Consistent with the requirements under the RFG program, § 80.195(a)(2) provides that, for purposes of sulfur compliance and reporting, volumes are expressed in gallons. Accordingly, credits and allotments are required to be calculated and reported in units of ppmgallons.

Although barrels may be the commercial units used by refiners, the conversion from barrels to gallons requires a simple calculation which should not impose an undue burden on regulated parties.