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 http://epa.gov/otaq/renewablefuels/420f08006.pdf
We are considering developing a PTD that lists ethanol and denaturant as separate items being transferred. RINs would be generated for the entire volume of denatured ethanol. If, for example, we transfer 950 gallons of ethanol and 50 gallons of denaturant
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