Frequent Questions

What requirements will be the subject of EPA inspections downstream from the refinery?

Downstream from the refinery or import facility, EPA will test gasoline for the applicable minimum and maximum parameters.

Prior to January 1, 1998, the Simple Model downstream standards apply: oxygen and benzene content, and RVP during the period May 1 through September 15 (June 1 through September 15 at the retail level). The minimum and maximum standards for these parameters are set out at section 80.41 of the Final Rule. (21)

From January 1, 1998 through December 31, 1999, the Phase I Complex Model downstream standards apply: these are oxygen and benzene content, and Nox emissions performance, and VOC emissions performance during the period May 1 through September 15 (June 1 through September 15 at the retail level). The benzene maximum and oxygen minimum under the complex model are unchanged from the standards for these parameters under the simple model. The minimums for VOC in Region 1 and Region 2 and for Nox are set out at section 80.41 of the Final Rule.
Beginning January 1, 2000, the Phase II Complex Model downstream standards apply. The oxygen and benzene downstream standards are unchanged. The minimums for VOC in Region 1 and Region 2 are set out in section 80.41 of the Final Rule. The NOx minimum is unchanged from the Phase I Complex Model in the case of RFG not designated as VOC-controlled, and in the case RFG that is VOC-controlled, the NOx minimum is 3.0 percent reduction.

These minimum and maximum standards are subject to change under the gasoline quality survey program. In the event of a survey ratchet, the more stringent standard would be enforced by EPA at the refineries and import facilities for which the adjusted standard applies. In addition, the adjusted minimum/maximum standard will be enforced in the covered area where the adjusted minimum/maximum standard applies.
In addition to the downstream minimum/maximum ststandards, EPA will inspect and audit downstream parties for all other requirements that apply to them. These downstream EPA inspection and audit activities will include, but are not limited to:

! Audits to see if product transfer documents are being maintained as required, and if product transfer documents are being transferred to the next party in the distribution network as required.

! Audits of distributor terminals that handle RBOB to see if RBOB is dispensed only to registered oxygenate blenders; if ether-only RBOB is dispensed to truck blenders, audit to see if an appropriate basis exists for the distributor-terminal to believe the oxygenate blender is blending with ether oxygenates.

! Audits to verify that RFG being dispensed is proper for time and place of use -- VOC-controlled during May 1 through September 15; VOC controlled for proper VOC-control Region; oxygenated fuels program RFG (OPRG) dispensed in OPRG areas (unless exception for OPRG designated RFG with 2.0 wt% oxygen).

! Audits for compliance with the requirement for segregation of ethanol-based VOC-controlled RFG during January 1 through Sept 15 each year.

! If any complex model RFG is present, audits for compliance with the requirement for segregation of complex RFG from simple RFG, and segregation of complex RFG from

! If any complex model RFG is present, audits for compliance with the requirement for segregation of complex RFG from simple RFG, and segregation of complex RFG from each refinery from any other refinery's complex RFG (unless refineries have identical
baselines).

! Audits for segregation of RFG from conventional gasoline, and no deliveries of conventional gasoline into RFG areas. Note however that RFG and conventional gasoline may be mixed and sold in conventional gasoline areas.

! In the case of ethanol blenders, audits for compliance with the requirements that apply to ethanol blenders, including blending of the proper type and amount of oxygenate, and conduct of the required sampling and testing.
(7/1/94)

(21) With respect to refiners electing to measure compliance under Early Use of the Complex Model, and the establishment of minimum and maximum standards: oxygen and benzene content are identical to the standards under the Simple Model; NOx and VOC standards are 2.5% less stringent than the refiner's calculated per-gallon standard.

This question and answer is posted at http://www.epa.gov/otaq/regs/fuels/rfg/qa/420r03009.pdf. The original was posted in the Q&A posted on 7/1/94 which can found at http://www.epa.gov/otaq/rfg_qa.htm" See Question ID 3857 for RFG (Taken from the first question on http://www.epa.gov/otaq/regs/fuels/rfg/qa/420r03009.pdf)


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