Pipelines are carriers under the regulations and as such have responsibility to ensure the product meets the standards while the pipeline has custody or title, and to provide appropriate product transfer documents to any downstream parties to whom it transfers custody. The responsibility to account for downgrade is a function of the point at which custody of the fuel is deemed to take place. This point is a function of contracts between the different entities. Each entity is responsible for all downgrading that occurs when it has custody.
Question and Answer was originally posted at http://www.epa.gov/otaq/diesel/documents/420b06010.pdf
Some pipelines operate a fungible batch system and some operate a segregated batch system. A shipper on a segregated batch system receives the batch that it tendered at the origin point. The pipeline has the responsibility to maintain batch quality while
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