Companies vary in their internal recordkeeping practices and not all similar records will take identical form. Therefore, in several places in the recordkeeping section (80.1151) we have required that "additional" information be retained. We certainly do not wish to dictate how a company keeps each and every record, as this would present an unnecessary compliance burden.
However, since one reason for retaining company records is to be able to produce them should an enforcement question arise, it is in a company's best interest to retain "additional information" that may fully explain the details of RIN generation as reported to EPA. These records must be presented to EPA upon request.
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)