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How will EPA enforce their regulations in California? Will the Agency defer to the California Air Resources Board?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Prior to the start of the California Phase II RFG program in March 1996, EPA generally will enforce the federal RFG program California in the same manner in which it will be enforced in other parts of the…
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Section 80.65(e) lists properties that product must be tested for before shipment. Some of these do not have standards in the simple model. Is it necessary to test, and ultimately report, those parameters not required for the simple model? Is reporting of
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Refiners and importers must test for each parameter listed in § 80.65(e) for RFG certified under the simple model with the exception of T-50 and, in the case of non-VOC controlled RFG, RVP. However, in the case of…
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At a recent seminar hosted by SIGMA, EPA officials indicated that transfer documentation would be satisfactory if initiated by the transferee as long as both parties agreed to this system. Please confirm this understanding?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Your understanding is correct. However, while EPA would not object to a cooperative agreement between the transferor and the transferee, the transferor remains liable if the transferee does not have all the required PTD information for each batch.(9/26/94)…
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Is independent sampling and testing required of oxygenate blenders?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . A party who meets the definition of oxygenate blender is not required to have the gasoline it produces sampled or tested by an independent lab. However, an oxygenate blender is required to sample and test the gasoline it…
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Who is the transferor and who is the transferee in the case of an exchange transaction? The sequence of physical custody is from terminal to truck to retail outlet, but the sequence of legal custody is from the terminal to exchange partner to marketer to
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Any party who is receiving title or custody of the delivery would be considered a transferee, any party who relinquishes title or custody would be considered a transferor and any party who both receives and relinquishes title or…
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Would the following scenario require product transfer documents? At the end of a month of gasoline transactions, the following shortages apply: Company A owes 10,000 barrels of product to company B Company B owes 10,000 barrels of product to company C Com
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . EPA would not consider this a transfer of either custody or title since no actual gasoline is represented by these "book transfers"; however, PTD's must be provided where there is a transfer of title or custody of any…
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Will a regulated party's defense fail if test results indicate the product is over the standard but within the EPA announced test tolerance?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . As discussed in the Enforcement Tolerance section of this document, all gasoline downstream of the refinery or importer level may be released if test results for each parameter show the gasoline to be within the applicable standard plus…
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Would it be permissible to send a manual to downstream parties detailing the minimum and maximum values and requirements of each standardized product code (including different product codes for the difference minimum and maximum standards that would apply
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . It would be permissible to use codes to represent all required PTD information except for the statements required under § 80.106(a)(1)(vii) and (b) for conventional gasoline and certain conventional blendstocks. The response to Question 4 of the Product…
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Will a portable midrange infrared analyzer be acceptable if correlated to the mandatory test method at an independent laboratory for monitoring the oxygenates, benzene, and aromatics for terminals and retailers in their quality assurance programs?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Testing for downstream quality assurance programs may be done with test methods other than the regulatory methods if adequate correlation to the regulatory test methods is demonstrated. However, testing for downstream oxygenate blending must be done using the…
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Are samples collected at a retail outlet dispenser acceptable for quality assurance testing requirements?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Yes, when sampling from retail outlets, nozzle samples should be collected according to the procedure specified in 40 CFR part 80, Appendix D, section 11.5.(7/1/94) This question and answer was posted at Consolidated List of Reformulated Gasoline and…
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Are there any temperature requirements for the shipping of samples?
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 )
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How should refiners use blending records for oxygenate parameters when distillation is nonlinear?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . In this situation, it may be necessary to do further testing with the same oxygenates and similar hydrocarbon blendstocks to determine the blending effects.(7/1/94) This question and answer was posted at Consolidated List of Reformulated Gasoline and Anti-Dumping…
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Are sampling requirements based on 50% of volume or on one-half of the number of batches?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Sampling requirements are based on the number of batches, not the volume, over a minimum of six months.(7/1/94) This question and answer was posted at Consolidated List of Reformulated Gasoline and Anti-Dumping Questions and Answers: July 1, 1994…
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Who is the transferee in a custody transfer where the owner of the receiving tank/truck/barge is different than the operator (scheduler) of the tank/truck/barge, who may also be different from the company that provides the employees of the site? Can a com
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Regarding transfers of custody, PTDs are intended to be given to the person physically taking custody of the product. Where multiple parties are involved in a physical transfer of the product, and the transferor does not know the…
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Will a foreign refiner or blender, or an importer of RFG produced overseas, be given some kind of credit for plant emissions outside the United States?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . No. The RFG regulations do not extend to foreign refineries.(8/29/94) 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…
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