the issue that two complying batches mixed downstream may not comply when tested downstream?

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . In the development of the Complex Model, EPA investigated the possibility that two complying batches, when mixed, may not comply with the RFG standards. This "fungibility" issue arises out of the model's nonlinear character. Based on a Monte…

  • Last published: July 15, 2024

• Does EPA know where the industry can purchase a standard with the list of aromatic analytes shown in method A?

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . No.(7/1/94) This question and answer was posted at Consolidated List of Reformulated Gasoline and Anti-Dumping Questions and Answers: July 1, 1994 through November 10, 1997 (PDF) (333 pp, 18.17 MB, EPA420-R-03-009, July 2003, About PDF )

  • Last published: July 15, 2024

• Are adjustments made to parameters for future vs. current test methods?

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . If a known bias can be shown, parameters should be adjusted based on the test method used. This will only be considered as part of an alternate test method petition.(7/1/94) This question and answer was posted at Consolidated…

  • Last published: July 15, 2024

• Will transmix processors be allowed to "stack" ethanol and exceed the maximum allowable oxygenate content without regard to VOC requirements?

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Transmix processors who produce RFG are considered to be refiners and are required to meet all RFG standards and requirements that apply to refiners for the RFG produced, including the standards for oxygen and the renewable oxygenate. To…

  • Last published: August 2, 2024

• Will the Complex Model for NOx emissions take additive effects into account?

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . No. However, the Complex Model can be augmented through the vehicle testing procedure outlined in the final rule to include the emission effects of an additive.(7/1/94) This question and answer was posted at Consolidated List of Reformulated Gasoline…

  • Last published: August 2, 2024

• Will internal auditors be able to perform the attestation audits under the direct supervision of an independent CPA firm? Can the internal audit department meet the attestation requirement using CPAs rather than CIAs?

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Section 80.125(c) provides that an independent CPA (or firm of CPAs) engaged by a refiner, importer or oxygenate blender may complete the attest engagement requirements with the assistance of internal auditors so long as such assistance is in…

  • Last published: August 2, 2024

• Can oxygen and benzene credits be transferred from the RFG area where they are created to another RFG area?

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Benzene and renewable oxygenate credits may be transferred from the refiner or importer who creates the credits to any other refiner or importer who would use the credits. Oxygen credits may be transferred from the refiner, importer, or…

  • Last published: August 2, 2024

• EPA has stated that product codes would satisfy the product transfer documentation requirements if each downstream party is given the information necessary to know the meaning of the product codes. Please explain how this should be done.

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . EPA believes that parties normally are able to meet the product transfer requirements by including the required information in the documents that the parties currently use to memorialize the transfer of title or custody of the gasoline. Therefore…

  • Last published: August 2, 2024

• Can exports of high olefins, high benzene, and/or nil oxygen gasolines from the U.S. generate credits for the exporter?

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . No. Section 80.67(g)(6) provides that oxygen and benzene credits are generated if the actual total for the oxygen standard is greater than the compliance total, or if the actual total for the benzene standard is less than the…

  • Last published: August 2, 2024

• Clarify that the proper version of the Complex Model that is to be used with an augmentation is the version that was in effect at the time the augmentation was approved. The preamble and regulations are inconsistent on this issue, and confusion arises in

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The proper version of the Complex Model that is to be used with an augmentation is the version that was in effect at the time the augmentation was approved.(7/1/94) This question and answer was posted at Consolidated List…

  • Last published: August 2, 2024

• Can conventional gasoline be used for off-road applications in an RFG area?

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . No. Only reformulated gasoline may be sold or supplied in a covered area.(7/1/94) This question and answer was posted at Consolidated List of Reformulated Gasoline and Anti-Dumping Questions and Answers: July 1, 1994 through November 10, 1997 (PDF)…

  • Last published: August 2, 2024

• The batch report requires reporting the volume percent for six oxygenates -methanol, MTBE, ethanol, ETBE, TAME and t-butanol. If a refiner or oxygenate blender uses MTBE or ethanol as an oxygenate, and does not include in its calculation of oxygen weight

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Trace amounts of oxygenates that may be present in MTBE or ethanol do not have to be reported. However, where a refiner reports total oxygen weight percent that includes MTBE or ethanol plus other oxygenates in larger than…

  • Last published: August 2, 2024

• Will EPA consider widening the limits on distillation?

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The range of data on which the Complex Model was based limits the range within which the model will exhibit appropriate accuracy. The E200 range in the database was 33 to 66 vol%; extrapolation widened this range to…

  • Last published: August 2, 2024

• § 80.101(i)(1) says that conventional gasoline cannot leave a refinery until testing is completed for all parameters used in the compliance calculation. (e)(2) of the same section says that for purposes of meeting (e)(1) a refiner may composite samples a

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The regulations have been revised at § 80.101(i)(1) to allow conventional gasoline to leave a refinery or importer facility prior to the completion of sample testing. Note that there are additional constraints related to composite samples at §…

  • Last published: August 2, 2024

• Will the EPA "Spreadsheet" be revised to be considered acceptable for fuel certifications?

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . No. The spreadsheet was designed to provide assistance in understanding and implementing the Complex Model equations as provided in the regulations. The EPA has no authority to endorse the spreadsheet as a legal instrument of certification. Only the…

  • Last published: August 2, 2024