March 15, 1996 Ian A. MacKay, CPA Director Federal Government Division American Institute of Certified Public Accountants 1455 Pennsylvania Avenue, NW Washington, DC 20004-1081 Re: Alternative Attest Procedures Dear Mr. MacKay: Thank you for your January 11, 1996 letter in which you seek EPA approval for alternative attest procedures for use in conjunction with the reformulated gasoline and anti- dumping programs. As you know, refiners, importers and many oxygenate blenders are required to commission annual attest engagements to review compliance with various aspects of the reformulated gasoline and anti-dumping programs. The minimum attest procedures are specified under 40 CFR Part 80, subpart F. In addition, the chapeau of 40 CFR Section 80.128 provides that alternative attest procedures may be used provided that prior approval is obtained from EPA. As a result of subsequent discussions, Mr. Stephen Chase, of the AICPA s Gasoline Attestation Task Force, has modified the alternative attest procedures for which you are seeking approval to those enclosed with this letter. EPA hereby approves use of the enclosed attest procedures. In particular, PP 2 (Agreed-upon procedures for refiners and importers) and PP 3 (Agreed-upon procedures for downstream oxygenate blenders) of the enclosed attest procedures may be used as alternatives to 40 CFR Sections 80.128 and 129, respectively. Moreover, PP 1 (Definitions) of the enclosed attest procedures may be used in conjunction with the these alternative attest procedures. An auditor has the option of using either the 40 CFR Section 80.128 attest procedures in their entirety, or the PP 2 alternative attest procedures in their entirety; and either the 40 CFR Section 80.129 attest procedures in their entirety, or the PP 3 alternative attest procedures in their entirety. For either section, an auditor may not use a combination of the original attest procedures and the alternative attest procedures. In addition, alternative attest procedures are not being approved for portions of 40 CFR Part 80, subpart F, other than 40 CFR Sections 80.128 and 129. Thank you for your efforts, and for those of the members of the AICPA's Gasoline Attestation Task Force, to develop alternative attest procedures. If you have questions, you may call Fielding Lamason, at 202-564-1024. Yours truly, George Lawrence Reformulated Gasoline Team Leader PP 1 Definitions. The following definitions apply for the purposes of these alternative attest procedures: (a) Attestor means the CPA or CIA performing the agreed-upon procedures engagement under this subpart. (b) EPA Reports or Company Documents may refer to copies of such documents provided to the attestor. (c) Foot (or crossfoot) is an attestation term that means to add a series of numbers, generally in columns (or rows), to a total amount. When applying the attestation procedures in this subpart F, the attestor may foot to subtotals on a sample basis in those instances where subtotals (e.g., page totals) exist. In such instances, the total should be footed from the subtotals and the subtotals should be footed on a test basis using no less than 25% of the subtotals. (d) GTAB (gasoline-treated-as-blendstock) refers to imported gasoline that is excluded from the import facility s compliance calculations, but is treated as blendstock in a related refinery that includes GTAB in its refinery compliance calculations. (e) Laboratory Analysis means the summary of the analysis that was used to determine a product s properties. For laboratories using test methods that must be correlated to the standard test method, the correlation factors and results should be included. For refineries or importers that produce RFG or RBOB and use the 100% independent lab testing, the laboratory analysis shall consist of the results reported to the refinery or importer by the independent lab. Where assumed properties are used (e.g., for butane) the assumed properties may serve as the test results. (f) Non-finished-gasoline petroleum products for attestation purposes is defined as liquid petroleum products that have boiling ranges greater than 75 degrees Fahrenheit, but less than 450 degrees Fahrenheit, as per ASTM D86 or equivalent. (g) Product Transfer Document(s) means copy(ies) of document(s): (1) represented by the refiner/importer/oxygenate blender as having been provided to the transferee, and (2) that reflect the transfer of ownership or physical custody of gasoline or blendstock (e.g., invoices, receipts, bills of lading, manifests, and/or pipeline tickets). (h) Reporting Period