Explain the volume determination requirement for independent labs.

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Section 80.65(f)(3)(i)(B) requires the independent lab to determine the volume of each RFG batch that is sampled. EPA expects the independent lab will determine the volume of a RFG batch in the same manner gasoline volumes currently are determined for commercial transactions, using standard industry methods such as ASTM standard D 1085, "Method of Gaging Petroleum and Petroleum Products." (This same method also is referenced by API as standard 2545, and by ANSI as standard 211.196.)

The independent lab's volume determination, of the volume of gasoline contained in the storage tank, would be the total production volume of the RFG batch. The refiner's report to EPA for RFG batch volume, however, is of the volume of RFG produced and shipped. The refiner reports the volume shipped in order to avoid double counting the RFG remaining in the storage tank when blending begins for the subsequent batch (i.e., the tank heel). This difference between the reported RFG batch volume for the independent lab (production volume) and the refiner (shipped volume) means the two volume reports normally will not match.

While it would be preferable for the independent lab's and the refiner's or importer's volume reports to match, such correlation currently is not anticipated. In order for the independent lab to be able to report the shipped volume for an RFG batch, which would match the refiner's batch volume, the independent lab would have to reinspect the tank subsequent to all gasoline movements from the tank in question. EPA believes the costs associated with such additional independent inspections are not warranted. The independent lab's report of production volume for an RFG batch serves an appropriate oversight function, because it constitutes an outside bound on the volume the refiner could report for the batch. Nevertheless, EPA intends to monitor the effectiveness of this portion of the independent sampling and testing program, and may modify this provision if greater correlation in volume measurements by refiners and independent labs is necessary.(7/1/94)

This question and answer was posted at Consolidated List of Reformulated Gasoline and Anti-Dumping Questions and Answers: July 1, 1994 through November 10, 1997 (PDF)(333 pp, 18.17 MB, EPA420-R-03-009, July 2003, About PDF)