As the expiration of a waiver allowing the use of CG in an RFG area approaches, what is the proper process for converting tanks in which a regulated party stored CG back to RFG tanks?
Before a regulated party designates a batch of gasoline as RFG from a tank that held CG pursuant to an RFG waiver, the regulated party must collect a representative sample from the tank and analyze the sample for benzene content using the regulatory test methods, or other test methods if the regulated party can demonstrate adequate correlation to the regulatory test methods. This analysis must show that the gasoline meets the downstream standards for benzene (not more than 1.30 volume percent). The regulated party must retain all documents relating to this compliance demonstration. Moreover, the normal requirements for tank turnover found in 40 C.F.R. ยง 80.78(a)(10), such as drawing the tank down prior to loading the new product type, do not apply.