means the time period relating to the reports filed with EPA by the refiner, importer, or oxygenate blender as noted in PP 2(a)(1) and PP 3(a), and generally is the calendar year. The 1995 Reporting Period includes 1994 activity reported for the first quarter of 1995 as required by 40 CFR Section 80.75(a)(3). (i) Tender means the transfer of ownership of a volume of gasoline or other petroleum product all of which has the same identification (reformulated gasoline, conventional gasoline, RBOB, and other non-finished-gasoline petroleum products), and characteristics (time and place of use restrictions for reformulated gasoline and RBOB). PP 2 Agreed-upon procedures for refiners and importers. The following minimum procedures may be carried out for a refinery and importer that is subject to the requirements of 40 CFR Part 80, subpart F, as an alternative to the procedures under 40 CFR Section 80.128. (a) EPA Reports. (1) Obtain and read a copy of the refinery s or importer s reports (except for batch reports) filed with the EPA as required by 40 CFR Sections 80.75 and 80.105 for the Reporting Period. (2) In the case of a refiner s report to EPA that represents aggregate calculations for more than one refinery (i.e., more than one facility is listed in section 2.0 of an Anti-Dumping Program Annual Report, or in section 2.0 of a Reformulated Gasoline Sulfur, Olefin and T90 Averaging Report), obtain the refinery-specific volume and property information that was used by the refiner to prepare the aggregate report. Foot and crossfoot the refinery-specific totals and compare to the values in the aggregate report. The procedures in PP 2(b) through 2(m) then are performed separately for each refinery. (3) Obtain a written representation from a company representative that the report copies are complete and accurate copies of the reports filed with the EPA. (b) Inventory reconciliation analysis. Obtain an inventory reconciliation analysis for the refinery or importer for the Reporting Period by product type (i.e., reformulated gasoline, RBOB, conventional gasoline, and non-finished-gasoline petroleum products), and perform the following: (1) Foot and crossfoot the volume totals reflected in the analysis; and (2) Compare the beginning and ending inventory amounts in the analysis to the refinery's or importer's inventory records. Note: If the analysis shows no production of conventional gasoline or if the refinery or importer represents per PP 2(l) that it has a baseline less stringent or equal to the statutory baseline, the analysis may exclude non-finished-gasoline petroleum products. (c) Listing of tenders. For each product type other than non-finished gasoline petroleum products (i.e., reformulated gasoline, RBOB, conventional gasoline), obtain a separate listing of all tenders from the refinery or importer for the Reporting Period. Each listing should provide for each tender the volume shipped and other information as needed to distinguish tenders. Perform the following: (1) Foot to the volume totals per the listings; and (2) For each product type listed in the inventory reconciliation analysis obtained in PP 2(b), compare the volume total on the listing to the tender volume total in the inventory reconciliation analysis. (d) Listing of batches. For each product type other than non-finished gasoline petroleum products (i.e., reformulated gasoline, RBOB, and conventional gasoline), obtain separate listings of all batches reported to the EPA and perform the following: (1) Foot to the volume totals per the listings; and (2) Compare the total volumes in the listings to the production volume in the inventory reconciliation analysis obtained in PP 2(b). (e) Reformulated gasoline tenders. Select a sample, in accordance with the guidelines in 40 CFR Section 80.127, from the listing of reformulated gasoline tenders obtained in PP 2(c), and for each tender selected perform the following: (1) Obtain Product Transfer Document(s) associated with the tender and compare the volume on the tender listing to the volume on the Product Transfer Document(s); and (2) Inspect the Product Transfer Document(s) evidencing the date and location of the tender and the compliance model designations for the tender (VOC-controlled [Region 1 or 2], non VOC-controlled, OPRG, non-OPRG, and simple or complex model certified). (f) Reformulated gasoline batches. Select a sample, in accordance with the guidelines in 40 CFR Section 80.127, from the listing of reformulated gasoline batches obtained in PP 2(d), and for each batch selected perform the following: (1) Compare