The answer to question 11 of Section F states that RFG produced by adding oxygenate to RBOB in the compartment of a truck is one batch and that each compartment must be given a different batch number. Section 80.69(c)of the regulations states "other than a truck delivering gasoline to retail outlets or wholesale purchaser-consumer facilities," which clearly indicates that retail delivery trucks are not included in the same class as storage tanks. Neither section 80.69(d) nor 80.69(e) require designation of compartments or even truck loads as separate batches and only sampling and oversight are required in section (e). It would appear that the Q and A document is in direct conflict with the July 1, 1994 memo signed by K. Stein, C. France, and M. Smith which states that the Q and A does not alter the requirements of the regulations.

It is assumed that the question and answer referred to is #10 of Section VI. F. of the July 1, 1994 "Reformulated Gasoline and Anti-Dumping Questions and Answers" document. EPA's response does not add or alter the requirements of the final reformulated gasoline regulations.

The term "batch" is used consistently and appropriately with regard to the regulations. Also, truck batch numbering applies to truck oxygenate blenders who meet the oxygen standard on average. Please refer to the July 1, 1994 "Question and Answer" document, Question 26, Section VI.H., as well. (8/29/94)

This question and answer was posted at