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Fuels Registration, Reporting, and Compliance Help

Refiners or importers producing or importing RBOB must blend the proper amount of oxygen with the RBOB and test it for the regulated parameters pursuant to § 80.69(a)(2). Since they are not responsible for the oxygen content, must they test for oxygen, a

Section 80.69(a)(2) requires an RBOB producer or importer to add the specified type and amount of oxygenate to a representative sample of the RBOB and to determine the properties and characteristics of the resulting gasoline using the methodology specified in § 80.65(e). Section 80.69(a)(2) does not exclude oxygen from the parameters to be tested, so the refiner or importer should test for oxygen.

Although the regulations do not require the RBOB producer or importer to report the oxygen results of the representative sample blend on its batch report, this test result, which would then be available for the attest engagement or in the event of an enforcement audit, would provide analytical verification of the amount of oxygen added to the representative sample blend.(1/30/95)

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)