the volume shown on the listing, to the volume listed in section 3.0 of the corresponding batch report submitted to EPA; and (2) Obtain the refinery s or importer s Laboratory Analysis and compare the properties listed in section 8.0 of the corresponding batch report submitted to EPA, to the properties listed in the Laboratory Analysis. (g) RBOB tenders. Select a sample, in accordance with the guidelines 40 CFR Section 80.127, from the listing of RBOB tenders obtained in PP 2(c), and for each tender selected perform the following: (1) Obtain Product Transfer Document(s) associated with the tender and compare the volume on the tender listing to the volume on the Product Transfer Document(s); and (2) Inspect the Product Transfer Document(s) evidencing the type and amount of oxygenate to be added to the RBOB. (h) RBOB batches. Select a sample, in accordance with the guidelines in 40 CFR Section 80.127, from the listing of RBOB batches obtained in PP 2(d), and for each batch selected perform the following: (1) Obtain from the refiner or importer the oxygenate type and volume, and oxygen volume required to be hand blended with the RBOB, in accordance with 40 CFR Section 80.69(a)(2) and (8); (2) Compare the volume shown on the listing, as adjusted to reflect the oxygenate volume determined under PP 2 (h)(1), to the volume listed in section 3.0 the corresponding batch report submitted to EPA; and (3) Obtain the refinery s or importer s Laboratory Analysis of the RBOB hand blend and compare the oxygenate type and oxygen amount determined under PP 2(h)(1), to the tested oxygenate type and oxygen amount listed in the Laboratory Analysis; and compare the properties listed in section 8.0 of the corresponding batch report submitted to EPA, to the properties listed in the Laboratory Analysis. (4) Categorize the RBOB Batch reports into two groups: (1) Group 1 - RBOB Batch reports showing (a) RBOB-any oxygenate with ethanol as oxygenate and an oxygen content of 2.0 weight percent, (b) RBOB-ethers only with only MTBE as oxygenate and an oxygen content of 2.0 weight percent, or (c) 4.0 volume percent ethanol and no other oxygenate, and (2) Group 2 - all other RBOB Batch reports. Perform the following procedures for each Batch report categorized in Group 2 (all others). [No additional procedures need to be performed for RBOB Batch reports categorized in Group 1.] (i) Obtain and inspect a copy of an executed contract with the downstream oxygenate blender (or with an intermediate owner) evidencing that the contract: (1) was in effect at the time of the corresponding RBOB transfer, and (2) allowed the company to sample and test the RFG made by the blender. (ii) Obtain a listing of RBOB blended by downstream oxygenate blenders and the refinery s or importer s oversight test results, and select a representative sample, in accordance with the guidelines in 40 CFR Section 80.127, from the listing of test results and for each test selected perform the following: (A) Obtain the Laboratory Analysis for the batch, and compare the type of oxygenate used and the oxygen content appearing in the Laboratory Analysis to the instructions stated on the Product Transfer Document(s) corresponding to a RBOB receipt immediately preceding the Laboratory Analysis and used in producing the RFG batch selected; (B) Calculate the frequency or amount of the volume blended between the test selected and the next test; and (C) Compare the frequency or volume blended between the test selected and the next test to the sampling and testing frequency rates stated in 40 CFR Section 80.69(a)(7). (i) Conventional gasoline and conventional gasoline blendstock tenders. Select a sample, in accordance with the guidelines in 40 CFR Section 80.127, from the listing of the tenders of conventional gasoline and conventional gasoline blendstock that becomes gasoline through the addition of oxygenate only, and for each tender selected perform the following: (1) Obtain Product Transfer Document(s) associated with the tender and compare the volume on the tender listing to the volume on the Product Transfer Document(s); and (2) Inspect the Product Transfer Document(s) evidencing that the information required in 40 CFR Section 80.106(a)(1)(vii) is included. (j) Conventional gasoline batches. Select a sample, in accordance with the guidelines in 40 CFR Section 80.127, from the conventional gasoline batch listing obtained in PP 2(d), and for each batch selected perform the following: (1) Compare the volume shown on the listing, to the volume listed in section 3.0 of the corresponding