PTD information is only required when there is a transfer of title or custody of any gasoline (with the exception of gasoline sold or dispensed at a retail outlet or wholesale purchaser-consumer for use in motor vehicles). As a result, PTD information is not required where no product custody exists, and no transfer of title occurs, provided that the volume of gasoline is de minimis in relation to the volume of gasoline involved in the parties' overall transactions.(9/26/94)
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 9/26/94 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)
Is EPA documentation necessary to settle inventory over/short accounts where the volume of gasoline involved is de minimis? If so, what are the parties documenting?
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