Assuming that EPA approves the use of analyzers to certify in-line blended RFG, if an analyzer has maintenance problems during a blend such that it did not give results for 50% of the blend, can the refinery use spot samples to track the property? Is there a specific percent uptime that the EPA requires should analyzers be used to certify blends?
Proposals for using results from on-line analyzers for purposes of certifying a batch will be evaluated on a case-by-case basis. EPA has not established the amount of up-time required in order to qualify the on-line analyzer results for use in certification.
However, in considering a proposal to use on-line analyzer results for certification, EPA expects that the proposal will include a back-up system and plan as part of the QC/QA program for dealing with outliers and analyzer failures. (7/1/94)
This question and answer was posted at List of Reformulated Gasoline and Anti-Dumping Questions and Answers: July 1, 1994 through November 10, 1997 (pdf)