batch report submitted to EPA; and (2) Obtain the refinery s or importer s Laboratory Analysis and compare the properties listed in section 8.0 of the corresponding batch report submitted to EPA, to the properties listed in the Laboratory Analysis. (k) Conventional gasoline oxygenate blending. Obtain either (1) a written representation from the refiner for the refinery or importer that it has not used any downstream oxygenate blending in its conventional gasoline compliance calculations, or (2) a listing of each downstream oxygenate blending facility and its blender, as represented by the refiner/importer, as adding oxygenate used in the compliance calculations for the refinery or importer. (1) For each downstream oxygenate blender facility, obtain a listing from the refiner or importer of the batches of oxygenate included in its compliance calculations added by the downstream oxygenate blender and foot to the total volume of batches per the listing; (2) Obtain a listing from the downstream oxygenate blender of the oxygenate blended with conventional gasoline or sub-octane blendstock that was produced or imported by the refinery or importer and perform the following: (i) Foot to the total volume of the oxygenate batches per the listing; and (ii) Compare the total volumes in the listing obtained from the downstream oxygenate blender, to the listing obtained from the refiner or importer in PP 2(k)(1). (3) Where the downstream oxygenate blender is a person other than the refiner or importer, as represented by management of the refinery or importer, perform the following: (i) Obtain the contract from the refiner or importer with the downstream blender and inspect the contract evidencing that it covered the period when oxygenate was blended; (ii) Obtain company documents evidencing that the refiner or importer has records reflecting that it conducted physical inspections of the downstream blending operation during the period oxygenate was blended; (iii) Obtain company documents reflecting the refiner or importer audit over the downstream oxygenate blending operation and inspect these records evidencing the audit included a review of the overall volumes and type of oxygenate purchased and used by the oxygenate blender to be consistent with the oxygenate claimed by the refiner or importer, and that this oxygenate was blended with the refinery's or importer's gasoline or blending stock; and (iv) Obtain a listing of test results for the sampling and testing conducted by the refiner or importer over the downstream oxygenate blending operation, and select a sample, in accordance with the guidelines in 40 CFR Section 80.127, from this listing. For each test selected, compare the tested oxygenate volume with the oxygenate volume in the listing obtained from the oxygenate blender in PP 2(k)(2) for this gasoline. (l) Blendstock tracking. Either: obtain a written representation from management of the refinery or importer that it has a baseline for each property that is less stringent or equal to the statutory baseline (i.e., it is exempt from blendstock tracking under 40 CFR Section 80.102(f)(1)(i)); or (2) perform the following procedures: (1) Obtain listings for those tenders of non-finished-gasoline petroleum products classified by the refiner or importer as: (i) Applicable blendstock which is included in the refinery s or importer s blendstock tracking calculations pursuant to 40 CFR Section 80.102(b) through (d); (ii) Applicable blendstock which is exempt pursuant to 40 CFR Section 80.102(d)(3) from inclusion in the refinery s or importer s blendstock tracking calculations pursuant to 40 CFR Section 80.102(b) through (d); and (iii) All other non-finished-gasoline petroleum products; (2) Foot to the totals of the tender volumes contained in the listings obtained from the refinery or importer in PP 2(l)(1); (3) Compare the total volume of tenders per the listings to the total tender volume of non-finished-gasoline products on the gasoline inventory reconciliation analysis obtained in PP 2(b); and (4) Compute and report as a finding the refinery s or importer s ratio of all non-finished petroleum products to total gasoline production. [Total gasoline production is the volume total of the batches from PP 2(d) for RFG, RBOB, and conventional gasoline, exclusive of California gasoline.] Note: No further procedures must be performed under PP 2(l) if: (1) the ratio in PP 2(l)(4) is less than or equal to 3%, and (2) the refiner represents in writing that blendstock accounting is not required under 40 CFR Section 80.102(g). Otherwise: (5) Select a sample, in accordance with the guidelines in 40 CFR Section 80.127, from the tender listing obtained in PP 2(l)(1)(ii), and for each tender selected perform the following: (i) Obtain the refinery s or importer s company documents that evidence the transfer of the product to another party and compare the volumes contained in these records to the listing of tenders; and (ii) Obtain documents from the refinery or importer that support the exclusion of the applicable blendstock from the blendstock-to-gasoline ratio, and agree that the documented purpose is one of those specified at 40 CFR Section 80.102(d)(3); (6) Compare the total tender volume obtained in PP 2(l)(1)(ii) to the total volume of applicable blendstock produced or imported, transferred to others and excluded from blendstock ratio calculations listed in section 3.3 of the Anti-Dumping Program Annual Report copy received pursuant to PP 2(a)(1), or to the refinery-specific volume under PP 2(a)(2) used to prepare an aggregate report submitted to EPA. (7) Compute and report as a finding the refinery s ratio of applicable blendstocks included in the tracking calculation (PP 2(l)(1)(i)) plus all other non-finished-gasoline petroleum products (PP 2(l)(1)(iii)), to total gasoline production. [Total gasoline production is the volume total of the batches from PP 2(d) for RFG, RBOB, and conventional gasoline, exclusive of California gasoline.] Note: No further procedures must be performed under PP 2(l) if : (1) the ratio in PP 2(l)(7) is less than or equal to 3%, (2) no exceptions were noted in PP (2)(l)(5), and (3) the refiner represents in writing that blendstock accounting is not required under 40 CFR Section 80.102(g) then. Otherwise: (8) Select a sample, in accordance with the guidelines in 40 CFR Section 80.127 , from the listing obtained in PP 2(l)(1)(iii), and for each tender selected perform the following: (i) Obtain the records that evidence the transfer of the product to another party and compare the volume contained in these records to the volume on the listing of tenders; and (ii) Inspect the product type assigned by the refiner or importer on the transfer document (i.e., alkylate, raffinate, etc.) and agree that this product type is excluded from the applicable blendstock list at 40 CFR Section 80.102(a). (9) Compare the total tender volume obtained in PP 2(l)(1)(i) to the total volume of applicable blendstock produced or imported, transferred to others and included in blendstock ratio calculations listed in section 3.2 of the Anti-Dumping Program Annual Report copy received pursuant to PP 2(a)(1), or to the refinery-specific volume under PP 2(a)(2) used to prepare an aggregate report submitted to EPA. (10) Compute and report as a finding the refinery s ratio of applicable blendstocks included in the tracking calculation (PP 2(l)(1)(i)) to total gasoline production. [Total gasoline production is the volume total of the batches from PP 2(d) for RFG, RBOB, and conventional gasoline, exclusive of California gasoline.] Note: No further procedures must be performed under PP 2(l) if: (1) the ratio in PP 2(l)(10) is less than or equal to 3%, and (2) the refiner represents in writing that blendstock accounting is not required under 40 CFR Section 80.102(g). Otherwise: (11) Obtain the refinery s or importer s blendstock-to-gasoline ratios for calendar years 1990 through 1993. (12) (i) In the case of averaging periods prior to 1998, compute and report as a finding the peak year blendstock-to-gasoline ratio percentage change as required under 40 CFR Section 102(d)(1)(ii); or (ii) In the case of averaging periods beginning in 1998, compute and report as a finding the running cumulative compliance period blendstock-to- gasoline ratio as required under 40 CFR Section 80.102(d)(2)(i), and the cumulative blendstock-to-gasoline ratio percentage change as required under 40 CFR Section 80.102(d)(2)(ii). (13) Obtain from the refiner or importer the prior year s peak year blendstock-to- gasoline ratio percentage change (if the prior year was prior to 1998), or running cumulative compliance period blendstock-to-gasoline ratio (if the prior year was 1998 or later). Note: No procedures must be performed under PP 2(m) if: (1) for the prior year the peak year blendstock-to-gasoline ratio percentage change (for 1995 through 1997), or the cumulative blendstock-to-gasoline ratio percentage change (for 1998 and after), is less than ten; and (2) the refiner represents in writing that blendstock accounting is not required under 40 CFR Section 80.102(g); otherwise proceed to