Under § 80.69(a) an RBOB refiner is required to calculate the non-oxygen parameter values for the RFG produced from the RBOB using either the oxygen blending assumptions under § 80.69(a)(8), or the actual oxygen blending levels if the refiner meets the contractual and quality assurance requirements specified in §§ 80.69(a)(6) and (7). The quality assurance provision of § 80.69(a)(7) states that the refiner must use sampling and testing to ensure that the RFG produced by the downstream oxygenate blender meets "applicable standards." The particular standards which are intended are not further specified in that paragraph, however.
EPA believes it is only necessary under § 80.69(a)(7) for the refiner to evaluate the RFG produced by an oxygenate blender for the oxygen type and amount, and not for other RFG standards. The RBOB used in any particular oxygenate blending operation could be from a fungible mixture of RBOBs (with identical requirements for oxygenate type and amount) that were produced at one refinery or at more than one refinery, and that probably would have different target values for the non-oxygen standards. As a result, it would not be meaningful for the refiner to test for the non-oxygen standards at the oxygenate blending facility. In addition, testing for the oxygenate type and amount will confirm whether the blender is using the oxygenate type and amount specified by the RBOB refiner and used by that refiner in their compliance calculations.
EPA believes there is little risk the RFG produced from RBOB will violate a downstream standard under this approach, because the RBOB refiner must specify an oxygenate type and amount for the RBOB such that the resulting RFG will meet all standards. For example, if a particular RBOB requires the dilution of 10 vol% ethanol to meet the benzene standard, the RBOB refiner is required to specify 10 vol% ethanol for the RBOB, and any downstream oxygenate blender who uses this RBOB is required to add 10 vol% ethanol. (4/18/95)
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)