How do owners of the ethanol account for product samples taken at the plant and downstream relative to RINs? Likewise, how is standard product shrinkage (i.e. when ethanol is transferred to a terminal) handled relative to RINs?

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In general, the RINs associated with small volumes removed for sampling and testing, or lost due to evaporation, leakage, or metering imprecision, remain valid for RFS compliance purposes.

Small volume losses can be accommodated through the regulatory provision which allows up to 2.5 gallon-RINs to be transferred with each gallon of renewable fuel. See regulation Section 80.1128(a)(4).

For larger volumes losses resulting from spills or other accidents, a provision exists for retiring the associated RINs. See regulation Section 80.1132.

Question and Answer was originally posted at: Questions and Answers on the Renewable Fuel Standard Program (PDF) (55 pp, 221 K, EPA420-F-07-041a, August 2007, About PDF)