Blendstock Accounting, PP 2(m): (m) Blendstock accounting. (1) Obtain listings for those tenders of non-finished-gasoline petroleum products tenders classified by the refinery or importer as: (i) Blendstock which is included in the compliance calculations for the refinery or importer; and (ii) All other non-finished-gasoline petroleum products; (2) Foot the total volume of tenders per the listings; (3) Compare the total volume of tenders per the listings to the gasoline inventory reconciliation analysis obtained in PP 2(b); (4) Select a sample, in accordance with the guidelines in 40 CFR Section 80.127, from the listing of blendstock tenders which are included in the compliance calculations for the refinery or importer, and for each tender selected perform the following: (i) Compare the volumes to company documents evidencing the transfer of the tender to another party; (ii) Note the Product Transfer Document(s) includes the statement indicating the blendstock has been accounted-for, and may not be included in another party s compliance calculations; and (5) Compare the total tender volume obtained in PP 2(m)(1)(i) to the total volume of blendstocks included in compliance calculations listed in section 3.4 of the Anti- Dumping Program Annual Report copy received pursuant to PP 2(a)(1), or to the refinery-specific volume under PP 2(a)(2) used to prepare an aggregate report submitted to EPA. (6) Select a sample, in accordance with the guidelines in 40 CFR Section 80.127, from the listing of tenders of non-finished-gasoline petroleum products that are excluded from the refinery s or importer s compliance calculations, and for each tender selected confirm that company documents demonstrate that the petroleum products were used for a purpose other than the production of gasoline within the United States. PP 3 Agreed-upon procedures for downstream oxygenate blenders. The following minimum procedures may be carried out for an oxygenate blending facility that is subject to the requirements of 40 CFR Part 80, subpart F, as an alternative to the procedures under 40 CFR Section 80.129. (a) EPA Blender Reports. Obtain and read a copy of the blender s reports (except for Batch reports) filed with the EPA as required by 40 CFR Section 80.75 for the Reporting Period. Obtain a written representation from a company representative that the copies are complete and accurate copies of the reports filed with the EPA. (b) Inventory reconciliation analysis. Obtain from the blender an inventory reconciliation analysis for the Reporting Period that summarizes: (1) RBOB, RFG, and oxygenate receipts, (2) RBOB , RFG, and oxygenate beginning and ending inventories, (3) RFG production, and (4) RBOB and RFG tenders, and perform the following: (1) Foot and the crossfoot volume totals reflected in the analysis; and (2) Compare the beginning and ending inventory amounts in the analysis to the blender s inventory records. (c) RBOB receipts. Obtain a listing of all RBOB receipts for the Reporting Period, and perform the following: (1) Foot to the total volume of RBOB receipts per the listing; (2) Compare the total RBOB receipts volume reflected on the listing to the RBOB receipts volume on the inventory reconciliation analysis; (3) Select a sample, in accordance with the guidelines in 40 CFR Section 80.127, of RBOB receipts from the listing. For each selected RBOB receipt, obtain product transfer document(s) specifying the type and volume of oxygenate to be added to the RBOB. (d) Oxygenate receipts. Obtain a listing of all oxygenate receipts for the Reporting Period, and perform the following: (1) Foot to the total volume of oxygenate receipts per the listing; (2) Compare the total oxygenate receipts volume reflected on the listing to the oxygenate receipts volume on the inventory reconciliation analysis. (e) RFG Tenders. Obtain a listing of all RFG tenders for the Reporting Period, and perform the following: (1) Foot to the total RFG tenders per the listing; (2) Compare the total RFG tenders volume reflected on the listing to the RFG tenders volume on the inventory reconciliation analysis; (3) Select a sample, in accordance with the guidelines in 40 CFR Section 80.127, of RFG tenders from the listing, and for each tender selected perform the following: (i) Obtain the Product Transfer Document(s) associated with the tender and compare the volume on the tender listing to the volume on the Product Transfer Document(s). (ii) Inspect the Product Transfer Document(s) evidencing the date and location of the tender and the compliance model designations for the