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• If an independent lab temporarily cannot run a required test, may the independent lab use a substitute lab for the test until the independent lab regains its testing capacity? May a refiner use one independent lab to collect samples at a refinery, and ano

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . An independent lab may use a second lab to collect samples or perform required tests, provided that: (1) the second lab is independent as defined in § 80.65(f)(2)(iii); (2) the primary independent lab is responsible for the quality…

  • Last published: July 15, 2024

• How does a refinery that in-line blends RFG generate a certificate of analysis (key RFG parameters) prior to shipment as required by the regulations?

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . For the simple model, refiners who petitioned for an exemption from the independent sampling and testing requirements are required to specify their reasonable basis for knowing that the fuel meets the standards for benzene and oxygen, and RVP…

  • Last published: July 15, 2024

• Section 80.41(h)(1) specifies that RFG may contain no heavy metals. What specifically does that mean, and is a refiner required to test for the presence of heavy metals?

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The prohibition of heavy metals in RFG means that heavy metals may not be added, nor may it contain more than trace levels that may be picked up from the transportation/distribution system. In fact, no substantially similar unleaded…

  • Last published: July 15, 2024

• A foreign cargo of RFG is to be imported into several terminals. Can the cargo be certified before discharge at the first U.S. port of entry and that certification used for all subsequent ports of entry, or must it be tested and certified separately at ea

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Certification of every batch of imported RFG must occur separately for Customs purposes at each U.S. port of entry. For example, if a vessel goes first to New York to discharge half its cargo, then proceeds on to…

  • Last published: July 15, 2024

• 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