The RINS should not be split between ethanol and denaturant. Section 80.1153(a) of the RFS rule refers to "the volume of renewable fuel that is being transferred" as necessary information for PTDs. Denatured ethanol is the "renewable fuel" in your example. It would be incorrect to split the RINs between ethanol and denaturant.
This Question and Answer was originally posted at: Questions and Answers on the Renewable Fuel Standard Program (PDF) (59 pp, 228 K, EPA420-F-08-006, April 2008, About PDF)