tender (VOC-controlled [Region 1 or 2], non VOC-controlled, OPRG, non-OPRG, and simple or complex model certified). (f) RBOB tenders. Obtain a listing of all RBOB tenders during the Reporting Period, and perform the following: (1) Foot to the total volume of RBOB per the listing; (2) Compare the total RBOB tenders volume reflected on the listing to the RBOB tenders volume on the inventory reconciliation analysis. (g) RFG batches. Obtain a listing of all RFG batches produced during the Reporting Period, and perform the following: (1) Foot to the total volume of RFG batches produced per the listing; (2) Compare the total RFG batch volume reflected on the listing to the RFG batch volume on the inventory reconciliation analysis. (h) Blenders sampling and testing batches. For blenders that meet the oxygenate blending requirements by sampling and testing each batch of RFG, select a sample, in accordance with the guidelines in 40 CFR Section 80.127, of RFG batches from the listing obtained in PP 3(g), and for each batch selected perform the following: (1) Obtain the internal Laboratory Analysis for the batch, and compare the type of oxygenate used and the oxygen content appearing in the Laboratory Analysis to the instructions stated on the Product Transfer Document(s) corresponding to a RBOB receipt immediately preceding the Laboratory Analysis and used in producing the RFG batch selected. (2) Compare the oxygen content results of the Laboratory Analysis to the corresponding batch information reported to EPA. (i) Blenders not sampling and testing each batch. For blenders that are NOT sampling and testing each batch of RFG, perform the following: (1) Obtain a listing of the monthly (or lesser period if used by the blender) oxygen compliance calculations, and (i) Foot the RBOB and oxygenate volumes used in the individual compliance calculations; and (ii) Compare the totals to the corresponding volumes on the inventory reconciliation analysis. (2) Select a sample, in accordance with the guidelines in 40 CFR Section 80.127, of RFG batches on the listing obtained in PP 3(g), and for each batch selected perform the following: (i) Compare the oxygen content information shown on the listing to the oxygen content reflected in the corresponding oxygen compliance calculation; and (ii) Obtain a written representation from a company representative as to whether the oxygenate blender is basing the calculation on the assumptions for specific gravity and denaturant content (if ethanol is used), or on measured values. If the blender is using measured values, obtain the blender s test results for specific gravity and denaturant content for the RBOB and oxygenate used, and compare the test results to the compliance calculations. If the blender is using the assumed values for specific gravity and denaturant content, compare the values used in the compliance calculation to the values specified by EPA. (3) Obtain a listing of reformulated gasoline samples tested in connection with the blenders quality assurance program, and: (i) Select a sample, in accordance with the guidelines in 40 CFR Section 80.127, of RFG samples from the list. (ii) For each RFG sample selected, obtain the corresponding Laboratory Analysis and compare the oxygen content to the ranges specified by the EPA. (iii) Based on the selected RFG sample s compliance with EPA oxygen content compliance, inspect the listing evidencing that the frequency of the next sample made in connection with the quality assurance program was within EPA specifications under 40 CFR Section 80.69(e)(2). (j) Blenders using assumed values. For blenders that are using the assumed values for ethanol denaturant content in the oxygen compliance calculation, obtain a chronological list of the ethanol samples tested in connection with the blender s quality assurance program. The listing should show the sampling dates and test results as to the oxygenate purity level. Select a sample, in accordance with the guidelines in 40 CFR Section 80.127, of ethanol samples from the list and perform the following: (1) Obtain the Laboratory Analysis corresponding to the selection and compare the oxygenate purity level per the Laboratory Analysis to the level on the list; and (2) Based on the level of oxygenate purity, inspect the listing evidencing that the frequency of the next sample made in connection with the blender s quality assurance program was at least once a month if oxygenate purity equals or exceeds 92.1%; or at least once every two weeks if oxygenate purity is less than 92.1%, for any of the past four tests.