If a pipeline must be classified as a refiner, how would that be handled administratively by EPA? Since pipelines don't own the product, would pipeline have to become buyers and sellers for regulatory purposes?

Refiners must be registered with EPA. The pipeline need not be an owner of the gasoline to be a refiner.(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)